PB94-964128
EPA/ROD/R05-94/254
September 1994
EP A Superfund
Record of Decision:
Van Dale Junkyard Site, OB
3/31/1994 .
o
Hazardous Waste Collection
Information Resource Cehter
US EP A Region 3
Philadelphia, PA 19107
EP A Report Collection
Information Resource Center --
US EP A Region 3 --
Philadelphia, PA 19107 ...
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DECLARATION FOR THE RECORD OF DECISION
SITE NAME AND WCATION
Van Dale Junkyard Site (also known as Vandale Junkyard Site)
Washington County, Ohio
STATEMENT OF BASIS AND PURPOSE
This decision document presents the selected remedial action for the Vandale Junkyard site,
in Washington County, Ohio. The Vandale Junkyard site is on the National Priorities List. .
This decision has been developed, and the remedy selected, in accordance with the
Comprehensive Environmental Response, Compensation and Liability Act of 1980
(CERCLA), as amended by the Superfund Amendments and Reauthorization Act of 1986
(SARA), and to the extent practicable, with the National Oil and Hazardous Substances
Contingency Plan (NCP). This decision selecting a remedial action for the site is based on
the Administrative Record for the site. The Administrative Record Index identifies items that
comprise the Administrative Record, and is attached to this Record of Decision (ROD).
The State of Ohio concurs with the selected remedy. The letter of concurrence is attached to
this ROD.
ASSESSMENT OF THE SITE
Actual or threatened releases of hazardous substances from the site, if not addressed by
implementing the response action selected in this ROD, may present an imminent and
substantial endangennent to public health, welfare, or the environment.
DESCRIPrION OF THE SELECTED REMEDY
The selected remedy at the Vandale Junkyard site will be a fInal site-wide remedy. The
selected remedial action for the site addresses the principle threats posed by the site through
treatment and containment of source materials. The major components of the selected
remedial action include:
*
Collection of materials estimated at 9,000 cubic yards of soils and 8,900 cubic
yards of solid wastes (including drummed wastes) containing organic and
inorganic contaminants.
*
Segregation of solid wastes, including drummed wastes, from soils.
*
Off-site disposal of drummed materials, sludges, and other wastes which
contain substances, especially hazardous wastes, not suitable for on-site
containment.

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...
. Screening of solid waste materials for salvageable materials. Salvageable
materials will be decontaminated on-site and taken off-site for salvage.
...
Consolidation of soils and remaining solid wastes in designated areas on-site
which contain contaminated soils, followed by construction of a RCRA Subtitle
C hazardous waste cap.
...
Bioremediation of organic contaminants in seep sediments.
...
Institutional controls necessary to ensure the integrity of the remedial action.
Site deed restrictions and fencing will be used to restrict site access as
necessary to prevent the installation of drinking water wells and the
disturbance of capped areas while cleanup levels are being achieved.
...
Ground water and surface water/sediments monitoring program to confIrm that
the removal, treatment, and containment of source materials and the natural
attenuation of residual contaminants results in the expeditious attainment of
cleanup levels.
USE OF NATURAL ATTENUATION FOR GROUND WATER RESTORATION IN
LIEU OF TREATMENT
U.S. Environmental Protection Agency (U.S. EPA) has determined that use of natural
attenuation for ground water restoration will result in expeditious attainment of cleanup levels
and that risks associated with the contaminated ground water will be minimized in the
interim. Based upon monitoring data and geological information, U.S. EPA believes that
cancer risks and other hazards to human health associated with contacting the ground water
can be minimized by monitoring the ground water and restricting its use until the levels of
contaminants in the water are below drinking water standards, background levels, andlor
other health-based standards. U.S. EPA has determined that ground water at the Vandale
Junkyard site does not pose a threat to off-site residential drinking water supplies and that
restricting ground water use will prevent any contact with this water.
Natural attenuation is a viable remedy for contamination found in the ground water at the
Vandale Junkyard site based on the specific hydrogeological conditions at the site. Ground
water distribution and availability under the site varies greatly due to the presence of
fractured bedrock. As a result, U. S. EP A believes that known ground water remediation
technologies will not significantly expedite attainment of ground water cleanup levels over
that anticipated to be attained through natural attenuation.
Contaminated soils and solid wastes which U.S. EPA believes are causing the ground water
contamination will be removed and either treated and disposed off-site or contained on-site.
Ground water contaminant levels will be closely monitored to ensure that there is progress
toward, and expeditious attainment of, ground water cleanup levels. In the event that
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progress toward or attainment of expeditious cleanup does not occur through natural
attenuation, U.S. EPA has specified contingency measures to be considered in this ROD.
These contingency measures include consideration of additional source removal, active
remediation of the ground water, and engineering controls.
STATUTORY DETElt.'fINATIONS
The selected remedy is protective of human health and the environment, complies with
Federal and State requirements that are legally applicable or relevant and appropriate to the
remedial action, and is cost-effective. This remedy utilizes permanent solutions and
alternative treatment technologies to the maximum extent practicable and satisfies the
statutory preference for remedies which employ treatment that reduces toxicity, mobility, or
volume as a principal element. The majority of principal threat wastes identified at the site
will be contained on-site in compliance with all ARARs. Principal threat wastes which are
unsuitable for on-site containment will be treated and/or disposed off-site in compliance with
all ARARs.
Because this remedy will result in hazardous substances remaining on-site above health-based
levels, a review will be conducted within five (5) years after commencement of the remedial
action to ensure that the remedy continues to provide adequate protection of human health
and the environment.
.3 - ~, - 0:\ '-I
Date
- }-':J... ""'-
fr\' 1.1~LU- 0 ~""L(!..,/"\-
Valdas V. Adamkus
Regional Administrator
U.S. EPA Region 5
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DECISION SUMMARy
V ANDALE JUNKY ARD SITE
WASHINGTON COUNTY, omo

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I.
n.
m.
IV.
v.
VI.
vn.
DECISION SUM:MARY
V ANDALE JUNKY ARD SITE
WASHINGTON COUNTY, omo
...........
TABLE OF CONTENTS
SITE LOCATION AND DESCRIPTION. . . . . . . . . . . . . . . . . . . . . . . .. 1
SITE HISTORY AND ENFORCEMENT ACTIVITIES. . . . . . . . . . . . . . " 1
HIGInlGHTS OF COMMUNITY RELATIONS ACTIVITIES. . . . . . . . . " 3
SCOPE AND ROLE OF RESPONSE ACTION. . . . . . . . . . . . . . . . . . . " 4
SUMMARY OF SITE CHARACTERISTICS. . . . . . . . . . . . . . . . . . . . . .. 5
SUMMARY OF SITE RISKS. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
13
REMEDIAL ACTION APPROACH. . . . . . . . . . . . . . . . . . . . . . . . . . .
19
VDI. DESCRIPTION OF ALTERNATIVES. . . . . . . . . . . . . . . . . . . . . . . . .. 23
IX.
x.
XI.
xn.
SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES. . . . . .
27
TIm SEI.EC'I'ED REld:EDY . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 36
DOCUMENTATION OF SIGNIFICANT CHANGES ................
40
STATUTORY DETERMINATIONS. . . . . . . . . . . . . . . . . . . . . . . . . .. 42
Appendix A -- Responsiveness Summary
Appendix B -- Administrative Record Index
Appendix C -- State Concurrence Letter
Appendix D -- Federal Applicable or Relevant and Appropriate Requirements
Appendix E -- State Applicable or Relevant and Appropriate Requirements

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DECISION SUMMARY
V ANDALE JUNKYARD SITE
I. SITE LOCATION AND DESCRIPTION
The Vandale Junkyard Site ("the site") is located in a rural area approximately 1.5 miles
northeast of Marietta, Ohio on an unpaved access road off Marietta Township Road 83 in
Washington County (see Figure 1). Marietta, which is situated along the Ohio River, has a
population of approximately 16,000. Located in the rolling hills of the Appalachian Plateau
Province in southeastern Ohio, the site occupies part of a natural ridge which runs east to
west. Duck Creek, a small tributary to the Ohio River, is located less than one quarter of a
mile to the west of the site. Surface water drainage from the site flows through two
intermittent streams to Duck Creek.
The site encompasses 31 acres, approximately 10 acres of which occupies the top of the
ridge and has been utilized as a junkyard (see Figure 2). The ridge is bordered on the north
and east by steep, wooded ravines with depths approaching 200 feet in places. The
remainder of the site consists of portions of the steeply sloped ravines. The Marietta
Sanitation Corporation Landfill, a closed landfill, borders the site on the south. The active
areas of the sit~ are largely unvegetated and contain several barns and an occupied residential
trailer, as well as a large quantity of junkyard materials. The wooded, sloped areas of the
site contain variable quantities of discarded junkyard materials, debris, and the remnants of
drums from industrial waste disposed at the site. A number of farm animals are currently
raised on-site, including cows, pigs, chickens, and other fowl.
Agriculture and residential dwellings are the primary land uses in the area. Approximately
210 residences are located within a one-mile radius of the site, including four residences.
along the access road to the site and one residence on-site. The nearest residence along the
access road is approximately 200 feet from the site boundary. Although a public water'
supply system is available in the area surrounding the site, 27 residences within a one-mile
radius of the site are believed to utilize private residential wells as a drinking water source,
including several in the vicinity of the site. There is no known usage of site ground water at
present.
n. SITE mSTORY AND ENFORCEMENT ACTIVITIR~
The Vandale Junkyard has been a county licensed junkyard operation since the early 196Os,
and may have been operated since some time in the 194Os. During its operation, it is known
to have received a variety of materials for disposal andlor salvage, including general wastes
such as scrap metal, appliances, furniture, automobiles, tires, and batteries. In addition,
disposal records from various industrial facilities indicate that for a period during the late
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1970s several thousand drums of industrial wastes were accepted at the site.
These drums contained such materials as waste industrial solvents, tar and iron cakes,
sludges, paints, and inks. Although no records confmn the disposal of industrial wastes
during other timeframes, there are indications that this may have occurred. Since drums
were accepted for salvage, the contents were either emptied on to the ground or burned on
the active parts of the junkyard. At some point a number of drums were also bulldozed over
the north slope of the site and it is suspected that at least some of these drums were not
emptied prior to this disposal.
Although investigations of hazardous substance disposal at the site began in 1980, when Ohio
Environmental Protection Agency (Ohio EPA) personnel fIrSt visited the site, the site has a
history of complaints to local authorities from nearby residents dating back to at least 1969.
Most of the complaints appear to have been related to open-burning and accepting wastes
which created nuisances, such as odors and rodents. Based on observations of drummed
waste at the site in 1980, preliminary assessments of contamination at the site were
conducted by the U.S. Environmental Protection Agency (U.S. EPA) and Ohio EPA (jointly
referred to as the "Agencies") during the period 1980 to 1983, under the authority of the
Comprehensive Environmental Response, Compensation and Liability Act of 1980
(CERCLA). Although the Agencies continued to fmd drums during these visits, no records
documenting the disposal of drummed waste after 1980 have been found.
The state of Ohio ftled suit against the owner/operator of the facility in 1984, and a
settlement was reached which assured access to the site for investigations and prohibited any
further collection of solid or hazardous waste, as well as filling, grading, excavation, or
burning activities. The owner/operator was allowed to continue junkyard operations
pennitted by Washington County, and the site remains a licensed junkyard. Since this time,
concern from nearby residents has greatly decreased.
Based on the assessments of the release of hazardous substances at the site, the site was
proposed for inclusion on U.S. EPA's National Priorities List (NPL) for Superfund sites in
1982, and was finalized on the NPL in J:une 1986. On July 7, 1987, U.S. EPA and Ohio'
EP A entered into an agreement, known as an Administrative Order on Consent, with five
parties which were believed to have contributed wastes to the site (potentially Responsible
Parties or PRPs): American Cyanamid Company, BF Goodrich Company, Kardex Systems,
Inc., UNISYS COlpOration, and Washington County Disposal Company.
The agreement with the PRP group allowed them to conduct the investigation of ground
water, soil, surface water, and sediment contamination which resulted from the release of
hazardous substances at the site. This investigation was to be conducted in two stages, the
Remedial Investigation (RI) and the Feasibility Study (FS). The purpose of the RI was to
detennine the nature and extent of on-site and off-site contamination with hazardous
substances and estimate the risks posed by the site to human health and the environment.
The purpose of the FS was to examine comprehensive cleanup options, called remedial
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alternatives.
Phase I of the RI study was conducted by the PRP group under the oversight of the
Agencies. Phase I activities began in September 1988 and included ground water monitoring
well construction and sampling, soil sampling, surface water sampling, and sediment
sampling.
The Agencies terminated the authority of the PRP group to conduct the RIfFS in August
1990, after a dispute about the work conducted by the group. U.S. EPA assumed
responsibility for completion of the RI and the FS, with the cooperation of Ohio EPA. Phase
II of the RI began in November 1990 and included additional monitoring well installation and
sampling, as well as additional soil, surface water, and sediment sampling.
m. IDGHLIGHTS OF COMMUNITY RELATIONS AC1'I£ITIES
A public availability session was held in Marietta on October 6, 1988 to explain the
Superfund process and the remedial investigation work which began in September 1988. An
infonnation repository was established at that time at the Washington County Public Library
in Marietta.
The Final RI Report, which included the Baseline Risk Assessment, was released to the
public in February 1992. A Fact Sheet summarizing the fmdings of the RI was distributed in
June 1992 to approximately 100 members of the public who were on the site mailing list.
The Final FS Report and Proposed Plan were made available to the public in August 1992.
A Fact Sheet summarizing the FS and Proposed Plan was distributed to members of the
public on the site mailing list in August 1992.
In order to encourage public participation in the remedy selection process consistent with
Section 117 of CERCLA, these documents and the remainder of the Administrative Record
me for the site were made available for review by the public at the Washington County
Public Library and the County Courthouse Commissioner's Office in Marietta, and at U.S.
EP A Region 5 offices in Chicago, during the public comment period which extended from
August 27, 1992 through November 13, 1992.
An announcement regarding the public comment period and the availability of the
Administrative Record fue was published in the Marietta Times newspaper on August 26,
1992. Following a written request from the public, a notice extending the public comment
period until October 29, 1992 was published in the Marietta Times newspaper on September
9, 1992. After a second written request from the public, a notice extending the public
comment period a fmal time through November 13, 1992 was published in the Marietta
~ on October 29, 1992.
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A public meeting was held in Marietta on September 10, 1992. At this meeting, attended by
approximately thirty members of the public, representatives from U.S. EPA and Ohio EPA
summarized the fmdings of the RIfFS, explained the Proposed Plan and remedy selection
process, answered questions from the public, and accepted statements from members of the
public. Comments, including formal statements from six community members, were
recorded by a court reporter and a transcript of the meeting is included in the Administrative
Record.
A total of 13 written submittals were received from the public during the public comment
period. A corrected version of one submittal, containing four pages which were
inadvertently excluded, was received several weeks after the close of the comment period.
U.S. EPA's responses to comments received during the public comment period are contained
in the Responsiveness Summary, which is part of this Record of Decision and may be found
in Appendix A. As explained in the Responsiveness Summary, several of the written
submittals from PRPs were lengthy and very detailed. Since these submittals typically did
not contain itemized individual comments or questions, U.S. EPA summarized the significant
comments, criticisms, and new information presented in these documents and responded to
them as completely as possible.
This decision document presents the selected remedial action for the Vandale Junkyard Site,
in Washington County, Ohio, chosen in accordance with CERCLA, as amended by the
Superfund Amendments and Reauthorization Act of 1986 (SARA), and to the extent
practicable, the National Oil and Hazardous Substances Contingency Plan (NCP). The
decision for this site is based on the Administrative Record. The Administrative Record
includes all items and documents such as work plans, data analyses, public comments,
transcripts, and other relevant information provided by Section 113 of CERCLA. The
Administrative Record Index is attached to this document as Appendix B. The provisions for
public participation in remedy selection in Section 113(k)(2)(B)(i-v) and Section 117 of
CERCLA have been satisfied.
IV. SCOPE AND ROLE OF RESPONSE ACTION
The response action at the"Vandale Junkyard site will be a final site-wide remedial action to
address contamination and potential contamination caused by waste disposed at the site. The
remedial action will address the principal threats at the facility: contaminated soils and
sediments, drummed wastes, and other solid wastes through excavation and treatment and/or
containment to meet all Applicable or Relevant and Appropriate Requirements (ARARs).
These contaminated materials have been identified in the RI as the primary risk to ground
water, surface water, and surface water sediments. Consequently, actions to treat and/or
contain contaminated soils and wastes and sediments, will, in addition to minimizing
concerns associated with direct contact, minimize the potential for contaminants to infiltrate
to the ground water or leach to the surface waters. Residual ground water and surface
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water! sediments contamUtation will be addressed through natural attenua~on so that cleanup
levels are achieved. If ground water and surface water/sediments cleanup levels are not
expeditiously achieved through natural attenuation, then additional measures will be required.
When the remedial action is completed, no further remedial action at the site other than
ground w~ter and surface water monitoring and O&M activities are envisioned. The
monitoring will be conducted to assure that the sources of ground water and surface water
contamination have been sufficiently reduced and that residual ground water contamination is
expeditiously eliminated through natural attenuation, so that clean up levels can be achieved.
Since hazardous substances will remain above health based levels in the capped area of the
site, five-year reviews of the remedial action will be necessary.
v. SUMMARY OF SITE CHARACTERISTICS
Field work for the remedial investigation was conducted in two phases. Phase I work began
in September 1988, and Phase n work began in ;November 1990. The RI consisted of the
installation of monitoring wells, sampling of monitoring and residential wells in the vicinity
of the site, soils, surface waters, and surface water sediments. In addition, geophysical
investigations were conducted in an effort to locate possible buried wastes.
The RI report details the fmdings of site investigations, characterizing the site resources and
the nature and extent of hazardous substances (or contaminants) at the site. The Baseline
Risk Assessment included in the RI used the fmdings of the site investigation to assess the
current and possible future risks to public health, welfare, and the environment posed by site
contaminants. The objective of the RI was not to remove all uncertaiDty regarding risks
posed by the site, but rather to gather information sufficient to support an informed risk
management decision regarding which remedy is the most appropriate.
Physical Site Characteristics
Before the start of junkyard activities, the topography of the site is believed to have been
dominated by a narrow ridge running east to west along the present crest. Large areas of the
site have been modified, however, and the billside to the north of the access road has been
flattened and widened to accommodate accumulated junkyard materials. Additionally, the
hillside to the south of the site has been modified by operations at the Marietta Sanitation
Corporation Landfill, which included the burying and layering of refuse and soil.
The soils overlying the site are composed primarily of clay and silt with lesser amounts of
sand and organic matter. The dominant soils have a thin silty clay layer over a thick subsoil
that contains shale mixed with clay and silt. The depth of unconsolidated materials (to
bedrock) varies from none on the steeply sloped areas where bedrock is exposed, to
approximately 20 feet. On the ridge top in the active area of the site, average soil depth is
approximately ten feet. The soils in the active areas of the site are highly disturbed as a
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result of modifications made to accommodate junkyard activities. Soils on the sloped areas
are highly susceptible to 'slippage and a number of areas have large landslides.
Bedrock in the region is composed primarily of alternating beds of calcareous red claystones,
siltstones, sandstones, and shales, with some thin beds of coal and limestone. Rock cores
taken during well installation at the site typically found alternating beds of light gray siltstone
to fme sandstone and reddish-brown to maroon claystone. These cores demonstrated that the
bedrock is highly fractured, and led to the conclusion that the occurrence and migration of
ground water is controlled primarily by the presence and orientation of these fractures.
Because the fractures do not occur uniformly throughout the stratigraphic section of rocks at
and near the site, water likely occurs at various depths and in various quantities in nearly all
strata but is found most commonly in the siltstone layers, which are separated by less
permeable claystone layers. Lateral movement of ground water occurs along bedding planes
and horizontal breaks, and vertical movement occurs through the fractures. Bedrock
outcrops can be found along the north and east slopes of the site. .
Sixteen monitoring wells were installed on and near the site during the RI. The total depth
of these wells varies from 29 to 157 feet. Multiple water bearing zones were encountered at
varying elevations during the installation of most of the wells. A readily dermed water-
bearing zone occupying a narrow range within the bedrock was identified in a number of on-
site wells, but the presence of water bearing zones above and below this zone was highly
variable. It appears that migration is primarily through interconnected fractures, and ground
water movement in the upper bedrock is controlled primarily by topography with radial
movement away from the crest of the site primarily towards the north, northwest, and
northeast, discharging along the valley walls.
Figure 3 demonstrates the ground water flow directions in the readily defmed water bearing
zone. Area ground water flow is towards the southwest. There is no evidence of a defmed
water-bearing unit in the deeper water-bearing zones. The ground water yield from all wells
installed during the investigation was typically very low. Individual water-bearing zones
intercepted during the investigation were judged not sufficient to sustain a residential water
supply well. However, residential wells in use near the site are known to penetrate a number
of water-bearing zones, thereby providing sufficient water.
Surface water drainage from the site occurs through two intermittent tributaries to Duck
Creek (see Figure 2). Duck Creek, which is a small tributary of the Ohio River, is
approximately one-quarter of a mile to the west of the site. Tributary A, which is located at
the bottom of the ravine on the northern part of the site, is relatively undisturbed and
receives most of the runoff from the site. Tributary B, which drains the southerly portions
of the site and part of the Marietta Sanitation Corporation Landfill, is highly modified from
landfilling operations.
Approximately half-way between the edge of the north and northeast slopes and Tributary A
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there is a "bench" where. water draining from above accumulates and fonns a series of small
wetland areas designated as "seeps" (see Figure 4). These areas were designated as seeps.
because they may receive a portion of their water from ground water seepage, but most of
the water is believed to be contributed by surface water runoff. Seeps A, B, C, and D and
the "Marsh" are all areas along this bench where sufficient water accumulated to support
sampling activities. All wetlands along the bench are estimated to comprise less than one
acre in total area.
Nature and Extent of Contamination
The Rl was designed to detennine the nature and extent of contamination at the site through
a sampling program for soils, ground water, surface waters, and sediments. The fIndings of
the Rl demonstrate the existence of widespread contamination in site soils, ground water,
surface waters, and sediments with organic and inorganic substances. The organic
contaminants are believed to be primarily associated with the industrial wastes disposed at the
site, while the inorganic contaminants (metals) may be related to both the disposal of
industrial wastes and the storage and salvage of junkyard materials on-site.
Records of wastes disposed at the site are incomplete, since the owner/operator was not able
to supply detailed records. Infonnation provided by industries which are believed to have
contributed waste to the site indicates that a minimum of 2200 drums of industrial wastes
were brought to the site. The limited infonnation available on the types of contaminants
which may have been contained in the wastes includes the following:
Volatile Organic
Compounds (VOCs):
n-butanol
2-butanone
diethylene glycol monoethyl ether
4-methyl-2-pentanone
"mineral spirits"
"naptha "
"paint thinner"
toluene
tricbloroethene
l,l,l-tricbloroethane
"waste solvent"
xylenes
Other Organic
Compounds:
bis(2-ethylhexyl)phthaIate
other phthalates
"organic ketones"
"organic tars"
"dyes"
rubber
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Inorganic
Compounds:
chromium
cyanide
iron.
lead
It is very likely that other contaminants were contributed to the site from industrial wastes.
In addition to the contaminants contributed by industrial waste disposal at the site, a number
of inorganic and organic contaminants typically associated with the operation of a junkyard
can reasonably be expected to have contributed to site contamination. These could include:
VOCs:
(from gasoline)
benzene
ethylbenzene
toluene
xylene
solvents
(from degreasing)
Other Organic
Compounds: (from cars)
greases
oils
plastics
rubber
Inorganic
Compounds: (from cars
and scrap
metals)
chromium
copper
iron
lead
nickel
zinc
Many of these contaminants are known to have toxic effects, both carcinogenic and
noncarcinogenic, and the metals and VOCs are highly mobile.
For discussion purposes, Figure 2 indicates five potential contaminant source areas,
designated as Areas 1 through 5 during the RI. Knowledge of past disposal activities at the
site and the results of previous investigations were used to delineate these areas. The
southern edge of Area 3 and all of Area 4 are believed to extend beyond the Vandale
Junkyard property lines. It is important to note that the site is bordered directly on the south
by the Marietta Sanitation Corporcltion Landfill, and that landfill material is believed to
extend very close to the road which separates the sites in the vicinity of Area 3. Although
the Vandale Junkyard site includes all areas where waste has come to be located, the
presence of the landfill (which was closed in 1985) does complicate this detennination. The
Area of Contamination was defmed by the site property boundary indicated on all figures.
Samples collected beyond this boundary were intended to investigate the off-site trclnsfer of
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contaminants via surface or ground waters. Area 4 is the only exception to this, and waste
disposal was not confmned in this area (see below). As a distinct parcel of property with its
own state-authorized waste disposal operations, the landfill was .nQ! treated as part of the site.
*
Area I encompasses the area along the northern slope of the hillside. Drums
containing various materials were apparently bulldozed into this area along
with other debris.
*
Area 2 includes the "bum" area, where drummed wastes were reported to have
been burned or poured on to the ground, and a large pile of used appliances
and other metal stored for salvage.
*
Area 3 includes a recently revegetated area where junk automobiles were
previously stored. This area may also have been used for storage and disposal
of drummed wastes.
*
. Area 4 includes an area adjacent to the site and behind a nearby residence,
where it was alleged that drummed wastes may have previously been disposed.
*
Area 5 includes the northeast slope of the site where a large pile of discarded
materials extends downslope from the active areas of the junkyard. These
materials include cars, tires, scattered drums, glass, plastic sheeting, furniture
upholstery, and a variety of other items.
A summary of the fmdings of the remedial investigation for each medium (soils, ground
water, surface water, and sediments) follows. Please refer to the RI Report for details.
Soils
Soils at and adjacent to the site were sampled at various depths and found to contain a wide
range of contaminants. Sampling locations were selected based on what is known about
disposal practices at the site and on observations of drum fragments and other indicators.
Table I indicates the major organic contaminants found and the range in concentrations.
Table 2 provides infonnation on inorganic contaminants and comparisons to site-specific and
published background level.s.
Area 1 (see Figure 2) soils contain the highest concentrations of VOCs and semivolatile
organic compounds (SVOCs) detected at the site. Chlorinated VOCs, including
tetrachloroethene and trichloroethene, and unchlorinated VOCs typically associated with
gasoline, including benzene, ethylbenzene, toluene, and xylenes (or BTEX compounds) were
found at relatively high levels. Phthalates were the SVOCs found. at very high levels. A
number of metals were also found to exceed background levels.
Area 2 generally contains the highest concentrations of metals, and the second highest levels
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of VQCs. This area alsQ contains elevated levels of polycyclic aromatic hydrocarbons
(PARs), a group of SVOCs. In addition, since this area was where chlorinated VQCs were
suspected to have been burned, the soils were sampled for dioxins and furans. These
potential combustion products of chlorinated VOCs were found at low levels in all samples.
Area 3 contains the highest levels of PAHs, significantly elevated levels of metals, and the
only detections of pesticides on site. Area 4, which is adjacent to the site boundary, contains
low levels of VOCs and slightly elevated levels of metals. Significant indications of site-
related contamination were not found, leading U. S. EP A to conclude that direct disposal of
waste from the site did not occur in this area. Area 5 contains elevated levels of both
SVOCs and metals.
Figures 5 through 8 provide detailed infonnation on soil sampling results. It is clear that soil
contamination is highly variable and widespread (both vertically and horizontally) over the
portions of the site affected by site operations. Significant soil contamination related to site
activities was not confmned off-site.
Ground Water
Ground water was sampled at a number of wells on and near the site. A total of 13 wells
were installed and sampled and 4 nearby residential wells were also sampled. Four shallow
wells (S-3, S-4, S-5, and S-6) and one deep well (D-3) were installed on-site. The remaining
wells are adjacent to the site. Figures 9 and 10 provide detailed results of ground water
sampling. Table 3 presents highlights of the results of this sampling. The highest levels of
organic contaminants were found in ground water in Areas 1 and 2 on-site, where soil
contamination is also highest. As indicated in Table 4, the three wells in these areas, S-4, S-
5, and S-6, all had multiple contaminants in excess of U.S. EPA's Maximum Contaminant
Levels (MCLs) for drinking water.
Table 4 also indicates that nearly all wells had MCL exceen~nces for inorganics, but the on-
site wells generally had the greater number. The off-site wells which are directly adjacent to
the southern edge of the site may be influenced by both the Marietta Sanitation Corporation
Landfill and the site. However, sampling results from wells located on the south and west
perimeters of the Marietta Sanitation Corporation Landfill do not indicate that the site is
influencing off-site ground water at present. In addition, ground water was not typically
encountered in off-site wens in the zones which were found to contain ground water on-site.
Ground water sampling results indicate that contamination is widespread and highly variable,
reflecting the distribution of contaminants over the surface of the site, and extending both
slightly east (beneath a residential property) and south of the site property line (beneath the
Marietta Sanitation Corporation Landfill property).
Surface Water
Surface waters and seeps which drain the site were sampled in a number of areas upstream
10

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and downstream of site influence. Organic contaminants were detected in only one stream
sample which drains Area 3 and at low levels in all seeps. No Ohio Water Quality Standards
(WQS) or U.S. EPA Ambient Water Quality Criteria (AWQC) were exceeded for organic
contaminants. Inorganic contaminants were found to exceed WQS and A WQC at a number
of locations, and this information is summarized in Table 5.
The exceedances in Tributary A and the seeps are believed to be directly attributable to
surface water runoff and ground water transport of contaminants at the site. It does appear
that the influence of the site on Duck Creek via Tributary A is limited, at least at the flow
conditions monitored during the RI. No correlations were found between contaminants in
Tributary A and those in Duck Creek downstream of their confluence. The exceedances in
Tributary B, which tended to be highest, are believed to primarily reflect the effects of
leachate from the Marietta Sanitation Corporation Landf"ill. Leachate seeps from the landf"ill
have been observed discharging directly into Tributary B and this stream is believed to
receive the majority of its base flow directly from leachate from the landfill.

Figures 11 and 12 provide more detailed results of surface water sampling.
Sediments
Surface water sediments were also sampled at all locations where surface water samples were
collected, including the seeps. Tributary A and most seep samples reflected some influence
from the site, with SVOCs and metals being the most common and highest in concentration.
Tributary B contained elevated levels of metals and organics, again probably reflecting more
influence from the landfill than the site.
Figures 13 and 14 provide more detailed results of sediment sampling.
Contaminant Persistence
The persistence of a contaminant refers to the amount of time a chemical compound resides
in the environment before its chemical structure is altered, as well as the residence time of
the compound in a particular environmental medium. Persistence is particularly critical when
a substantial period of time has elapsed since waste disposal occurred. The VOCs at the site,
primarily chlorinated solv~ts but also some unchlorinated solvents, are generally
characterized by rapid voI3tm7~tion, low adsorption to soil and sediment, and varying
degrees of solubility and biodegradability.
The low adsorption properties of most VOCs at the site indicate that these contaminants
would be expected to leach relatively unimpeded through soils and into ground water and
surface waters. The RI did demonstrate that while surficial levels of VOCs in soils were not
consistently high, many VOCs were distributed at varying concentrations throughout the site
and the various media. Biodegradation of chlorinated VOCs is likely occurring at slow rates,
while unchlorinated VOCs are likely biodegrading at a higher rate.
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Phthalates and other SVOCs at the site tend to have moderate to high soil adsorption, low
volatility, and a high potential for biodegradation. These contaminants would be expected to
reside preferentially in soils and sediments and not leach readily into ground water and
surface waters. For example, bis(2-ethylhexyl) phthalate, which was found to be widespread
and at very high concentrations in some soil samples, was found at low levels in only two
ground water and two surface water samples. Alternatively, the more mobile VOCs which
were often at lower levels and less well distributed in soils were often well distributed and at
higher levels in ground water samples. The RI also confIrmed that surface water runoff
containing sediment particles effectively transponed SVOCs around the site.
Metals tend to be the most persistent of all contaminants, although they may change form
quite readily in the environment. The abundant supply of exposed scrap metal and drums
provides a constant source of some metals, and surface water runoff serves to transpon
dissolved metals and those attached to soil particles very readily around the site.
Contaminant Migration
The principle routes of contaminant migration at the site are likely by overland flow from
precipitation, downward inf1ltration through unsaturated soils and bedrock, lateral and
venical migration in ground water in unconsolidated soils and within saturated fractures,
joints, and bedding planes of bedrock, and airborne transpon of volatile contaminants by
volatilization and fmer soil particles containing adsorbed contaminants. Figure 15 provides a
conceptual view of contaminant transpon at the site. It appears that while all pathways are
important, the least significant of these is volatilization to the atmosphere.
Summary
The RI demonstrated that the distribution of contaminants at the site is widespread, as
evidenced by the distribution of organic contaminants across the various media in Table 6.
In addition, what is known about disposal activities and contaminant transport mechanisms
. appears to correlate with the observed distribution of contaminants. For example, the highest
levels of organic contaminants in soils were found below the "bum area" where drums were
allegedly emptied for salvaging and also in areas over the north slope where drums were
apparently bulldozed prior to being emptied (see Areas 1 and 2 in Figure 2). .
Similarly, the highest levels of inorganic contaminants in soils were generally found in the
active areas of the junkyard where metals have been disposed and stored over several
decades (see Area 2 in Figure 2). Analogously, the ground water monitoring wells with the
highest levels of organic contaminants are located over the north slope where soils levels are
highest in organics, and the wells with the highest levels of inorganic contaminants are
located closer to the active ponions of the junkyard. Table 7 presents a summary of
apparent correlations between elevated ground water and soil contaminants.
While the sampling conducted during the RI allows us to delineate contaminant source areas
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in a general fashion, the .RI did not attempt to determine with precision the areas and
volumes which will require remediation. It is important to note that eXJPOsure of waste
materials to weathering processes continues at the site, which can result in the movement of
contaminants beyond and within the source areas identified in the RI. In addition, the site
soils have been heavily disturbed over time through bulldozing, burning, and recontouring.
A very intensive sampling network would be necessary to fully characterize the lateral and
vertical heterogeneity of soil contaminants. The RI does allow us to generally identify the
boundaries for contaminant source area removal, but further delineation of contaminant hot
spots within these source areas will be necessary during remedial design and remedial action.
This delineation will include collection of soil samples for analysis and the use of field
screening techniques.
VI. SUMMARY OF SITE RISKS
As part of the RIfFS, U.S. EPA prepared a Baseline Risk Assessment for the site. This risk
assessment was developed to characterize, in th~ absence of remedial action, the current and
potential threats to human health and the environment that may be posed by the site through
different exposure pathways, such as ingestion and dermal contact. The risk assessment
involves identifying contaminants which are judged to represent the major potential health
risks at the site, and assessing the toxicity, or degree of hazard, posed by substances found at
the site, and the routes by which humans and the environmental receptors (plants and
animals) could come into contact with these substances. The process is summarized below~
and the Baseline Risk Assessment in the RI report may be consulted for further information.
Figure 16 provides a conceptual model of contaminant sources, transfer, and receptors at the
site.
Identification of Contaminants of Concern
Based on frequency of detection, concentration relative to background, and toxicity, the list
of contaminants found in the various media at the site was screened to 23 Contaminants of
Concern. These contaminants have been used to evaluate toxicity, exposure pathways, and
potential health risks for receptors at and near the site. The contaminants are listed on Table
8 and include ten metals, five VOCs, and eight SVOCs. Although the toxicity screening
aspects of this procedure were oriented specifically to identifying human health threats, this
same list of contaminants was deemed suitable for use in assessing ecological threats.
Exposure Assessment
Exposure assessment is the process of identifying potential pathways for contaminants to
reach human or ecological receptors and estimating contaminant uptake by these receptors.
The NCP requires that the Baseline Risk: Assessment consider Reasonable Maximum
Exposure scenarios for both current land use and for potential future uses.
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Current land use at the site includes operation of the junkyard business, a residential trailer
occupied by an adult maie (with an off-site drinking water supply), and the rearing of
domesticated animals for food, including cows, pigs, and fowl. The site continues to be
actively used by workers and residents on a daily basis. It is also important to note that
there is no current use of on-site ground water and that no nearby residential wells in use at
this time appear to have been affected. .
The future use scenario assumed by U.S. EPA for the site is full residential use. The basis
for this assumption is that the site is only 1.5 miles from the city of Marietta, and the
vicinity is dominated by residential use. This scenario includes the construction of houses
with drinking water wells. U.S. EPA does not consider this to be a remote hypothetical
threat, particularly since the occupied mobile home was placed on-site in 1990, during the
site investigation.
Human Health
For the current use scenario, potentially exposed populations are adults, adolescents, and
children who live in the immediate vicinity of the site, work in contaminated site areas,
andlor visit or trespass onto the site for the purposes of domestic animal care, hunting, and
recreation. These receptors may come into direct contact with contaminants in shallow soils,
surface water, sediments, and air during these activities. For the future use scenario,
potentially exposed populations are adults, adolescents, and children who reside on-site in .
newly constructed housing. These receptors will have free access to all parts of the site and
may come into contact with contaminants in shallow to deep soils, surface water, sediments,
and ground water.
Specific exposure pathways examined in these scenarios are:
o
o
o
o
o
incidental ingestion of contaminated soil;
dermal (skin) contact with contaminated soil;
inhalation of contaminants in ambient air;
dermal contact with contaminated surface water and sediment
ingestion, dermal contact, and vapor inhalation of contaminants in ground
water.
Chronic daily intakes of contami~nts of concern were calculated for all receptors and
exposure pathways using U.S. EPA guidance. Please refer to the Baseline Risk Assessment
for details on this process.
Ecoloeical
With the widespread contamination of the various media at the site, ecological receptors may
be exposed to contaminants from a number of routes. Terrestrial plants may be exposed to
contaminants in soils by root uptake and airborne contaminants from deposition. Terrestrial
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animals may be exposed to dennal uptake of soil and water contaminants; ingestion of
contaminated plants, soil, animals, and water; and inhalation of airborne VQCs and .
contaminated dust. Aquatic plants and animals may be exposed to contaminants in the water
and sediment, and aquatic animals may be exposed to contaminants in ingested plants, soil,
animals, and water. Exposure to contaminants through most of these routes could increase
with a future residential use scenario since there would be extensive disturbance of soils. and
waste materials.
The primary on-site locations where ecological resources may encounter contaminants
include:
o
o
o
all terrestrial locations south and west of Tributary A;
Tributary A; and
seeps south and west of Tributary A.
Secondary areas where ecological resources may encounter contaminants include:
o
terrestrial locations north and east of Tributary A, via airborne movement of
contaminants;
terrestrial and aquatic locations downwind from the site, via airborne
movement of contaminants;
Duck Creek via drainage of Tributary A into the creek; and
Tributary B.
o
o
o
Toxicity Assessment
The purpose of toxicity assessment is to estimate the likelihood and severity of adverse
effects, both carcinogenic (cancer-causing) and non-carcinogenic, from exposure to
contaminants. Based on toxicological studies of the contaminants of concern, several are
classified as carcinogens. Cancer classifications represent weight-of-evidence judgements of
the likelihood that a chemical is a human or animal carcinogen. Carcinogens found in
ground water include:
Group A Known Human Carcinogens:
Arsenic
Vinyl chloride
Group Bl Probable Human Carcinogen:
Cadmium
Group B2 Probable Human Carcinogen:
Bis(2-ethylhexyl) phthalate
Group C Possible Human Carcinogen:
1,1- Dichloroethene
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the RIDs in order to assess the potential for noncarcinogenic effects.
Risk Characterization
Risk characterization combines the exposure assessment results with the toxicity assessment
results to estimate health risks from contaminants at the site. Human health risks at
Superfund sites are assessed with respect to the separate carcinogenic and noncarcinogenic
effects of substances found at the sites under the current and future exposure scenarios.
Carcinogenic risks from various exposure pathways are assumed to be additive and are
presented in terms of the degree of increased risk over the average or background level in
humans. For the general population, the background risk of developing some form of cancer
in one's lifetime is one chance in three. The NCP specifies that acceptable carcinogenic
risks are those that may result in less than one additional cancer case in 10,000 (lxlQ'4) to
1,000,000 (lxl0-6) people over a lifetime (70 years) after exposure to the site. An excess
lifetime cancer risk of 1 in '1 million indicates that, as a plausible upper bound, an individual
has a one in one million chance of developing cancer as a result of site-related exposure to
carcinogen(s) over a 70-year lifetime under the specific exposure conditions at a site. The
NCP specifies that lx10-6 is the point of departure for the development of remedial goals.
Noncarcinogenic risks to humans, or hazards, are evaluated with respect to a hazard quotient
(HQ), which is the ratio of the level of exposure for a particular contaminant at the site to
the RID for that contaminant. If the HQ for an individual or group from exposure to a
contaminant exceeds 1, noncarcinogenic health effects may result from exposure to that
contaminant. By adding the HQs for all contaminants within a medium or across all media
to which a given population may reasonably be exposed, the hazard index (HI) can be
generated. If the HI exceeds 1, noncarcinogenic health effects may result from exposure to
that medium or to all site media.
Human health hazards associated with the presence of lead are assessed differently than for
other noncarcinogens. A model developed by u.S. EPA was used to estimate possible blood
lead levels for children exposed to the site for the existing and future scenarios.
Since the site is currently being used to raise various types of domestic animals, the Baseline
Risk Assessment also attempted to examine the potential for human health effects from
consumption of meat from "these animals. Meat from the domestic animals at the site was
not analyzed for the presence of contaminants; this ~ysis was done using a model.
DefIning the potential risks to ecological receptors at the site was approached through
comparison of sampling results to available criteria and standards for aquatic exposure and to
known toxicity thresholds for terrestrial wildlife. In addition, an ecological survey was
performed on the site and this included a qualitative assessment for toxic effects.
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Carcinogens found in soils include:
Group A Known Human Carcinogens:
Arsenic
Nickel
Vinyl chloride
Group Bl Probable Human Carcinogen:
Cadmium
Group B2 Probable Human Carcinogen:
Benzo(a)anthracene
Benzo(a)pyrene
Benzo(b )fluoranthene
Benzo(k)fluoranthene
Bis(2-ethylhexyl) phthalate
Indeno(I,2,3-cd)pyrene
Lead
Group C Possible Human Carcinogen:
1,I-Dichloroethene
U. S. EP A has also developed carcinogenic and non-carcinogenic toxicity factors to reflect the
relative risks (i.e. potency) associated with contaminants. These contaminant specific
factors, along with other factors such as the uptake estimated for each contaminant of
concern at the site, are utilized to develop the risk characterization for the site presented
below.
U.S. EPA's preferred toxicity value for evaluating carcinogenic effects is the Cancer Slope
Factor (CSP). U.S. EPA's preferred toxicity value for evaluating non-carcinogenic effects is
the Reference Dose (RID). Both CSFs and RIDs have been derived from human
epidemiological studies and animal bioassay studies. The CSF or RID value for each.
contaminant includes a margin of safety to reflect, among other things, the inherent
uncertainties in extrapolating from studies. .
CSFs are statistical values developed by U.S. EPA to conservatively reflect (i.e. show the
"upper-bound" estimate of) potential cancer risks resulting from a specified exposure to a
contaminant. In particular, CSFs represent the 95% upper confidence limit on the slope of
the dose response relationship at low doses for a carcinogen. The larger the CSF value, the
more potent is the carcinogen; i.e., a smaller dose of a high CSF value contaminant is
sufficient to increase the risk of cancer. CSF values can range from about 0.0001 to
100,000 in units of lifetime risk per unit dose (mg/kg-day). CSFs are multiplied by the
estimated uptake of a potential carcinogen to provide an "upper-bound" estimate of the
excess lifetime cancer risk associated with exposure at that uptake level. This approach
makes underestimation of the actual cancer risk highly unlikely.
RIDs are estimates of lifetime daily exposure levels which are believed to result in no
adverse health effects. Estimated uptakes of contaminants at a site can then be compared to
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Human Health Risk Summary
The Baseline Risk Assessment concluded that the contaminants which contributed most to
elevated site risks for human health include: the VOCs l,l-dichloroethene, tetrachloroethene,
and vinyl chloride; the SVOCs bis(2-ethylhexyl)phthalate and polycyclic aromatic
hydrocarbons (PAHs); and the metals antimony, arsenic, barium, cadmium, and lead.
The risk assessment also concluded that approximately 95 % of the excess risk to human
health associated with the site is due to potential use of ground water, with the remaining 5 %
associated with contact with site soils. The contaminants which contribute most to excess
risks and hazards in ground water include antimony; arsenic; barium; bis(2-ethylhexyl)
phthalate; cadmium; l,l-dichloroethene; nickel; tetrachloroethene; vanadium; and vinyl
chloride. The contaminants which contribute most to excess risks and hazards in soils
include antimony, arsenic, bis(2-ethylhexyl)phthalate, lead, and PAHs.
The risk assessment indicates that for the CUITent use scenario at the site, lifetime risks could
reach 3 additional cases of cancer in 1000 exposed adults and 4 additional cases of cancer in
10,000 exposed adolescents. These results exceed the acceptable risk range of 1 in 10,000
(lxIO-4) to 1 in 1,000,000 (lxl()'6) exposed individuals. For the future residential use
scenario, lifetime risks could reach 2 additional cases of cancer in 100 exposed adults, 3
additional cases of cancer in 100 exposed adolescents, and 4 additional cases of cancer in 100
exposed children. These results all exceed the acceptable risk range.
The risk assessment indicates that total site hazard indices for CUITent use scenario were 2.7
for adults, 3.4 for adolescents, and 1.9 for children, all of which exceed the acceptable level
of 1. It also indicates that for the future use sCenario, the total site hazard indices were 27
for adults, 43 for adolescents, and 28 for children, all well in excess of the acceptable level.
The model used to estimate health effects from exposure to lead indicates that child blood
lead levels could be unacceptably high for both the CUITeDt and future use scenarios. The
model looks at the potential for lead uptake from diet, ambient air, drinking water, and soil.
Exposure to lead in site soils is estimated to be the primary cause of elevated blood levels.
Results utilizing cows to represent domesticated animal meat consumption indicated that for
the contaminants found at the site, only the PAIls and some VOCs would be expected to
occur in vegetation at levels of concern for bioaccumulation in grazing animals. These
contaminants could cause health effects in consumers if they are accumulated to high enough
levels in the meat derived from these animals. These contaminants are rapidly metabolized
in animals, however, and are not known to accumulate to any great degree in animal tissue.
Therefore, no unacceptable risks are believed to exist from this exposure route.
Environmental Risks
Evaluation of the potential toxic effects of site contaminants on teITestrial, wetland, and
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aquatic communities at the site is complex. Generally, visible indications of contamination
are present, and sampling results confmn widespread contamination at the site.
Nevertheless, only isolated signs of environmental distress from the contaminants were
observed during the investigation. In addition, despite the extensive habitat degradation at
the site due to disposal activities, diverse terrestrial and aquatic habitats were observed over
the north slope. Tissue samples were not collected to identify actual uptake of contaminants
by ecological receptors.
Evaluation of site contaminant levels against known toxicity thresholds for animals indicates
that no toxic effects are identifIable. The site contaminant levels did not exceed the
chemical-specifIc concentrations associated with acute or chronic toxic effects in wild or
laboratory animals. However, absolute conclusions regarding the potential effects of site
contaminants cannot be made due to uncertainties about the estimates of toxicity and
exposure for animals. Toxicity thresholds for plants were not identified so a similar
comparison could not be made. In addition, exceen~nces of surface water quality criteria and
standards indicate that more subtle adverse effects on aquatic life may be occurring,
particularly in the surface water and sediments in the seeps located on the north slope of the
site.
Based on information supplied by the State of Ohio and surveys conducted during the
investigation, no endangered or threatened species are known to occur on the site.
Conclusion
In summary, releases of hazardous substances from the site, if not addressed, may present an
imminent and substantial endangerment to public health, welfare, and the environment.
Please refer to the Baseline Risk Assessment in the RI report for a complete discussion of
these results.
VD. REMEDIAL ACTION APPROACH
The Feasibility Study built upon the fmdings of the RI by identifying, screening, and
evaluating remedial action al~matives for addressing the cont~minants contributing to
unacceptable risks at the site. The primary remediation approach developed during the FS
emphasizes a combination of removing and treating or containing contaminated soils, solid
waste, and sediments to specifIed cleanup levels, thereby eliminating andlor minimi7.ing their
contribution of hazardous substances to the ground water and surface waters/sediments.
u. S. EP A anticipates that once the sources of contaminantS to the ground water and surface
waters/sediments are reduced sufficiently, ground water and surface waters/sediments will
expeditiously achieve their cleanup levels through natural attenuation. However, if
contaminant concentrations in ground water, surface waters, or sediments are not diminishing
sufficiently to achieve cleanup levels in a reasonable timeframe through source removal and
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containment, additional work may be required. A reasonable timeframe for assessing
cleanup is not being specified at this time. Information to be obtained during remedial
design and remedial action will affect this detennination.
Regular monitoring will indicate if progress in achieving the cleanup levels is occuning.
Although additional work options are provided in this Record of Decision, criteria for
making a determination that progress toward cleanup levels is not occuning at a reasonable
rate is difficult to make in advance. However, delineation of an acceptable rate of natural
ground water attenuation capable of measuring whether reasonable progress is being made
towards attaining ground water cleanup levels will be conducted during remedial design,
based in part on additional ground water information to be collected. The effectiveness of
the selected ground water remedy will be evaluated at the required five-year review. If it is
determined at the five-year review that the rate of acceptable natural ground water
attenuation is not being achieved, then additional work may be required. U.S. EPA
anticipates that no additional work will be necessary, and will conduct regular reviews of the
effectiveness of the remedy.
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 remedial measures such as treatment and
engineering controls, and other activities such as institutional controls.
Principle threat wastes are those source materials considered to be highly toxic or highly
mobile and that cannot be reliably contained or would present a significant risk to human
health or the environment if exposure occurs. They include liquids, highly mobile materials
such as solvents, and materials having high levels of toxic substances. Principle threat
wastes at the Vandale Junkyard site consist of possible buried drums, drum fragments,
sludges, and related industrial wastes containing VOCs, semivolatile organic compounds, and
metals as well as soils closely associated with (and significantly contaminated by) these
materials.
It is important to note thanhe widespread and diverse contaminant distribution at the site,
when combined with the diverse physical characteristics of the site, resulted in major
constraints on the development of a straightforward remediation approach. In particular, two
factors were critical in directing remedy development: the presence of large quantities of
"junkyard" wastes in association with the industrial wastes, and the steeply sloped and
unstable nature of the area where much of the waste has come to be located.
Soils
Soil sampling during the RI confmned widespread contamination with organic and inorganic
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substances. This contamination results in elevated risks/hazards to human health and in
potentially hannful effects to the environment. Soils at the site are not only a direct contact
hazard but also a source area for ground water and surface water contamination at the site.
The cleanup requirements for soils at the site are to excavate, then treat and/or dispose off-
site or consolidate and contain on-site, principle threat wastes in soils to acceptable levels for
direct contact exposures and to reduce leaching of contaminants so that ground water, surface
water, and sediment cleanup levels are achieved.
Since the Agencies do not have chemical-specific cleanup requirements (Applicable or
Relevant and Appropriate Requirements, or ARARs) for soil, site-specific cleanup levels
were developed based on risk-based criteria, U.S. EPA guidance, and water quality ARARs.
Water quality ARARs are used because remedial action objectives for soils must also be
protective of ground water, surface waters, and sediments. The soil cleanup levels were
selected based on a comparison betWeen background levels in the vicinity of the site, soil
concentrations which are protective of ground water, risk-based standards for soils generated
from the results of the risk assessment, and analytical detection limits. Cleanup levels for
soils are listed on Table 9. These cleanup levels will be used to determine which soils
require remediation, and these cleanup levels will be attained in all areas of the site that
remain uncapped. Some modifications to these cleanup levels may be made by U.S. EPA
during remedial design based on additional site-specific information (e.g., site-specific
leachability tests), provided that cumulative total site risk remains less than lxlQ-6 and
cumulative total site hazard does not exceed 1.
Through a combination of removal, treatment, and containment of contamination in the soils,
the selected remedy will effectively address the principle threats and satisfy CERCLA's
preference for treatment. Soil volumes which may require consolidation and containment or
excavation and treatment for the various alternatives were developed based on a comparison
of RI sampling results to the cleanup levels and on knowledge of site II1istory and waste
deposits. The actual soil volumes requiring excavation and treatment or containment may be
greater or less than the volume estimated based on the sampling to be conducted "during
remedial design.
Solid Waste
Solid waste materials at the site, including possible buried drummed waste and junkyard
materials, have been identified as source materials for soil, ground water, surface water, and
sediment contamination. The cleanup requirements for solid wastes at the site are to remove
and treat principle threat wastes (drummed and other wastes) and other source materials to
reduce leaching of cont~minants, so that soil, ground water; surface water, and sediment
cleanup levels can be achieved.
The RI/FS concluded that a listed hazardous waste under the Resources Conservation and
Recovery Act (RCRA), waste code K086, ink formulation wash water, was disposed at the
site. Although other listed hazardous wastes may have been disposed at the site, available
21

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infonnation on wastes disposed is not specific enough to be conclusive. However, it is likely
that many or all of the otganic solvent VOCs found at the site may also be derived from
other listed RCRA wastes. Although it appears that disposal of listed wastes (including
K086) may have ended prior to the effective date of RCRA, any materials excavated for the
puzpose of off-site disposal would require compliance with RCRA ARARs. Cleanup
requirements for the K086 and other potential RCRA wastes are addressed in the Evaluation
of Alternatives section of this plan.
Ground Water
Ground water sampling has confmned widespread contamination with organic and inorganic
substances and exceedances of Maximum Contaminant Levels (MCLs) promulgated under the
Safe Drinking Water Act. This contamination is believed to be the result of leaching from
site soils and solid wastes. The fractured bedrock geology at the site prevents the
development of a homogeneous aquifer, instead allowing only marginally interconnected
zones of ground water. These zones of ground water, while they may be sufficient to
support the low pumping rate of a domestic water supply well, do not yield water at a rate
sufficient to support pumping for remediation. These hydrogeologic characteristics would
limit the effectiveness of an active ground water remediation system. As a result, U.S. EPA
believes that there is no currently available ground water remediation system which would
effectively prevent migration of contaminated ground water away from the site or
significantly expedite the cleanup of existing ground water contamination over the cleanup
anticipated to occur with natural attenuation.
Source removal and containment of contaminants in site soils will be utilized to eliminate or
minimize, to the extent technically feasible, additional leaching of the contaminants from the
soils to the ground water. U.S. EPA anticipates that once the sources of ground water
contaminants are eliminated or reduced, ground water cleanup levels will be expeditiously
achieved through natural attenuation.
Cleanup levels were developed for ground water by comparing site background levels; MCLs .
and Maximum Contaminant Level Goals (greater than zero), both of which are ARARs for
ground water; risk/hazard based levels generated from the results of the risk assessment for
the site; and analytical detection limits. Cleanup levels are listed in Table 9.
Surface Water
Contamination of surface waters at the site with organic and inorganic substances reflects the
influence of contaminated soils, solid wastes, and sediments. Surface water quality standards
and criteria ARARs, consisting of Ohio EPA's Water Quality Standards and U.S. EPA's
Ambient Water Quality Criteria, were exceeded in the seeps for numerous inorganic
substances. The seeps are directly downgradient of some of the most highly contaminated
soils at the site and it is believed that the exceedances are related to runoff from these areas.
By remediating soils, sediments, and other wastes and attaining all cleanup levels for the
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protection of ground water, the migration of these contaminants to surface waters will be
eliminated or minimized. It is anticipated that the ARAR-based cleanup levels in Tal)les 10
and 11 will then be expeditiously attained in the seeps through natural attenuation once
source removal measures are completed.
Some surface water ARARs were also exceeded in Tributary B, which is located adjacent to
the site. The RI concluded that it is very unlikely that the site is contributing significantly to
this problem. Rather, it appears that the Marietta Sanitation Corporation Landfill, which
Tributary B partially drains, is causing these exceedances. Attainment of cleanup levels for
the protection of ground water and soils will further decrease the possible transport of
contaminants from the site to Tributary B, but it appears unlikely that surface water quality
criteria will be attained in Tributary B unless the contributions from the Marietta Sanitation
Corporation Landfill diminish.
Sediments
Seep sediments were found to contain levels of contaminants which could lead to surface
water quality criteria or standards exceedances. Since there are no chemical-specific ARARs
for sediments, the cleanup requirement for these sediments is to reduce contaminants to
levels necessary to attain all water quality ARARs. This will be accomplished through
source removal, natural attenuation, and active remediation of organic contaminants in the
sediments as necessary. The sediment cleanup levels were derived to ensure that water
quality ARARs are attained, and are listed in Tables 10 and 11.
vm. DESCRIPTION OF ALTERNATIVES
The Feasibility Study developed and examined six alternatives for remedial action, including
a "No Action" alternative. This section summarizes the alternatives examined in detail in the
FS. For more infonnation on the development of the alternatives please refer to the FS
report. All of the alternatives described in this section, except for the No Action alternative,
include the following common elements:
Institutional Controls
Institutional controlS will be utilized to restrict future access to areas or resources
(such as ground water) where cleanup levels have not yet been fully attained and to
ensure that the effectiveness of the remedy is maintained. These controls will consist
of fencing and other measures necessary to restrict access to the site, deed restrictions
to ensure that capped areas are not disturbed or built upon and contaminated ground
water is not utilized for drinking water during cleanup, and the prevention of future
waste disposal.
Ground Water and Surface Waters/Sediment Monitoring
Ground water and surface waters/ sediments will be periodically sampled to assess
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progress toward a,ttainment of all cleanup levels. This sampling will consist of the
collection of samples from locations established during site remediation on a quarterly
basis.
In addition, it is important to note again that all action alternatives rely on source control and
natural attenuation of contaminants for remediation of ground water and surface
waters/sediments. This is because, based on existing knowledge of site conditions and
, available technologies, active remediation of these resources, with the exception of organic
contaminants in seep sediments, is not expected to significantly expedite achieving cleanup
levels in the resources or effectively prevent further migration of contaminants at the site.
As described in depth in Section X of this document, progress towards achieving these
cleanup levels will be assessed periodically, and additional remedial measures will be
implemented if source control and natural attenuation is not effective.
Alternative 1: No Action
CERCLA requires that a "No Action" alternative be considered as a basis upon which to
compare other alternatives. Under this alternative, no remedial action would take place and
the site would remain in its present condition. All contamination would remain in site soils,
ground water, surface water, and sediments. Solid waste materials would remain on-site.
This alternative would not comply with State or Federal ARARs and would not adequately
protect human health or the environment. There is no cost for this alternative.
Alternative 2: On-Site Consolidation and Capping of Contaminated Soils and Solid
Waste; Off-Site Treatment and Disposal of Contstminated Solid Waste (Including
Dnunmed Wastes); On-Site Bioremediation of Seep Sediments
Under this alternative, an estimated 9,000 cubic yards of soils which exceed the cleanup
levels and 3,600 cubic yards of unsalvageable solid wastes on the north slope of the site
would be collected and consolidated with 500 cubic yards of unsalvageable solid. wastes in
the active areas of the site. No treatment of the soils would be performed. The consolidated
materials would be placed over active areas where soils exceed cleanup levels, compacted to
the maximum extent practicable, and capped with a RCRA Subtitle C hazardous waste cap.
No soils would be excavated in the active areas of the site.
Any drummed or other wastes (including soils) encountered during excavation which are not
suitable for on-site disposal or may be RCRA listed or characteristic wastes would be taken
off-site for treatment and disposal. All non-hazardous solid wastes (i.e. junkyard materials,
empty drums) would be screened for salvageable items. Materials found salvageable
(estimated at 900 cubic yards for the north slope and 3000 cubic yards for the active areas)
would be decontaminated as necessary and taken off-site for salvage. Sediments in the seeps
on the north slope which exceed cleanup levels for organic contaminants would be
bioremediated in place. Finally, as described above, necessary institutional controls would
be implemented and monitoring conducted. The FS report provides a complete breakdown
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of cost estimates for this .alternative.
Months to Implement Action: 10-12 months
Estimated Capital Cost: $3,709,650
Estimated 30 Year Operation and Maintenance (O&M) Cost:
Estimated Present Net Worth Cost (30 years): $4,564,880
$855,230
Alternative 3A: On-Site Treatment of Contaminated Soils and Contaminated Solid
Waste (Including Dnnnmed Wastes) by Incineration and/or Stabilization/Solidification
(as Necessary); On-Site Placement and Capping of Treated Materials; On-Site
Bioremediation of Seep Sediments
Under this alternative, an estimated 9,000 cubic yards of soils on the north slope of the site
and an estimated 24,600 cubic yards of soils in the active areas of the site which exceed
cleanup levels would be excavated. All excavated soils would then be screened for the
presence of organic contaminants, inorganic contaminants, or both. Soils with organic
contaminants above cleanup levels, estimated at 17,600 cubic yards, would be incinerated.
Residuals from incineration would be stabilized! solidified as. necessary to meet ARARs and
placed on-site under a cap meeting the requirements of Ohio EP A for a solid waste landfill
(OAC 3745-27-11). Soils containing only inorganic contaminants above cleanup levels,
estimated at 16,000 cubic yards, would be stabilized and solidified as necessary to meet
ARARs, and the residuals placed on-site under the solid waste cap. Any RCRA restricted
soils and debris would be delisted after treatment so that residuals could be disposed as a
solid waste.
Any drummed wastes encountered during excavation would be incinerated and residuals
stabilized/solidified as necessary. RCRA restricted residuals would be delisted and disposed
as a solid waste. Other solid wastes such as junkyard materials and empty drums would be
screened for salvageable items. Salvageable materials (estimated at 900 cubic yards for the
north slope and 3000 cubic yards for the active areas) would be decontaminated as necessary
and taken off-site for salvage. Unsalvageable materials would be consolidated with treated
soils and placed under the solid waste cap. Finally, sediments on the north slope of the site
would be bioremediated in place, institutional controls implemented, and monitoring
conducted. The FS report provides a complete breakdown of cost estimates for this
alternative.
Months to Implement Action: 18-24 months
Estimated Capital Cost: $26,763,740
Estimated 30 Year Operation and Maintenance (O&M) Cost:
Estimated Present Net Worth Cost (30 years): $27,618,970
855,230
Alternative 3B: On-Site Treatment of Contaminated Soils and Contaminated Solid
Waste (Including Drummed Wastes) by Incineration and/or Stabilization/Solidification
(as Necessary); Off-Site Land Disposal of Treated Materials; On-Site Bioremediation of
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Seep Sediments
All activities under this alternative would be the same as those described for Alternative 3A
except that all treated materials and non-hazardous solid wastes would be taken off-site for
disposal. No wastes would remain on-site for capping. The FS report provides a complete
breakdown of cost estimates for this alternative.
Months to Implement Action: 18-24 months
Estimated Capital Cost: $29,627,900
Estimated 30 Year Operation and Maintenance (O&M) Cost:
Estimated Present Net Worth Cost (30 years): $30,273,250
$645,350
Alternative 4A: On-Site Treatment of Contaminated Soils by Low Temperature
Thermal Desorption and/or Stabilization/Solidification (as Necessary); On-Site
Placement and Capping of Treated Soils; Off-Site Treatment and Disposal of
Contaminated Solid Waste (Including Drummed Wastes); On-Site Bioremediation of
Seep Sediments
Under this alternative, the estimated 9,000 cubic yards of soils on the north slope of the site
and 24,600 cubic yards in the active areas of the site which exceed cleanup levels would be
excavated. All excavated soils would then be screened for the presence of.organic and
inorganic contaminants. Soils with organic contaminants above cleanup levels would be
treated with a low temperature thermal desorption unit. Treated materials would be
stabilized! solidified as necessary, with residuals placed on-site under a cap meeting the
requirements of Ohio EPA for a solid was'~~ landfill (OAC 3745-27-11). Soils containing
only inorganic contaminants above cleanup levels would be stabilized and solidified as
necessary, and the residuals placed on-site under the solid waste cap. Any RCRA restricted
soils and debris would be delisted after treatment so that residuals could be disposed as a
solid waste.
Any drummed wastes encountered during excavation would be taken off-site for treatment
and disposal. RCRA restricted residuals would be delisted and disposed as a solid waste.
Other solid wastes such as junkyard materials and empty drums would be screened for
salvageable items. Salvageable materials (estimated at 900 cubic yards for the nonh slope
and 3000 cubic yards for the active areas) would be decontaminated as necessary and taken
off-site for salvage. Unsalvageable materials would be consolidated with treated soils and
placed under the RCRA Subtitle C cap. Finally, as described above, sediments on the north
slope of the site would be bioremediated in place, institutional controls implemented, and
monitoring conducted. The FS report provides a complete breakdown of cost estimates for
this alternative.
Months to Implement Action: 18-24 months
Estimated Capital Cost: $14,514,490
Estimated 30 Year Operation and Maintenance (O&M) Cost: $855,230
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Estimated Present, Net Worth Cost (30 years): $15,369,720
Alternative 4B: On-Site Treatment of Contaminated Soils by Low Temperature
Thermal Desorption and/or Stabilization/Solidification (as Necessary); Off-Site Disposal
of Treated Soils; Off-Site Treatment and Disposal of Contaminated Solid Waste
(Including Drummed Wastes); On-Site Bioremediation of Seep Sediments
All activities under this alternative would be the same as those described for Alternative 4A
except that all treated materials and unsalvageable solid wastes would be taken off-site for
disposal. No wastes would remain on-site for capping. The FS report provides a complete
breakdown of cost estimates for this alternative.
Months to Implement Action: 18-24 months
Estimated Capital Cost: $17,305,930
Estimated 30 Year Operation and Maintenance .(O&M) Cost:
Estimated Present Net Worth Cost (30 years): $17,951,280
$645,350
IX. SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES
Each of the alternatives was evaluated using the nine criteria described below. These criteria
are specified in the NCP at 40 CPR 300.430(e)(9)(ili).
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 Applicable or Relevant and Appropriate Requirements (ARARs):
Addresses whether a remedy will meet all requirements of other federal and state
environmental laws and regulations or provides grounds for invoking a waiver.
Primary Balancing Criteria:
3.
Long-Term Effectiveness and Permanence:
Refers to expected residual risk and the ability of a remedy to maintain reliable
protection of human health and the environment over time, once cleanup levels have
been met. .
4.
Reduction of Toxicity, Mobility, or Volume Through Treatment:
Assesses the degree to which a remedy utilizes treatment to address the principle
threats at the site.
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5.
Short- Tenn Effectiveness:
Addresses the potential adverse effects that implementation of a remedy may have on
human health and the environment, i.e. during construction and before cleanup levels
are achieved.
6.
Implementability:
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, also
expressed in net present worth costs.
Modifying Criteria:
8.
State Acceptance:
Indicates whether the State of Ohio supports the alternative.
9.
Community Acceptance:
Addresses the acceptability of the alternative to the local community based on
comments received during the public comment period.
The following discussion summarizes the compliance of the alternatives with the nine
criteria. For a more detailed discussion of this evaluation, please refer to the Feasibility
Study.
1. Overall Protection of Human Health and the Environment
All alternatives under consideration except Alternative I (the No Action alternative) are
expected to be protective of human health and the environment in the long term.
Alternatives which utilize treatment are preferred and provide a greater degree of protection
for human health and the environment in the long-tenn.
Alternative 2, which provides for removal and off-site treatment of drummed materials,
sludges, and other wastes (including soils) not suitable for containment but does not provide
on-site treatment of soil source materials, allows for a greater potential of future leaching and
migration of contaminants from the untreated soils. This potential is mitigated by the use of
a RCRA Subtitle C multilayer cap, which may reduce infiltration of surface water
significantly over the solid waste cap proposed for Alternatives 3A and 4A with on-site
containment of treated materials.
Alternatives 3A and 4A may provide a higher level of overall protection than Alternative 2
by providing both treatment of soil source materials and on-site containment of the residuals
with a solid waste cap. Alternatives 3B and 4B would provide the highest level of overall
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protection at the site by t,reating the source materials and disposing of the residuals off-site.
However, since the treated residuals from Alternatives 3B and 4B would be disposed at an
off-site facility within a reasonable distance of the site, the overall impacts on human health
and the environment might be similar to those for Alternatives 3A and 4A.
2. Compliance with ARARs
CERCLA requires that remedial actions meet legally applicable or relevant and appropriate
requirements of other environmental laws. "Applicable requirements" means those cleanup
standards, standards of control, and other substantive environmental protection requirements,
criteria, or limitations promulgated under Federal or State law that specifically address a
hazardous substance, pollutant, contaminant, remedial action, location, or other circumstance
at a CERCLA site. These laws include, but are not limited to the following: the Toxic
Substances Control Act, the Safe Drinking Water Act, the Clean Air Act, the Clean Water
Act, the Resource Conservation and Recovery Act, and any state environmental law that has
more stringent requirements than the corresponding Federal law .
"Relevant and appropriate" requirements are cleanup standards, standards of control, and
other substantive environmental protection requirements, criteria or limitations promulgated
under Federal or State law that, while not legally "applicable" to a hazardous substance,
pollutant, contaminant, remedial action or circumstance at a site, address problems or
situations sufficiently similar to those encountered at the site so that their use is well suited to
that site. A requirement that is judged to be relevant and appropriate must be complied with
to the same degree as if it were applicable. However, there is more discretion in this
determination; it is possible for only part of a requirement to be considered relevant and
appropriate, the rest being dismissed if judged not to be relevant and appropriate in a given
case.
In addition to legally binding laws and regulations, many Federal and State environmental
and public health programs also develop criteria, advisories, guidance and proposed standards
that are not legally binding, but that may provide useful information or recommended
procedures. These "To Be Considered" (TBC) materials are not potential ARARs but are
evaluated along with ARARs, as part of the risk assessment condu~ for each CERCLA
site, to set protective cleanup level targets. Chemical-specific values such as health
advisories and reference doses are used in the absence of ARARs or where ARARs are not
sufficiently protective to develop cleanup goals. Other 1BC materials such as guidance and
policy documents developed to implement regulations may be considered and used as
appropriate where necessary to ensure protectiveness.
Potential Federal and State ARARs for this site are listed in Appendices C and D. ARARs
are addressed in three categories: chemical-specific, action-specific, and location:-specific.
Chemical-Specific ARARs: Usually health or risk-based numerical values which establish
the acceptable amount or concentration of a chemical that may be found in or discharged to
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the ambient environment. All alternatives except Alternative 1 (the No Action alternative)
are anticipated to comply' with air, ground water, and surface water chemical-specific
ARARs. There are no chemical-specific ARARs for soils. Significant federal chemical-
specific ARARs are summarized below.
Safe Drinking Water Act
The ,Safe Drinking Water Act (SDW A) has established maximum contaminant levels (MCLs)
allowable in regulated public water supplies. The MCLs are relevant and appropriate for
determining ground water clean-up requirements at the site since the ground water serves as
an actual or potential source of drinking water. Maximum Contaminant Level Goals
(MCLGs) are non-regulatory health-based goals established under SDW A, and non-zero
MCLGs may also be relevant and appropriate under some circumstances. Ground water
cleanup levels specified for Alternatives 2 through 4B were developed to assure compliance
with MCLs and with MCLGs as appropriate. These alternatives also provide for a
monitoring component to assure detection of compounds with SDW A MCLs and MCLGs (as
appropriate) .
Clean Air Act
The Clean Air Act sets maximum contaminant concentrations for airborne releases.
Depending on the alternative, these requirements may be applicable or relevant and
appropriate to the remedial action. Alternatives 2 through 4B provide for monitoring to
evaluate air releases during all soils removal, handling, and treatment processes. This
monitoring and any necessary control devices will be used to assure compliance with these
requirements.
Clean Water Act
The Clean Water Act (CW A) is administered by Ohio EPA and establishes surface water
quality standards. These standards and U.S. EPA's Ambient Water Quality Criteria serve as
ARARs for surface waters at the site.
Action-Specific ARARs: Usually technology or activity-based requirements or limitations
on actions taken with respect to hazardous wastes. All action alternatives are expected to
comply with action-specific ARARs. Significant action-specific ARARs are highlighted
below.
Resource Conservation and Recovery Act
The Resource Conservation and Recovery Act (RCRA) requirements for treatment, storage,
or disposal of hazardous wastes apply to a site under the following circumstances:
I) if the site contains RCRA listed or characteristic hazardous waste that was treated
or disposed of after the effective date of the RCRA regulations under consideration as
potential ARARs for the site, or
2) if the CERCLA activity at the site constitutes current treatment, storage, or
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disposal of RCRA hazardous waste.
In cases where it is not known whether RCRA hazardous wastes were disposed at the site
after the effective date of this law, RCRA requirements may not be applicable, but may be
relevant and appropriate if the CERCLA action involves treatment, storage, or disposal of
wastes similar or identical to RCRA hazardous waste.
40 CPR Pan 264 lists requirements for Hazardous Waste Management units under RCRA,
and specifies that hazardous waste management units may be closed in either of two ways: a
RCRA compliant cover system or "clean" closure corrective action. The Site was not
regulated under RCRA, and hazardous waste disposal after the effective date of RCRA has
not been confmned. However, certain wastes disposed at.the site were later listed as RCRA
wastes and others may be characteristic RCRA wastes. Therefore, parts of 40 CPR Pan 264
are ARARs for remedial alternatives at the Site.
The Hazardous and Solid Waste Amendments (HSW A) to RCRA include provisions
restricting land disposal of RCRA hazardous wastes. The putpOse of the RCRA Land
Disposal Restrictions (LDRs) at 40 CPR Pan 268 is to minimize the potential of future risk
to human health and the environment by requiring treatment of hazardous wastes prior to
land disposal. As available records indicate that prior to the effective dlate of RCRA a waste
was disposed at the site which would have been a RCRA listed waste if disposed after the
effective date of RCRA, LDRs are relevant and appropriate. Consequently, all action
alternatives (2, 3A, 3B, 4A, and 4B) must comply with LDRs for this waste. This listed
waste, K086, is an ink fomulation wash water which is listed due to potentially high levels
of lead and chromium.
No drums of K086 or other identifIable listed wastes have been found at the site, but there is
a reasonable possibility that drums of such wastes will be found during remediation. U;S.
EP A also recognizes that soils and debris which contain constituents found in K086 waste
must be considered restricted soil wastes under RCRA. RCRA characteristic wastes and! or
soils may also be encountered.
RCRA LDR compliance would require treatment to Best Demonstrated Available Technology
(BDAT).for any drummed waste subject to LDRs and placement of residuals under a RCRA
Subtitle C cap. Alternatives 3A and 3B would meet BDAT for drummed K086 waste by
incinerating the waste on-site, whereas under Alternatives 4A and 4B this waste will be taken.
off-site for treatment and disposal. .
Two alternatives to BDA T treatment requirements are available for on-site disposal of RCRA
restricted soils and debris after treatment: a Treatability Variance under 40 CPR 268.44
requiring placement of residuals under a RCRA Subtitle C cap, or delisting residuals under
40 CPR 260.20 and .22 and placement of residuals under a solid waste cap. Soil and debris
Treatability Variances are intended to address situations where a CERCLA waste differs
significantly from the waste used to set the LDR treatment standard such that the LDR
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standard cannot be met or the BDAT used to set the standard is inappropriate for the waste.
This Variance would result in the use of stabilization/solidification to attain U.S. EPA's
alternate treatment levels. An alternative way to comply with LDRs for soils, and preferred
route for Alternatives 3A, 3B, 4A, and 4B, is to treat any soils to site cleanup levels and
then "delist" the residuals so that they can be disposed as a solid waste. Under these -
alternatives, the residuals would be shown to be nonhazardous wastes and thus no longer
subject to RCRA Subtitle C hazardous waste regulations. The treated soil residuals would
then be managed in accordance with Ohio EPA solid waste disposal requirements.
As described in the Proposed Plan, K086 waste is listed primarily due to the presence of lead
and chromium. Delineation of RCRA restricted soils associated with K086 wastes will be
complicated by the presence of lead and chromium from junkyard materials, especially
automobile batteries and chromed parts. The approach developed in the Proposed Plan to
delineate these soils is the following: soils which are excavated over and surrounding areas
where drummed waste disposal appears to be the predominant influence over soil
contamination and which exhibit levels of chromium or lead above cleanup levels will be
considered RCRA restricted soils. The north slope and bum areas of the site are the likely
candidate areas for this approach.
However, it is important to note that BDA T treatment standards for K086 address a whole
range of contaminants which may be found in this waste and are distributed widely in site
soils, many of which are contaminants of concern for remediation. This includes bis(2-
ethylhexyl)phthalate; butylbenzylphthalate; methyl ethyl ketone; methyl isobutyl ketone;
toluene; I, I, I-trichloroethane; trichloroethene; and xylenes. Delineation of these RCRA
restricted soil wastes from other contaminated soils may be very difficult. Furthermore, it is
likely that most soils contaminated with organic solvent VOCs are derived from RCRA listed
wastes for which sufficient documentation is not available.
Alternative 2, which provides for no on-site treatment of soils, would comply with LDRs by
consolidation of soils which can be identified as having contacted K086 waste within the
Area of Contamination (the site) followed by 'capping with the RCRA Subtitle C multilayer
cap. It is important to note that although RCRA regulations do not prohibit the on-site
consolidation and capping of drummed K086 waste or other identifIable LDR restricted
wastes encountered, Alternative 2 does provide for the off-site disposal of any such wastes in
compliance with all RCRA ARARs.
State of Ohio action-specific ARARs, as listed in Appendix E, are similar to the federal
ARARs described above.
Comprehensive Environmental Response. Compensation and Liability Act
The CERCLA Off-Site Rule, 40 CFR 300.440, would be followed under all action
alternatives to ensure that any wastes sent off-site are directed to a CERCLA "off-site
compliant" and RCRA permitted and compliant facility.
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Location-Specific ARARs: Restrictions placed on the concentration of hazardous substances
or the conduct of activities solely because they occur in special locations. The primary
location-specific ARARs which could apply to actions at the site relate to wetlands and
floodplains for surface waters, and EPA anticipates that all aspects of all action alternatives
will comply with these ARARs.
TBCs:
The U.S. EPA Office of Groundwater has published Groundwater Classification Guidelines
(GWCGs) which enable classification of all groundwater as Class I, n, or m, based on its
use, value, and vulnerability. The ground water beneath .the site would be classified as a
Class n aquifer (current or potential source of drinking water). A Class n aquifer should be
protected from contamination which might render the aquifer unusable or unacceptable as a
source of drinking water. Therefore, contamination and degradation of the groundwater is
unacceptable and should not be allowed to occur. The GWCGs are mc for the site.

The U.S. EPA Environmental Criteria and Assessment Office has prepared the Integrated
Risk Information System (IRIS) to provide health based and regulatory information on
specific chemicals. IRIS provides chemical specific information which is utilized by U.S.
EPA in risk calculations and development of health based cleanup goals and is a TBC. The
RI and FS utilized IRIS values where appropriate. As presented in all action alternatives, the
elimination of the direct contact threat by excavation and treatment or containment of
contaminated materials would comply with the health based cleanup goals developed utilizing
the IRIS database.
3. Lonl!-Term Effectiveness and Permanence
Alternative I would not be effective over the short or long-term. Alternative 2, which
provides for the off-site disposal of drummed wastes and other unsuitable wastes and relies
on containment for contaminated soils, is expected to provide a high degree of reliable
protection of human health and the environment over time. Alternatives which employ
treatment and containment or removal of soils, in addition to the removal of drummed wastes
and other solid wastes (3A, 3B, 4A, and 4B) are considered to provide a greater degree of
reliable protection of human health and the environment over time. Alternatives 3B and 4B
provide the greatest long-term effectiveness and permanence at the site since treated materials
are disposed off-site. .
4. Reduction of Contaminant Mobilitv. Toxicitv. and Volume Throueh Treatment
Alternative 1 provides no treatment, so there is no reduction in contaminant toxicity,
mobility, or volume (TMV) through treatment. Alternative 2 provides for a significant
reduction in TMV through off-site treatment and disposal of drummed and other wastes
which are unsuitable for on-site containment, as well as bioremediation of seep sediments.
Alternatives which employ treatment and containment or removal of soils, drummed wastes,
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expensive alternative, followed by (from most to least expensive) Alternatives 3A, 4B, 4A,
and 2. It is important to note that the estimated cost for Alternative 2 is only 30 % of the
cost of the least costly remedy which employs soil treatment, 4A. Cost estimates for
Alternatives 3B, 3A, 4B, and 4A exceed the cost estimate for Alternative 2 by factors of 6.7,
6.1, 4, and 3.5 (respectively).
8. State Acceptance
The State of Ohio supports the selected remedy discussed below.
9. Community Acceptance
Community acceptance of the alternatives was evaluated based on the comments received
during the public comment period. The primary concern expressed by community members,
especially nearby residents, was that the excavation and treatment of contaminated materials
could pose a greater risk to their health than leaving the contaminants in place. As the
Responsiveness Summary explains, U.S. EPA remains convinced that no action at the site
would allow contaminants to continue to migrate off-site. In addition, site characteristics
prevented the development of a containment remedy which does not require significant
collection and consolidation of contaminated materials. The use of long-term or permanent
institutional controls to limit exposure to contaminants via ground water consumption and
direct contact with soils does not provide reliable protection of human health and the
environment over time and is therefore not acceptable. Finally, U.S. EPA believes that the
action alternatives can be implemented without significantly increasing the short-term risks or
hazards for nearby residents from contaminant releases associated with soil excavation and
treatment. Alternative 2, which minimizes the disturbance of wastes at the site and does not
include on-site treatment while providing the necessary protection of human health and the
environment, is the action alternative most closely aligned with the expressed community
concerns.
Comments submitted by various PRPs found fault with many aspects of the RI, FS, and
Proposed Plan. These comments are addressed in considerable detail in the Responsiveness
Summary. Sections X and XI of this Record of Decision explain the modifications
incorporated into the selected remedy to address concerns expressed in these comments.
U.S. EPA maintains that the RIfFS and Proposed Plan were completed in accordance with
CERCLA/SARA, the NCP, and Agency guidance available when the studies were
completed, and that many of the comments resulted from misinterpretation of these
documents and the investigation.
x. THE SELECTED REMEDY
U.S. EPA selects Alternative 2 for the remediation of the Vandale Junkyard site. The
objectives of this remedial action are to achieve a total site risk of lxl
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and other solid wastes (3A, 3B, 4A, and 4B) will provide a greater reduction in TMV. Each
treatment alternative would achieve essentially similar performance goals and standards.
Treatment of the soils and other wastes will destroy most of the organic contaminants and
will incorporate the inorganic contaminants in a matrix which greatly reduces their mobility
and toxicity.
5. Short-Term Effectiveness
Alternatives 2, 3A, 3B, 4A, and 4B all require substantial soil excavation at the site. As a
result, all will increase short-term exposure of human and environmental receptors to
contaminants which are released through vaporization, surface water runoff, or fugitive dust
emission. The excavation necessary on the north slope of the site for these alternatives will
also have significant impacts on the plant and animal communities in this area. Measures
necessary to minimize these impacts during site remediation and restoration activities are
incorporated into these alternatives.
Alternative 2, which requires less excavation and does not require treatment of excavated
soils, has a lesser potential for short-term effects than the other action alternatives since it
can be completed in a shorter time frame and there will be no air emissions from treatment
units. .
Alternatives 3A, 3B, 4A, and 4B all require on-site treatment units which will have air
emissions. However, engineering controls and the site safety plan requirements (including
air monitoring) to be implemented during excavation and treatment activities will ensure that
contaminant emissions meet ARARS, thus ensuring the safety of on-site workers and nearby
residents. Alternatives 3B and 4B will also greatly increase truck traffic along the route used
for transport of treated materials and may present exposure risks along the route if a spill or
other release of these materials occurs.
6. ImDlementabilitv
All action alternatives are expected to be technically feasible and administratively
implementable. Alternative 2 would be the easiest and fastest to implement due to the need
for less excavation, the lack of treatment for soils, and fewer administrative difficulties.
Alternatives 3A, 3B, 4A, and 4B would all require either Delisting or a Treatability Variance
for RCRA restricted soils and debris and as a result would be slightly more complex to
administer. Alternatives 4A and 4B would also require the performance of treatability tests
to confIrm their anticipated technical feasibility. Alternatives 3B and 4B would be most
complex to administer due to the need to dispose of treated materials off-site.
7. 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. Alternative 3B is estimated to be the most
34
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carcinogens, a total site hazard index of I or less for noncarcinogens, and to meet all
ARARs. U.S. EPA believes that this remedy meets the threshold criteria and provides the
best balance of trade-offs among the alternatives with respect to the criteria used to evaluate
remedies. Based on available information, U.S. EPA also believes that this remedy will
protect human health and the environment by removing, treating, or containing all significant
threats at the site, and thereby reducing human health risks and hazards, and environmental
hazards, to acceptable levels.
This remedy will also comply with ARARs, will be cost-effective, and will utilize permanent
solutions and alternative treatment technologies (such as bioremediation of sediments) to the
maximum extent practicable. The selected remedy does satisfy the preference for treatment
as a principle element.
The components of this remedial action are:
...
Collection and consolidation of materials estimated at 9,000 cubic yards of
soils and 8,900 cubic yards of solid wastes (including drummed wastes)
containing organic and inorganic contaminants.
...
Segregation of solid wastes, including drummed wastes, from soils.
...
Off-site disposal of drummed materials, sludges, and other wastes which
contain substances, especially hazardous wastes, not suitable for on-site
containment.
...
Screening of solid waste materials for salvageable materials. Salvageable
materials will be decontaminated on-site and taken off-site for salvage.
...
Consolidation of soils and non-salvageable solid wastes in areas on-site which
exceed soils cleanup levels, followed by the construction of a cap meeting
requirements for a RCRA Subtitle C hazardous waste landfill.
...
In-place bioremediation of sediments in the seeps on the north slope which
exceed cleanup levels for organic contamina.nts.
...
Institutional controls necessary to ensure the integrity of the remedial action.
Deed restrictions and fencing will be used to restrict site access as necessary to
prevent the installation of drinking water wells in contaminated ground water
and the disturbance of capped areas while cleanup levels are being achieved.
...
Ground water and surface water/sediments monitoring program to confinn that
the removal, treatment, and containment of source materials and the natural
attenuation of residual contaminants allows the expeditious attainment of
cleanup levels.
36
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...
Other Operation and Maintenance (O&M) requirements, including cap
mowing, inspection, and repair.
Soil Collection and Consolidation:
Figure 17 provides the anticipated area for collection of soils which exceed cleanup levels.
Sampling during remedial design and screening during remedial action will be necessary to
confmn all areas where soils exceed cleanup levels. Cleanup levels are specified in Table 9.
U. S. EP A believes it has conservatively estimated the volume of soils requiring collection for
consolidation in the active areas of the site. Final soil volumes to be collected may be
reduced significantly, but could also increase, based on this sampling.

Dnunmed Waste Disposal:
Off-site treatment and disposal will be necessary for drummed materials, sludges, and soils
which are not suitable for containment under the cap. The following materials will be
unsuitable for consolidation and containment:
o
drums containing liquid industrial wastes, especially those which may be
RCRA characteristic or listed wastes;
droms or drom fragments containing solid industrial wastes, especially organic
wastes 'Such as solvents and tars and including any which may be RCRA
characteristic or listed wastes;
identifIable industrial sludges, especially those highly organic in composition,
such as solvents and tars, and including those which may be RCRA
characteristic or listed wastes; and
soils visibly contaminated with industrial wastes, especially organic wastes
such as solvents and tars and particularly those located near fragments of
drums which may have contained RCRA characteristic or listed wastes.
o
o
o
These materials will be taken off-site and receive the level of treatment necessary to comply
with all state and federal requirements prior to disposal at an approved facility.
Solid Waste:
Materials which are anticipated to be salvageable will consist primarily of scrap metal,
household appliances, automobile parts and batteries, and empty drums. Salvage of these
materials will recycle the metals and reduce the volume of waste requiring disposal as solid
waste on-site. Decontamination by steam cleaning or other means may be necessary for
materials to be taken off-site for salvage. Drums that contain or may have contained
hazardous waste must be properly emptied per RCRA and Ohio EPA requirements (see OAC
3745-51-07) before they may be considered non-hazardous.
37
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Capping:
Figure 17 shows the locations for consolidation of all materials to be capped on-site. Figure
18 provides a cross-section view of the cap to be required. Soils and other materials,
including un salvageable solid wastes, will be placed in two areas comprising approximately 3
acres on-site and capped with a RCRA Subtitle C multilayer cap.
U.S. EPA's recommended design for a cap and cover system which complies with RCRA
Subtitle C requirements is a multilayer system consisting of, from bottom to top (or
equivalent as approved by U.S. EPA):
A low hydraulic conductivity geomembrane/soil layer consisting of 2 feet of
compacted natural or amended soil with a hydraulic conductivity of lxlO-7centimeters
per second or less overlain by a geomembrane layer with a minimum thickness of 20
mils (0.5 millimeters);
A drainage layer consisting of at least I foot of material (typically sand) with a
minimum hydraulic conductivity of Ixl Q-2centimeters per second, overlain by fIlter
fabric to prevent clogging by fmes; and
A vegetationlsoillayer consisting of at least 2 feet of soil, sloped at 3 to 5 percent,
covered with vegetation to protect the drainage and lower levels from penetration and
frost.
Sediments:
In-place bioremediation of seep sediments will be accomplished by adding nutrients and
providing supplemental oxygen as necessary to speed the degradation of organic
contaminal1ts, while minimizing physical disturbance of the seeps. Bioremediation would be
initiated after source removal activities are completed and is anticipated to require a
maximum of five years.
Institutional Controls:
Deed restrictions will be used to prevent installation of drinking water wells and disturbance
of capped areas until cleanup levels have been achieved. Fencing and other measures will be
used to restrict site access until cleanup levels are achieved and as necessary to maintain the
long-term reliability of the remedy.
Ground Water Monitoring:
A goal of this remedial action is to restore the ground water to its beneficial use, which at
this site is to serve as a potential drinking water supply. Based on the information obtained
during the RI and the analysis of all remedial alternatives, U. S. EP A believes that the
38
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selected remedy will be able to achieve this goal. Ground water contamination may be
especially persistent in the immediate area of the contaminant sources, where concentrations
are relatively high. The ability to achieve the cleanup levels specified in Table 9 at all points
throughout the site cannot be determined until all source removal activities are completed and
ground water contaminant levels are monitored over time. Monitoring for ground water
contaminants of concern will be conducted on a quarterly basis at a minimum of six locations
for a thirty year period. This will include compliance with RCRA requirements, including at
least 1 upgradient and 3 downgradient wells for the capped area in addition to other RCRA
ground water monitoring requirements.
If the selected remedy fails to demonstrate expeditious progress toward meeting the specified
remediation levels at any or all of the monitoring points, after the period of time established
by U.S. EPA during remedial design, the contingency measures described in this section may
replace the selected remedy and remediation levels for these areas. Such contingency
measures will at a minimum include consideration of additional source removal activities,
ground water extraction and treatment, and institutional controls. These measures are
considered to protect human health and the environment, and may be technically practicable
under the appropriate circumstances.
If it is determined, on the basis of the preceding criteria, that ground water in certain
portions of the site is not being expeditiously restored to beneficial use, consideration will be
given to the installation of a ground water extraction and treatment system where feasible.
This system will be operated as long as progress is being made towards attainment of the
specified cleanup levels. If even a limited application of such a system to speed the
attainment of cleanup levels is found to be technically infeasible, or if after a reasonable
amount of time even this activity fails to attain cleanup levels, then the following measures
involving long-term management may occur, for a yet to be determined period of time:
Engineering controls such as physical barriers or long-term gradient control provided
by low level pumping, will be implemented as containment measures;
Chemical-specific ARARs will be waived for the cleanup of those portions of the site
based on the technical impracticability of achieving further contaminant reduction;
Monitoring of specified wells will continue; and
Remediation technologies for ground water restoration will be re-evaluated
periodically.
The decision to invoke any or all of these measures may be made at any time, including a
periodic review of the remedial action which will occur at five year intervals in accordance
with CERCLA Section 121(c).
39
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Surface Water and Sediment Monitoring:
The surface water and sediment monitoring program will be used to confirm that the removal
of source materials and the natural attenuation of residual contaminants allows the attainment
of cleanup levels, which are the more stringent of U.S. EPA's Ambient Water Quality
Criteria or Ohio EP A' s Water Quality Standards listed in Tables 10 and 11. Surface waters
will be monitored quarterly for contaminants of concern until cleanup levels are attained.
Six locations for surface water monitoring will be selected during remedial design.
Sediments will also be monitored for contaminants of concern until cleanup levels are
attained. Eight locations for sediment monitoring will be selected during remedial design and
two locations will be monitored each quarter on a rotating basis so that each location is
monitored annually. Sediments in seeps where active bioremediation is implemented will be
monitored at least quarterly during active bioremediation. Sediment cleanup levels are the
more stringent of the calculated sediment criteria presented in Tables 10 and 11. These
criteria were developed to assure compliance with U.S. EPA's Ambient Water Quality
Criteria and Ohio EPA's Water Quality Standards.
Detailed Cost Estimate:
Table 12 provides a breakdown of the cost estimate for Alternative 2. Operation and
maintenance costs were estimated for a thirty year period. A discount rate of 5 % percent
before taxes and after inflation over a thirty year period was used for present worth
calculations of capital and operating costs. This estimate is intended to represent -30% to
+ 50 % of the overall implementation costs for the selected remedy. The cap maintenance
cost estimates described in Table 12 may be adjusted during remedial design to reflect the
cost of one major cap repair in the event of cap failure during the O&M period.
XI. DOCl1MENT A TION OF SIGNIFICANT CHANGES
Section 117 (b) of CERCLA requires that the fInal remedial action plan be accompanied by a
discussion of any significant changes in the Proposed Plan. The Proposed Plan issued by
U.S. EPA identified Alternative 4A as the preferred alternative for site remediation. In
selecting a remedy for the Vandale Junkyard site, U.S. EPA has chosen Alternative 2 over
Alternative 4A based on ptlblic comment and further consideration of the alternatives. In
selecting Alternative 2 over Alternative 4A, U.S. EPA has carefully reviewed the balancing
and modifying criteria as they relate to the identified action alternatives, all of which were
developed to be protective of human health and the environment.
The Responsiveness Summary attached as Appendix A provides the comments received
during the public comment period on the Proposed Plan and U. S. EP A's responses to the
comments. These comments covered a broad range of issues relating to remedy selection,
but a major focus of the comments from PRPs was the need for and type of soil treatment to
be employed. The primary concern expressed by community members, especially nearby
40
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residents, was that the excavation and treatment of contaminated materials could pose a
greater risk to their health than leaving the contaminants in place.
As the Responsiveness Summary explains, U.S. EPA remains convinced that no action at the
site would allow contaminants to continue to migrate off-site. In addition, site characteristics
prevented the development of a containment remedy which does not require significant
excavation and consolidation of contaminated soils. The use of long-term or permanent
institutional controls to limit exposure to contaminants via ground water consumption and
direct contact with soils does not provide reliable protection of human health and the
environment over time and is therefore not acceptable. Finally, U.S. EPA believes that the
selected remedy can be implemented without significantly increasing the short-term risks or
hazards for nearby residents from contaminant releases associated with soil excavation and
treatment. Alternative 2, which minimizes the disturbance of wastes at the site and does not
include on-site treatment while providing the necessary protection of human health and the
environment, is the action alternative most closely aligned with the expressed community
concerns.
Soil Treatment V5. Containment
Treatment of soils at the site, while desirable and preferred under CERCLA, is difficult and
expensive due to the nature of the site soils and the extensive contamination with organic and
inorganic contaminants. Much of the site contamination is anticipated to be at relatively low
levels -- above the cleanup levels but below levels at which treatment is cost-effective. In
. addition, the need for separate treatment technologies for organic and inorganic contaminants
in soils significantly increases costs. Finally, the treatment for inorganic contaminated soils
is only capable of immobilizing the contaminants, which necessitates long-term containment
of the treated soils. Cap maintenance and related activities are significant costs which must
be borne regardless of the degree of treatment provided to the contained materials.
Cleanup Levels
U. S. EP A is also making an adjustment to the method for determining cleanup levels for
soils and water. The cleanup levels listed in Table 9 were developed to assure that after
remediation the cumulative total site risk for carcinogens would not exceed Ixl04 and that
the cumulative total site hazard index for noncarcinogens would not exceed 1. Since there
are a large number of cont~minants of concern at the site, this resulted Un very low calculated
cleanup levels for individual contaminants. In order to promote flexibility in assessing
remediation needs, particularly for soils excavation, the selected remedy provides that
individual contaminant cleanup levels may be adjusted by U.S. EPA provided that the total
site risk remains less than lxl04 and total site hazard does not exceed 1.
In addition, soil cleanup levels for the protection of ground water were calculated on a
theoretical basis using an equilibrium partitioning methodology, and with no allowance for
dilution and attenuation of cont~minants as they migrate through soils or ground water. This
41
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method is a conservative ,approach that may overestimate the actual transfer of contaminants
from soils to ground water. The selected remedy provides the flexibility to conduct
leachability tests on site soils to determine soil cleanup levels needed to assure compliance
with ground water cleanup levels during remedial design. Site-specific leachability tests must
be ~1iable and accurate and utilize a methodology approved by U.S. EPA before conducting
such tests. .
Finally, the cleanup level for vinyl chloride in ground water has been lowered to reflect the
more sensitive detection limit readily available. This new cleanup level, 0.5 ugfliter, was
achieved in the residential well samples collected at the site and is low enough to assure
compliance with the U.S. EPA Maximum Contaminant Level drinking water standard for
vinyl chloride.
Conclusion
Alternative 2, as described in Section X of this ROD, is the U.S. EPA fInal remedial action
plan for the Vandale Junkyard site. Alternative 2 was presented in the Proposed Plan, and
the selection of Alternative 2 could have been reasonably anticipated based upon the RIfFS,
Proposed Plan, and the other contents of the Administrative Record for the site, particularly
since this selection was responsive to public comments.
m. STATUTORY DETERMINATIONS
CERCLA Section 121(b)(1) (Cleanup Standards) states that, "remedial actions in which
treatment which permanently and significantly reduces the volume, toxicity or mobility of the
hazardous substances, pollutants, and contaminants is a principle element, are to be- preferred
over remedial actions not involving such treatment. The off-site transport and disposal of
hazardous substances or contaminant materials without such treatment should be the least
favored alternative remedial action where practicable treatment technologies are available."
Section 121 of CERCLA also requires that the selected remedy be protective of human health
and the environment, comply with ARARs unless a statutory waiver is justified, cost
effective, and use permanent solutions and alternative treatment technologies or resource
recovery technologies to the maximum extent practicable. Tbe following sections discuss
how the selected remedy meets these statutory requirements.
1. Protection of Human Health and the Environment
The selected remedy provides a sufficient degree of overall protection of human health and
the environment, by treating, disposing off-site, and/or containing all source materials in
excess of the cleanup levels and eliminating further ground water, surface water, and surface
water sediment contamination. Institutional controls will be implemented during remediation
to assure protection until confirmation sampling and analyses indicate that all cleanup levels
have been achieved and as necessary to protect the effectiveness of the remedy.
42
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Any short term risks associated with excavation of contaminated materials (dust generation
and contaminant vaporization) will be minimized by the use of good construction practices.
Air monitoring will be conducted during remedial action to assure compliance with all
ARARs and other specified air quality standards.
2. Attainment of ARARs
The selected remedy will attain all Federal and State ARARs. Section IX of this Record of
Decision provides an overview and description of the potential ARARs and the requirements
which significantly impact the remedy are summarized here. The primary chemical-specific
ARARs are the Safe Drinking Water Act MCUMCLG standards for drinking water, Clean
Water Act.water quality criteria and standards for surface waters, and Clean Air Act
standards for fugitive emissions. .
The primary action-specific ARARs are RCRA Land Disposal Restrictions (LDRs) at 40
CPR Part 268, RCRA hazardous waste management unit closure requirements at 40 CPR
Part 264, and the CERCLA Off-Site Rule at 40 CPR 300.440. Compliance with RCRA will
be achieved through consolidation within the Area of Contamination and containment within
a RCRA Subtitle C cap. Compliance with the Off-Site Rule will be assured by sending any
wastes off-site to a CERCLA "off-site compliant" and RCRA pennitted and compliant
facility .
The primary location-specific ARAR for the selected remedy relates to the protection of
wetlands at the site, as the site is not located in a floodplain. Compliance will be assured by
minimizing physical disturbance of the seep wetlands which have developed on the north
slope of the site during soil and solid waste removal activities and during bioremediation
activities in the seeps.
Regarding application of State ARARs for the selected remedy, it is important to note that
when State ARARs are substantially equivalent to Federal ARARs, deference is generally
given to the Federal ARARs. The primary State ARARs for this site relate to the Ohio
hazardous waste rules, e.g., Management of Hazardous Wastes (OAC 3745-54), Closure and
Post-Closure Requiremen~ (3745-55), and Hazardous Wastes Restricted from Land Disposal
(3745-59). Other State ARARs which apply to the selected remedy include, but are not
limited to, Primary Contaminant Control, i.e., drinking water standards (3745-81), Air
Pollution Control requirements (3745-15, 3745-17, and 3745-21), Recyclable Materials
(3745-58), and Water Quality Standards (3745-1). The complete list of potential State
ARARs for this site can be found in Appendix E of this ROD.
In addition, the selected remedy attains all Federal and State "To Be Considered"
requirements. The primary TBCs include the U.S. EPA Groundwater Classification
Guidelines and the Integrated Risk Information System, both of which were utilized in
developing the selected remedy.
43
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3. Cost-Effectiveness
The selected remedy provides overall cost-effectiveness because it utilizes a variety of on-site
and off-site remedial measures to obtain a high level of protectiveness without the need to
provide costly soil treatment. A high degree of pennanence will be achieved by removing
for off-site treatment and disposal those materials which are unsuitable for on-site
containment and bioremediating organic contaminants in seep sediments, while containing
contaminated soils and non-salvageable solid wastes on-site. Cap maintenance after on-site
disposal of soils is required regardless of whether soils are treated or not treated, and the
operations and maintenance costs for the selected alternative are no higher while the capital
costs are estimated to be only 30 % of the lowest cost alternative which includes treatment of
soils. In addition, provisions for removal of all salvageable solid wastes prior to
consolidation and capping will significantly reduce capping costs.
4. Utilization of Permanent Solutions and Alternative Treatment Technologies to the
Maximum Extent Practicable
The selected remedy provides the best balance with respect to the nine evaluation criteria as
described in Section IX of this Record of Decision. Alternative treatment technologies,
including bioremediation of seep sediments, are utilized to the maximum extent practicable
while maintaining cost-effectiveness. The presence of a large volume of soils contaminated
with inorganic substances makes it cost-prohibitive to develop a remedy which does not
require long-tenn containment, and the selected remedy attains a high degree of pennanence
as long as the cap is maintained. Although the remedy utilizes off-site disposal for some.
hazardous materials or wastes, the quantity of these wastes is estimated to be relatively small
and the wastes will be treated prior to off-site disposal if appropriate. Resource recovery
will be accomplished by segregating any salvageable solid wastes during excavation and
decontaminating them as necessary prior to taking them off-site for disposal, thereby
reducing the volume requiring on-site containment.
The ground water and surface water/sediment monitoring component of the selected remedial
action will assess whether concentrations of contaminants decrease after implementation of
the source control remedial action, and whether attainment and maintenance of cleanup levels
is achieved. If these cleanup levels are not expeditiously attained then this remedy requires
consideration of additional remedial measures which should ensure expeditious compliance.
s. Preference for Treatment as a Principal Element
The selected remedy eliminates the principal threats at the site through excavation of source
materials in excess of the cleanup levels, off-site treatment (as necessary) and disposal of
source materials unsuitable for on-site containment, on-site containment of contaminated soils
and unsalvageable solid wastes, and bioremediation of organic contaminants in seep
sediments.
44
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FIGURES
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CONTOUR --:TERVAL
20 FEET
ADAPTED FROM
Project Number
250066-0001
Figure
1
USGS (1975)
lOCA TION OF
W THE
ASHINGTON
V ANDAlE
COUNTY JUNKYARD
, OHIO '
-------
ApprOXimate Prope .
Vandale Junky d rty Line Location OHIO
,- - - ar
. k~~:~ --.- --I'

~ --. /'" ~,

cJ! /' AREA 1 ~~"~'
. ~ I . . I BulldOZed drums \ ,
.~o/ and some refuse ~.~ .

, AREA 3 """"",,' ..~~
.,,' Junk cars " ~ '\
/':
buned waste
, '\ Refuse wltn
. . \ some arums
VandaJe
Junkyard
.
Marietta
Sanitation
Corporation
Landfill
\ AREA 2
\ "Burn" Area
. with stored
\ scrap metal

\

AREA 4
Groves Area
J\
N
Not To Scale
FIGURE 2
V ANDALE JUNKY ARC SITE
-------
,
~.

'600
~
LEGEND
WELLS SCREENED IN THE "720 ZONE"
M~t!
.. -.".Eddy
POTENTIOMETRIC SURFACE AND FLOW DIRECTIONS
OF GROUNDWATER IN THE ''720 ZONE"-
VANDALE JUNKY ARD RI
NORTH
SCALE (IN FEET)
~O 2~0 3JO 4~0 5~O
Project Number
250066-0001
. . . POTENTIOMETRIC SURFACE CONTOUR LINE
. GROUNDWATER FLOW DIRECTION
3
ADAPTED FROM PHASE I RI
-------
APP~OXIM
__~T~ P~OPE'RT
Y LINE'
SGI'\-J --
62
~.

'600
~2.~
LEGEND
. SEPT. 1988 SEEP SAMPLING LOCATION-PHASE I
. NOY. 1988 seEP SAMPLING LOCATION-PHASE I
. PHASE II SEEP SAMPLING LOCATION (SAME AS
NOY. 1988. PHASE I)
NORTH
M~~
.-"u.iii
LOCA TIONS OF AQUEOUS AND SEDIMENT SEEP
SAMPLES-PHASE I AND II OF
THE VANDALE JUNKYARD RI
SCALE
4
ADAPTED FROM PHASE I RI
-------
PPROXJ..~I~ p
- ROPER'T'Y LINE
-......
r-'7..-'"


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.00'
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B
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ii
LEGEND
SUSPECTED CHEMICAL DUMP AREAS-PHASE I
''TOE'' OF WASTE MATERIALS PUSHED OVER EDGE-PHASE I
SUSPECTED COVERED WASTE AREA-PHASE I
BACKGROUND LOCATIONS-PHASE I SCALE (IN FEET)
AREA OF OPEN BURNING-PHASE I ~
ELEV A TED OV A/PID READING-PHASE I 0 100 2 0 3 0 400 5 0
AMP IN L CATIONS-PHA E I
AREAL DISTRIBUTION OF TCL ORGANIC reject Numbe
CONSTITUENTS IN SHALLOW SOILS-PHASE I OF THE 250066-0001
VANDALE JUNKYARD RI na
5
NORTH
M~~
... oM &Eddy
ADAPTED FROM PHASE I RI
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APP~OX'M
-~I.J: PROPERTY
I.altl".." -- -LINE
- -
~ . 100m.
501." 100m,
IIIC C...,rOwl
IIIC. ~ :o..a.
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1» WftCII .,. .. "9"'9
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E
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G
H
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LEGEND
BURN AREA SAMPLING LOCATIONS-PHASE II
HILLSIDE SAMPLING LOCA TIONS-PHASE II
SOIL BORING LOCA TIONS'~HASE II SCA E (IN FEET)
BACKGROUND SAMPLING LOCA TIONS-PHASE II L
G'ROVES SAMPLING LOCATIONS-PHASE II ~,
SAMPLING LOCATIONS-PHASE II ~o
AREAL DISTRIBUTION OF TCL ORGANIC ProfeCt NumDe
CONSTITUENTS IN SOILS-PHASE II 250066-0001
OF THE V ANDALE JUNK Y ARO RI nJ
6
NORTH
ADAPT.ED FROM PHASE I RI
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i''''''80 ..... -
96&'" ....". ......
M~~
~...~
LEGEND
SUSPECTED CHEMICAL DUMP AREAS-PHASE I
"TOE" OF WASTE MATERIALS PUSHED OVER EDGE-PHASE I .
SUSPECTED COVERED WASTE AREA..:pHASE I
BACKGROUND LOCATIONS-PHASE I SCALE (IN FEET)
AREA OF OPEN BURNING-PHASE I ~
ELEVATED OVA/PIO READING-PHASE I ~O
AMPLING LOCATION -PHA I
AREAL DISTRIBUTION OF TAL METALS IN SHALLOW roject Number
SOILS WHICH EXCEEDED SITE AND PUBLISHED 250066-00'0
BACKGROUND CONCENTRATIONS-PHASE I OF THE '
VANDALE JUNKYARD RI
NORTH
A
e
C
. x
Z-S
AA-250
~
ADAPTED FRO"'- PHASE I RI
-------
M~~
. .JI UdIt.I
D BURN AREA SAMPLING LOCATIONS-PHASE II
E HILLSIDE SAMPLING LOCA TONS-PHASE II
F SOIL BORING LOCA TlONS-PHASE II
G BACKGROUND SAMPLING LOCATIONS-PHASE II SCALE (IN FEET)
H GROVES SAMPLING LOCATIONS-PHASE II O~100 2~0 3~0 .~O 5010
SAMPLING LOCATIONS-PHASE II ..

AREAL DISTRIBUTION OF TAL METALS IN SOILS roieCt Number
HICH EXCEEDED SITE AND PUBLISHED BACKGROUN 250066-0001
CONCENTRATIONS PHASE II OF THE
VANDALE JUNKYARD RI
NORTH
ADAPTED FROM PHASE I RI
-------
VlI¥o- . .7 II()
......,.. CN8IM IJ. II()
I I . CCE . I.. II()
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1.Z . CCE . l1li. "
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FORMER ROSS/ELDER WELL
LEGEND RS~3 D~
~ NORTH
+ PHASE I MONITORING WELL ~ S"'I1"'"
. PHASE II MONITORING WELL S-11 I l.z.OCE 7 I SCALE (IN FEET)
. RESIDENTIAL WEll ~
* MCL EXCEEDANCE ~o
AREAL DISTRIBUTION OF TCL ORGANIC f'OJ8C Numoer
CONSTITUENTS IN GROUNDWATER-PHASE I AND 250066-0001
PHASE II OF THE VANDALE JUNK YARD RI re
9
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12.oa;
1.2 . CCA
1.1.1'TCA
1.1.2 . TCA
TCE
PCE
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ADAPTED FROM PHASE I RI
-------
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FORMER ROSS/ELDER WELL
LEGEND RS':3 D-6

. PHASE I MONITORING WELL ,
.. PHASE II MONITORING WELL .."
. RESIDENTIAL WELL
M~~
It.. .,4 &.Eddy
NORTH
SCALE (IN FEET)
~O zAo 3!0 .!O sJo
reject Number
250066-0001
re
10
AREAL DISTRIBUTION OF TAL METALS IN
GROUNDWATER WHICH EXCEEDED MCLI-PHASE I
AND II OF THE
ANDALE NK YARD RI
-------
I.I.CC& I.
I.I.QCA ,1
1.z.OCE 21
1.1.1. TCA 10
Ta; II
--- 7
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-------
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NO . Nell 011«1111
o - ~...-
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LEGEND fJOO
.. SEPT. 1988 SEEP SAMPLING LOCATION-PHASE I .
. NOV. 1988 SEEP SAMPLING LOCATION-PHASE I
. PHASE II SEEP SAMPLING LOCATION (SAME AS NOV. 1988. PHASE I) NORTH
. SURFACE WATER AND SEDIMENT SAMPLING LOCATION~HASr:: II
OTE: LOCATIONS SW-1 THRU SW-6 SCALE (IN FEET)
WERE ALSO SAMPLED DURING PHASE I. LOCATIONS ~
SW-4, SW-10 AND SW-11 REPRESENT BACKGROUND. ~O
AREAL DISTRIBUTION OF TAL METALS IN SURF ACE Projed Number
A TERS/SEEPS WHICH EXCEEDED A wac AND/OR wa 250066-0001
VALUES.. PHASES I AND II OF
THE VANDALE JUNKYARD RI
12
ADAPTED FROM PHASE I RI .
-------
SW-4
If: I BACK
. ~ I IS FU
!~~-~

-' ,
S..III.: 11'10,

, ...."'- CNanoe NO IQ./
p- NO 2500
1Io8(2'E",.....,.~ ~ HO
Pft1IIaI8/e
S...t841'I%'I01 ;:. ~~X
~- IMA T~
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Ac8- NO 56J M J.INE' Lec
2.B- NO 10J 8..I(MI:12I'101 -- A T'ON
T~ N02J ~ '
TCIIaI P- *-I NO DoI(2.E"".....,.. IIOJ NO SW.' ,i.i.C'
Dl&12.E""...,..,~ "OJ NO --. . 12.'101
pnt~.,.. . '5W-~""""''''' ,,-.-C,,-
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~~ ~--.~v ~7CJI~
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BenIDC - NO. NO IO\DI: 58.1: NO 0_" ~ 1aQ,j NO 120.1 . .....,."... I
B",~--- NO.NOIO\DI;'CIII.I:HD IIII(~~", NO:i.;IJD1111Q1 ~o.....,.S' 'EEP--'C ~~!iOJ~=g
tIooI2'£,.....", NO. 17Q,j IO\DI: IC.I; 2IIXICC ..-- . .
--
D. "-.yI- NO. NO IO\D,; NO;'"

. ;\E~\
...
_..~ -".
."-.-"" LEGEND ~ '~r,~ 11
~ SEPT. 1988 SEEP SAMPLING LOCATION-PHASE 'r- r"''l. II
. NOV. 1988 SEEP SAMPLING LOCA TlON-PHASE ,
. PHASE II SEEP SAMPLING LOCATION (SAME AS
NOV. 1988. PHASE I)
~ SURFACE WATER AND SEDIMENT SAMPLING LOCATION-PHASE II NORTH

NOTE: LOCATIONS SW-1 THRU 'SW-6 WERE AL:SO SCALE (IN FEET)
SAMPLED DURING PHASE I, LOCATIONS ~
SW~, SW-10 AND SW-11 REPRESENT ~O
BACKGROUND.

AREAL DISTRIBUTION OF TCL ORGANIC Project Number
250066-0001
ONSTITUENTS IN SURFACE WATER/SEEP SEDIMENTS- re
PHASES I AND II OF THE VANDALE JUNKYARD RI 13
, e.--
. 0I8a.- ~
, Hal 8II8Ift8I .,...
, HaI-
. 1.'.'.T.,.j~~-
, =-~--4"""""----
M~~
fA\.., #1M &~
ADAPTED FROM PHASE I RI
-------
LEGEND
~ SURFACE WATER AND SEDIMENT SAMPLING LOCATION-PHASE II NORTH
NOTE: LOCATIONS SW-1 THRU SW-6 WERE ALSO SCALE (IN FEET)
SAMPLED DURING PHASE I, LOCATIONS ~
SW-4. SW-10 AND SW-11 REPRESENT O~OO 2 0 3 0 ..00 500
BACKGROUND. ..

M!~ AREAL DISTRIBUTION OF TAL METALS IN SURFACE f'0250j8ct066N-oumOOb8,r
.. WA TERISEEP SEDIMENTS WHICH EXCEEDED SITE
BACKGROUND CONCENTRATIONS - PHASES I AND II
.. .M&~ OF THE VANDALE JUNKYARD RI
14
ADAPTED FROM PHASE I RI
-------
t
fi
\
-
-.
~

-L-(

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.
--v-
..
LEGEND
AIHBORNE OUST TRANSI'OR r
VOLA TILllA TlON
INF IL T RATION AND T R ANSPOR T
OVERLAND ft OW ANO T HANSPOR I
INTERfACE fLOW AND TRANSPOH I
GROUNDWATEH MIGRATION ANO IRANSPORI
WEt l SCREEN AND RISt; II
PIEZOMETRIC SURF ACE
fi
& Eddy
CONCEPTUAL MODEL OF WA TER It OW AN"
CONT AMINANT T R ANSPOR T A I "II,
VANDAl. E JUNK Y A III>
CHECKED
RL
JS
-------
Primary
Smu.ca
M~~
Metcalf &~
Primary
Release
Mechanism
Transpof1
UcdIwo
Secondary
SIIwu
Inlermediate
Rec8D'ors
e.posure
fgjot
CONCEPTUAL MODEL OF SOURCES, TRANSPORT MEDIUM
AND POTENTIAL RECEPTORS OF
CONT AMINANTS. AT THE VANDAlE JUNKY ARD
8Iw1e
fAlulJaLReUpJlUS
tiJm1I1 EoobJwI
~ UI1u!l: J I.'!!CSJ!!i1Il\QuiIJ!i;
Inhalalion
x
x
IngesJion X X x
Dennal conlaCI X X X
Ing86l1on )( )( 
IngeSlion X X 
Dermal COniact X X 
Inhalallon X X 
Ingesllon
II
II
Ingesllon
II
II
Dennal contac.
x
x
x
x
x
II
II
Project Number
250066-0001

Figure
16
-------
-~
r
. '.
\.
OElINEATlON OF NORTH SLOPE AREA TO BE
EXCAVA fEO ANO HIE PROPOSED CAP lOCA TlONS
FOR THE VANDALE JUNKYARO ALTERNATIVE 2
ProjPcl t IWllber
250066

r ifJllI f!
17
-------
2'
I '
2'
CONT AMINA TED SOILS
M:~
MotC8lf & &ktJ
'YPICAt CROSS-SECflON FOR nlE AL TERNA TE 2 CAP DESIGN
NO SCAtE

Project Number
250066

figuro
18
-------
TABLES
-------
TABLE 1
PRINCIPLE ORGANIC CONTAMINANTS IN SOILS
V ANDALE JUNKYARD SITE
Volatile Ol'2anic ComDounds
Concentration Ran,e in u2lk2
1,1, I-Trichloroethane
1,I-Dichloroethane
1,1-Dichloroethene
1,2-Dichloroethene
2-Butanone
Trichloroethene
Tetrachloroethene
Benzene
Ethylbenzene
Toluene
Xylenes
Total VOCs
ND - 27,000
ND - 1,700
ND - 360*
ND - 1,800
ND - 1,900
ND - 2,900
ND - 39,000
ND - 310*
ND - 28,000
ND - 8,900*
ND - 150,000
ND - 266,300
Semivolatile Ol'2anic Comoounds
Concentration Ranee in Ul,/k2
Bis(2-ethylhexyl)phthalate
Butylbenzylphthalate
Total PAHs
ND -1,000,000
ND - 78,000*
ND - 6,445*
ND means not detected .
*Estimated concentration
-------
TABLE 2
Comparisoa of Inorganic Concentrations in Sballow and Borehole Soils
To Local and Published Ambient Conditions
Phase I and D Vandale luokyard RI
(mglkg)
 RaIl.. ia    Vudale Silo  PubUlbed
 Vud8Je  VudaIe s. PuWiMed I8cqrouad  A8bi8l&
 OIt-SIte SoD ~ A8b.. C, L""". CD LI...~
Paramca Mia Mu C,. = I all'ltio.... C .- 1.""""'" ~w -"'J  E&CIIded
AlullUAlUII 12,100 2.5.200 9,810 - 21,000 20,000 - 65,000  Y  H
AAtLaaoay HD '.61 .HD <150 - SOO  Y  H
ArICIIi&: 2J 50 1.61- 9.51 <0.2 - 73  Y  H
Barium 96 389 62 - 1501 90 - 520  Y  H
BayUium 0.69 1.6 0.67 - 1.7 <2-2  H  H
Cadmium. HD 10 HD - '.2 0.2 - 0.4+  Y  Y
Calcium 904J 19.000 372 - 2.800 100 - 34,000  Y  H
ChrollUum- 23 515 2.5.9J - 44.9 5 - 20++  Y  Y
Cobalt 14.1 72 11.3 - 15.' . -27  Y  Y
COIl1lCr+ 18 78U 13.6 -73.9 13 - 19+  Y  Y
Iron 25.500 64.100 21.500 - 56.400 7.700 - 130.000  Y  N
Lc:ad+ 13.51 3050J 6.7J - 24.6 28 - 36.  Y  Y
Magncaium 2.660 5.2401 3.040 - 5.050 500 - 6.000  Y  N
ManpnCM 2141 2.240 169J - 1.48QI 46 - 1.800  Y  Y
Merc:ury ND 0.24 HD 0.01 - 3.4  Y  N
N ic:1ccJ + 21 79 20.8 - 33.1 20 - 29+  Y  Y
Potassium+ ND 2.750 ND - 2.560 4.200 - 5.400+  Y  N
Sc:1cnium ND 2.51 ND <0.1 - U  Y  Y
Silver NO 1.2 NO <0.5 - 3  Y  N
Sodium ND 875 ND - 170 200 - 13.000  Y  N
ThaUium ND .59 ND -  Y  -
Vanadium 25J 64.9 32.6 - 67 15 - 120  N  N
Zinc+ 61.1 1.570 59.2 - 89.3 6S - 92+  Y  Y
Cyanide NO 3.2 ND -  Y  -
NotCl:
N D = N at cIc:tec:tcd.
J = i:.;....t...l value
. = VudaIe ambialt IOi1 clara aIIWaed (rom Iocatioa8 X-I, X-2. 0-1. 0-2 ud 0-3.
# = DIta Source: Coaaor ud S"-Irldte. 1975; AI. 8&. Be. Ca. Co. Fe. MI. Ha. Th. V. ud CN clara (rom
unc::u1tiv8llld IOi1 from tile A boriz.oa ill KCDtucky: Sb, A.. HI and Se data from adtivared ud
UDCu1tivlted IOU (rom die A horizon of the Eastern United Slntes; and Ag data from
eu1tiV8&ed IOU from die A 1Iorizc8 of Miuouri.
+ = DIta Source: Lopn ud Miler. 1913; Cd. Cu. lib. NI. K ud
Zo data frolD 6 -pica c:oUoc:t.od ill Mu8kialum CouIIt)'. Ohio.
++ K Data Source: Logan ud Miler. 1913; Cr data from ?I_pica c:oUcc:ted
ill Picb_y CouDty, Ohio.
-------
TABLE 3
PRINCIPLE CONTAMINANTS IN GROUND WATER
V ANDALE JUNKYARD SITE
Volatile O~anic Compounds
Concentration RalU!e in uall
1,1 , I-Trichloroethane
1,1-I>ichlo~~e
1,I-Dichloroethene
1 ,2-Dichlo~thene
Trichlo~thene
Tetrachloroethene
Vinyl chloride
ND - 450
NI> - 610
ND - 220
ND - 2300
NI> - 250'"
ND - 86'"
ND - 47
Semivolatile Orvanic Compounds
Concentration RalU!e in ul!!l
Bis(2-ethylhexyl) phthalate
NI> - 30
Metals
Maximum Concentration in uall
Arsenic
Barium
Beryllium
Cadmium
Chromium
Lead
Nickel
80
3200
46
128
802
272'"
1300
NI> means not detected
"'Estimated concentration
-------
TABLE 4
PARAMETERS DETECTED IN GROUNDWATER SAMPLES
THAT EXCEED MAXIMUM CONTAMINANT LEVELS (MCLs) FOR DRINKING WATER
VANDAlE JUNKYARD RI
CHEMICAL STATUS MCl (mgll) S-1 S-2 S-3 S-4. S-5. S-6' S-7 S..;8 S-9 S-10 S-11 0-1 0-3 RS-01 RS-02 RS-03 RS-04
ORGANICS      . II I " ' II           
1,1-0lchloroethene F 0.007      XX X            
1,1,1- Trichloroethane F 0.2      X X             
Trlchloroethene F 0.005     X X X X            
Vinyl Chloride F 0.002        X            
T etrachloroethene F 0.005     X X X             
(cis) 1,2-0lchloroethene F 0.07      X X X            
(trans) 1,2-0lchloroethene F 0.1      X X X            
INORGANICS (Metals)                 
Arsenic (As)  .. 0.05   X X         X  
Barium (Ba)  P 2   X X X           
BeryUlum (Be)  P 0.001 X X X X X X X X X X X X X X   
Cadmium (Cd)  F 0.005 X  X X X X X X X X X    
ChromIum (Cr)  F 0.1 X X X X X X X X        
lead (Pb) - F 0.015 X X X X X X X X  X X   X X X
Nickel (NI)  P 0.1 X  X X X X X  X        
Thallium (Th)  P 0.00210.001     X          
. Exceedences reported lor both Phase' and Phase II results lor Wells S-4, 8-5, and 8-6.
X - Concentrallons 01 parameter exceeds MCl
F - Final
P - Proposed
.. - Under review
-------
TABLE 5
Sample Acute U.S. EPA AWOC (1) Chronic U.S. EPA AWOC (1) Ohio was (max) (2) Ohio was (30 day avg) (2)
location Analyte . .Uml1 (ugll) Analyte . . Limit (ugll) Analyte . .Llmlt (ugll) Analyte . . Limit (ugll)
SW-1       Se 5
SW-3       Se 5
SW-4   CN- 5.2   CN- 12
SW-5   CN- 5.2   Ag 1.3
   Ag 0.12    
SW-6 CN- 22 CN- 5.2   CN- 12
   Fe 1000   Fe 1000
   Ag 0.12   Ag 1.3
SW-7   Fe 1000   Fe 1000
SW-8   Fe 1000   Fe 1000
SW-9   Fe 1000   Fe 1000
(and dup)   Pb 12.82,(12.53)    
Seep A CN- 22 CN- 5.2 CN- 46 CN- 12
(and dup)   Fe 1000 Ag 4.72 Fe 1000
     Zn 199.(148) Ag 1.3
       Zn 180.(134)
Seep B   Cd 11.1 Zn 1358 Fe 1000
   Fe 1000   Zn 1230
Seep C Hg 2.4 Cd 44.5 Cu 1993 Cd 54.7
   Cu 641 Hg 1.1 Cu 880
   Fe 1000 Zn 6016 Fe 1000
   Hg 0.012   Hg 0.2
   NI 3332   Ag 1.3
   Ag 0.12   Zn 5449
   Zn 15.535    
Seep D   Cu 18.1 Cu 29.3 Cu 18.7
   Fe 1000   Fe 1000
Marsh CN- 22 CN- 5.2 CN-. 46 CN- 12
   Fe 1000   Fe 1000
EXCEEDENCESOF
U.S. EPA AMBIENT WATER QUAlITY CRITERIA (AWOC) AND
OHIO WATER QUAlRY STANDARDS (WaS)
FOR INORGANIC CONSTITUENTS IN SURFACE WATERS.
VANDAlE JUNKYARD RI
'Only analy1es which are exceeded by any Phase I and/or II sample are IIsled.
Please see Tables 5-19. 5-21, 5-28, and 5-29 lor Ihe analyte concentrallon lor each locallon.
"The limits lor Cd, Cu, Pb, NI, Ag, and Zn were calculated using the hardness of each respecllve sample.
No Iron limlls are established for acute AWQC or maximum was.
(1)U.S. EPA. 1987. Water Quality Crllerla.
(2)Ohlo EPA. Water Quality Siandards, Chapter 3745-1 OAC.
-------
TABLE 6
PRESENCE OF ORGANIC COMPOUNDS IN ENVIRONMENTAL SAMPLES - V ANDALE RI
   Surface    
  Surface Water  Seep Ground Residential
PARAMETER Soil Water Sediment Seep Sediment Water Wells
, .' .1- Trichloroethane X X X X - X -
, .1.2.2- Tetrachloroethene - - - - ..; - X
1,1.2- Trichloroethane - - - - - X -
1.1-Dichloroethane X X - X - X -
1,1..Dichloroethene X X - - - X -
1'2-Dlchloroethane .X X - - - X -
, .2-Dichloroethene (total) X X - X - X X
2-Butanone (MEt<) X - X - - - -
2-Hexanone - - - - - - X
Carbon Tetrachloride - - - X - - -
Chlorobenzene X X X - - X -
Chloromethane - - - X - - -
4-Methyl-2-Pentanone (MIBK) - - - - - X -
Tetrachloroethene X X - X X X -
Trichloroethene X X - X - X X
Vinyl Chloride - - - - - X -
Acetone X X X X - X -
Benzoic Acid X - - X X - -
Carbon Disulfide X - - - - - -
Chloroform X - X - - - -
Methylene Chloride - - X - - - -
Phenol X - X - - - -
   -
Benzene X X - - - X -
Ethylbenzene X - X - - - -
2-Methylnaphthalene X - - - - - -
Naphthalene X - - - - - -
Toluene X X X - - X X
Xytenes X X X - - X -
Styrene - - X - - - X
Bis(2-ethylhexyl)phthalate X X X - X X -
Bu!y\benzylphthalate X - - - X  -
Di-n-butylphthalate - - - - X - -
Diethylphthalate X - - - - - -
Di-n-octYlphthaiate X - - - X - -
X . Present
- . Absent
. = Not Sampled
-------
~.
.~
f'
TABLE 7
SUMMARY Ot. API-ARENT CORR~IA TIONS HE1WEEN
ELEVATED GROUNDWATER AND SOIL CONTAMINANTS
Wells S-3 and S-4 Well S-6 Well S-4  Well S-S
Boring Z-S Boring E-I Borings F-I, F-2. and F-3 Borings B-2 ami E-4
Elevated Elevated Elevated Elevated Elevated Elevated Elevated Elevated
Groundwater Soil Groundwater Soil Groundwater Soil Groundwater Soil
Contaminants Contaminants Contaminants Contaminants Contaminants Contaminants Contaminants Contaminants
Wells S-3 Boring Z-S Well S-6 Boring E-I Well S-4 Borings F-I, Well S-S Borings B-2
and S-4     F-2, F-3  and E-4
Arsenic Arsenic Vinyl Chloride  I,I-DCE I,I-DCE I,I-DCE 
Barium  I,I-DCE I,I-DCE I,I-DCA  Itl-DCA I,I-DCA
Beryllium  I,I-DCA I,I-DCA 1,2-DCE 1,2-DCE .I,2-DCE 1,2- DeE
Cadmium Cadmium It2-DCE 1,2-DCE I,I,I-TCA I,I.I-TCA 1,2-DCA 
Chromium Chromium I,I,I-TCA I,I,I-TCA TCE TCE I,q-TCA I,I,J-TCA
Lead Lead TCE TCE PCE PCE TCE TCE
Nickel  PCE PCE  Methylene Chloride I,J,J-TCA 
  Chlurohcnzene   2-Butllnone Benzene 
   BTEX  Toluene ~CE PCE
     Elhylhenzenc Chlorobcnzenc
     X ylencs X ylenes 
-------
TABLE 8
CONTAMINANTS OF CONCERN
V ANDALE JUNKYARD SITE
Antimony
Arsenic
Barium
Benzo(a)antbracene
Benzo(b)f1uoranthene
Benzo(k)f1uoranthene
Benzo(a)pyrene
Beryllium
Bis(2-ethylhexyl)phthalate
Cadmium
Chrysene
l,l-Dichloroethene
1,2-Dichloroethene
Indeno(1,2,3-cd)pyrene
Lead
Naphthalene
Nickel
Silver
Tetrachloroethene
1ballium
1,1, I-Trichloroethane
Vanadium
Vinyl Chloride
)
. .
. ,
)

,--,.I
-------
(.
(
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-.----.. .
TABLE 9
CLEANUP LEVELS FOR V ANDALE JUNKYARD SITE
Grouadwater
Substance

umony
Arsenic
Barium
Beryllium
Bis(2-etbylhexyl)pbthalate
Cadmium
1.1-DicbJoroethene
1.2-Dicb10r0etbenc
Nickel
TetracbJoroethene
1.1.1- Trichloroethane
Vanadium
Vinvl Chloride
canup
Uve1 (mg/L)
.
8.8E-02
3.02E-Ol
5.0E-03
1.0E-03
8.58E-03
1.5E-03
0.10
6.0E-02
I.5E-03
2.0E-02
4.0E-02
S .OB-04
BG
BG
MDL
MDL
BG
MDL
HBC
HBC
MDL
HBC
HBC
MDL
SoU
Substance

tunony
Arsenic
Barium
Benz.o( a )anthracene
Benzo( a )pyrene
Benz.o(b )fluoranthene
Benz.o(k)fluorantbcnc
Beryllium
Bis(2-ethylhexyl)phthalate
Cadmium
Chrysene
1.1-DicQJoroethene
lDdeno( 1,2.3-
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TABLE 10
SELECl'ED CIIEMICAL-SPECIFIC POTENTIAL APPLICABLE OR REt.EV ANT AND APPROPRIATE REQUIREMENTS ..
FEDERAL GOVERNMENT
CW A Waler Quality Criteria
ror Protection or Human Ifcallh
CW A Ambient Water Quality Criteria.
ror Protcc:tion or Aquatic Lire
Water and
Fish Ingestion
(mg/l)
Fish Consumption
Only
(mg/l)
Freshwater
AcutelChronic
(mg/l)
Federal Sediment.
Standard (calculated)"
(mg/kg)
Antimony
Arsenic
Beryllium
Bis(2 -elhylhClyl)phlhalale
Cadmium
Chromium
Copper
Cyanide
Chlorororm
1,l.Dichloroelhene
1,2-Dichlotoelhene
Iron
Lead
Mercury
Nickel
Selenium
Silver
Telrachloroelhene
Thallium .
1,1,1. Trichloroel hane
Vanadium
Vinyl Chloride
Zinc.
1.4E-02
'2.2E-06
1.1E-06
1.8E-03
1.6E-02
3.3E+01
1.3 .
0.10
S.1E.03
S.1E-OS
0.10
4.3
I.SE-OS
1.3E-04
S.9E-03
0.11
6.7E +02
. .
9.0 '1.6 .
0.85.t4.8E-02.
0.13 /S.3E-03
8.0E +04 -
0.24
2.2E+02
0.41
3.2E-03
1.4E+02
..

3.9E.03 + /1.1 E-03 +
1.1+,U210+
1.8E-02 +/1.2E-02 +
2.2E-02/S.2E-03
../1.~4
11.6.1--
11.6 /..
1.03S+
S.91 E-02 +
2.6E-02
S.45E+0I
S.OE.02
1.4E-04
0.61
0.10
0.105
8.0E.04
1.1E-03
3.1
I.SE-04
4.6
6.8
65
8.85E.03
6.3E-03
1.7E+02
--

8.2E-02 +13.2E.03 +
2.4E-03/1.2E-OS
1.4+"..16+
2.0E.02/S.0E-03
4.1 e.03 +/1.2E-04 +
5.28 10.84
1.4/0.04
I.S9E+0I +
6.0E-f)J
3.06E+02
2.0E-03
0.S25
..
0.12+ ,fl.1I +
5.JE+01 +
. 1.-.. OIIserwd Elfed Lcwl
.. Cak.lalioft.oI Sedimelll Standards is plOVidcd ita Appcndi. III oIlhis report
+ lIardneu clcpenden. cri.eria (100 """ used) .
SnuKCS: U.S. 1:'1\. QutJl;" Or/trilllor W"," If»fd. I:PA 44O/S-IIlo-OOI. Ma,. 19M (SI l1cdenl Rep.er OMS) and A';'mdm,,,, 101M Wal" Qu..I;" SIa"dards R".,Iatio" 10 ":110611111 III,
N/l1IfI'ric (""'triG lar I'Wnrif1 To.ric 1'01l1li..11" Nrcnuny 10 Brill' All Sta"., '''/0 Compliatt wit" SrctilJfl Jo.l (cl(IUHI. I'topo~d Ruin. Nowml>cr. 1991 (S6 feclcnl Resister S8420.
(
\
-...
(
,
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/ .
--..
.'
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TABLE 11
SELECTED CHEMJCAL-SPEClnC POTENTIAL APPLICABLE
OR RELEVANT AND APPROPRIATE REQUIREMENTS - STATE OF 0"10
  Ohio EPA Water Quality State of Ohio
Chemical Name Standards for Aquatic Sediment Standard
  LiCe Habitat( 1) (Calculated )(2)
  (30 day average) (mg/l) (mg/kg)
Antimony 0.19 9.5E + 03
Arsenic 0.19 0.95
Beryllium 2.3E-02+ 
Bis(2-etbylhexyl) phtbalate 8.4E - 03 1.68E + 07
Di-n-butylpbthalate 0.19 3.23E + 04
Butylbenzylpbtbalate 4.9E - 02 245£ + 03
2-Butanone 7.1E - 03 I.28E - 02
Cadmium 1.4£-03+ 
Chlorobenzene 26E . 02 8.58
Cblorofonn 7.9E . 02 3.48
Chromium 0.207+ 1.035+
Copper 1.18E - 02+ 5.89E + 01 +
Cyanide I.2E . 02 6.0E - 02
l,l-dichloroethene 7.8E - 02 
1.2-dichloroethene 0.31 
Ethylbenzene 6.2£ - 02 6.82£ + 01
Iron . 1.0 
Lead  6.92£ - 03 + 3.46£ + 01 +
Mercury 20E - 04 0.1
4-Methylpbenol 6.2£ - 03 0.215
Nickel  0.17+ 
Napbthalene 4.4E - 02 
Selenium 5.0E - 03 
Silver  I.3E - 03 
Styrene 5.6E - 02 4.45£ + 01
Tetracbloroethene 7.3£ - 02 266E + 01
Toluene 1.7 4.2SE + 02
Thallium 1.6£ - 02 
1.1 , I-Trichloroethane 8.8£ - 02 
Vanadium -
Vinyl Chloride -
Zinc  0.1()6 + 5.30£ +01 +
(1) Source: Ohio EPA Water Quality Standards, Chapter 374S-10AC
(2) Calculation of Sediment Standards is provided in Appendix m of this report.
+ Hardness depende!1t criteria were calculated with a hardness value of 100 ppm.
. -. --...----- p-- --
. - .- -- --
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TABLE 12
-Cost Estimate lor Alternative 2-
On-Site Consolidation and Capping 01 Contaminated Soils: Oil-Site Treatment
and Disposal 01 Contaminated Solid Waste (including drummed waste)
Vandale Junkyard
Mariena. Ohio
CAPtT Al COSTS   
   Cost
lIem Unit Cost Units ( t992 dollars)
I. North Slope Excavation and Grading Activities   
A. Access Road Construction.   
1. Ctearing lor Road Construction 7.000 lacre 1 7.000
2. Purchase and Place Gravel lor Roadway 3.16 Isq. yd. 4.800 15,170
(6-inches deep)   
B. Clear Areas to be Excavated (includes grubbing 01 7,000 lacre 1.9 13.300
stumps and chipping 01 trees)   
C. Excavation Activities   
1. Excavation 15 leu. yd. 18.000 270.000
2. samre Collection and Analysis 1.215 Isample 40 48,600
D. Backli I and Gradin: Activities .   
1. Place. Grade. an Compact Clean Soils From 8 leu. yd. 3.600 28.800
North Slope Excavation   
2, Purchase. Transport. Place. and Comeact Addi- 17.64 Icu. yd. 12.900 227,560
tionat Fill Material as Necessary lor Sue   
Grading 20.29 leu. yd.  
3. Purchase. Transport. Place, and Compact Topsoil 1,500 30,440
(6-inches thick)   
. 4. Seeding to Provide Vegetative Cover 1.400 lacre 1.9 2,660
5. Covering 01 Seeded Area With DrainaHe Net 1.44 Isq. yd. 9.200 13.250
. E. Construct Drainage Trench Atop North lope to   
Divert Runo"   
1. Trench Excavation 10 leu. yd. 600 6.000
2. Purchase, Pour. and Mold Concrete for Trench Base 8 Icu. yd. 200 1,600
F. Construct Surface Water Conoc'ion Pond to Collect   
RunO" During North Slope Excavation Activities   
(3-leet deep)   
1. ExcavatiOn 10 leu. yd. 3,400 34,000
2. Synthetic Geomembrane Liner (tested and Installed) 4.45 Isq. yd. 3.400 15.130
G. Equipment MobilizationlDemoblliz8tion .   30.000
SUBTOT Al(Category I)   743.510'-
(

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lIem
.. -- --_..
. ..- ----.-------.---- -.------...
TABLE 12
..-. --------- ----.
II. Segregalion/Handling of Excavaled Malerials and Aclive
Area Solid Wasles (a)
A. Segregalion/Deconlaminalion AClivily labor COSIS
B. Segregalion/Decontaminalion Equipmenl COSIS
C. Sample and Analysis Costs lor Solid Wasle Malerial
Classi'icalion
D. Sample and Analysis COSIS for liquid Wasle Material
Classilicalion
E. Transport andOIf-Sile Trealme", and Disposal of
Conlaminaled Solid Waste .
F. On-Site Treatmenl and Discharge or Transport and
Off-Site Trealment and Disposal of liquid
Wastes horn Deconlamination Operalions and
Collecled Surlace Water Runoff .
G. Equipmenl Mobilization/Demobilizalion

SUBTOTAL (category II)
III. Capping Activities
A. Clear and Prepare Areas for Capping
B. Place and Compact Contaminated Soils and Unsalvage-
able Solid Wastes From North Slope Excavation and
Unsalvageable Solid Wastes From Active Areas
C. Clay Borrow Source Testing
D. Purchase, T,ansporl, Placement and Compaclion 01
Clay hom OU-Site Borrow Source (2-Ieetlhick)
E. Synthetic Geomemb,ane liner (tested and installed)
F. D,ainage layer Mate,ial Purchase and T,ansporl
(sand. 1-tootlhick) . .
G. Sand Borrow Sou,ce Testing
H. Sand Placement and Comraction
I. Purchase and Installation 0 Geotextile Fabric
J. Purchase. T,anspo,t, Place, and Compact Topsoil
. (2-Ieetthick)
K. Seeding 10 P,ovide Vegetative Cove,
l. Equipment Mobilizalion/Demobllizalion
SUBTOTAL (category III)
IV. Sedimenl Remedialion
A. Purchase of Pumps 10 Aerale Sediments and Nut,ienls
10 Enhance Biodegredation
B. Purchase 0' Per'oraled Tubing
SUBTOTAL (calegory IV)
  Cost
Unil COSI Unils (1992 dollars)
640 Iday 24 15,360
15 Iday 24 1,800
1,215 Isample 6 7,290
870 Isample 6 5,220
600 leu. yd. 900 540,000
1.50 Igallon 100,000 150,000
  10,000
  729,670
1.500 lacre 3.2 4,800
8 leu. yd. 13.100 104,800
1 ,100 Isample 2 2,200
24 leu. yd. 12,640 (b) . 303,360
4.45 Isq. yd. 15.500 68.980
15 leu. yd. 5.560 (b) 83,400
400 Isample 2 800
1.02 leu. yd. 5,560 5.670
1.28 Isq. yd. 15.500 19.840
20.29 leu. yd. 12,640 (b) 256.470
1.400 lacre 3.2 4,480
  30,000
  8ii4:eoo
  18,000
  2,000
  ---- ----20:000 -
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TABLE 12
CAPITAL COST SUMMARY
Item
.... - ---- --.----
------. - .-------
CAPITAL COST SUBTOTAL
CONTINGENCY (20%)
TOT Al CONSTRUCTION COST
DESIGN. ENGINEERING, AND CONSTRUCTION MANAGEMENT (30%)
TOT Al CAPITAL COST
ANNUAL OPERATION AND MAINTENANCE (0 & M) COSTS
Item

I. Annual 0 & M Costs, Years 1 through 5
A. Sampling and Analysis of Surface/Seep Water and
Groundwater on a Quarterly Basis (6 samples/quarter)
B. Sampling and Analysis 01 Sediments on a Quarterly
Basis (2 samples/quarter)
C. Sediment Aeration Pumps
D. Cap Maintenance
1. Mowing (8 times/year)
2. Inspection and Repair
ANNUAL 0 & M SUBTOTAL, YEARS 1 THROUGH 5

CONTINGENCY AND OVERHEAD (200/0)

ANNUAL 0 & M COST, YEARS 1 THROUGH 5

PRESENT WORTH 0 & M, YEARS 1 THROUGH 5
($84,tI0/year lor 5 years @ 5%)

II. Annual 0 & M Costs, Years 6 through 30
A. Sampling and Analysis 01 Surface/Seep Water and
Groundwater on a Quarterly Basis (6 samples/quarter)
B. Cap Maintenance
1. Mowing 01 Cap (8 times/year)
2. Inspection and Repair 01 Cap
ANNUAL 0 & M SUBTOTAL. YEARS 6 THROUGH 30

CONTINGENCY AND OVERHEAD (20%)

ANNUAL 0 & M COST. YEARS 6 THROUGH 30
"
Cost
(1992 dollars)
2.377,980
475,600
2.853,580
856,070
3,709,650
   Cost
Unit Cost Units ( 1992 dollars)
1.070 'sample 24 25.680
900 'sample 8 7,200
258.30 'day 100 25.830
0.0075 'sq. It. 140,000 1.050
258.30 'day 40 10,330
   -70,090-
   14.020
   84,110
   364,150
. 1,070 /sample 24 26,680
0.0075 'sq. It. 140,000 1,050
258.30 'day 40 10,330
   37,060
   7.410
   44.470
::
t;
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TABLE 12
Item
- - -. -. "-
-'~-'--- -- --..... -.--.-
. .-.. ..---- -----.-
PRESENT WORTH 0 & M, YEARS 6 THROUGH 30
($44.470Iyear lor years 6 through 30 @ 5%)

TO"r AL PRESENT WORTH 0 & M COST, YEARS 1 THROUGH 30
INET""PRE5ENT WORTH COST FOR AlTERNAfivE2
. (T olal capilal cosl + lolal 0 & M CO'SI) .
(a) Cost 10 Iransport salvageable solid waste 10 an off-sire 'acility 'or reuse is not
accounted for because it is assumed Ihatthe value 01 the salvageable materials will
be approximately aquallo the Iransport cost.
(b) Exlra malerlal 'or compaction and spillage is included. This exlra material is
assumed 10 be 250/0 0' Ihe lolal compacled cubic yardage 'or clay and lopsoil
and 10% lor sand (U.S. EPA, 1986)
Note: sq. yd.=square yard; cu. yd.=cubic yard
COSI
{1992 dollars)
491.080
855.230
4,564.880
~
J
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APPENDIX A
RESPONSIVENESS SUMMARY
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SUMMARY OF COMMENTS RECEIVED DURING PUBLIC COMMENT PERIOD
This Responsiveness Summary has been prepared to meet the requirements of Sections
113(k)(2)(B)(iv) and 117(b) of the Comprehensive Environmental Response, Compensation
and Liability Act of 1980, as amended by the Superfund Amendments and Reauthorization
Act of 1986 (CERCLA), which requires the United States Environmental Protection Agency
(U.S. EPA) to respond" ...to each of the significant comments, criticisms, and new data
submitted in written or oral presentations" on a proposed plan for a remedial action. The
Responsiveness Summary addresses concerns expressed by the public and potentially
responsible parties (pRPs) in written and oral comments received by U.S. EPA regarding the
proposed remedy for the Vandale Junkyard site.
A. Overview
1. Pro Dosed Plan
The Final RI Report, which included the Baseline Risk Assessment, was released to the .
public in February 1992. A Fact Sheet summarizing the fmdings of the RI was distributed in
June 1992 to approximately 100 members of the public who were on the site mailing list.
The Final FS Repon and Proposed Plan were released to the public in August 1992. A Fact
Sheet summarizing the FS and Proposed Plan was distributed to members of the public on
the site mailing list in August 1992.
The Proposed Plan for the remedial action included six alternatives for the site: one No
Action alternative and five action alternatives. The action alternatives called for various
combinations of containment, treatment and containment, and/or treatment and off-site
disposal of contaminated materials. The preferred alternative in the Proposed Plan called
for on-site treatment of soils, on-site containment of treated residuals and other wastes, and
off-site disposal of materials not suitable for on-site treatment or disposal.
2. Public Comment Period
The Administrative Record me for the site was made available for review by the public at
the Washington County Public Library and the County Courthouse Commissioner's Office in
Marietta, and at U.S. EPA Region 5 offices in Chicago, during the public comment period
which extended from August 27, 1992 through November 13, 1992.
An announcement regarding the public comment period and the availability of the
Administrative Record me was published in the Marietta Times newspaper on August 26,
1992. Following a written request from several PRPs, a notice extending the public
comment period until October 29, 1992 was published in the Marietta Times newspaper on
September 9, 1992. After a second written request from several PRPs, a notice extending
the public comment period a fmal time through November 13, 1992 was published in the
I
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Marietta Times on October 29, 1992.
. .
A public meeting was held in Marietta on September 10, 1992. At this meeting, attended by
approximately thirty members of the public, representatives from U.S. EPA and Ohio EPA
summarized the fmdings of the RIfFS and the Proposed Plan, described the remedy selection
process, answered questions from the public, and accepted statements from members of the
public. Comments, including formal statements from six community members, were
recorded by a court reporter and a transcript of the meeting is included in the Administrative
Record.
A total of 13 written submittals were received from the public during the public comment
period. Two letters were from the general public and 11 comments were from PRPs. A
corrected version of one PRP submittal, containing four pages which were inadvertently
excluded, was received several weeks after the close of the comment period. The corrected
comment has been accepted in lieu of the original comment.
Responses to comments received during the public comment period are contained in this
Responsiveness Summary. Several written submittals from PRPs were lengthy and very
detailed. Since these submittals did not contain itemized individual comments or questions,
U.S. EPA summarized the significant comments, criticisms, and new information contained
in these documents and responded as completely as possible.
B. CommunitY Involvement
Although investigations of hazardous substance disposal at the site began in 1980, when Ohio
Environmental Protection Agency (OEPA) personnel fIrSt visited the site, the site has a
history of complaints to local authorities from nearby residents dating back to at least 1969.
Most of the complaints appear to have been related to open-burning and accepting wastes
which created nuisances, such as odors and rodents. The state of Ohio filed suit against the
owner/operator of the facility in 1984, and a settlement was reached which assured access to
the site for investigations and prohibited any further collection of solid or hazardous waste,
as well as filling, grading, excavation, or buming activities. The owner/operator was
allowed to continue junkyard operations permitted by Washington County, and the site
remains a licensed junkyard. The level of public interest and involvement regarding the site
has been relatively low since this time.
Based on the assessments of the release of hazardous substances at the site, the site was
proposed for inclusion on U.S. BFA's National Priorities List (NFL) for Superfund sites in
1982, and was finaH7ed on the NPL in June 1986. A public availability session was held in
Marietta on October 6, 1988 to explain the Superfund process and the RI work which began
in September 1988. An information repository was established at that time at the
Washington County Public Library in Marietta. .
2
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C. Summary of Sienificant Comments
The public comments regarding the Vandale Iunkyard site are organized into the following
categories:
Summary of comments from the local community regarding the RIfFS and
proposed plan;
Summary of comments from PRPs concerning the RIfFS and the proposed
plan. Due to the extensive number of comments, this section is organized by
topic: General Comments, Remedial Investigation Comments, Baseline Risk
Assessment Comments, Comments on the Development of Remedial
Objectives, Comments on the Development and Evaluation of Remedial
Alternatives in the Feasibility Study, and Comments on the Cost and Volume
Estimates in the Feasibility Study.
Many of the comments below have been paraphrased in order to effectively summarize the
II significant comments, criticisms, and new data" for this document. The reader is referred
to the Administrative Record for this site, located at the Washington County Public Library
in Marietta and at U.S. EPA Region 5, which contains copies of all written comments
submitted. The Administrative Record also contains a copy of the public meeting transcript.
The Administrative Record Index is included in Appendix B of the Record of Decision.
Comments from the Community
1.
A commenter suggested that U.S. EP A had overlooked a remediation technology
which could be utilized at the site. This technology, in-situ vitrification (ISV), would
be used to create vitrified cell structures where the contalJ'lin:lted soils and other
materials from the site could be deposited. The cells could be constructed by
vitrifying a floor liner, and walls and placing contaminated soils inside.
Subsequently, clean soils used to cover the contaminated soils could be vitrified to
provide a low permeability . cap. The commenter offered the services of his company
in utilizing this technology. .
U.S. EPA Re$PQnse: U.S. EPA did evaluate ISV for treatment of contaminated soils in the
FS and rejected this technology as unproven and inappropriate for the CODtamin:lnts and soils
at the site. However, U.S. EPA is not familiar with the ISV adaptation which this
commenter called "barrier/liner concept," and the documentation provided by the commenter
does not completely describe the implementation of this concept. As a result, U.S. EPA is
not able to assess the feasibility of this process or its potential effectiveness at the site. The
construction of vitrified containment cells is not a proven or commercially available remedial
technology and was therefore not evaluated in the FS report.
3
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Research is currently being conducted to evaluate the use of vitrified cells for disposal of
radioactive wastes and other waste materials but to date the research is inconclusive. One of
the most significant unresolved issues associated with the use of vitrified cells is the
long-term integrity of the cell, including the potential for cracking and breaking. Cracking
or breaking is of particular concern when large volumes of waste material are placed within
the cell which cause loading and stress on the vitrified material. Vitrification contractors
contacted indicated that large-scale commercial application of vitrified containment cells is
not currently available.
2.
One set of commenters noted that anyon-site containment of materials, even if treated
prior to containment, would allow the potential for future releases of contaminants
and therefore represents a hazard. The commenters requested that no contaminated
materials be left on site.
U.S. EPA ReSJK>nse: U.S. EPA acknowledges that on-site containment of materials does
allow the potential for future releases of contaminants, but believes that containment under a
RCRA Subtitle C hazardous waste cap is adequate to protect human health and the
environment. Off-site disposal of treated materials entails substantial additional costs and
does not reduce the overall potential impact of these materials. In addition, the
transportation of these materials off-site creates short-term impacts on human health and the
environment.
3.
One set of commenters asked for an explanation of the bioremediation planned for
sediments on the north slope of the site.
U. S. EP A ReSJK>nse: In-place bioremediation of seep sediments on the north slope of the
site will be accomplished by adding nutrients and providing supplemental oxygen as
necessary to speed the degradation of organic contaminants. Since U.S. EPA wants to
minimi7.e physical disturbance of the seeps, nutrients will be added manually and oxygen will
be supplemented with small flexible hoses running from aeration pumps. Bioremediation
would be initiated after source removal activities are completed and is anticipated to require a
maximum of five years.
4.
A commenter expressed concern that he and his family may have been exposed to
contaminants from the site through his private residential well prior to connection to
the local public water supply system. This commenter pointed out on a map at the
public meeting that his residence is separated from the site by a ravine, through which
Tributary A runs.
U.S. EPA Response: Although the commenter did not provide sufficient information to
assess the possibility of his private well being impacted by the site, the current ground water
monitoring results indicate that off-site transport of contaminants is limited. In addition, the
location of the residence across the ravine from the site makes it unlikely that this well was
impacted. Tributary A serves as a natural outlet for ground water from the north and east
4
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slopes of the site.
s.
A commenter asked why U.S. EPA was proposing to use the site for disposal of
hazardous waste when it appeared that the existing site has never met standards for
such disposal and is not an "acceptable facility. "
U.S. EPA ReS1'Onse: U.S. EPA is proposing to use the site for disposal of materials,
especially soils and debris, which must be classified as hazardous wastes due to its
association with the disposal of drummed wastes at the site. However, this material will be
capped as a hazardous waste. U.S. EPA believes that the site is an acceptable facility for
on-site disposal in accordance with all substantive disposal rules and regulations. U.S. EPA
also believes that this is the only reasonable way to handle the large volume of wastes at the
site, and that relocating all of this waste to be deposited in another location only adds to the
cost and short-term impacts.
6.
A commenter asked why U.S. EPA cannot leave the contaIninated materials
undisturbed at the site since the investigation seemed to show that there is no "off-site
hazard" from the site. The commenter went on to say that there must be a number of
sites around the country which are in greater need of cleanup than the Vandale
Junkyard site.
~ U.S. BFA acknowledges that the investigation has not shown that the
site is causing substantial off-site hazards at present, and that the peak off-site impacts
probably occurred shortly after industrial wastes began to be disposed at the site. However,
there is no doubt that in the absence of remedial action, the site will continue to act as a
source of contaminants to the surrounding area, particularly during periods of significant
precipitation and surface water runoff. In addition, there will continue to be very significant
on-site hazards for current and future workers, residents, and visitors. The Superfund law
requires U. S. EP A to act to protect human health and the environment under these .
circumstances. The selected remedy, however, is a reasonable compromise between leaving
the site unremediated, which is unacceptable, and a remedy which requires extensive
treatment of soils at the site. This is because the physical site characteristics do not allow all
wastes to be capped in place. Consolidation of wastes and soils on the active areas of the
site, followed by capping, is a protective remedy which is more cost-effective and can be
implemented more quickly. than the remedy preferred in the Proposed Plan.
7.
A commenter asked why U.S. EPA did not address the possibility that the site had
been used to dispose materials as long ago as 125 years.
U.S. EPA Response: U.S. EPA is not aware of any information beyond the commenter's
speculation that the site has been used for waste disposal for such a long time, and the
relevance of this possibility is unclear. U.S. EPA has acknowledged that the site may have
been in use for junkyard activities since as early as the 1940's, and that these activities have
certainly contributed to the contamination at the site, particularly for metals. The key reason
5
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that the site was investigated and is being proposed for remedial action, however, is the
relatively short period during which the site was used for the disposal of dIUmmed industrial
wastes.
8.
A commenter asked whether U.S. EPA had investigated the possibility that the
contaminants found in ground water at the site might have been the result of other
sources in the area, particularly the "BPI Landfill. " .
o
U.S. EPA Response: U.S. EPA does not believe that ground water beneath the site has been
affected by off.site sources. The remedial investigation results showed a very good
correlation between contaminants known to be disposed at the site and found in the soils at
the site and the ground water. In addition, most of the contaminated ground water was found
at elevations above the level of surrounding areas. This ground water is effectively isolated
from other influences.
9.
A commenter asked what health risks might result from site cleanup activities,
particularly for children in the vicinity of the site. The same commenter asked what
reassurance there is that the current problems at the site will not be repeated some
time in the future.
U.S. EPA Response: Health risks associated with implementation of the remedy will be
controlled through compliance with all regulations for emissions and through development of
a health and safety plan for all on-site activities during remediation. Air modelling will be
used as necessary to assure that all nearby residences are not affected. Short-term risks to
area children are expected to be negligible.
Repetition of the current problems at the site will be avoided through institutional measures
necessary to protect the effectiveness of the remedy particularly since contaminated materials
will be left on-site. These measures include deed restrictions and fencing to protect the
remedy and control exposure to the residual contamination. Future waste disposal at the site,
if any is allowed at all, must comply with all federal, state, and local laws.
10.
A commenter expressed concern about where the funds will come from to implement
the remedial action at the site.
U.S. EPA Re~nse: u.s. EPA anticipates providing all identified PRPs at the site an
opportunity to fund and conduct remedial design and! or remedial action. If negotiations with
the various PRPs are not successful, U.S. EPA has the option of conducting these activities
with Superfund monies and billing the PRPs later or issuing an order to the PRPs to conduct
the activities.-
c,
11.
A commenter expressed concern about U.S. EPA's understanding of the relationship
between contaminants in the different site media and whether U.S. EPA believes it
has discovered all contaminants which pose a threat at the site.
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U.S. EPA Re:sponse: As U.S. EPA attempted to explain in the RIlFS and Proposed Plan,
complete characterization of contamin~"t distribution in all media at the site is very difficult.
U.S. EPA believes that the nature and extent have been adequately characterized to reach a
decision on a course of action at the site, but readily concedes that further characterization
will be necessary before contamina"t sources can be removed for treatment or containment.
In addition, after the necessary sources are removed and treated or contained, continued
monitoring will be necessary to assure that all media on site, especially ground water,
surface waters, and sediments, achieve the cleanup goals.
12.
A commenter noted that vinyl chloride was the only known human carcinogen
identified at the site, claiming that all other carcinogens are "speculation."
U.S. EPA Response: U.S. EPA acknowledges that the only known human carcinogens at the
site are arsenic and vinyl chloride. All other carcinogens are termed probable or possible
human carcinogens. U.S. EPA disagrees that assessing the potential risks from these other
carcinogens is speculative. The protocols adopted to address these contaminants have
undergone extensive scrutiny and U.S. EPA believes that it is important to go with the
"weight of the evidence" under such circumstances.
13.
A commenter asked whether U.S. EPA had any plans to install a permanent
automated water quality monitoring station on Tributary A where it joins Duck Creek.
U. S. EPA Response: U.S. EPA does not plan to install any permanent or automated
monitoring stations at this time. However, water quality will be monitored on a quarterly
basis at the site and this will include at least one monitoring .location on Tributary A. U. S.
EP A believes that it is important to have the flexibility to alter sampling locations as
necessary .
14.
A commenter expressed concern about the amount of space avai1able on-site for
deposition of contaminated materials and capping. The commenter also noted that
slippage of soils has occurred on the north slope of the site and expressed concern
about the stability of any deposited materials on-site.
U.S. EPA Re$pOnse: U.S. EPA believes that sufficient area is available for deposition of
excavated materials on-site-and capping. U.S. EPA shares the commenter's concern about
slope stability and the limitations this will impose on both contaminant source removal and
containment. These activities will be carefully engineered to assure that additional
contaminants are not released due to slope instability. The locations chosen to consolidate.
and subsequently cap treated materials will be evaluated in detail during the remedial design
stage to ensure that they are appropriate locations for disposal. The disposal locations will
be properly prepared prior to placement of excavated materials and the cap will be designed
to ensure long-term effectiveness and stability. In addition, implementation of an Operation
and Maintenance Plan will require activities to mamtain the long-term effectiveness and
stability of the contained wastes and cap.
7
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15.
A commenter expressed concern about the necessity to monitor the cap at the site for
an extended period, and asked who would conduct this monitoring and how it would
be funded.
U.S. EPA Re$pOnse: U.S. EPA's selected remedy calls for monitoring .the cap for a
minimum of thirty years. Vegetation on the cap will be cut and maintained to prevent
deep-rooted vegetation from damaging the cap. Inspections of the cap will be performed and
the necessary repairs made (an estimated 40 days/year will be adequate to perform inspection
and repair activities as noted in the FS). U.S. EPA understands the concern about the need
to monitor and maintain the cap for an extended period, and the Superfund law provides for
funding of this activity if U. S. EP A is not successful in requiring PRPs to conduct the
monitoring. Any agreement with PRPs for implementing the remedy will require monitoring
and maintenance of the cap for the minimum thirty year interval.
"
16.
A commenter expressed concern about the effectiveness and cost of the
bioremediation ptanned for seep sediments on the north slope of the site.
U.S. EPA Re$pOnse: U.S. EPA appreciates the concern of the commenter. The
bioremediation planned for the sediments is intended to accelerate natural degradation of
organic contaminants. Bioremediation is expected to occur for a maximum of five years and
is a very small fraction of the total estimated costs for remediation. If a reasonable effort to
implement bioremediation is found to be unsuccessful, appears to be causing more harm than
good, or is excessively costly relative to its benefits, U.S. EPA may decide to curtail or
eliminate these efforts. In this case, U.S. EPA will continue to monitor the sediments to
assure that natural degradation and attenuation assures expeditious compliance with cleanup
levels.
17.
A commenter stated that the most cost-effective solution to the problem at the site
would be to move any people at risk off-site, put a fence around the site, and
monitor. The commenter went on to indicate that he felt that the worst was over at
the site and that the estimated cost of 15 million dollars for remedial action was
excessive relative to the risks posed by the site. Another commenter added that as a
nearby resident, she had already been exposed to the worst the site had to offer and
that she preferred to "leave it be. "
U.S. EPA R.e$ponse: U.S. EPA appreciates the concern of the commenter, and reiterates
that, as expressed in the response to Comment 6 above, the Superfund law does not allow
U.S. EPA to fence off sites and abandon them when there is a feasible remedy to the
situation. .However, U.S. EPA agrees that the alternative which was preferred in the
Proposed Plan is too costly relative to its benefits. As a result, U.S. EPA has selected a
remedy which is estimated to cost less than one-third as much and can be accomplished in
approximately half of the time. U.S. EPA believes that remedy implementation can be
accomplished without appreciably increasing the exposure of nearby residents to site
contaminants over the short-term, thereby greatly reducing potential exposure of these
c.~
8
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residents over the long-~nn.
18.
A commenter stated that since a public water supply is available for all residents in
the vicinity of the site, there is no need for anyone to consume ground water from
private residential wells. As a result, there is less of a need for remediation of the
site. Another resident added that Superfund could fund the connection of residences
which are currently not connected to the public water supply system and that this was
an acceptable alternative to remediating the site.
U.S. EPA Re!iPOnse: U.S. EPA appreciates the comments and wishes to state for the record
that whenever ground water supplies are affected by a Superfund site to the extent that
existing residential wells are rendered unsuitable for consumption, U.S. EPA will act to
connect the affected residences to a public water supply, if available. However, this is
typically done in conjunction with other actions intended to protect and eventually restore the
affected ground water supplies for future use. For the Vandale Iunkyard site, U.S. EPA .
believes that the existing residential wells in the vicinity of the site which are in use have not
been affected by the site. The identified remedial action is intended to protect the possible
future use of ground water at the site.
Comments from PRPs
GENERAL COMMENTS
1.
The PRPs commented that U.S. EPA intends to require other PRPs to fund the
remedy for the site and rebJm the site to the owner "free of charge" when the owner
is responsible for the "mess now found there. "
U.S. EPA Re$pOnse: U.S. EPA considers the site owner a PRP under CERCLA. The
owner will receive a notice letter for remedial design and remedial action, just as the owner
received a notice letter for the remedial investigation. The implication that the owner will be
able to avoid his responsibility for contributing to the contamination at the site is not true.
However, U.S. EPA's primary responsibility under CERCLA is to protect human health and
the environment. U.S. EPA cannot compel the owner to cooperate with the other PRPs in
funding the site cleanup, but CERCLA does allow cooperating PRPs to pursue funds or other
contributions toward site cleanup from non-contributing PRPs.
2.
The PRPs stated that the RIfFS fails to adequately characterize the site and that as a
result U.S. EPA's selected remedy is arbitrary and capricious, and inconsistent with
the NCP.
U.S. EPA Re!iPOnse: U.S. EPA believes that the RIfFS was developed and the remedy
selected in accordance with the NCP. Specific comments and criticisms are addressed
9
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below.
3.
The PRPs contend that the RI, Risk Assessment, and FS contain fundamental eITOrs
and show disregard for U.S. EPA Guidance and the NCP, thereby rendering the
RI/FS useless.
U.S. EPA ReS1X>nse: U.S. EPA believes that all work during the RIlFS was conducted in a
manner consistent with the NCP and the applicable guidance available at the time of the
RI/FS investigation.
4.
The PRPs stated that the RI fails to establish the need for any remedial action, and
that institutional controls already in place would adequately address any risks at the
site.
U.S. EPA Re$pOnse: U.S. EPA disagrees. The RI and Baseline Risk Assessment were
conducted in accordance with the NCP and applicable guidance, and the findings of the
investigation clearly necessitate remedial action at the site. Specific comments and criticisms
are addressed in detail below.
5.
The PRPs recommend that U.S. EPA should issue a "flexible ROD" which would
allow for the evaluation and selection of additional technologies for soil treatment
during remedial design, more precise determination of soil volumes, and a closer
evaluation of the feasibility of the selected remedy. This recommendation was
provided despite the claims that the RI/FS and Proposed Plan were completely
inconsistent with the NCP.
U.S. EPA Re$pOnse: U.S. EPA has selected a remedy which does not require on-site
treatment of soils. As a result, the flexibility requested by the PRPs is not necessary.
6.
The PRPs commented that the Administrative Record compiled by U.S. EPA is
incomplete because'it does not include documents submitted to U.S. EPA by the PRP
group during Phase I of the RI (and related correspondence). The PRPs submitted
copies of nine documents for inclusion in the Administrative Record, dated from April
1989 through August 1990, which the PRPs maintain helped "form a basis for
selection of a response action. "
U.S. EPA Re$ponse: Since these documents were submitted as comments during the public
comment period, U.S. EPA accepts the documents as a supplement to the Administrative
Record. However, U.S. EPA excluded these documents from the Admini~trative Record
compiled for the Proposed Plan after careful consideration. The nine documents essentially
comprise the various drafts of and correspondence con~rning a Phase I S\linmary Report,
which the PRPs were required to submit after the fIrst phase of the RI. Draft reports and
related correspondence are generally not included in an Administrative Record, since the
final reports are relied upon. to form the basis for selection of a response action. U.S. EPA's
10
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repeated rejection of this. report as technically flawed and inconsistent with the requirements
of the Administrative Order on Consent, resulted in the eventual termination of the PRPs'
authority to conduct the RIfFS.
U.S. EPA clearly acknowledged in the RI Report that all data from the PRP-conducted Phase
I investigation which was properly collected and satisfied quality assurance criteria was
utilized in the RI Report. The basis of the dispute between U.S. EPA and the PRPs over the
Phase I Summary Report primarily concerned the presentation and interpretation of the
results of the work and the additional work necessary to complete the RI. U.S. EPA did not
utilize the various drafts of the disputed report or related correspondence in developing a
basis for remedy selection, and therefore they were properly excluded from the
Administrative Record.
7.
The PRPs focussed criticism specifically on U. S. EP A's contractor, Metcalf & Eddy,
Inc. (M&E), for their perfonnance during Phase IT of the RI, and the preparation of
the RI Report, including the Baseline Risk Assessment (Risk Assessment), and the FS
Report. Throughout their comments and reports, the PRPs continually refer to
perceived errors made by M&E and the alleged failure of M&E to comply with U.S.
EPA guidance. In addition, the PRPs commented that M&E "rushed" to submit the
RI and/or FS, implying that the quality of the reports suffered as a result.
U.S. EPA Re$ponse: U.S. EPA takes full responsibility for the RI and FS. It should be
noted that before all RI and FS work was conducted, U.S. EPA approved a Work Plan
Package for this work. This package consisted of a Work Plan, a Quality Assurance Project
Plan (QAPP), a Field Sampling Plan, a Health and Safety Plan, and a Data Management
Plan. All work to be conducted during the Phase IT lU and FS was outlined in detail. In
addition, the preparation of the RI Report, the selection of exposure scenarios in the Risk
Assessment, and the screening and selection of remedial alternatives in the FS were all
conducted and written in conjunction with U. S. EP A. The RIfFS reports were carefully
reviewed by U.S. EPA prior to finalization. The implication that M&E had "free rein" in
preparing the RIfFS documents or was encouraged to rush the documents, and that U. S. EP A
willingly accepted the prepared documents "as is" without first undergoing scrutiny and
review for technical quality and adherence to the established guidelines and protocol, is
simply not true.
8.
The PRPs contend that during the public meeting on the Proposed Plan, community
members commented that the proposed remedial action was so far out of line with
economic reality and site conditions that the RIfFS documents must have contained
fundamental errors.
U.S. BFA Response: U.S. EPA believes that this assertion does not fully characterize the
community member comments. A review of the public meeting transcript reveals that the
only comment made by community members similar to this assertion was a question
regarding the proposed expenditures to clean up the site when there was no apparent threat to
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off-site populations and the funds might be better spent cleaning up a site which was more of
a threat. See Comment 6 above in the Comments from the Community section.
REMEDIAL INVESTIGATION COMMENTS
1.
The PRPs contend that the RI, and therefore the selection of the remedial alternative,
was flawed in that the lateral and vertical extent of soil CODtamination was not
adequately defmed, and in the case of the "areas" delineated in Figure 6-1 of the RI
Report, that the extent of contamination was visually delineated without an adequate
number of soil samples.
u.s. EPA Re~nse: U.S. EPA acknowledges that the number of soil samples collected is
not sufficient to precisely delineate all soil contamination. As the RI Report indicates, the
nature of waste disposal at the site resulted in "hot spots" of soil contamination as well as
widespread 'contamination at lower levels. The purpose of the RI was to characterize the
nature and extent of contamination to the extent necessary to support an informed risk
management decision regarding whether remedial action was necessary and, if so, which
remedy appears to be most appropriate for the site. As a result, the soil sampling program
focussed on known and suspected areas of past waste disposal.
The areas of con~ination delineated in Figure 6-1 show, as stated in the RI report on page
6-15, the maximum lateral extent of contaminated soils. It is further stated on page 6-15 that
all soils within these areas are not likely contaminated but "hot spots" within these areas
represent potential point sources of contaminants. It is troe that these areas were partially
delineated visually, but this was done to identify areas within which "hot spots" likely occur
(such as, where drum fragments were observed at the surface), not to delineate the extent of
contamination. As stated in the FS Report, the extent of soil contamination will be better
defmed through more extensive sampling in these areas during the initial stage of Remedial
Design/Remedial Action (RDIRA) activities before the implementation of the selected
remedial action, rather than during another phase of RI sampling. U.S. EPA believes that
this is more efficient since experience bas shown that additional soil contamin"nt
characterization is typically necessary during RD.
With respect to the vertical extent of soil contamination, soil samples were collected during
both phases of the RI mainly with a hand auger. A hand auger was used primarily because
of the lack of accessibility for a drill rig to collect split spoon soil samples in a majority of
the contaminated areas, specifically on the steep, wooded slopes at the site. It would have
been possible to modify portions of the slope with heavy constroction equipment to provide
access to additional sample locations on the slopes, but this would have required measures to
insure slope stability which would have been time and cost prohibitive for pUIpOses of the
RI. This could also have resulted in the disturbance and movement of waste materials and
caused additional releases of contaminants.
(:.
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The utility of a hand auger to collect samples from depth was limited at times due to the
difficulty of turning the auger by hand in tight, clayey material containing roots and waste
material. At many of the locations along the slopes, the depth to bedrock was very shallow
(for example, 30 inches at E-l and 28 inches at E-2), and the hand auger was sufficient.
Knowing the depth to bedrock at some locations gave an indication of how thick the soils on
the slope may be and the depth of potential vertical soil contamination. As stated on page 6-
15 of the RI Report, "the maximum vertical extent of soil contamination may extend down to
bedrock~ especially where"... the soils are "... underlying point sources of contaminants and
depths to bedrock are shallow". Again, the vertical extent of soil contamination will be
better defmed during the initial stages of RD/RA activities.
2.
The PRPs contend that the horizontal and vertical extent of contaminant sources (such
as buried drums) were not adequately defmed in the RI Report and could have been
done so by visual observation for surface waste and by borings and/or trenches for
buried wastes.
U.S. EPA ReS1'Onse: U.S. EPA disagrees. Based on historical infonnation such as site visit
photos and reports, visual observations, discussions with the owner/operator of the site, and
sampling results, the prirncuy areas of past waste disposal on-site appeared to be the north
slope, the "bum area", and the area behind the red bam. The "red bam area" and "bum
area" were investigated during Phase I of the RI by the PRPs using a magnetometer survey
and a soil gas survey.
Both measures were relatively unsuccessful in that possible areas of waste materials and
sources of contaminaf1ts could not be defmed adequately. Because of interference from
surface metal in these two areas (a large number of junked automobiles behind the red barn
and scrap salvageable metal throughout the "bum area"), the results of the magnetometer
survey were considered inconclusive by U.S. EPA. This does not mean, as contended by the
PRPs "that no evidence of buried drums was produced". It means that anomalies detected
during the magnetometer survey could not conclusively be attributable to buried metal such
as drums because of possible interference from nearby surface metal. .
U.S. EPA also considered the results of the soil gas survey to be inconclusive because the
clayey nature of soil at the site inhibited a sustainable "flow" or "migration" of soil vapors
surrounding the probe. Therefore, hot spots or source areas of contaminants would not
likely be identified unless one was fortunate enough to obtain a soil gas reading within a hot
spot at a depth of approximately three feet (the depth of the slotted soil probe tip). The
results of soil gas surveys conducted within clayey soils are often unreliable.
The delineation of subsurface wastes by borings or trenching in the source areas identified in
Figure 6-1 of the RI Report was not conducted for several reasons. First, drilling and/or
trenching activity along the sloped portions of the site would have required measures to
provide access to the slope and insure slope stability which would have been time and cost
prohibitive for purposes of the RI. Second, drilling and/or trenching in the "bum area" was
13
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not considered because the site owner/operator was allowed to continue his metal salvaging
activities in this area, and drilling and/or trenching would have interfered with his right to
conduct his business in the area. Third, drilling and/or trenching was not conducted in the
area behind the red bam because U.S. EPA was not aware that Mr. Vand.ale had removed
the junked automobiles from that area just before the initiation of Phase IT RI field activities
(it was flI'St noted on the flI'St day of field activities). The area by the Groves trailer was not
addressed because U.S. EPA did not believe that there was sufficient evidence of possible
buried drums to justify disturbing this private property. Another primary factor in not
drilling and/or trenching in the five areas to identify waste was that these activities would
, have resulted in the disturbance and movement of possible buried waste materials which may
have caused additional releases of contaminants, and possibly exposed the field personnel to
unnecessary health and safety hazards.
-v
3.
The PRPs identified several pieces of information missing from the RI Report that
renders the report "incomplete" or would add to its completeness, if included.
U.S. EPA Re$pOnse: U.S. EPA disagrees that the RI Report should be considered
incomplete. Specific items are addressed below.
Boring logs were not included for boreholes F-I through F-3 because, as stated in the RIlFS
Work Plan, the sole purpose of these borings was to collect samples of soil to determine
whether vinyl chloride was present from a depth interval (6 to 10 feet) at which vinyl
chloride was possibly identified with a Draeger tube during Phase I drilling of well S-4
(conducted by the PRPs). These three boreholes were initially drilled to six feet, at which
depth two, two-foot long split-spoon samples (6 to 8 feet and 8 to 10 feet) were collected for
analysis. Samples were collected from these depths because the "positive" reading of vinyl
chloride on the Draeger tube was detected at these depths from the well S-4 borehole during
Phase I of the RI. Because these boreholes were drilled within approximately 25 feet of well
S-4 (the well log is included in Appendix A of the RI Report) in similar soil, boring logs
were not completed.
The air compressor used during drilling activities was outfitted with a ftlter to prevent any
compressor lubricants from being introduced into the borehole.
The outcrop of "weathered" ~ used to determine the strike and dip of bedrock at the site
was located approximately 500 feet southwest of well S-3, approximately half way between
wells S-2 and S-7. The elevation of this outcrop is 775.07 feet mean sea level (msl). The
Washington Coal was not projected into the "weathered zone" in geologic cross section D-D'
and E-E' (Figures 5-2 and 5-3) because the coal was not encountered during the drilling of
well S-7. From review of historical aerial photographs, well S-7 is located along the toe of
landfilled material across the access road from the red bam. Therefore, the Washington
Coal outcrop within the "weathered zone" near well S-7 was removed during past landfill
activities. The outcrop of coal in the "weathered zone" that was used to help calculate the
strike and dip of the beds was half way between wells S-2 and S-7 in an area that, according
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to review of historical aerial photographs, the soil of the "weathered zone" was not removed
during past Ialtdfill activities.
Hydraulic conductivity of soils was determined on five samples during Phase I of the RI.
The hydraulic conductivity for all five samples was determined to be less than lxlo-' cm/see
with all samples being identified as clay except one, which was identified as silt.
The HNu results of shallow soil samples were not included in the report during Phase I or
Phase n of the RI. During Phase n, the selection of the soil interval to be sampled based on
HNu readings was conducted for the "E" and "H" samples. No "H" sample had elevated
HNu readings above background, and therefore, in accordance with the approved RI Work
Plan, the 18"-36" interval was submitted for analysis. The 18"-36" interval from E-l, E-2,
E-3, and E-4 had the highest HNu reading of the two respective intervals. These values
were recorded in the field logbook.
A diagram showing the distribution of TAL constituents in various media was not done (as it
was for TCL constituents) because listing the name and concentration of at least one round of
every TAL metal result next to each sampling location would have resulted in a cluttered and
unreadable diagram. However, the FS Report does include a series of figures which show
TAL constituents as cOmpared to background or regulated standards.
A structural contour map of bedrock units was not constructed because, as shown in the
cross sections constIUcted for the RI, there were prominent and identifiable beds that could
be correlated between wells, indicating the attitude of the beds on-site. The cross sections
thus show the general stIUcture of the beds on-site, as well or better than would a structural
contour map.
4.
The PRPs identified some apparent discrepancies in the RI Report.
U.S. EPA Response: U.S. EPA believes the noted discrepancies are based on erroneous
assumptions or misunderstanding of the infonnation presented in the report. They are
addressed below.
One comment indicated that the RI Report states that background soil samples X-I and G-I
were collected at a location "where waste disposal is now known to have occurred". "This is
an incorrect statement. The report states that the owner/operator claimed, after the
completion of Phase n RI field activities, that his house is built on land that he brought to a
level grade by piling junked cars into a gully and then grading soil over the top. Background
soil samples X-I and G-I were collected from a sloped, wooded area adjacent to the
owner/operator's house, not from within the level area that he supposedly brought to grade.
What is actually stated in the report is that the "trace concentrations of VOCs in G-l
indicates that soils used to build up the land mu have been somewhat impacted by wastes".
This statement was made in the report to possibly explain the presence of some trace
concentrations of VOCs in G-L Nowhere in the report does it state that "waste disposal is
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now known to have occurred" in the area from which X-I and G-l were collected. In fact,
the evergreen trees in the small wooded area from which samples X-I and G-l were
collected are fairly mature which may indicate that the immediate area may not have been
disturbed by the ownerl operator's alleged filling and grading activities. This would depend
how long ago these alleged filling activities would have taken place (before or after the
planting of the trees). .
Another comment indicated that detailed geologic logs of the site borings should have been
maintained by an experienced geologist, in reference to the statement in the RI Report that
"it is difficult to determine precisely the elevation of the top of the underlying claystone from
the information on the driller's logs". The geologic logs of all site borings were maintained
by an experienced geologist during both Phase I and Phase n. Most of the borings into
bedrock were logged by examining fme drill cuttings blown up and out of the hole during air
rotary drilling and noting color changes in the fme cuttings. It is difficult to determine
precise depths of beds by this or any other drilling method (except coring) because of the
"lag time" for cuttings from a certain depth to be blown up and out of a hole. The deeper
the borehole and the larger the cuttings, the longer the lag time.
The PRPs also erroneously assume that it is inferred in the report that "the prominent
siltstone bed that outcrops below the ridge top above the Marsh and seeps" is the siltstone of
the 720 Zone. It was n21 inferred in the report that this siltstone is of the 720 Zone.
5.
The PRPs question some of the methods used duqng Phase n of the RI.
U.S. EPA Response: The following are brief responses to the methods followed during
. Phase IT which were questioned.
It was stated by the PRPs that the method of placing soil in sealable plastic bags and placing
them next to a heater in the field trailer to collect headspace reading may have caused
excessive heating of the plastic which could have contributed to elevated headspace readings.
Because Phase n of the RI was conducted during the winter months, it was necessary to heat
the soil samples and the air in the plastic bags to a temperature of above 40 degrees F so that
an HNu reading could be taken. An HNu does not take accurate readings below a
. temperature of 40 degrees F. Therefore, the sealable plastic bags (Ziploc), of soil were
placed next to a small radiator-type heater in the trailer to sufficiently raise the soil and
headspace temperatures above 40 degrees F. The bags were placed close enough to the
heater to heat them but far enough from the heater so that excessive heating did not occur.
The method of placing all decontaminated Phase n sampling equipment into new plastic bags
for transportation from the decontamination station to the sampling station was questioned
because the plastic bags may have introduced contaminants (particularly phthalates) into the
samples. U.S. EPA felt that it was very important to protect decontaminated equipment from
possibly getting "contaminated" during transport to the sampling stations and that
transporting equipment in new plastic bags was the best method. It is true that some
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-J
phthalates ma.y have been introduced into the samples but the concentrations would have been
very lJIinimll and would not account for the very high phthalate concentrations detected in
some site media such as soils (3100 to 1,000,000 JLg/kg) and seep sediments (130,000
[estimated] to 260,000 JLg/kg). Also, phthalates are known to have been disposed at the site.
Therefore, the high phthalate concentrations are likely the result of past disposal on-site and
not from transporting equipment in new plastic bags.
The PRPs question whether an avenue of contaminant migration between shallower to deeper
zones may have been created from an "improper"" seal in borehole D-4 and from allowing
drill cuttings to fill the borehole below the well screens of wells D-5 and D-6. At borehole
D-4, 19 feet of to-inch ID steel casing was installed to the soiIlbedrock contact and
approximately 47.5 feet of 6-inch ID PVC casing was installed through the soil into the
bedrock to seal off the flI'St water encountered. After the 6-inch casing was grouted in, no
water was detected inside the casing. In the flI'St core run started inside the PVC casing, a
chunk of PVC was noted in the core. Apparently, as indicated by water dripping inside the
casing, the core barrel had punctured the PVC casing. It was believed that the integrity of
the annular seal along its length between the casing and borehole wall had not been breached.
Because a portion of the casing and the annular seal was breached from inside the casing, it
was believed that the problem was corrected by filling the inside of the casing with grout.
'At boreholes D-5 and D-6, because water was not detected during coring below the water
zones sealed off by the 6-incb PVC casing, it was felt that a "significant" pathway for
contaminant migration was not introduced by allowing cuttings to backi1ll the corehole.
Because well D-6 was at an off-site residence and was to serve as a background well, it was
assumed that contaminants would not be present. The coreholes of D-5 and D-6 were not
sealed with bentonite below the screen depth because of the possibility of grout contamination
in the wells as apparently occurred at well D-4A, when the borehole below the well screen
was sealed with a bentonite grout. Apparently, grouting of the bottom of the well D-4A
borehole with a tremie pipe resulted in splashing of the grout on the wall of the borehole or
grout got on the borehole wall of the screened interval when the tremie pipe was pulled out
of the borehole. The PRP's oversight contractor during Phase n also agreed that these
methods were acceptable. Contrary to the assertion of the PRPs, U.S. EPA does not believe
that a "significant" pathway for contaminant migration was created in boreholes D-5 and D-
6.
The PRPs state that the monitoring wells may not have been developed! properly because
residual materials in the upper or unsaturated portion of the well screen were not flushed or
. removed during development. It is further stated that to properly develop the wells, "high
purity water" should be added to the wells to "flush" the residual material from the upper,
unsaturated portion of the well screen. First, residual materials containing contaminants
were likely nQ! canied down from shallower depths during drilling because the air pressure
used during drilling was great enough to blow all cuttings up and out of the borehole. Also,
the drillers always "cleaned out" the borehole of any remaining drill cuttings after reaching
the desired depth. Second, the static water levels in the monitoring wells installed during
Phase IT were not "significantly" below the top of the intake interval. Of the six water-
17
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producing monitoring w~lls (S-7 through S-I1, and D-3) installed and sampled during Phase
II, the static water level before development in Well S-11 only was below the top of the well
screen (approximately 4 feet). Of the wells installed and developed during Phase I conducted
by the PRPs, all wells except well S- 5 had a water level below the top of the well screen
before development. .
L.
u
Third, U.S. EPA does not believe that possible residual materials in the unsaturated portion
of the well screen could "contaminate" ground water samples if ground water is not in
contact with these residual materials. Also, all wells were adequately purged before
sampling anyway. U.S. EPA is not aware of any protocol or guidelines that mandate the
removal of residual materials in the unsaturated portion of a well screen before sampling. In
fact, most monitoring wells are installed so that approximately 6 to 8 feet of screen is in
ground water with 2 to 4 feet out of the water to allow for better detection of VOCs
dissolved in ground water and LNAPLs floating on ground water, and to allow for seasonal
fluctuations in the water levels. Fourth, it may be difficult to get a "turbid-free" water
sample from a monitoring well because the wells are partially screened through claystone
units of varying thicknesses, and clay- and colloidal-size particles could easily enter into, and
accumulate in the well while suspended in the water that recharges in a well after
development andlor purging. These accumulated fme particles could get "stirred up" during
subsequent purging and/or sampling activities, resulting in varying degrees of turbidity and
thus never assuring a completely turbid-free water sample. This scenario was potentially
observed during the Phase II RI investigation as four monitoring well samples were slightly
"cloudy" or "milky", seven samples were "turbid", and two samples were "very turbid".
Fifth, it is out of line with any accepted U.S. EPA protocol or guidelines to propose
"flushing" the residual materials out from the unsaturated portion of a well screen by
introducing high purity water to a well, especially low yielding wells as some of the wells
are at the site. Introducing high purity water to a well would dilute the concentrations of any
CODuminant present, and there is no assurance that all of this water would be removed
during development. In very few cases, if any, is it an acceptable practice to the U.S. EPA
to allow any "foreign" material such as distilled or deionized water to be introduced into a
monitoring well, especially ones of lower yield. Finally, it is an accepted practice to develop
monitoring wells with a bailer. The development method used during Phase II was approved
by U.S. EPA in the RI Work Plan Documents Package and was the same method used by the
PRPs to develop the wells during Phase I of the RI.
6.
The PRPs contend that the RI Report does not provide an adequate characterization of
the hydrogeologic conditions at the site, and that several "essential" components
necessary to properly characterize the site hydrogeology are not provided in the
report.
U.S. EPA Response: U.S. EPA disagrees. The combined information on the site
hydrogeology collected during Phase I (conducted by the PRPs) and Phase II is sufficient and
adequate for the pUIpOses of the RI. Specific aquifer characteristics such as horizontal and
vertical hydraulic conductivity of the bedrock, porosity of specific bedrock units, ground
18
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water flow rate, and quantity of ground water, were not determined because to do so would
have been time and cost prohibitive for purposes of the RI and would have resulted in
tenuous infonnation for the time and cost invested to gather it. Porosity was not considered
an important parameter because, as stated in the RI Report, the hydrogeology of the site is
controlled by secondary permeability, or the number, size, and orientation of joints and
fractures in the bedrock. Because all of the bedrock units are predominantly claystones and
siltstones, porosity was not considered an important parameter.
Hydraulic conductivity values (K) were not determined because a sustainable supply of water
was not available in a well to do a pump test. Also, the thickness of the water column in
almost all of the on-site wells was not sufficient to totally immerse an adequately-sized slug
to perform a "slug in" or "slug out" test. A packer test was not done because it would have
resulted in the introduction of water "foreign" to the bedrock unit (see previous response #5
on introducing water from an outside source into a well). The collection of rock cores for
laboratory testing of K values would have resulted in artificially induced fractures in the core
from the coring process and possibly from the release of stress when !bringing the core
sample from depth to the ground surface. Also, laboratory testing of K values on rock cores
results in very inaccurate, biased K values. Because it was noted during Phase I of the RI
that several wells recharged very slowly, it was felt that this was an indication that the K
values were small.
Because of the complex and heterogeneous nature of the site geology and hydrogeology, the
quantity and flow rate of ground water could not be determined. Again, these two
parameters are controlled by the secondary permeability which could vary widely across the
site. To determine flow rates, it would be necessary to have at least two wells screened in
the same bedrock unit and the fractures encountered within the screened interval of the two
wells would have to be interconnected. There would be no assurances that the two wells
would be interconnected through fractures.
Examples of the complex and heterogeneous nature of the site geology and hydrogeology
noted in the RI Report include the presence of ground water in the borehole of D-2 at a
depth of approximately 56 feet whereas water was not initially present at the same depth in
well 5-2 located approximately a few feet away. Another example is that water encountered
within two to three productive zones during drilling of wells 5-10 and D- 5 indicates tliat the
Groves residential well, which is approximately 10 feet from either well 5-10 or D-5,
receives enough water from each of these zones to collectively produce a sustainable supply
of water for priVate residential use. This scenario appears to also hold! tnle with wells 5-
lllD-6 and the fonner RosslElder well. Contrary to the comment made by the PRPs, these
two statements QQ...nQt conflict. Each statement was made based on actual observations made
by field staff during the field program. The same holds tnle for the statement made in the
RI Report that the higher water level in well 5-5 is present because water from a shallower
siltstone mu be entering the well. The PRPs question why this is not tnle also at well 5-3
which, like well 5-5, is screened within the 720 Zone and a shallower siltstone. It cannot be
determined whether this is tnle at well 5-3 because it does not have a higher water level like
19
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well S-5. It was an attempt to possibly explain the higher water level actually noted in well
S-5. The same scenario was not applied to well S-3 because it was not actually noted to
have a higher water level.
With respect to their comment on this scenario, it is rather confusing for the PRPs to state,
"( c )onc1usions based on conditions observed in one area should be applied to all areas of the
site", which completely contradicts what they stated for a previous comment which said,
"(p )rojecting stratigraphic conditions from one location to another should not be done due to
the complex nature of the site geology". It is not clear how the PRPs believe that data on
site geology and hydrogeology should be used. U.S. EPA believes that because of the
complex and heterogeneous nature of the site geology and hydrogeology, certain conditions
observed at one location should not be projected across the site. This is another reason
hydraulic conductivity values, ground water flow rates and quantity, potentiometric surfaces,
etc. were not determined for bedrock units at the site. The values determined at one location
may vary widely with values determined at other locations because of differences
lithologically and in the effect of secondary permeability.
"
The PRPs state that the RI Report fails to mention that saturated rocks of very low porosity
and permeability are often not readily detected as water-bearing using air rotary drilling
methods. U.S. EPA believes that coring and drilling with air was the best method used for
drilling. Any other type of bedrock drilling (mud rotary, cable tool) would have required the .
use of water or other materials to drill which would have made the detection of water in the
rocks even less apparent than it was using air rotary. Even if a well was installed into rocks
of very low porosity and permeability, it would not likely yield any water initially and may
take several months to do so. Regardless, the amount of water that this hypothetical well
would yield is minimal and insignificant when compared to the yield of wells within water-
producing fractures (which are the primary routes for water yield and potential contaminant
migration at the site).
The PRPs correctly state that during Phase n well drilling, wells were initially installed into
the fIrst zone of producing water, regardless of the elevation. However, they assumed that
this criteria was used to ensure a sufficient quantity of ground water for sampling, and that
this strategy was marginally successful as indicated in discussions of water available for
sampling. Furthermore, they state because of this strategy, potentiometric surfaces could not
be determined. .
First, contrary to the implication of the PRPs, water availability in Phase n wells during
sampling was more than "marginally successful". In the Phase n wells (wells S-7 through S-
11) installed into the fIrst water-producing zone in bedrock, enough water was available to
develop/purge at least three well volumes and sample each well for all TCL and TAL
parameters, except for well S-7. Most wells that did not produce enough water for sampling
of all TCL and TAL parameters were installed into the "720 Zone" by the PRPs during
Phase I. The varying amounts of water determined during Phase n in the wells screened
within the 720 Zone further illustrates the heterogeneity of the hydrogeologic system at the
20
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site. Some wells produced little water (wells S-l, S-2, and S-4) whereas others in the same
unit produced' enough water to purge three well volumes and sample for all TCL and TAL
parameters (wells S-3, S-5, and S-6).
"',
Second, this well installation criteria was used to monitor whether the first producing water
encountered during drilling into bedrock (especially wells S-7 and S-lO) was impacted by
site-related contaminants migrating down from the ground surface, not to ensure sufficient
ground water quantity for sampling. This criteria was also followed to illustrate the
anticipated heterogeneity of the presence, quantity, and elevations of ground water in the
bedrock. Also, because of the heterogeneity of the site hydrogeology, installing wells to
similar elevations so that potentiometric maps could be developed was of secondary
importance to identifying whether a release had occurred to the first producing water. It was
believed that other than discharging towards the slopes of the hill, lateral movement of
ground water would predominantly follow the dip of the bedrock until encountering vertical
joints and fractures, which is generally true as sh6~n for the 720 Zone in'Figure 5-10 of the
RI Report. . ,
Contrary to the PRPs' statement, U.S. EPA does not believe that horizontal ground water
flow directions may "vary significantly" from that determined for the 720 Zone. Moreover,
potentiometric maps of any specific zone' may be of local extent; the contours could change
radically over short distances in the vicinity of vertical conduits and such maps would add
little to the conceptual understanding of the flow system. U.S. EPA also does not agree with
the PRPs assertion that "there is a piezometric surface that could represent horizontal flow"
within the deeper portion of the bedrock. To make this statement, one would have to assume
that water is present in fractures throughout a deeper unit and that these fractures are
interconnected. As previously stated, very little water was found in boreholes drilled to
deeper depths. It appears rather unlikely that water in one deep well, if present, would be
interconnected with water in a separate well in the same unit any distance from the first well '
because of the heterogeneity of the hydrogeological system, especially with, respect to the
presence of water at depth. To investigate each and every water-producing unit and to install
wells to similar depths of a producing unit throughout the site to produce potentiometric
maps of these units would require the installation of tens of monitoring wells, some of which
would have to be double- and triple-cased to monitor water below shallower producing units.
The time and cost of this would be very p~hibitive for the purposes of the RI and the
selection of a remedial alte~tive.
The PRPs contend that drilling with compressed air may be responsible for the absence of
water in the 720 Zone in off-site boreholes D-4A, D-5, and D-6 and further states that
because "hydraulic communication" apparently exists between the 720 Zone and the Groves
well, then the 720 Zone siltstone was misinterpreted as being dry because ground water was
blown out or evaporated during coring. During coring of borehole D-5 at a depth of
approximately 116 feet (712 ft msl), some slight "bubbling" of the water in the adjacent
Groves well could be heard, which had a depth of approximately 98 feet (730 ft msl).
Because this bubbling was heard in the Groves well while coring D-5, the PRPs correctly
21
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state that there is hydraulic communication between the Groves well and D-5, but they also
assume that this communication is via ground water. It is also very possible that the
bubbling in the Groves well, the bottom of which is approximately 18 feet higher than the
elevation in D-5 at which the bubbling was noted, was caused by air enlarging dry fractures
between D-5 and the Groves well, eventually resulting in the "release" of air into the Groves
well. It was not necessarily water in the 720 Zone of D-5 being blow up into the Groves
well. The fractures may have allowed forced air to pass through them while still small
enough that capillary forces within the fracture network in the 18 vertical feet of bedrock
between D-5 and the Groves well may have been great enough to exhibit the migration of
water. Also, the air may have enlarged the fractures enough to form a new "avenue" of
water migration. It is true that it is possible that if borehole D-5 was left open long enough
at a depth of 116 feet, water from the Groves well would eventually migrate into it along the
new "avenue". It is also possible that any water originally present in the 720 Zone at D-5
and D-6 were drained by the vertical fracture. The PRPs are incorrect in stating that the
Groves well is exerting 80 or more feet of hydraulic head in the 720 Zone because the
bottom of the Groves well (approximately 730 ft msl) does not intersect the 720 Zone.
Two other minor issues raised by the PRPs on ground water are briefly addressed. First, the
horizontal component of ground water flow in the 720 zone is indeed radial. Second,
vertical head differentials can generally be noted during drilling if hydraulic heads (water
levels) drop abruptly from each specific water-bearing zone to the next lower zone,
especially if the vertical distance between water-bearing zones are not that close. However,
it is true that accurate detennination can only be made by comparing static water levels in
monitoring well clusters.
BASELINE RISK ASSESSMENT COMl\1ENTS
1.
The PRPs commented that the use of a future residential use scenario for the site was
highly improbable and not appropriate. The PRPs went on to point out that many
residences in the vicinity of the site are mobile homes and/or currently unoccupied.
U.S. EPA Response: U.S. EPA disagrees. The decision to use the future residential use
scenario is well documented in the risk assessment and addressed extensively in this section
of the responsiveness summary. The permanence of residences in the area of the site is not a
consideration for U.S. EPA, as the past and current use of the area and the site provide
sufficient evidence of the probability of a future residential use scenario.
2.
The PRPs questioned the inclusion of vinyl chloride in the Baseline Risk Assessment.
The PRPs stated that the risk assessment was based on incorrect vinyl chloride test
"data" which seriously misrepresented actual field test results (for example, the RI
listed a maximum reported concentration of 90 J.'g/l in Table 2.2 of Appendix H,
whereas vinyl chloride was, in fact detected at only 47 p.g/l in only one well sample).
22
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c~
u.s. EPA Response: !'be vinyl chloride data was used because it was suspected that vinyl
chloride may have been a chemical which was disposed at the site historically. Furthennore,
vinyl chloride is a known degradation product for the numerous chlorinated organic
compounds which have historically been disposed and detected at the site. U.S. EPA
guidance for the perfonnance of Risk Assessments, the Human Health Evaluation Manual
(U.S. EPA, 1989), recommends that chemicals historically associated with site activities
should not be eliminated. from evaluation as a chemical of concern. Although it cannot be
stated with absolute certainty that biodegradation of chlorinated organic compounds is
occurring at the site, the conservative approach is to assume that biodegradation to vinyl
chloride may be occurring or may occur.
The only detection of vinyl chloride occurred in the sampling and anaJlysis of ground water
perfonned during Phase I of the RI. Vinyl chloride was not detected in any samples
analyzed during Phase n. Vinyl chloride did fit the primary requirement for inclusion in the
group of potential chemicals of concern in that the compound was detected at least once, in
at least one of the environmental media investigated. Despite the relative infrequency of
detection of vinyl chloride across the different environmental media, the decision was made
to retain vinyl chloride as a chemical of concern based on the toxic potential of the
compound. The maximum reported concentration of 90 p.g/l in Table 2.2 of Appendix H is
indeed incorrect. The maximum reported concentration should be 47 p.gll. However, the
incorrect maximum reported concentration was not carried through the risk calculations.
Rather, the 95 percent upper confidence limit value was carried through the risk assessment
(i.e., 52 p.g/l vinyl chloride).
If a detection limit of 0.4 ug/l or less had been utilized in the risk assessment and the single
detection of vinyl chloride was not considered in the data set, the overall total risks for
ground water exposures at the site would be as follows for vinyl chloride:
FUTURE RECEPTORS/RISKS FOR VINYL CHLORIDE
CHILD 3xlo-"
TEEN 2xlo-"
ADULT 1 x 10-"
However, the total future risks associated with all of the chemicals of concern would remain
on the order of at least IxH)"2 for each of the receptors regardless of this change, with the
primary contributor to risk being 1, l-dichloroethene.
3.
The PRPs commented that monitoring well instaIIation, development, and pre-
sampling purging were improperly perfonned during Phase n, thereby generating
suspect and unscientific test data. u.S. EPA guidelines preclude the use of such
suspect data in developing risk assessments.
u.S. EPA ReSJ)Onse: U.S. EPA followed proper data collection procedures as outlined in
23
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the approved RI Work Plan Documents Package. Methods for data utilization outlined in the
U.S. EPA Risk Assessment Guidance for Superfund and Guidance for Data Usability in Risk
Assessment (U.S. EPA, 1989; 1990) were employed in the Baseline Risk Assessment.
4.
The PRPs commented that U.S. EPA incorrectly used only unflltered samples in
detennining metals contamination. The commenters felt that approved procedures
require the use of filtered as well as unflltered samples for metals testing and, in cases
such as this where there are wide discrepancies noted in such results, the filtered
results must be used in detennining environmental risks [see, e.g., Kent County v.
U.S. EPA (May 1, 1992, U.S. Dt. App. S.D., 1992 U.S. App. LEXIS 8606) and
Anne Arundel County v. U.S. EPA (May 1, 1992, U.S. Ct., App. S.C., 1992 U.S.
App. LEXIS 8607)].
U.S. EPA Response: U.S. EPA guidelines for risk assessment require that unfiltered ground
water samples be utilized to estimate exposure if the unflltered water is of potable quality
(U.S. EPA Risk Assessment Guidelines for Superfund, 1989, pages 4-12, 4-13, 6-26, 6-27,
and 6-34). It is conceivable that residents would utilize unflltered ground water in the site
vicinity. The Vandale Iunkyard site is in a rural area where residents in the vicinity do
utilize ground water as a potable supply. In fact, several nearby residences were identified
during the RI at which ground water is used as the sole source of water and which is not
treated before use. It is pumped directly into an eqtlali7~tion tank: for distribution throughout
the house.
There are no regulations which forbid a resident from drinking water from a well in
Washington County. To install a potable drinking water well, the land owner must get a
permit from the county Health Department and the installation must be performed by a
licensed drilling fIrm. If the private landowner installs a well and upon sampling and
analysis of the well, the Health Department finds the water unfIt for consumption, there is no
enforcement action m place to prohibit the landowner from using the well for drinking water
purposes. Also, a well permit is.not needed if the intended purpose of the well is to provide
water to non-dairy farm ailimals. In this case, the Health Department would not even have
to be notified.
While arguments can be made on both sides of the issue for using filtered versus unflltered
water samples to evaluate ground water at hazardous waste sites, U.S. EPA must consider
site-specific information to determine which data will provide the best characterization of
potential exposure. Filtered ground water samples are a reasonable alternative for sites
where it is not likely that ground water users will utilize water which has not undergone
some type of filtration or purification. Unfiltered ground water provides a better
characterization of potential exposure at sites where ground water is not f1ltered or purifIed.
There are residents in the vicinity of the site who do not filter, purify, or treat their ground
water supplies before potable utilization of the groundwater. Because of the long time
potentially needed (over the course of possibly several weeks to months) to attempt to
"
24
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develop a low-yielding ~onitoring well installed in claystone/siltstone units to provide a
relatively turbid-free ground water sample, U.S. EPA decided to develop the wells as best as
possible during the course of RI field work. rather than returning daily, weekly, or monthly
to remove recovered ground water during the development of the wells. Also, because the
monitoring wells are partially screened through claystone units of various thicknesses, clay-
and colloidal-size particles could easily enter into, and accumulate in the wells while
suspended in the water that recharges in the well after purging. These accumulated fme
particles could get "stirred up" during subsequent purging and/or sampling, thus never
assuring a completely turbid-free water sample. This was potentially observed during the RI
investigation as. indicated by the varying degrees of turbidity of the well samples. For
example, of the 13 monitoring wells sampled during Phase IT of the RI, four samples were
slightly "cloudy" or "milky", seven samples were "turbid", and two samples were "very
turbid" .
U.S. EPA recognizes that it is unlikely that water used by local well users is as turbid as
some or most of the ground water samples collected at the site during the RI, and that the
use of the unf'Iltered metals data from these samples could overestimare the risk calculated
for ground water consumption in the Baseline Risk Assessment. Conversely, it is just as
unlikely that any ground water used by local well users are or will be filtered through a 0.45
micron membrane as are samples for filtered metals. The use of the filtered metals data in
the risk calculations would. result in an underestimate of risk. Because the standard
acceptable protocol for ground water sampling for metals concentrations is to submit an
unfiltered sample and/or a filtered samples (through a 0.45 micron membrane), U.S. EPA
decided to take the conservative approach and use the unfiltered metals data in the Baseline
Risk Assessment for the Vandale Junkyard. While the use of unfiltered ground water data
for metals concentrations in the risk assessment can provide an overestimate of potential
exposure, hazard, and risk, the approach is justified because some local residents are using
(and could possibly use in the future) unflltered ground water for their domestic water
supply, and the use of fIltered data would provide an underestimate of calculated risks and
hazards.
5.
The PRPs commented that the Baseline Risk Assessment did not adhere to U. S.
EP A's recommendations for exposure assessment and utilized exaggerated exposure
assumptions in developing the risk analysis.
U.S. EPA Re$pOnse: U.S. EPA disagrees. The exposure scenarios evaluated in the Baseline.
Risk Assessment were selected based on several years of on-site observations and
conversations with area and site residents. In particular, the scenario of the trespassing child
was based on the knowledge that children (the site owner's grandchildren) were observed and
were known to enter onto the site on a regular basis. U.S. EPA felt it particularly important
to evaluate the exposure to this population of receptors because they potentially represent one
of the most sensitive populations for site-~lated exposures. The site is not secured to
prohibit trespassing. The exposure pathways evaluated and the exposure parameters utilized
for the child receptor characterized a child playing on-site. BeCause of the nature of the
25
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. .
activities in which a child/adolescent of this age might engage in such an area, it was
assumed that the receptor would likely play without regard to becoming wet through wading
or splashing in the seeps or surface water, or dirty from contact with the soils or sediments.
While the site cannot be considered akin to a playground, in the rural area in which this site
is located, children do engage in such outdoor activity. In fact, because of the rural nature
of the area, children and adolescents would be more likely to play in such a setting,
compared to a suburb, due to the distance to the nearest playground.
U.S. EPA supplemental guidelines for standard default exposure factors (U.S. U.S. EPA,
1991, OSWER Directive 9285.6-03, March 25, 1991) for commerciall industrial exposures
provides soil ingestion rates "that should be used to estimate exposures for certain workplace
activities where much greater soil contact is anticipated, but with limited exposure frequency
and! or duration." The soil ingestion rate for site workers was based on the recommendations
of these guidelines (page 10 and Attachment B) to characterize exposures for outdoor
activities such as landscaping. The activities evaluated for the site workers were based on
site-specific observations and information.
With respect to ground water consumption by the adult site worker, U. S. EP A evaluated the
consumption of ground water by the adult worker because ground water has historically been
utilized by residents in the area. It was assumed that the site worker would be exposed to
the area ground water while at work and at home. U.S. EPA evaluated this scenario as a
CUITent scenario to determine whether some immediate action should be taken to limit ground
water consumption at the site. U.S. EPA recognizes that while no individual MCL was
exceeded in samples from the residential wells, the simple comparison of chemica1levels to
chemical-specific MCLs will not account for any additivity of effect from exposure to more
than one chemical.
With regard to future exposures to site soils which exist on slopes or beneath the surface,
U.S. EPA sought to evaluate the potential future exposures for receptors where soils had
been excavated or moved for construction or landscaping purposes to a location where
receptors could come in contact with the cont:lmin:lted soils. The potential for a future
residential scenario was based to some degree upon the stated desire of the current site owner
to build a house on the property in the future. The site has historically been utilized for
residential and agricultural pUIpOses. In addition to houses in close proximity to the site, the
site owner's son lives in a"mobile home on-site.
The idea that people have historically and are currently living on the site seems
incomprehensible to the PRPs. However, the lack of understanding may in part be because
the reviewers have not had the opportunity to observe the site activities as U.S. EPA has
over the past three years. U.S. EPA believes that the potential exposures for receptors at
this site must be evaluated from a conservative perspective because people either historically
have or cUITently do reside on-site or in very close proximity to the site, work on-site, drink
ground water, hunt on-site, and trespass on-site.
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6.
The PRPs comm~nted that upper-bound limits of cancer risk due to inhalation of
arsenic (entrained dusts) were incorrectly quantified because U.S. EPA's IRIS system
advises risk assessors to assume that no more than 30 % of inbaled arsenic will be
systemically absorbed. They contended that such disregard of IRIS's explicit
instructions in this instance resulted in at least a three-fold overestimation of the 95 %
upper-limit of lifetime cancer risk associated with inhalation of arsenic present in
respirable dusts.
U.S. EPA Response: U.S. EPA disagrees. The inhalation cancer slope factor (CSF) for
arsenic utilized in the baseline risk assessment is based on an admini~red dose for
inhalation. The toxicity factor utilized does take into account that 30 percent of the inhaled
arsenic is systemically absorbed. However, an administered dose must be utilized for
comparison to the intake estimate calculated using the U. S. EP A standard equation for
inhalation exposure (U.S. U.S. EPA Risk Assessment Guidance for Superfund, 1989, page
6-44). If the intake was derived such that the estimated intake was an abSorbed dose, then
the absorbed dose CSF would have been employed in the calculation of the risk.
7.
The PRPs commented that risk analysis was based on invalid, worse-than-worst-case
assumptions, rather than utilizing scientific data. In particular, the comments noted
that P AHs do not bioaccumulate to any significant degree in animal tissue and should
not have been evaluated.
U.S. EPA Response: U.S. EPA acknowledges that the modeling of soil to anim~1 meat
CQncentrations in the Risk Assessment does not provide a valid representation of potential
uptake and bioaccumulation of the chemicals of concern by cattle or deer. However, the
model was retained in the Baseline Risk Assessment to demonstrate that an attempt to
evaluate such exposure had been made, but that the model results in highly unlikely
exposure, risk, and hazard estimates. U.S. EPA acknowledges, both here and in the text of
the Baseline Risk Assessment that the model overestimates exposure, hazard, and risk. The
calculation of the ingestion and bioaccumulation of site-related contaminants by cattle and/or
deer and subsequent ingestion of the animal meat by humans was qualified in the text of the
Baseline Risk Assessment:
"It should be noted that inherent uncertainties as to the actual bioaccumulation of the
chemicals of concem in animal tissue may have resulted in an overestimate of
exposure and the associated risks and hazards. For example, PAHs (and related
compounds) and low molecular weight chlorinated solvents, which contribute to the
majority of the estimated or calculated risks, are rapidly metabolized by organisms
and do not bioaccumulate to any great degree." (RI - Section 8.6.4, page 8-37)
Furthermore, the results of this evaluation of meat consumption were not inCluded in the
calculation of the total site risk or hazard. Rather, they were considered separately and
qualified as an overestimate of true exposure, hazard, and risk.
27
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8.
The PRPs indicat~ that the report ignored data validation qualifiers and failed to note
that certain data utilized were suspect.
u.s. EPA R~nse: Data validation qualifiers were not ignored in the report. Methods for
data utilization outlined in the U.S. EPA Risk Assessment Guidance for Superfund and
Guidance for Data Usability in Risk Assessment (U.S. EPA, 1989; 1990) were employed in
the Baseline. Risk Assessment. According to these guidelines, I-qualified sample results (i.e.,
estimated concentrations for compounds) are to be evaluated in the risk assessment in tbe
same way as detections that are not I-qualified. What may be lacking in the Remedial
Investigation and Risk Assessment is a more detailed accounting of the relative uncertainties
. associated with using sucb qualified data and the potential effects of the estimation of
exposure, hazard, and risk. When a I-qualifier is attacbed to a chemical result it represents
some uncertainty as to the true concentration for the cbemical. A I-qualifier may be placed
on the results for a particular analyte for a number of reasons (exceedances of sample
bolding time, calibration errors, low surrogate recoveries, variations in instrument
quantitation and detection limits). The implications of applying a I-qualifier to a sample
result may be as follows:
The reported concentration may underestimate the true value for the sample;
The reported concentration may overestimate the true value for the sample; or
The reported result may be of poor precision and highly variable.
Therefore, depending on whether the actual chemical concentration is higher or lower, the
exposure, risk, and hazard could be correspondingly over- or underestimated. While the I-
qualifier is meant to be interpreted as an indicator of uncertainty in the reported
concentration of a chemical, it does not represent uncertainty as to the presence of the
cbemical in a sample. Rather, as stated in U.S. EPA Guidelines for Superfund, Human
Health Evaluation Manual (U.S. EPA, 1989), I-qualified data are to be used as positive data
indicating that the identified chemical has been detected in the sampled media.
9.
The PRPs commented that U.S. EP A guidelines stress the crucial importance of
employing analytical techniques which will afford detection sensitivities necessary for
proper risk analysis. They took issue with the use of analytical methods yielding
detection limits of between 10 and 100 ",g/l for vinyl chloride despite stated efforts to
specifically determine the presence of this compound in various media.
U.S. EPA ~nse: As stated in the response to Comment 1, vinyl chloride was suspected
as a potential chemical of concern for the site based on historical information concerning the
types of chlorinated organic compounds dumped or released at the site over time. A major
problem at any hazardous waste site is the accurate characterization of chemical
concentrations in environmental media. The sampling and broad-scan laboratory analysis of
samples of environmental media mayor may not capture the range of chemicals which exist
28
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at a site. However, it is .the best overall methodology for at least identifying the presence or
absence of different chemicals at a site. The available data as collected and analyzed for the
site is all that can be employed to perform this exposure and risk characterization.
Vinyl chloride was detected in one ground water sample and is a chemical associated with a
relatively high toxic potential. While the detection limits varied for vinyl chloride, the actual
chemical concentration carried through the risk assessment was 52 j.£g/l. The maximum
detected vinyl chloride concentration was 47 j.£g/l. The difference between these two
concentrations is minimal. The assumption of one half the sample quantitation limit
obviously did not result in an exposure concentration which overestimated the maximum
detected concentration by an order of magnitude. Further, it is feasible that the maximum
vinyl chloride concentration for the site may not have been encompassed by the concentration
of 47 j.£g/l.
The selected remedy does include a more sensitive detection limit for vinyl chloride in
ground water.
10.
The PRPs commented that comparisons of naturally-occurring analytes detected in on-
site samples with corresponding samples collected from locations upgradient or
beyond significant site influence were not properly evaluated in accordance with U.S.
EPA guidance.
U.S. EPA Re~nse: The naturally occurring analytes detected on-site were compared to
appropriate background results. A statistical comparison was not performed. Rather the 95
percent UCL or maximum concentration, whichever was lower, was compared to background
levels. The data for the site was grouped. Therefore, the grouped data was compared to
background levels rather than individual sample location compared to background levels.
11.
The PRPs commented that the selection of n chemicals of concern" was based largely
on whether toxicity values (e.g., risk reference doses) for chemicals identified were
available in U.S. EPA's IRIS or BEAST. They stated that U.S. EPA's RAGs states
that this is not a valid justification for eliminating chemicals from the quantitative risk
assessment process. They felt that a high level of uncertainty in the estimates of risk
is the inevitable an~ direct result of omitting contaminants from the assessment.
u. S. EP A Re~nse: The selection of chemicals of concern was based in part upon whether
toxicity values were available for the chemicals of concern. Additional information,
however, was also considered as to whether a chemical's toxic potential was high. A case in
point is that of the inclusion of lead as a chemical of concern despite tl!te fact that a toxicity
factor was unavailable for the metal. If anything, exclusion of chemicals resulted in an
underestimate of the potential risk for the site. When more chemicals are evaluated, the
exposure, risk, and hazard estimates will increase due to the summation of these estimates.
12.
The PRPs stated that a qualified, well trained toxicologist should be involved in the
29
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risk: assessment process and that all chemicals of concern be quantitatively evaluated.
The PRPs also questioned the toxicity values utilized and the uncertainties associated
with the values.
u.s. EPA Response: U.S. EPA agrees that toxicity assessments are an integral part of a risk
assessment. A qualified toxicologist at M&E was responsible for the interpretation of
toxicity values for use in the risk assessment process. For additional guidance for derivation
and use of toxicity values, appropriate sources are sought which include U.S. EPA's Office
of Health and Environmental Assessment (OHEA) and Superfund Health Risk Technical
Support Center Environmental Criteria and Assessment Office (ECAO).
Chemicals lacking RID or CSF toxicity values were not quantitatively evaluated in the risk
assessment. Reference dose toxicity values are estimates of acceptable daily exposure to a
chemical that would not result in deleterious noncarcinogenic effects. Cancer slope factors
are the upper bound estimates that represent the carcinogenic risk associated with daily
exposure to the chemical. The slope factor converts estimated daily intake directly to
incremental risk of an individual developing cancer. Noncarcinogenic effects are not
expressed as a probability but rather evaluated by comparing an exposure level over a time
period with a reference dose derived for a similar exposure period. Therefore, if toxicity
values do not exist for a chemical, then exposure to that chemical cannot be quantified. The
risk assessment does provide critical toxic effects (Table 8-19) as well as toxicological
prof1les (Appendix K) for each chemical of concern. Uncertainties associated with the risk
assessment process are addressed in Section 8.6.6.
13.
The PRPs contend that the toxicity value for the oral carcinogenic slope factor (CSF)
of arsenic is not acceptable because sound scientific data for the development of a
slope factor does not exist.
U.S. EPA ReS1X>nse: The oral CSF of 1.75 per mglkglday for arsenic was derived from the
unit risk: value of 5.Oxl0.s per ugll in drinking water. According to an IRIS printout
(December 3, 1992), U.S. EPA recommends that the unit risk be adopted. Furthermore,
contact with Office of Health and Environmental Assessment (OHEA) supported the use of
the unit risk value in risk assessments.
The inh:tl:ttion slope factor'for arsenic of 50 per mg/kg/day is listed in the 1992 Health
Effects Assessment Summary Tables (BEAST). According to the Associate Director of the
Superfund Health Risk Technical Support Office, the slope factor value was derived by
assuming a 30% absorption of inhaled arsenic. The value of SO risk units per mg/kglday is
intended to be used as an admini~red dose. in the risk evaluation. Furthermore, the
Associate Director explained that the unit risk of 4.3xl0'3 per uglm3 is derived from the
slope factor.. The following equation shows the derivation of the unit risk from the slope
factor taking into account the 30 % absorption value for arsenic:
30
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(SF) (Inh) (Abs) /. (BW) = Unit Risk
slope factor, 50 per mg/kg/day
inhalation rate, 20 cu. m/day
absorption, 30 %
body weight, 70 kg

(50 per mg/kg/day)(20 m3/day)(0.3) / (70 kg) = 4.3x1o-3 per ug/cu.m
where:
SF =
Inh =
Abs =
BW =
14.
The PRPs commented that the toxicity values for 1, 1-dichloroethene were not applied
correctly in the Risk Assessment.
U.s. EPA ReSJX>ose: The U.S. EPA Cancer Slot" -~ Factor of 1.2 (mg/kg/day)-l was applied
to the estimated inhaled intake (administered dose! of 1,1-DCE. The PRPs contend that the
CSF should-have been applied to the metabolized dose of 1,1-DCE. Although the PRP
comment specifically mentions 1, l-dichloroethene, the issue of toxicokinetics is of generic
relevance to risk assessment models.
According to IRIS (December 3, 1992), the inhalation CSF for 1,1-DCE was calculated
using estimated animal administered doses. It should also be noted that U.S. EPA accounted
for interspecies differences, including metabolism of 1,I-DCE in mice, when the Agency
estimated human equivalents to the mouse dose schedule used in the studies from which the
inhalation CSF was derived (Mattoni et al.. 1977, 1985).
Other than the method by which U.S. EPA derived the CSF for 1,1-dichloroethene, there are
several other reasons why the approach taken in the toxicity assessment is defensible in the
context of this risk assessment.
Many chemicals produce toxic effects through active metabolic intennediates. However,
U.S. EP A's Risk Assessment Guidance for Superfund does not account for the amount of
administered dose which is converted to active metabolite(s). It is only rarely that the
metabolic fate of a non-pharmacologic substance such as 1, 1-DCE is well delineated in
humans. Although the U.S. EPA approach contributes to the conservatism of the risk
estimate, it is a consistent inethod for dealing with the paucity of toxicokinetic data for
humans. .
It is not appropriate to assume that the relative proportions of 1, l-dichloroethene metabolites
(or many other xenobiotic substances) produced in humans would be similar to laboratory
rodents. There is a considerable difference in the proportion of metabolites formed in mice
as compared to rats (ATSDR Toxicological ProfIle, 1989). Furthermore, the toxicokinetics
of 1, I-DCE may be quite different at the very low concentrations encountered in the ambient
environment as compared to laboratory studies. Since this type of infonnation is not readily
available in the published literature, it would be inappropriate to estimate the proportion of
31
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inhaled 1,1-DCE which ~ converted to the oxirane (epoxide) or other electrophilic species in
a hypothetical human receptor under the conditions potentially encountered at the site. .
U.S. EPA agrees that applying the inhalation CSF to an administered dose of 1,1-
dichloroethene (or similar compound) rather than the dose of the active metabolite is very
likely to overstate the risk. The influence of metabolism on the estimate of risk posed by
constituents of concern is discussed in the uncertainties section of the Baseline Risk
Assessment. .
The uncertainties for the slope factor for arsenic are acknowledged in the toxicity prof1le for
arsenic (Appendix K): "There is a fair amount of uncertainty about the studies from which
the oral slope factor was derived. At present, the ingestion unit risk estimate for arsenic is
undergoing further review and a final ingestion unit risk is pending. " The toxicity value for
utilization of the arsenic oral slope factor was based on consultation with the U.S. EPA
Environmental Criteria and Assessment Office (ECAO). Further, the uncertainties associated
with the use of all of the slope factors are discussed on page 8-39 of the report.
15.
The PRPs commented that improper statistical analysis was applied to generate the
upper-95th confidence limit for the mean concentrations of chemicals in various
media.
U.S. BFA Response: U.S. EPA Risk Assessment Guidance for Superfund, Human Health
Evaluation Manual (U.S. EPA, 1989) does not provide a specific methodology for deriving
the exposure concentration. New guidelines for deriving the exposure concentration have
since been released by U.S. EPA in 1992. However, the U.S. EPA Guidance for Superfund,
Human Health Evaluation (U.S. EPA, 1989) simply provided references to statistical analysis
text books. These analyses were based on the concept of normality and sample size is key to
, the particular method of analysis selected.
In the Baseline Risk Assessment, a normal Gaussian distribution of the data was assumed
based on the availability of 30 sample results. When a sample size is greater than 30, it is
assumed that the sampling distribution approaches that of a normal distribution (Daniel,
1983). The 95 percent UCL values calculated were based on the sample standard deviation
rather than the population standard deviation. In the former the denominator is n-l rather
than the n utilized in the calculation of the latter case. The sample standard deviation will
therefore be greater in magnitude than the population standard deviation.
16.
The PRPs commented that the seeps and intermittent streams do not support the
sensitive aquatic life which may be present in Duck Creek and therefore, Ambient
Water Quality Criteria (A WQC) do not apply to the evaluation of the seeps and
intermittent streams.
U.S. BFA Re~nse: Ambient Water Quality Criteria (AWQc) were evaluated for the seeps
and intermittent streams as a pertinent ARAR or toxicity values for comparison to chemical
32
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concentrations detected in these surface water bodies. Specific biota were identified during
the ecological survey which could indeed be subject to exposure to site related contaminants
in the seeps and intermittent streams. . Such receptors included crayfish, tadpoles,
salamanders, and frogs. Furthermore, the seeps may runoff into the intermittent streams
during precipitation events and the intermittent streams feed into Duck Creek which has been
designated as an exceptional wannwater habitat, capable of supporting/maintaining
exceptional or unusual wannwater organisms. The potential eventual contribution of the
seeps and intermittent streams to Duck Creek must also be considered in evaluating potential
risks to environmental receptors.
17.
The PRPs commented that the shower model utilized in the Baseline Risk Assessment
was unscientific and overly conservative.
U.S. EPA Response: At the time of the preparation of the Baseline Risk Assessment,
models for evaluating shower-related inhalation exposure were not approved or recommended
by U.S. EPA guidance for risk assessment, ECAO, or by U.S. EPA or Ohio EPA
toxicologists. Although models which predict the rate of volatilization of chemicals from
potable water and subsequent exposure to receptors are reported in the literature, none of
these models have been incorporated into U. S. EP A guidelines for the performance of human
health risk assessments such as the Human Health Evaluation Manual [(HHEM) U.S. EP A,
1989], HHEM Supplemental Guidance: "Standard Default Exposure Factors" (U.S. EPA,
1991), the Superfund Exposure Assessment Manual (U.S. EPA, 1988), or the Exposure
Factors Handbook (U.S. EPA, 1989).
The model used in the risk assessment was simplistic in that it is assumed that the total
concentration of the volatile organic chemicals will be released into the area of a shower stall
and will be available in air for inhalation during the showering period. The model employs
exposure parameter values (such as the shower water flow rate, and shower duration) from
the Exposure Factors Handbook (U.S. EPA, 1989). The parameter values utilized were
based on maximum or upper 9S percent confidence level estimates for the general population.
No factor such as an octanol water partitioning coefficient (Koc) or other indicators of
relative volati1i7:1tion rates were employed in the model. Ranges of inha lation-to-ingestion
doses for volatile organic compounds have been reported in the literature whereby the
exposure from inhalation exceed that from ingestion. 10 addition, dermal exposure of
volatile organic compoundS has also been noted to occur during showering (Risk Analysis,
Vol. 10, Jo, Weisel, and Lioy, 1990).
In the case of the shower model used in the risk assessment, dermal eXJPOsure was not
evaluated quantitatively as contributing to overall exposure. Similarly, the contribution of
volatiles remaining in the showering room air, or the rest of the house after the shower were
not incorporated into the model. Other sources of inhalation exposure to volatile chemicals
in indoor air not quantified using the showering scenario include washing dishes, washing
clothes, and cooking. There is also the possibility that more than one occupant in a
residence may take a shower in close proximity to the time that other residents have taken
33
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showers. In this case, volatile chemical concentrations in the bathroom air may not decline,
but will likely increase to levels higher than predicted for a single showering event.
Exposure levels, therefore, would also be expected to be much higher than levels predicted
for a single showering event scenario.
Thus, the shower model provides some under- and overestimation of overall exposure. The
model utilized was developed to provide a conservative estimate of exposure. Because actual
air measurements were not available, the model was designed to err on the side of
conservatism rather than to potentially underestimate risk because ground water has
historically been utilized as a potable source in the vicinity of the site.
18.
The PRPs commented that the assumption that ground water was used as a potable
supply was overly conservative and is not consistent with U.S. EPA guidelines. In
addition, the PRPs stated that ground water at the site does not need to be returned to
beneficial uses because this is not "practicable," due to site complexity and the
difficulty of implementation of "treatment technologies."
U.S. EPA Res.ponse: U.S. EPA disagrees. Private wells have historically been utilized as
potable water supplies on and near the site. A well survey, detailed in Section 4.4 of the RI
report, indicates that 27 residences within a one-mile radius of the site rely on the use of the
wells as a ground water resource. In fact, the former Ross/Elder residence is again occupied
and the sole water supply is provided by a private well. Another residence (Drennen's) .
down the road from the site owner was identified during Phase IT of the RI at which a private
well provides the sole source of water to the residence. Also, there are no regulations that
could stop the future use of the Groves well (located just adjacent to the site), if the Groves
or future owners so desired. It was determined during Phase IT of the RI that the residential
wells nearest the site (Groves and former Ross/Elder) receive water from two or three water-
producing horizons which collectively produce enough water to supply a private residence.
U. S. EP A also disagrees that the ground water at the site should not be returned to beneficial
use due to impracticability. The NCP clearly recognizes that ground water restoration
through source removal and natural attenuation is an acceptable alternative to implementation
of ground water treatment. U.S. EPA has acknowledged the difficulty of actively
remediating the ground water and identified source removal measures which should
expeditiously restore this resource.
19.
The PRPs commented that chemicals such as arsenic, beryllium, and the polycyclic
aromatic hydrocarbons (PARs) should not have been included in the risk assessment
because they occur at levels that are consistent with background soils concentrations.
The PRPs and their consultants also commented that the "midpoint" of USGS soil
level of metals would result in a risk level of 2xl Q4.
U.S. EPA Res.ponse: Chemicals of concern were selected based on an evaluation of all of
the environmental media sampled on-site. Thus, while the chemical may not have occurred
34
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at levels which were higher than background in one media, it may have exceeded background
levels in another media. 'In the case of the arsenic, soil concentrations were higher than site-
specific background soil concentrations. However, ground water concentrations of arsenic
were in the same range as the site-specific background data for groundwater. Site ground
water concentrations of beryllium were higher than background ground water concentrations.
Yet, the soil levels found in on-site and site-specific background samples were comparable.
The summary for the Baseline Risk Assessment, Section 8.7, recognized that chemical
concentrations in some media did not exceed background. Furthermore, in the Feasibility
Study, the remedial objectives selected for arsenic and beryllium in soil were set at the
background concentrations.
Polycyclic aromatic hydrocarbons (pAHs) were also cited as chemicals of concern which
should not have been evaluated in the Baseline Risk Assessment or the Feasibility Study
because the concentrations were considered by the commenters to be in line with natural and
anthropogenic background concentrations. The PAIls were detected in the soils samples
collected from the site; however, the P AHs were not found above detection limits in
background soils. Furthermore, elimination of chemicals from further consideration in the
risk assessment or the feasibility study is typically limited to inorganic analytes. The PAHs
were also associated with historical disposal activities at the site. Therefore, these chemicals
were retained as chemicals of concern in both the Baseline Risk Assessment and the
Feasibility Study.
Overall, the risk assessment serves to provide an evaluation of potential risk associated with
the chemical concentrations detected in environmental media on-site. The initial evaluation
of site-to-background metals concentrations was performed to identify analytes which exceed
the site-specific chemical concentrations. Arsenic is one metal which provides a significant
contribution to the overall risk from exposure to soil and ground water. Site soil, sediment,
and surface water arsenic concentrations exceeded background concentrations. Site ground
water arsenic concentrations did not exceed background levels. The maximum arsenic
concentration in soil was 50 mg/kg. Concentrations of arsenic in Ohio farm soils may range
from approximately 5 to 10 mglkg (personal communication from Terry Logan, The Ohio
State University, 1991). Other sources report that arsenic in some parts of the country may
be much higher.
However, environmental conditions may vary across the United States whereby, metals
concentrations may be much higher or lower than at the site, some of this variability may be
related to man-made or anthropogenic sources of chemical concentrations. However, site-
specific background sampling data were collected from the site vicinity to determine
appropriate comparison data for this site in particular. The Baseline Risk Assessment must
focus on potential site-related exposures, risks, and hazards which exceed background levels
for the site. The summary of the Baseline Risk Assessment concedes that "inclusion of
media-specific concentrations that are not higher than background could result in an overly
conservative, exposure, hazard, or risk estimate. "
35
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With respect to the PRP's comment concerning the risk associated with the midpoint of
USGS soil levels, it should be noted that the variability associated with the USGS data may
result in ranges of soil concentrations across the United States which may not be comparable
to site-specific infonnation. The basis for collecting such soil data may differ in tenns of the
data quality, sampling distribution, soil stratigraphy, and laboratory analyses and quality
assurance compared to the data collected for the Vandale site. Furthennore, it is not clear
what is meant by the tenn "midpoint". Such a value may represent the average or median
values for samples collected from the same or different areas in the country. The "midpoint"
of the number and type of samples collected in the USGS data may not provide a
representative point of comparison for the site.
20.
The PRPs commented that a functional uncertainty analysis was not perfonned in the
Baseline Risk Assessment.
U.S. EPA ReSJK>nse: A qualitative evaluation of uncertainties associated with the Baseline
Risk Assessment was presented in Section 8.6.5 of the Remedial Investigation Repen. In
addition, uncertainties associated with various~spmptions utilized in the risk assessment
were provided throughout the repon and appen~s. A quantitative analysis of uncertainties
in the risk assessment process can be perfonned ""'t is not required according to U.S. EPA
Risk Assessment Guidance for Superfund, Human Health Evaluation Manual (1989). The
guidance states that "highly quantitative statistical uncertainty analysis is usually not practical
or necessary for Superfund site risk assessments for a number of reasons, not the least of
which are the resource requirements to collect and analyze site data in such a way that the
results can be presented as valid probability distributions. "
21.
The PRPs commented that the risk and hazard estimates should not have been
expressed using more than one significant digit.
U.S. EPA ReSJK>ose: U.S. EPA agrees that this comment is consistent with the U.S. EPA
Risk Assessment Guidance for Superfund, Human Health Evaluation Manual (U.~. EPA,
1989). The risk assessment tables should have expressed the risk and hazard using only one
significant digit. The results have been presented to two or three significant digits in the text
and tables. However, such presentation does not change the overall fmdings of the risk
assessment.
22.
The PRPs expressed concern that the risk assessment consists of a worst case risk
assessment and cautioned U.S. EPA to pay heed to a 1991 repon from the Office of
the President. This repon claimed that the use of worst case assumptions by U. S.
EP A distons the results of risk assessments.
U.S. EPA ReSJK>nse: U.S. EPA disagrees that the risk assessment is excessively
conservative. The risk assessment was conducted in accordance with the NCP and U.S.
EPA guidance available at the time of the assessment. In addition, the Vandale Junkyard site
is currently and has historically been inhabited by residents and used for occupational
36
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"
purposes. The population of residents in the vicinity of the site are known to utilize ground
water as a potable water source, raise livestock on-site, live and/or work on-site, and hunt
and fish in the site vicinity. There is also the potential of gardening on-site. The population
in the vicinity of the site is comprised of both very young and older aged individuals.
Further, there are virtually no prohibitions to trespassers entering the site premises.
From an environmental (rather than human health) standpoint, there are many ecological
receptors located on-site and associated with on-site biota which may be subject to exposure
to chemicals detected in environmental media at the site.
In many cases the mention of a Superfund site brings to mind an industrial site where
residents are not likely to come into contact with site contaminants, on-site entry is limited,
ground water is not used for potable purposes, food is purchased at a local grocery, and on-
site work and living activities are typically very limited. Yet, at the Vandale Junkyard site,
residents do live in the site vicinity, and also live and work on-site. In this situation, U.S.
EP A would be failing its statutory mandate to protect human health and the environment by
conducting a risk assessment at this site which em on the side of potential under-estimation
of risk.
23.
The PRPs commented that volatile organic compounds would be expected to vaporize
and would not be available for skin absoxption.
U.S. EPA Response: U.S. EPA followed the guidance outlined in the U.S. EPA "Interim
Guidance for Dermal Exposure Assessment" (U.S. BFA, 1991) to evaluate dermal (skin)
exposures to chemicals detected in soils. Chemical-specific dermal absorption values were
not available for the chemicals of concern at the site. Therefore a default absorption factor
of 25 percent was utilized for volatile organic compounds. However, as is the case with any
modeled exposure pathway, direct measurements of relative skin absorption and ultimate
exposure were not available. This approach may have resulted in an overestimate of
potential exposure, hazard, and risk for volatile organic compounds which may volatilize.
However, in no case did the dermal exposure route result in an unacceptable risk or hazard
(Le., risk greater than lxlQ-4 to lx1Q-6 or hazard greater than 1.0) for the volatile organic
compounds. Overall, the risks and hazards associated with dermal exposure did not provide
a significant contribution to the total site risks and hazards for the chemicals of concern.
24.
The PRPs commented that a Monte Carlo analysis should have been performed to
provide a less conservative, more reasonable approach to evaluating exposure.
U.S. EPA Re$pOnse: Monte Carlo analyses can indeed provide much insight into the
evaluation of exposure at a site. However, for the most part, such analyses are typically
applied to uncertainty analysis rather than to the detennination of reasonable maximum
exposure. U. S. EP A Risk Assessment Guidance for Superfund, Human Health Evaluation
(1989) provides a description of some of the uncertainty associated with such an analysis as
follows:
37
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"These quantitative techniques require defInition of the distribution of all input
parameters and knowledge of the degree of dependence (i.e., covariance) among
parameters. The value of flI'St-order analyses or Monte Carlo simulations in
estimating exposure or risk probability distributions diminishes sharply if one or more
parameter value distributions are poorly defmed or must be assumed. These
techniques also become difficult to document and to review as the number of model
parameters increases. Moreover, estimating a probability distribution for exposures
and risks can lead one into a false sense of certainty about the analysis. n
It should be noted that the pool of scientifIc data from which exposure parameter values have
been derived is very limited for a number of the parameters. Complete distributions for the
general population are not be available for parameters such as intake rates, exposure
durations, exposure frequencies, etc. Therefore, while the PRPs contend that exposure, risk,
and hazard have been overestimated at the site, the potential also exists that Monte Carlo
analysis/development of exposure parameters may also significantly under- or overestimate
exposure depending upon the default values assumed for missing data from the distributions
of data evaluated in the Monte Carlo simulations.
Furthermore, a Monte Carlo analysis may be a viable path to take for sites where more
variability in the probability of exposure may occur and there is room for the risk assessment
to potentially err on the side of a lesser degree of conservatism. However, the site is known
to be an area where people work, live, farm, hunt, and trespass on-site. Ecological receptors
also inhabit and traverse the site. U.S. EPA cannot afford to err on the side of under-
estimation of exposure and risk at such a site.
25.
The PRPs commented that the Baseline Risk Assessment for the Vandale Junkyard
site provides a bounding or screening estimate of risk rather.than a realistic estimate
of risk. .
U.S. EPA Res,ponse: U.S. EPA disagrees. The Vandale Junkyard site is not a site where
exposures to human and ecological receptors can be considered hypothetical (as might be true
at some sites in more restricted, or lesser inhabited, industrial areas, etc). The site is one
where the potential for human or environmental exposures is very high. It is for this reason
that U. S. EP A felt very strongly that a conservative evaluation of risk must be performed for
the site. The site owner has indicated that he would like to build a house on the site in the
future, and his son lives in a mobile home on-site. Livestock and poultry are being raised
on-site. The owner's grandchildren visit the site frequently. The owner and people who
reside in the site vicinity hunt deer and other game animals on-site. The owner works on-
site. Ground water use as a potable source has been documented over time in the site
vicinity. There is a potential for the raising of vegetables on-site. These points all resulted
in U.S. EPA's decision to prepare a risk assessment which would err on the side of
conservatism rather than underestimation of exposure, hazard, and risk. While it is true that
only a small number of human receptors may be affected by or subject to exposure at the site
currently, such individuals and potential future users of the site are entitled to the same
38
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attention and protection t?y the U.S. EPA as a larger ~eptor population.
26.
The PRPs commented that if exposure concentrations were set to one half the
detection limits for all of the chemicals of concern, a total risk of 2xl0"3 would result
for the site.
U.S. EPA Re$pOnse: It should be noted that the toxic potential of the chemicals detected at
the site weighed heavily in the selection of chemicals of concern for the Baseline Risk
Assessment. Many of the chemicals are considered carcinogens. As such, and in view of
the cancer-causing potential of any exposure to carcinogens, it is not surprising that the
simple assumption of the presence of the chemicals of concern, albeit at very low
concentrations, may be associated with unacceptable risk estimates. U.S. EPA's regulation
of drinking water contaminants includes the setting of maximum contaminant level goals
(MCLGs). For the most ideal situation, an MCLG would be the nonexistence of carcinogens
in drinking water to provide the maximum protection against exposure to a carcinogen.
Because the exact mechanism for the initiation of cancer is not currently known, U. S. EP A
attempts to be as conservative as possible in the evaluation of available toxicity data and the
associated development of cancer toxicity data and the associated development of cancer
toxicity factors (slope factors) for carcinogens. Therefore, the detection of carcinogens, even
at very low concentrations, at a site may be unacceptable because of the relative toxic
potential of the contaminants. Proof of the lack of an unacceptable risk for a site would be
the absence of contaminants. However, detection of chemicals in environmental media
indicates that contamination is present. If the chemicals were never detected (at whatever
quantitation or detection limit), there would be no need to evaluate risk or hazard at the site,
and no calculations of excess risk (associated with even one-half of the detection limit) would
be performed.
27.
The PRPs identified an apparent contradiction in the RIfFS documents in that no
dilution is assumed to occur as water infiltrates through contaminant sources to the
fIrst water-producing zones within the bedrock, but potential mixing and dilution of a
contaminated water zone is identified for private residential wells, because these wells
were observed to intersect two to three water producing zones.
U.S. EPA Re$pOnse: It is tnle that drilling of monitoring wells adjacent to residential wells
at the former Ross/Elder (RS-03) and Groves (RS-04) residences identified that each
residential well receives water from two to three water zones. However, this does not
necessarily mean that any potential residential well drilled on or near the site would have to
intersect multiple water zones to receive a sufficient water supply for residential use. It is
possible that there are potential well locations Gn or near the site that would produce a
sustainable and adequate water supply for residential use by only intersecting the flJ'St water-
producing zone. Although pumping tests were not conducted on any monitoring wells during
the RI, possible evidence of this is that a few of the wells (S-8, S-9) installed into the flJ'St
water zone produced a good quantity of water, even though it was not determined whether
the quantity was sufficient to supply a residential well. Even if a residential well intersected
39
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two or three water-bearing zones, there are no assurances that the lower zones would be less
contaminated than the uppermost zone.
. REFERENCES FOR REMEDIAL INVESTIGATION COMMENTS
A TSDR. 1989. Agency for Toxic Substances and Disease Registry. . Toxicological ProfIle
for 1,I-Dichloroethene. Prepared by Clement Associates for U.S. Public Health Service.
Daniel, W.W. 1983. Biostatistics: A Foundation for Analysis in the Health Sciences.
Third Edition. John Wile & Sons, Inc., New York.
Maltoni, et ale 1977. Carcinogenicity Bioassays of Vinylidene Chloride, Research Plan and
Early Results. Medicina del Lavora, 68(4):241-262.
Jo, W.K., C.P. Weisel, and P.J. Lioy. 1990. Routes of Chloroform Exposure and Body
Burden from Showering with Chlorinated Tap Water. Risk Analysis, 10(4): 575-580.
u.S. EPA. 1989. U.S. Environmental Protection Agency. Risk Assessment Guidance for
Superfund, Volume 1, Human Health Evaluation Manual (Part A), Interim Final. Office of
Emergency and Remedial Response, EPA/54O/1-89/002, Washington D.C.
u.S. EPA. 1990. U.S. Environmental Protection Agency. Guidance for Data Useability in
Risk Assessment, Interim Final. Office of Emergency and Remedial Response, EPA/540/G-
90/008, Washington D.C.
COMMENTS ON THE DEVELOPMENT OF REMEDIAL OBJECTIVES
1.
The PRPs commented that MCLs should have been considered as ARARs for ground
water during the development of remedial objectives.
u.S. EPA ReS1K>nse: MCLs were evaluated in the context of the relevant exposure pathways
identified for the site. When these evaluations were performed, the total risk associated with
ground water exceeded a lxl04 risk. The PRPs appear to have misconstrued that U.S. EPA
had evaluated the total risk" associated with the chemical-specific MCLs based on a lxl()"06
risk. The language in the FS which refers to a lxl~ risk was directed at the development
of total allowable site risk, rather than the determination of the risk associated with the
MCLs as remedial objectives. As noted on page 2-3 of the FS, when the risk associated with
the MCLs was evaluated, the total site risk was 1.16x10'3. This risk exceeded the Ixl()"04
criterion as described in the NCP at 40 CPR 300.430(e)(2)(i)(D).
2.
The commenters indicated that arsenic, beryllium, vinyl chloride, polycyclic aromatic
hydrocarbons (PAHs), and diethylhexyl phthalate [DEHP, or as referred to in the
RIlFS, bis(2-ethylhexyl phthalate)] should not have been considered as chemicals of
40
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concern in the ev~uation of site remediation.
U.S. EPA ReS1X>nse: U.S. EPA disagrees. Arsenic in soils at the site exceeded site-specific
background concentrations by a five-fold factor. The development of ground water remedial
goals included the evaluation of arsenic because the soil-related contamination of ground
water could potentially occur at the site. The overall cleanup level for arsenic was set at the
method detection limit which is equal to the MCL for arsenic at 0.005 mg/L. U.S. EPA
guidelines for the development of preliminary remedial goals (U.S. EPA Human Health
Evaluation Manual, Part B: "Guidelines for the Development of Preliminary Remediation
Goals" OSWER Directive 9285.7-0lB, December 13, 1991) stipulate that for a medium
which does not exceed applicable preliminary remediation goals, but which may contribute to
the protectiveness criterion for another medium (i.e., soil to ground water in this case), clean
up goals should be developed for that potentially contributing medium.
The rationale for the inclusion of vinyl chloride has been discussed in the comments on the
RI and Risk Assessment. However, the major considerations were the Imowledge that the
vinyl chloride may have been associated with site disposal activities and that vinyl chloride is
a chemical breakdown product of other contaminants which were disposed at the site.
The commenters contended that beryllium was found at concentrations on-site which were
below naturally occurring levels. The site-specific and background ground water
concentrations of beryllium at the site were 0.04 mg/L and 0.001 mg/L, respectively.
Beryllium concentrations were not lower than the site-specific background concentrations.
In the case of the P AHs and the DEHP, these organic chemicals were detected on-site at
levels which were higher than background site-soil concentrations. In fact, PAHs were not
found above detection limits in the background soils. Both the P AHs and the DEHP are
associated with past disposal activities at the site. Although DEHP is a component of plastic
materials and can be associated with field or laboratory error, evaluation of quality control
samples of field and laboratory blanks did not demonstrate that DEHP should be qualified as
the result of sample contamination during field or laboratory sampling and analysis. Further,
detections from the site were higher than background concentrations for all of these
chemicals. If field and or laboratory contamination were the cause of SUlch detections, it
would be expected that background concentrations would also be subject to the
contamination.
3.
The PRPs commented that a total site cleanup goal of lxl~ shoUlld not have been
utilized for the pUIposes of developing remedial goals.
"
U.S. BFA ReS1X>nse: Current U.S. EPA guidelines concerning the development of
preliminary remedial goals (U.S. EPA Human Health Evaluation Manual, Part B:
"Guidelines for the Development of Preliminary Remediation Goals" OSWER Directive
9285.7-OlB, December 13, 1991) are indeed directed toward determining remedial goals
based on a chemical- and media-specific basis. However, the guidelines also allow for the
41
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fact that exposure to receptors may occur through more than one medium. For the Vandale
site, U. S. EP A felt particularly compelled to account for the combined exposures relative to
soil and ground water as a measure' of protection at a site where people have historically had
access to the site and utilized ground water as a potable supply. U.S. EPA guidelines allow
for such a determination to ensure the protection of human health and the environment.
4.
The PRPs commented that remedial" alternatives 3A and 4A unnecessarily include
treatment of sediments [sic]," stating that metals were shown to be near or below
background and that "neither the organic nor the inorganic substances present [in
sediment] contributed significantly to the cancer risk or non-cancer hazard. "
U.S. EPA ReSJX>nse: U.S. EPA disagrees that metals were found to be near or below
background. Table 1 in Appendix m of the FS (page m-6) shows the maximum metals
concentrations for the seep sediments, as compared to the 95 % upper confidence level (VCL)
for background metals concentrations. None of the maximum concentrations for the RCRA
metals shown on this table is consistent with, or below, the 95 % VCL for background. The
maximum concentration for chromium m is 1.12 times greater than the 95 % VCL for
background, and all other RCRA metals exceed their respective 95 % UCL by even greater
factors. Barium, a metal which often contributes significantly to site hazards, was detected
at a maximum concentration 2.3 times that of the 95% UCL for background. To consider
these concentrations to be "near or below background" is incorrect and unfounded.
The PRPs contend that remediation of the sediments is unnecessary because the risk
assessment showed acceptable risks and hazards. The risk assessment results which the PRPs
reference comprise the human health risk as~ssment, based solely on primary human contact
with contaminants in the sediments. The calculated human health risks for such contact are
below lxlQ-6. However, sediment criteria were calculated using water quality standards
which are protective of aquatic life, and these criteria were exceeded, showing the potential
for effects on ecological receptors. The potential for related human health impacts, as a
result of ecological impacts, also exists. The bioremediation of organic contaminants in
sediments is recommended in all remedial alternatives because this treatment should
accelerate degradation of these contamirnutts and reduce such impacts. Treatment of
inorganic contaminants in the seeps is not recommended ,due to the lack of a non-destructive
remediation approach.
Another case-in-point for remediation of the seep sediments is that the concentrations of
metals in these sediments exceed the 95 % VCL for background. Numerous other studies and
the calculated sediment criteria also indicate that metals concentrations are elevated at this
site. These elevated levels in sediments may cause organics and inorganics to be released to
the receiving streams and other surface waters at concentrations which exceed applicable
water quality standards. Please see the comments which follow for additional discussion of
data that indicate that seep sediment metals concentrations are elevated.
5.
The PRPs state that the terms "criteIia" and "standards" are used interchangeably
42
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"
throughout the discussion of the sediments, and that the precedence of state water
quality over federal "standards was ignored. The PRPs state that" (t)here are no
federal or state sediment criteria or standards." The PRPs cite a recent U.S. EPA
report, which states that "(t)he specific regulatory uses of SQC [Sediment Quality
Criteria] have not been established. " "
The PRPs also disagree with the use of an lllinois sediment study for comparison
with, and assessment of, the site sediments.
Finally, the PRPs question the lack of "discussion regarding the classification of Duck
Creek as a surface water affected by mining activities." The PRPs state that time-
varying water quality standards should have been used when calculating sediment
quality criteria for this stream.
U.S. EPA Response: Any references to "sediment standards" are intended to read "sediment
criteria." These criteria are not state or federal criteria, but they are based on state and
federal water quality standards.
In regards to the use of water quality standards, it should be noted that, with the exception of
lead from sample SW -9 and Seep A, all maximum detected metals concentrations that are
shown to exceed sediment criteria, exceed both the Ohio EPA and U.S. EPA-based criteria.
The maximum detected organics concentrations that exceed calculated criteria, exceed Ohio
EPA-based criteria in every case. Therefore, the precedence of state water quality standards
over federal is of little consequence. In SW-9 and Seep A, lead only exceeds the U.S. EPA-
based criteria.
Although calculating criteria for sediment quality is an idea open to much debate, there is a
scien~c foundation for the concept, and criteria are evolving. Preliminary criteria already
exist, as evidenced by the quote cited in the comments by the PRP's consultant. The quote
reads "(t)he specific regulatory uses of SQC [Sediment Quality Criteria] have not been
established." This statement implies that such criteria do exist. The use of such criteria is
appropriate, despite the fact that specific regulatory uses have not been establishC:d. U.S.
EP A believes that such criteria can be a useful tool in identifying contaminated sediments.
Although pre1iminary, this is a reasonable approach in making sediment remediation
decisions.
"'
Ohio EP A uses the I11in6is study as a screening tool to identify elevated levels of inorganics
in sediment. In the absence of state- or site-specific criteria, such a study can prove useful
in assessing sediments. The lllinois study provides additional evidence that seep sediments
contain elevated levels of many of the inorganics. For further comparison, Table 1 shows
other sediment criteria and background values for inorganics from a variety of sources.
Please note "that, in every case, the maximum inorganic concentrations detected in site
sediments exceed the background and criteria values reported.
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Regarding Duck Creek water quality standards, the only exemptions are total dissolved solids
(IDS) for the mainstem and TDS, Ph, iron, and zinc criteria for the east and west forks.
These exemptions exist because Duck Creek receives mine drainage. Aside from these
exemptions, Duck Creek and its forks are subject to all warmwater habitat water quality
standards. The sediment criteria tables are based on water quality standards for Duck Creek,
which is only exempt from the TDS criterion. Therefore, no standards were used
inappropriately.
6.
The PRPs state that the water quality standards used in calculating sediment criteria
should have been calculated based on site-specific hardness values. The PRPs also
question the substitution of the Koc for chromium (VI) for chromium (ill), since
chromium (Ill) is not hazardous, and chromium (VI) is a carcinogen.
U.S. EPA Response: Site-specific hardness values were used in Tables 6 and 7 of Appendix
m of the FS. These tables show sediment criteria based on hardness-dependent water quality
standards. Seep A sediments exceed criteria based on U.S. EPA hardness-dependent water
quality standards for lead and Ohio EPA- and U.S. EPA-based criteria for zinc. The marsh
sediments exceed both Ohio EPA- and U.S. EPA-based criteria for chromium and lead.
Certain surface water sediments also exceed Ohio EPA- and U.S. EPA-based criteria for
chromium and federal-based criteria for lead. It should be noted that copper is the only
inorganic which did not exceed any sediment criterion based on site-specific hardness.
. Chromium, lead, and zinc all exceed the site-specific criteria in at least one sediment sample.
The Koc for chromium (VI) was substituted for that of chromium (ill) because no Koc was
available for chromium (Ill). Because chromium (VI) has a greater afflnity for organic
matter than does chromium (IIT)(U. S. EP A 1979), the use of the Koc for chromium (VI)
results in a higher calculated sediment criterion. That is, because chromium (VI) tends to
bond to organic matter more readily than does chromium (DI), more chromium (VI) will be
"locked up" in sediment. Therefore, it is not as easily released to the aquatic environment.
If a Koc were available for chromium (DI), the resulting sediment criterion would be lower
(more conservative) than that which was calculated using the Koc for chromium (VI).
The fact that chromium (VI) is a carcinogen, while chromium (ill) is not considered
hazardous, has no bearing on the use of Koc values in the calculation of sediment criteria.
The Koc relates only to the partitioning of a chemical between sediment organic carbon and
water. The organic carbon to water partitioning properties of a chemical are not detennined
by its health effects.
7.
The PRPs state that Duck Creek is affected by acid mine drainage and is exempt from
certain water quality standards. The PRPs also state that "Metcalf & Eddy should use
the 30 day average concentration outside the mixing zone to determine sediment
criteria. Sediment pore water will be diluted as it enters surface waters, so the use of
the outside the mixing zone standards is more appropriate to derive sediment criteria
[sic]. "
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,
U.S. EPA Response: Tl}e Duck Creek exemptions are addressed in the response to comment
2. U.S. EPA did use the 30-day average, outside the mixing zone standards, as listed in
Appendix m.
8.
The PRPs state that the procedure used to derive sediment criteria is appropriate only
for non-ionic organic chemicals. The PRPs also question the fact that the
uncertainties regarding the sediment criteria are not addressed. The PRPs mention
that if 95 % UCLs had been calculated for the sediment criteria, lead would no longer
exceed the sediment criterion.
The PRPs state that the source of Koc values for inorganics was not identified and
that "the partitioning coefficient derived from the well waters cannot be used for this
purpose since the organic matter regime is different. Chemicals in sediments are
partitioned into three phases; 1) free, 2) sorbed on to particulate organic carbon, and
3) sorbed onto particulate organic carbon. Metcalf & Eddy should have determined
the total and dissolved organic carbon content of the well water before attempting to
develop partitioning coefficients that would be applied to seep sediments [sic]."
The PRPs also state that information which became available since the publication of
the U.S. EPA report which was referenced in the FS should have been used. This
new information suggests that acid volatile sulfides (A VS) control the availability of
trace metals and, therefore, the A VS of ground water and sediments should have been
analyzed.
Finally, the PRPs state that the derived sediment criteria were not appropriately
applied. The consultant cites a U.S. EPA document, which reads "(t)he EqP
[Equilibrium Partitioning] method is presently restricted to computing effects-based
criteria for the protection of benthic organisms. The direct extension of this
methodology for computing sediment criteria that are protective of human health,
wildlife, and marketability of fish and shellfish requires that the equilibrium
assumption be extended to the water Column and to water column organisms.
...Hence, the application of the final residue values from the WQC [Water Quality
Criteria] for the computation of SQC ...is not technically justifiable. "
U. S. EP A Response: The. equilibrium partitioning (EP) approach is intended for the
calculation of sediment criteria for organics. However, because a method of calculating
criteria for inorganics was not available, U.S. EPA computed some sediment criteria for
inorganics using the same method. Koc values were found for most of the metals in the
U.S. EPA document about determining soil response action levels (U.S~ EPA, 1989). The
calculated criteria were intended to support what was already shown in the comparison of
Vandale sediment concentrations to 95 % UCL background concentrations. In every case
where metals exceed the calculated sediment criteria, they also exceed site background
concentrations by a factor of at least 1.12. Lead is nearly 3 times its 95 % UCL background
concentration in the marsh sediments.
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The uncertainties in the calculation of sediment criteria are addressed, in part, in the
assumptions which are reported in Appendix m. Although any individual method for
assessing sediment contamination has numerous uncertainties, the use of additional methods
and sources provides mounting" evidence of sediment quality. Because of such uncertainties,
this is the approach which was used in assessing site sediments.
The PRPs suggest calculating an upper 95 % confidence limit for the sediment quality
criteria. No sample calculation was provided, and the comment is unclear. The calculated
sediment criteria resulted in only one value per chemical. It is not possible to calculate the
95 % UCL of a single value. U.S. EPA assumes that this was not what PRPs meant, but the
comment implied such an approach.
U.S. EPA did not derive Koc values from well water, as the PRPs inferred. The Koc values
were taken from scientific literature, U. S. EP A guidance, or were calculated from Kow
values.
The PRPs state that chemicals in sediments exist in three phases. The PRPs only list two
phases (one phase is listed twice). It is assumed that the third phase is bound to A VS.
A VS was not tested for, since the guidance regarding the ability of A VS to control the
availability of trace metals was only recently published (1991). Field work on this project
had been completed by the date this report was published, and, therefore, this analytical
parameter was never measured.
As previously stated, the EP approach is used as a tool. If calculations show that chemicals
may be released to the water column at concentrations that exceed water quality standards,
the need to remediate sediments is supported. The water quality standards used to calculate
sediment criteria are intended to be protective of aquatic life. Therefore, the calculated
sediment criteria are intended to be protective of aquatic life. This includes both benthic
organisms and "water column organisms." The interim guidance on sediment criteria (U.S.
EPA, 1988) states:
For compounds where chronic water quality criteria are not available, the EP
approach can still be useful. For example, using upper-bounds effects concentrations
will give comparable (i.e. upper-bounds effects) sediment concentrations. The
interpretation of such sediment values is analogous to the interpretations of the
comparable water column values used in their derivation.
This is interpreted to mean that if water standards which are protective of aquatic life are
used to calculate sediment criteria, the resulting sediment values will be protective of aquatic
life.
It should be noted that the fInal residue values (FRV), mentioned in the consultant's quote in
the above paraphrased comment (Comment 6.5.4), are intended for protecting the uses of
46
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'-,
aquatic life (e.g. the marketability of fish and shellfish). It is the application of FRVs in
calculating sediment quality criteria that is not "technically justifIable." This does not apply
to the criteria which were calculated for the FS. The calculated sediment criteria are not
purported to be protective of human health, wildlife, and the marketability of fish and
shellfish.
9.
The PRPs commented that default equations should have been utilized to calculate the
remedial objectives for the site.
U.S. BFA ReS1K>nse: Current U.S. EPA guidance for the "Development of Risk-based
Preliminary Remediation Goals" is directed toward the derivation of "initial clean-up goals
that (1) are protective of human health and. the environment and (2) comply with ARARs.
They are developed early in the process based on readily available information and also are
used during analysis of remedial alternatives in the remedial investigation/feasibility study
(RIIFS)." Key to this description is the word "initial." This guidance was issued after the
Remedial Investigation and Baseline Risk Assessment for the Vandale Junkyard site were
completed. Therefore, initial, preliminary remedial goals were not derived for the site
before development of the RI. In such a case, where the preHminary remedial goals are
developed before performance of the risk assessment, default equations and parameter values
are utilized in the goal calculations.
U.S. EPA believes that when a Baseline Risk Assessment has been developed to specifIcally
address potential exposures at a site, the site-specific scenarios utilized in the Baseline Risk
Assessment may then be used to develop remedial objectives. If default values are used to
develop remedial objectives in the Feasibility Study, then site-specific information identifIed
in the Baseline Risk Assessment is lost and the Remedial Investigation and Feasibility Study
can become inconsistent. The Baseline Risk Assessment serves to identify, on a site-specific
basis, which chemicals and exposure pathways can potentially pose a problem for a site. The
remedial objectives developed to reduce unacceptable risks or hazards should be derived from
the site-specifIc information identifIed in the Baseline Risk Assessment. The Baseline Risk
Assessment for the site was developed from information gathered for receptors during visual
observations, conversations, and models prepared specifIcally for the site.
10.
The PRPs commented that ground water would be undrinkable at some wells where
high levels of inorganics were detected.
-'
U.S. EPA Re$pOnse: It is true that high levels of some analytes in ground water may make
the water unsuitable for ingestion because of poor taste, odor, or other such "organoleptic"
qualities. However, where such high levels of one chemical may make the water unsuitable
for ingestion, inhalation or dermal contact might occur. Further, while the water might be
treated in some way to decrease the concentrations of one particular metal, the other metals
may still remain at high, yet non-organoleptic concentrations. The corresponding variability
of the occurrence of the different metals only allows for a conservative estimation of
potential exposure concentrations, rather than following the tract of ignoring results for
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samples which contain extreme concentrations for particular metals such as iron and
magnesium.
,.
11.
The PRPs commented that the number of background samples collected for the site
was inadequate, and as such did not conform with Ohio EP A's "How Clean is Clean
Policy. "
U.S. EPA ReS!X>nse: Prior to initiation of Phase IT sampling and analysis at the site, both
U. S. EP A and Ohio EP A provided significant scrutiny and input into the plan for sampling
background locations. Both U. S. EP A and Ohio EP A approved the number of background
samples collected during Phase n sampling. Current Ohio EPA "How Clean is Clean
Policy" guidelines provide a detailed accounting of how the number of background sampling
locations for soil and ground water should be derived. However, those guidelines were not
developed until after the Phase n sampling was performed. The previous versions of the
"How Clean is Clean Policy" in effect during the development of the sampling and analysis
plan and during Phase n sampling did not provide such a format for deriving the number of
background samples.
U.S. EPA "Guidance for Data Usability for Risk Assessment" (U.S. EPA, 1991) provides a
description of techniques for deriving sample location numbers for background samples.
Using such guidelines in conjunction with assumptions concerning the requirements for the
coefficient of variation and reliability of the data, results in background sampling numbers .
which range between three and five samples for an environmental medium. Higher numbers
of background samples are typically required where suspected contaminants of concern are
expected to be difficult to distinguish from background levels. Remediation for metals
concentrations will be based upon achieving site-specific chemical concentrations which are
consistent with background levels. Additional background sampling and analysis of
environmental media will be performed during the Remedial Design (RD) phase of activities
at the Vandale site. While metals were a consideration at the site, organic chemicals were
the primary chemicals of concern suspected to exist on-site. Such chemicals would not be
expected to occur naturally on-site, and therefore a large number of samples would not be
required to distinguish site-related contamination from background locations (i.e., any.
concentration above detection limits would be expected to be site-related).
12.
The PRPs commen~ed that the influence of background levels on risk should be
subtracted from the overall site risks when developing remedial objectives.
U.S. EPA Re~nse: U.S. EPA disagrees. The contribution of background levels of
chemicals were flfSt eliminated from development of site remedial objectives in the initial
screening of chemicals of concern in the Baseline Risk Assessment section of the Remedial
Investigation. Chemicals carried through the risk assessment from that point on were
selected because they occurred at levels which exceeded background levels in particular
environmental media. For the most part, such exceedances of background concentrations
occurred in soil. For some chemicals, such as arsenic, corresponding exceedances of
()
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c,
background did not occur in both ground water and soil. However, the potential for inter-
media migration must also be accounted for, such that remedial objectives for media which
may be influenced by the future migration of chemicals (such as ground water contaminated
by leachate for soils) must also be determined.
Remedial objectives are derived to protect against unacceptable "excess" risk. When
chemical concentrations are higher than background levels in a particular media, such
chemical levels are contributing to excess risk, over and above background levels. Remedial
objectives for metals for the site were set at background levels for all metals but antimony
and nickel. However, to determine whether the chemical concentrations for all chemicals
will result in an acceptable risk, the total concentrations for all of the chemicals of concern
must be included in the analysis, rather than subtracting out background levels.
13.
The PRPs and their consultants commented that short-term risk of remedy
implementation should be evaluated.
U.S. EPA ReSJ'Onse: U.S. EPA acknowledges that a quantitative evaluation of the short-
and long-term risks associated with remedy implementation and post-remedial conditions was
not included in the Feasibility Study. In accordance with U.S. EPA Guidelines for the "Risk
Evaluation of Remedial Alternatives", such an evaluation would likely be qualitative in
nature because data associated with remediation of the site environmental media will not
become available until remediation begins (U.S. EPA Risk Assessment Guidance for
Superfund, Pan C, OSWER Publication 9285.7-01C, December 1991).
The only background information which can be evaluated for potential risks associated with
remediation would be that of the results of the future scenarios of the Baseline Risk
Assessment which assumed that soils would be disturbed for future site development. Shon-
term exposures would be expected to follow the pattern of short-term or subchronic
exposures, hazards, and risks determined in the future scenarios of the Baseline Risk
Assessment. As such, the short-term hazards and risks would likely be lower than the long-
term risks. However, in the case of emissions related to remedial activities, the associated
air concentrations of the chemicals of concern would likely be higher than the concentrations
modeled in the Baseline Risk Assessment (based on fugitive dust emissions). The exposures
relative to emissions generated during remediation may result in higher risks and/or hazards
for receptors. Workers performing remedial work would likely be subjected to the highest
exposures.
But it should be noted that ARARs will have to be complied with during remediation (i.e.,
air and water quality standards and criteria, ambient and occupational air quality/exposure
standards and criteria, etc.). Compliance with such ARARs will require that appropriate
techniques are followed to prevent or mitigate additional contamination and exposure of
environmental media or human or environmental receptors. In addition, a Health and Safety
Plan will be developed to ensure that unacceptable exposures to site workers will not occur
during remedial activities. In both the short- and long-term remediation scenarios, potential
49
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exposures, risks, and hcu;a.rds for the receptors would be expected to decrease with time if
remediation is successful in decreasing chemical concentrations. As for the potential effects
on ecological receptors, care would be required to protect potentially vulnerable species and
to rebuild vegetation and species once remediation has been achieved. Finally, U.S. EPA's
selected remedy has the lowest short-tenn effects of all action remedies evaluated in the FS.
14.
The PRPs commented that cleanup levels are calculated such that the chemicals of
concern have 'an interdependent relationship.
U.S. BFA Response: The cleanup levels were developed to encompass the total site risk
from all of the chemicals of concern contributing to unacceptable hazards and risks. The
approach took into account both the relative contribution of the chemicals to the overall risk
as well as the relative toxic potential of each of the chemicals/exposure pathways. While this
approach limits the relative percentage of allowable risk for each of the chemicals of
concern, this interdependence is based on the results of the Baseline Risk Assessment. The
PRPs contend that media-specific and independent chemical-specific cleanup levels should be
developed for the site. However, the site risks and hazards are comprised of potentially
concurrent contributions from both soil and ground water exposures. If each of the
chemicals are allowed a total risk of IxlQ-6, for each of the two environmental media, it is
not possible for the point of departure for developing a site remedial goal of lxlQ"06 to be
achieved.
15.
The PRPs commented that the method of developing soil cleanup levels for the
protection of ground water is overly simplistic because it does not allow for
attenuation or dilution of contaminants leached from soils.
U.S. EPA Response: U.S. BFA concedes that a conservative approach was used to develop
ground water protection cleanup levels in soils. U.S. EPA believes that in the absence of
site-specific soil leaching tests, this methodology is appropriate for the circumstances at the
site. This is especially true for areas where soils are not very deep and fractured bedrock is
close to the surface, since this provides for a direct conduit from soil contamination to
ground water contamination. However, U.S. BFA has agreed to allow for the development
of rermed soil cleanup levels for the protection of ground water in the selected remedy.
These refmed cleanup levels may be pursued during remedial design based on site-specific
leaching tests and modeling of contaminant transfer from soils to the ground water.
16.
The PRPs commented that site-wide average concentrations of contaminants in soils,
as related to the required cleanup levels, should be used to determine whether or
w here remediation is necessary.
U.S. BFA Response: U.S. BFA disagrees. The site has been found to have highly variable
contaminant distributions with "hot spots" of contamination from waste disposal, especially in
association with drum fragments. Clearly, it is not appropriate to measure site-wide averages
prior to removal of contaminant hot spots. These hot spots may be the primary source of
50
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L-~
ground water contaminants. The use of statistically derived site-wide averages to show
compliance with cleanup 'levels after remediation is recommended by U.S. EPA, and will be
necessary at the site.
17.
The PRPs commented that an uncertainty analysis was not perfonned for the cleanup
levels developed for the site.
U.S. EPA Response: U.S. EPA acknowledges that a fonnal uncertainty analysis was not
performed for the development of remedial objectives for the site. However, from a
qualitative standpoint, all of the uncertainties discussed in the Baseline Risk Assessment,
including the assumption that chemical concentrations will remain constant over time; the
lack of site-specific activity pattern infonnation; and uncertainties associated with toxicity
data, also apply to the calculation of the remedial objectives.
REFERENCES FOR COMMENTS ON THE DEVEWPMENT OF REMEDIAL
OBJECTIVES
U.S. EPA. 1979. Water-related Environmental Fate of 129 Priority Pollutants. Volume I:
Introduction and Technical Background, Metals and Inorganics, Pesticides and PCBs.
EPA-440/4-79-029a. December 1979. .
U.S. EPA. 1988. Interim Sediment Criteria Values for Nonpolar Hydrophobic Organic
Contaminants. SCD #17. May 1988.
U.S. EPA. 1989. Detennining Soil Response Action Levels Based on Potential
Contaminant Migration to Ground Water: A Compendium of Examples. EPA/540/2-89-Q57
October 1989.
COMMENTS ON THE DEVELOPMENT AND EVALUATION OF REMEDIAL
ALTERNATIVES IN THE FEASmILITY STUDY
1.
The PRPs commented that the FS failed to properly develop a combined remedy for
the site, because it does not differentiate between the various areas of contamination
at the site and should have considered separate remedial approaches for Active Area
A, Active Area B, and the North Slope.
U.S. EPA Re$pOnse: U.S. EPA disagrees. A review of Figure 2-1 in the FS clearly shows
that in Active Area A, only a portion of the entire area (approximately 16%) is expected to
include both organic and inorganic contaminants. The remainder of this area is expected to
include only inorganic contaminants. The soil volume estimates in Appendix VI, the cost
estimates in Section 4.0, and supporting information in Appendix VII (page VII-4) of the FS
further document and support this differentiation of contamin~ted areas.
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The FS does, in fact, prqvide for "combined remedies" by separately addressing treatment
technologies/remedial approaches for inorganic and organic contaminants in soil, seep
sediments, ground water, surface/seep water, and solid wastes separately and then developing
a combined remedy which will fully address the variety of contaminants and contaminated
media along the North Slope and interactive areas of the Vandale Junkyard site.
2.
The PRPs commented that Table 2-7 in the FS report indicates the contaminants of
concern in Active Area A are metals and chlorinated volatile organic compounds; the
contaminants of concern in Active Area B are metals and non-chlorinated
semi-volatile organic compounds; and the contaminants of concern in the North Slope
Area are metals, chlorinated volatile organic compounds, and bis (2-ethylhexyl)
phthalate. Based on this information, the PRPs claim that the FS should have
considered separate remedial approaches for each of these areas and the FS
inappropriately screened remedial technologies as if all of the contaminants were
found in each of these three areas.
U.S. EPA Response: U.S. EPA did attempt to provide for separate remedial approaches for
the various areas on-site. A5 discussed in the response to the preceding comment, Active
Area A was clearly noted in Figure 2-1 to include a small area of inorganic and organic
contamination and a much larger area of inorganic contamina.tion only. Furthermore, the
estimates in the FS indicate that the North Slope Area is expected to account for over 50 % of
the site soils which will require treatment for organic contaminants. The organic
contaminants detected above cleanup levels along the North Slope include chlorinated organic
compounds and non-chlorinated organics. Furthermore, both chlorinated and non-chlorinated
organic compounds have been detected in soil samples from Active Areas A and B.
Although.not all of these compounds were detected above cleanup levels, historical disposal
practices at the Vandale Junkyard (as discussed in the FS report) are considered too
ill-defmed to conclude that the Active Area A soils will not include non-chlorinated organic
compounds above cleanup levels and Active Area B soils will not include chlorinated organic
compounds above cleanup levels. Selection of flexible treatment remedies that can
effectively treat a wide variety of organic contaminants is therefore a justifIable approach for
the Vandale Junkyard technology screening process. However, U.S. EPA has provided
additional flexibility in the selected remedy to investigate the utility of other technologies to
remediate distinct areas of .the site during remedial design. This determination will depend
on the results of additional soil sampling, soil treatability studies, and other site-specific
information.
3.
The PRPs commented that in-situ bioremediation was inappropriately eliminated as a
potential treatment technology for the site soils.
U.S. EPA ReS1>Onse: U.S. EPA eliminated in-situ bioremediation as a potential treatment
technology for organic contaminants in soils during the FS for the following reasons:
52
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'"
o
The high clay content and low-permeability of the site soils will, as stated in
the FS report, limit the ability of nutrients to migrate through the soils and
make contact with contaminants. The inability of nutrients to make contact
with contaminants may prevent them from promoting biological degradation of
the organic contaminants. The PRPs performed a. sieve analysis on five site
soil samples during the RI. Four of the five samples classified as clay and one
sample classified as silt. The PRPs detennined the coefficient of permeability
(k) for each of the soil samples to be less than lxl0"7 em/sec.
o
The U.S. EPA Publication, Innovative Treatment Technologies, Overview and
Guide to Information Sources, October 1991 (EPA/540/9-91/002), indicates
that applications for in-situ bioremediation are limited to favorable site
conditions which require soils that are sandy and highly permeable (K greater
than lxlO-! cm/sec).
o
An article entitled "Pedormance of In-situ Soil Decontamination Technologies:
An Air Force Perspective" in the August 1990 issue of Environmental
. Progress (Volume 9, Number 3) stated the following:
"Our experiences at Kelly AFB and Eglin AFB test sites have shown
that enhanced biodegradation cannot be applied at sites with poor
permeability and that contaminant accessibility can be a problem even
in more permeable, sandy soils. This technology seems best suited for
sandy or gravel aquifers where the majority of contamination is in the
saturated zone."
o
The U.S. EPA Handbook, "Stabilization Technologies for RCRA Corrective
Actions", August 1991 (EPA/625/6-91/026) states the following:
"Many chlorinated solvents, such as tetrachloroethene (PCE),
trichloroethene (TCE), and 1,1, I-trichloroethane (TCA) can be resistant
to aerobic biodegradation. These compounds may, however, be
degraded under anaerobic conditions. The degradation of these
compounds involves reductive dehalogenation, where chlorine is
replaced with hydrogen to form new compounds that may be more
mobile and toxic than the original compound before being mineralized."
o
Several of the project managers listed in Attachment 1 of the PRP's comments
(Field Applications of Bioremediation) were contacted to detennine the types
of soils that were effectively treated in-situ. None of the project managers
indicated that their project had successfully treated soils characterized by the
low-permeability of the Vandale Junkyard site soils. Most of the sites where
in-situ bioremediation was being performed were characterized by highly
permeable sandy soils. Several of the project managers were very skeptical
53
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regarding the ability of nutrients to migrate through the low-permeability clays
and provide effective treatment.
Since the selected remedy does not require on-site treatment of soils, this question is no
longer relevant.
~
4.
The PRPs commented that ex-situ bioremediation was inappropriately eliminated as a
potential treatment technology for site soils.
U.S. EPA Response: U.S. EPA eliminated ex-situ bioremediation as a potential treatment
technology for organic contaminants in soils during the FS based on the following reasons:
o
As stated in the FS and supported in the response to the preceding comment,
the high clay content of the site soils is expected to limit the effectiveness of
this technology.
o
As stated in the FS and supported in the response to the preceding comments,
the presence of both chlorinated and non-chlorinated organic compounds are
expected to complicate the bioremediation process.
Since the selected remedy does not require on-site treatment of soils, this question is no
longer relevant.
.5.
The PRPs commented that the FS failed to identify and evaluate in-situ
stabilization/ solidification as a treatment alternative for site soils.
U.S. EPA Response: Tables 2-8 and 2-9 in the FS include a discussion and evaluation of
treatment technologies for site soils. In-situ vitrification is an ~-:-situ stabilization technology.
In-situ stabilization/solidification involves mixing soils with a chemical reagent using a
backhoe, auger, or rotary filling device to provide stabilization/solidification of soil
contaminants. This technology was not addressed in the FS report. U.S. EPA believes that
implementation of this technology may be limited at the site for the following reasons:
o
In-situ mixing operations will be very difficult to implement and control along
the north slope.
o
The high clay con~nt of the site soils will complicate the mixing process and
volatilization of some organic compounds is likely to occur during mixing.
o
In-situ mixing operations are typically limited to the treatment of lagoon
sludge.
Since the selected remedy does not require on-site treatment of soils, this question is no
54
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longer relevant.
6.
The PRPs commented that the FS inappropriately restricted potential use of
stabilization/solidification to the treatment of inorganic contaminants in the site soils.
This technology may also be used to treat organic contaminants in soil.
U.S. EPA Response: The use of stabilization/solidification technologies to treat organic
contaminants in soil has some potential drawbacks or limitations which include:
o
Impediment or retardation of mixture setting/curing, particularly at high
concentrations of organic contaminants.
o
Volatilization of volatile organic compounds during mixing.
Since the selected remedy does not require on-site treatment of soils, this question is no
longer relevant.
7.
The PRPs commented that low temperature thermal desorption (LTID) is not
effective for treatment of P AHs and will not be effective for volatile organic
compounds (VOCs) in the soils at the Vandale Junkyard. The high clay content of
the site soils will limit the effectiveness of LTID.
u. S. EP A Response: References more recent than those used by the PRPs to support this
comment indicate that LTID is effective for treatment of PAHs. A U.S. EPA Engineering
Bulletin, "Thermal Desorption Treatment," from May 1991 (EPA/540/2-91/008) indicates
that removal efficiencies for PAHs are typically greater than 97%. More specifically, for
constituents of concern at the Vandale Junkyard site, the following removal efficiencies were
noted:
PAR Comoound
Removal Efficiencv (%)
Benzo(b )anthracene
Chrysene
Benzo(b)fluoranthene
Benzo(a)pyrene
> 97 to > 99.99
93.6 to > 99.8
82.3 to 97.9
98 to > 99.9
Results are provided for benzo(b )anthracene because tests were not performed for
benzo(a)anthracene. These removal efficiencies compare very favorably with removal
efficiencies for other technologies, including bioremediation (which had an average removal
rate of 87% according to the document referenced by the PRPs).
To further support the effectiveness of LTID for treatment of PAHs, a pilot scale test
performed by IT Environmental Programs, Inc. and IT Corporation in February 1991
(On-site Engineering Report for the Low-Temperature Thermal Desorption Pilot Scale Test
55
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on Contaminated Soil, Volume I, Contract No. 68-C9-0036, August 1991), indicated that
PAHs were effectively treated using LTID. The results from this pilot scale test are
presented below:
PAD Compound
Pre- Treatment
Concentrations (mg/kg)
Post-Treatment
Concentrations(m2/kg)
Benzo(a)anthracene
Chrysene
Benzo(b,k)fluoranthene
Benzo(a)pyrene
160; 150;210; 160; 160; 190
150; 140;200; 140; 150; 170
180; 130;220; 130; 130; 160
73;62; 120;64;65;76
all < 0.23
all < 0.120
all < 0.047
all < 0.110
Benzo(b)- and Benzo(k)fluoranthene were found to co-elute; therefore, a total amount is
given.
With respect to treatment of VOCs, the table used in the PRP comments to demonstrate
LTID's ineffectiveness shows an average soil bed temperature between 90°F and 115°F. It
is not surprising that treatment of VOCs was not achieved with these low temperatures. As
noted in the U.S. EPA Engineering Bulletin referenced above, LTID technology "heats
contaminated media between 2QO-l,OOO°F, driving off water and volatile contaminants". At
the higher temperatures, LTID has proven very effective in removing volatile organic
constituents (including halogenated compounds) from soil.
There is documented evidence that LTrD can effectively treat soils with a high clay content.
The U. S. EP A Engineering Bulletin referenced above indicated that P AH removal
efficiencies in excess of 99 % were typical for creosote contaminated clay soils. In addition,
L TID units operated by Chemical Waste Management have been demonstrated to
successfully treat very cohesive clays.
Since the selected remedy does not require on-site treatment of soils, this question is no
longer relevant.
8.
The PRPs commented that U.S. EP A has not properly developed the concept of
operable units and combined technologies at the Vandale JunkyaId site, which has
resulted in the improper elimination of potential cost-effective remedies.
U.S. EPA Re$P<)nse: The FS report divided the site into three distinct areas which include:
the North Slope, Active Area A, and Active Area B. The North Slope and the Active Areas
were evaluated for potential remedial actions separately in the FS report, consistent with the
"operable unit" approach. The applicable portions of the responses to Comments 1 and 2
also support this response.
9.
The PRPs commented that the rationale used to eliminate in-situ bioremediation of site
soils as a treatment alternative (high clay content and limited access to contaminants)
56
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::,.
should also have been used to eliminate in-situ bioremediation as a treatment option
for site seep secfuDents. Furthermore, the FS did not consider the adverse
environmental effects of the proposed sediment remediation activities. .
U.S. BFA Response: U.S. EPA believes that the contaminated sediment particles are not
present in a tightly bound soil matrix, as with the contaminated soil particles. The
contaminants in the sediment are therefore expected to be more accessible and amenable to
in-situ bioremediation. The proposed use of nutrients and aeration pumps are not expected to
adversely effect human health or the environment. The implementation of this treatment
approach would be carefully monitored and could be performed when the seep collection
areas have little or no standing water in them, thereby limiting the potential for suspension of
fme particles and eutrophication. It is important to note that only the seep sediments are
proposed for remediation, not the stream or tributary sediments.
10.
The PRPs commented that the short- and long-term impacts were not identified in the
evaluation of alternatives in the FS report. Furthermore, no specific short- or
long-term problems are identified and no specific control measures described.
U.S. BFA Response: The FS report does identify short- and long-term impacts for all of the
action alternatives as presented on pages 4-11, 4-12, 4-13, 4-24, 4-25, 4-32, 4-33, 441, 4A2,
443, 4-50, and 4-51. The long-term impacts discussed in the FS include the anticipated
magnitude of residual risks following treatment and the anticipated adequacy and reliability
of controls, including the potential for future contamin~l1t migration and attainment of site
cleanup goals. These issues are addressed and considered separately for each alternative.
The shott-term impacts discussed in the FS include the need for protection of site workers
and nearby residents from exposure to contaminants during remedial activities, collection of
surface water runoff, control of sediment transport, and the need for North Slope restoration.
A specific plan, including the use of engineering controls (i.e., spraying work areas to limit
dust generation and sediment control barriers to limit contaminant migration), personal
protective equipment for site workers, and restoration along the north slope are described for
each alternative as controls for anticipated short-term impacts.
11.
The PRPs expressed concern about several issues related to compliance with ARARs
for the remedial alternatives in the FS. These issues are as follows:
o
There is no assurance that the delisting of listed hazardous wastes found on
site (as proposed for Alternatives 3A, 3B, 4A, and 4B) will be successful.
o
There is no indication that remedial alternatives 3A or 4A will achieve MCLs
for groundwater.
o
Ohio's regulations regarding lead in particulate matter are not identified or
addressed.
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U.S. EPA Res.ponse: Th~ FS report clearly presents delisting as one viable option for
ensuring compliance with land disposal restrictions (LDRs) if treatment of soils is desired.
The other option is to obtain a treatability variance. Pages 4-22 and 4-23 of the FS report
present a detailed discussion and explanation of these options. At no point do these
discussions claim that delisting will definitely be successful, as the difficulty of achieving
delisting requirements for all contaminants was recognized. This is why the treatability
variance was included as another option. However, U.S. EPA has determined that the
selected remedy will not require soils treatment. This decision was made after further
consideration of site-specific information and the comments from the PRPs.
l-
The discussions regarding achieving ground water MCLs under each alternative in the FS
report state that the proposed remedies will promote compliance with MCLs. Removal of
the contaminant source is the mechanism for reducing contaminant concentrations in ground
water. This is expected to be accomplished in conjunction with capping, whereby limiting
the infIltration of water through impacted soils is expected to reduce contaminant
concentrations in the ground water. By removing or containing the source of ground water
contamination, it logically follows that (as stated in the FS report), the naturally-occurring
processes of adsorption, dilution, and biodegradation will reduce the concentrations of
contaminants in ground water over time, thereby promoting compliance with MCLs.
Ultimate compliance with MCLs or the more stringent hea1th-basedcleanup levels specified
in the ROD is not assured, and the ROD clearly acknowledges this.
With respect to lead in particulate matter issue, the PRPs provide no regulatory citation for
the Ohio regulations concerning lead in particulate matter. However, the FS report states
that work areas will be sprayed to limit fugitive emissions during excavation activities.
Furthermore, the FS indicates that the necessary air pollution control devices will be used to
control emissions on the incineration and/or thermal treatment units.
12.
The PRPs commented that aU. S. EP A demonstration of an incinerator unit treating
lead-containing soils encountered" extreme difficulty in meeting particulate emissions
requirements" .. .
U.S. EPA Res.ponse: The referenced U.S. EPA document used to support this comment
(EPA/540/5-88/002a, September 1980) is a report on the results of a single demonstration
test performed for a specific type of incinerator (the Shirco Infrared Incineration System) .
over the course of three days of testing. Based on the results from this test, it is certainly
not prudent or technically sound to conclude that the same problems will be encountered at
the Vandale JuDkyard. The FS report does not suggest that the Shirco Infrared Incineration
System will be used to treat site soils. The discussion of incineration treatment on pages
2-33 and 2-34 of th~. FS indicate that rotary kiln incineration is likely to be the most suitable
incineration system for the organic contaminants at the Vandale Junkyard. Furthermore, the
test results in the referenced U. S. EP A document indicated that particulate emission
requirements were achieved with the Shirco System following system maintenance and
modifications. The document also included suggestions for providing more effective
58
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.:'
treatment of emission gases (pages 94 and 94) using the ShiIco System. These suggestions
included:' .
o
The reorientation of spray and distribution nozzles/headers and the introduction
of additional or new scrubber internals to effect increased scrubber efficiency.
o
The replacement of the scrubber system with a more efficient vertical or wet
electrostatic precipitator design.
Another important factor to consider in response to this comment is that the lead
concentrations in the Vandale Junkyard site soils are substantially lower than the lead
concentrations in the soils treated in the referenced demonstration test. The highest detected
concentration of lead in the Vandale Junkyard soils was 720 mglkg whereas the
demonstration test soilS had lead concentrations between 4,400 and 5,900 mg/kg.
Finally, sj.nce the selected remedy does not require treatment of soils, this issue is no longer
relevant.
13.
The PRPs commented that the FS report does not adequately address the
implementability issues associated with proposed alternatives 3A and 4A.
U.S. BFA Response: The selected remedy does not require treatment of soils. However,
U.S. EPA has prepared the following responses for comments related to the implementability
issues associated with Alternatives 3A and 4A and the PRPs' proposed bioremediation
alternative.
Alternative 3A
One of the many advantages to the use of a rotary kiln to treat contamin~ted materials is its
capability of buming waste in any physical form and accept waste feed with little or no
preparation, thereby limiting the potential complications associated with materials h~nd1i"g
and feed preparation.
The BTU content is not a relevant factor in treating contaminated soil via thermal treatment
unless there are plans to use the contaminated soil as a fuel. There are no plans to burn the
Vandale site soils as a fuel.
Siting requirements and the community's reaction to the use of an on-site incinerator were
not addressed in the FS because, as stated in the Community Acceptance section (page 4-31),
community comments on site remediation issues were expected to be received during the
public comment period. This public comment period is now complete and based on the
comments received, there does not appear to be any public opposition specifically directed
towards incineration. The public has raised concerns and questions concerning why any type
of remediation needs to be performed at the Vandale Junkyard; and partly in response to this
59
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concern, U.S~ EPA has ~lected a remedy which does not require treatment of soils.

Incineration was selected in the ROD as an alternative treatment technology for the site only
in the event that LTI'D treatment was determined to be ineffective. As noted in the response
to comment 7 above, LTI'D was expected to be an effective treatment technology.
The implementation of excavation activities along the north slope, as discussed in the FS
report, is expected to be difficult. However, there is no evidence to support suggestions that
excavation cannot be accomplished. The FS report discusses the possible need for retaining
walls along the north slope to ensure slope stability during excavation activities (refer to the
response to Comment 14 below for more information).
Alternative 4A
The potential for high particulate loadings was only one factor used to eliminate LTID as a
treatment approach for site sediments. There is no conclusion drawn in the FS to indicate
the particulate loading will be an insurmountable problem. Another factor used to eliminate
LTID as a potential treatment option is the anticipated high moisture content of the
sediment.
With respect to excavation activities along the north slope, the response under Alternative 3A
above and the response to Comment 14 below should be referenced.
Bioremediation (PRP's Proposed Alternative)
The PRPs contend that a tractor with a disk and fenilizer attachment can be driven up and
down the north slope to provide for in-situ bioremediation of organic contaminants in the
soils. The steep grades along the north slope will simply make this impossible in some
locations. The PRPs have not indicated how this problem will be addressed. Furthermore,
as discussed in the response to comment 3 above, the breakdown products associated with the
treatment of chlorinated organics in the site soils may be more toxic and mobile than the
contaminants being treated, and the low-permeability of the site soils may make in-situ
bioremediation infeasible.
The PRPs contend that excavation of the upper 18 inches of soil along the North Slope will
not present the excavation implementation problems associated with Alternatives 3A and 4A.
U. S. EP A believes that the steep grades along the north slope will complicate the
maneuvering of heavy equipment alQng the north slope, regardless of the depth of
excavation.
14.
The PRPs commented that the FS fails to fully assess the technical feasibility of
excavation along the North Slope and the risk posed by excavation activities.
I'
U.S. EPA Response: The FS report is not intended to present detailed design requirements
60
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for implementation of excavation activities along the North Slope. As stated in the FS,
detailed review of slope conditions during the remedial design phase of the project will be
performed to establish the most appropriate approach for North Slope excavation.
Consideration of shoring to promote slope stability during excavation is discussed in the FS
report. Excavation along steep slopes is a proven engineering practice and the North Slope
of the Vandale Junkyard is not expected to present any limitations which will prevent
excavation.
The FS presents a discussion of the short-term risks posed by excavation and how these risks
can be controlled. As noted in the FS report, controlling the short-term health risks and the
potential cross-media impacts during excavation activities will be accomplished by:
o
Constructing a drainage trench along the top of the North Slope and a surface
water collection pond downgradient of the excavation area to collect runoff.
The drainage trench atop the slope will divert runoff away for the excavation
. area, thereby reducing the amount of surface water runoff collected
downgradient of the excavation. The level bench area along the north slope
provides a good location for collection pond construction.
o
Wetting the soils to limit dust generation during excavation activities and
employing sediment control barriers to control the migration of sediments and
associated contaminants.
o
Ensuring that site workers don appropriate PPE and are properly trained to
perform work which requires excavation and handling of potentially
contaminated soils.
15.
The PRPs commented that soil washing and soil vapor extraction (SVE) were not
given proper consideration as a treatment technology for site soils.
u. S. EP A Response: The FS report considered soil washing as a treatment technology and
eliminated the technology from further consideration during the initial screening process (see
Section 2.5) based on the high clay content of the site soils. A recent U.S. EPA publication
(Innovative Treatment Technologies, EPA/540/9-911002, October 1991) supports the
elimination of soil washing" as a treatment technology based on the clay in the site soils. The
reference document states: "this process (soil washing) is relatively ineffective on soils with
high silt and clay content. n
The FS report also considered SVE for treatment of site soils but eliminated this technology
from consideration based on the low permeability of the site soils (high clay content) and the
technology's inability to treat heavy metal contaminants in soil. The EP A publication
referenced above states that soils exhibiting low air permeability are difficult to treat with
SVE. SVE generally works best in well-drained soils and is only effective for treatment of
volatile organic compounds.
61
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Since the selected remedy does not require treatment of soils, concerns regarding the
effectiveness of these technologies are no longer relevant.
16.
The PRPs commented that excavated material from the North Slope area will be a
mixture of roots, rocks, and moist plastic soil, and stated that these materials cannot
be treated with the thermal desorption unit without pretreating the soils.
U.S. EPA Re$pOnse: The FS report includes a discussion of the need to segregate excavated
materials into separate piles of clean soils, contaminated soils, salvageable solid wastes,
unsalvageable solid wastes, and contaminated solid wastes under all alternative descriptions.
It was understood that the segregation process may be an expensive undertaking, which is
why the cost estimates for each alternative include several line items for segregation and
handling of excavated materials. Since the selected remedy does not require treatment of
soils, this concern is no longer relevant.
17.
The PRPs commented that site constraints, especially with respect to the North Slope, .
would require that areas of contamination must be more accurately defined prior to
initiating excavation activities.
U.S. EPA Re$pOnse: As discussed repeatedly in the FS report, the remedial design stage of
this project will include additional investigations which will more accurately define areas of
site contamination.
18.
The PRPs commented that the discussion on reducing toxicity, mobility, or volume
through treatment on page 4-42 of the FS does not note that the stabilization!
solidification process will result in an increase in the volume of the material being
treated. The PRPs also noted that the discussion of Alternative 2 on page 4-56
incorrectly states that Alternative 2 does not provide for treatment of CODtaminated
materials.
U.S. EPA Re$pOnse: U.S. EPA agrees. Page 4-42 of the FS should state that the
stabilization! solidification process will result in an increase in the volume of the material
being treated (as was stated on page 4-24 of the FS and also noted on page vn -5 of
eAppendix VII). The discussion of Alternative 2 on page 4-56 should note that off-site
treatment and disposal of drommed materials and other wastes which are unsuitable for on-
site containment and bioremediation of sediments are proposed under Alternative 2. Natural
degradation and attenuation of constituents of concem is not considered a treatment
technology .
COMMENTS ON THE COST AND VOLUME ESTIMATES PRESENTED IN THE
FEASmD.JTY STIJDY
/)
1.
The PRPs commented that the FS is flawed in the estimation of the areal extent and
62
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Ii
volume of contaminated soils at the site.
u.s. EPA Response: U.S. EPA has conceded that available site infonnation is not sufficient
for accurate delineation of the areal extent and volume of contaminated soils at the site. The
FS report repeatedly states that .the estimates are not expected to be highly accurate, and
describes how additional sampling.is proposed during the remedial design phase of the
project to better delineate areas which will require remediation. The FS report states that the
estimates provided are conservative and will require further refmement. All available
infonnation was used to develop the estimates in the FS report, including available analytical
results, historical disposal practices, and visual observations of disposed waste materials.
u.s. EPA believes that this approach is reasonable because it did not hinder the selection of
a remedial action for the site-.
With respect to the north slope area, it is important to note that although Figure 2-1 shows
the entire nonh slope as potentially contaminated (9,000 square yards), the figure also notes
that only 30 % of the north slope is expected to require excavation. Furthermore, as noted in
Appendix VI of the FS repon, only 50% of the excavated material from the north slope is
expected to be contaminated soil.
The PRPs have expressed disagreement with the area of contamination delineated in the FS
and state that "a more valid area of contamination is approximately 71,000 square feet ...
only 26% of the area" identified in the FS. A close review of the contaminated soil areas in
the FS report indicates that the FS has estimated an area of soil contamination of
approximately 163,300 square feet, which .indicates that the PRP's estimate is actually 43 %
of the area identified in the FS.
The response to Remedial Investigation Report Comment 1. should also be referenced for
additional infonnation related to the estimation of the areal extent and volume of
contaminated soils at the site.
2.
The PRPs commented that the estimated time required to implement Alternative 3A is
too short to be realistic.
u.s. EPA Response: U.S. EPA believes that this statement stems from the PRP's apparent
miscalculation of the volume of soils contaminated with organic constituents. Appendix VI
indicated the total volume of contaminated soils at the site is estimated to ,be 33,600 cubic
yards. However, as shown in Figure 2-1 and clearly noted on page W-4 of Appendix vn,
only 17,600 cubic yards of soil are expected to require treatment for organic contaminants
(i.e., incineration under the Alternative 3A scenario). In addition to the organic-
contaminated soils, an estimated additional 1 ,400 cubic yards of contaminated solid waste
material and liquid waste (i.e., runoff) may require treatment, resulting in a total estimated
. volume of 19,000'cubic yards of organic-contaminated materials to be treated via incineration
under Alternative 3A. Item IV-B in Table 4-2 indicates that the 19,000 cubic yards will
consist of organic-contaminated soils, contaminated solid waste, and liquid waste.
63
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Based on the assumptions made on page 7-21 of the PRPs comment document, the time
required to design and implement Alternative 3A would be approximately 22 months,
consistent with the FS estimate of 18 to 24 months.
3.
The PRPs commented that the cost estimates in the FS used incorrect volumes for soil
treatment.
U.S. EPA Response: As discussed in the response to Comment 2 above, the volumes used
in the FS cost tables are correct. It appears that the PRPs incorrectly detemrined that all of
the impacted soils at the site will require treatment for organic contaminants.
4.
The PRPs commented that the FS report does not include a sensitivity analysis.
Given the limited site information regarding the areal extent and volume of impacted
site soils, a cost sensitivity analysis is considered appropriate.
U.S. EPA Response: The information provided by the cost sensitivity analysis performed by
the PRPs is interesting but not persuasive. If the volume of contaminated soil at the site
were to decrease substantially below the estimates presented in the FS, it logically follows
that the differences in the costs between all alternatives (including on-site and off-site
disposal alternatives) will decrease. The lack of soils treatment in the selected remedy makes
this question inelevant, as U.S. EPA has concluded that containment of soils is most cost-
effective.
5.
The PRPs commented that the cost associated with the delisting of treated soils and
waste was apparently overlooked in the cost estimates for Alternatives 3B and 4B.
U.S. EPA Response: U.S. EPA believes that the 20 percent contingency cost incoxporated
into these cost estimates would be more than adequate to cover the delisting expenses and
other cost elements which were not itemized in the cost estimate. The itemized cost elements
in FS Tables 4-1 through 4-5 are expected to include the significant cost items associated
with the remedial alternatives but are not intended to represent a detailed list of every cost
item which may be associated with the implementation of each alternative. The 20 percent
contingency is included with each cost estimate to account for these additional costs.
6.
The PRPs commented that a simplified approach may have been used in evaluating
the available capacity of the site for placement of soils and waste, stating that
approximately one-fourth of the Cap "A" area is unavailable due to the severe slopes
and that variations in elevation at the Cap "B" location make capping impractical.
U.S. BFA Re$pOnse: The FS report provides a preliminary evaluation of a theoretical cap
design in order to "provide some insight concerning the relationship between the depth of
contaminated soils placed in the active site areas prior to capping and the slope of the cap
and cover system". The preliminary calculations in the FS provide this "insight". The FS
report explicitly states that cap construction would require clearing and grading of the
64
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L.
proposed cap.areas (to eliminate variations in elevation) prior to placement of contaminated
materials and that the optimum specifications of the cap system will be established during
. remedial design. The FS report repeatedly indicates that the proposed areas of excavation
and impacted soils will require further delineation during remedial design. Since the selected
remedy does not require excavation in the active areas of the site or treatment of soils, it is
unlikely that, based on further delineation of contaminated areas during remedial design, the
proposed cap areas will not be able to accommodate the actual quantity of excavated soil and
waste materials. Obviously, if the on-site areas cannot accommodate placement of treated
soils, other options will require consideration.
65
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q
APPENDIX B
ADMINISTRATIVE RECORD INDEX
-------
...
~~c.
.---
~AiE
----
iI), ,7 :,31
z
}:,":-31
3
:J ;, .;'~I ~ ~
~
'ji, ~&,.,3
5
-. ." ..
I~. . ~", OJ
&
.:;, ~1)/&3
..
,
041~i'04
8
05/;..,84
',0' Ii;. ,4
10
01/15,8)
11
05 :;U7
12
07i~9/87
13
I~a, 05/07
14
u8131i87
~5
o ~/liO/ai
111
09'01;07
U.s. EPA ADHINISiRATIVE RECORD INDEX
~:r;;.;:R
------
~oraan. ?. Q~PA
)c~~rnstheiler. K..
a.::. Ii.;oari.;h
:~vl~~Y & Environ.e-
~It
ORIGINAL
VANDALE JUNKYARD SITE
MARIETTA. OHIO
0c3/2S/92
RECIP!ENT
---------
---------
u.s. ,p:,
uur.an. ~.. vEPA
1.1.5. E?A
~e~~s. G., Ecolu~Y & U.5. ~PA
t~vHon.ent
bur Ufo. P. r.€PA
u . S. EPA
DettiaDlI. E.. HoLoiska.;,.. :U.
E';,jloqy & ,nvironle- ,PA
n',
Gviaa~. ".. OHA
:.~:II hili
~,jr.ad. P.. OEP~
~onall, P.. or
j~ciikeY. ".. ~EPA
!leierer. R..
ClilG;!Che.
Lu;ton j., U.S. E~A
U.S. EPA
Eli" GrvuP
ER" Grouo
E!ill Qrouo
u.~. m.
U.S. EPA
U.S. EPA
u.s. EPA
Addressees
PUblic
ihe Vandale PRP
\irou~
ille ~andale PRP
Gr,jijO
ill, Vandile PRP
Group
iIT~EfDE5~ftIPjION
-----------------
----------------.
Praliainary AsseSSlent
~P TOli~ity i~st ~esutts & DescriPtion of aFG
Oruis vn Site
jite LnS~ecti,jn ;~g~rt
C~ver & Prelilinary Assess;~nt
~ite Inspection Reoort
Inspecti~n of -~n Oale Junkyard
5ite ~n!Oectlon Report
Findi aela~ial Action "aster Plan (RA"P)
5ite Inspection Report
Prelilinary AsseSSlent
COlouChel Laboratories' Quality Assurance
Plu
Cover Letter & ~dlinistrative Order on
Consent for RIfFS
NEWS ~ElEASE: U.S. EPA, Ohio Seek C~II'Dt on
vandal, Junk)ard Investigation
Health & Safety Plan
~e.eoial Investigation Work Pl.t
Rel.dial Investigation; Quality AssuraRct
Project Plan
PA6ES
-----
5
14
4
14
21
15
127
14
s
89
39
2
73
82
165
-------
DOC I  DAfE AUfijOR ~ECIPIEMT :iiLE/~E;:;rPTlvH PAGES
---- ---- ------ ....-----..- ------------.-.-- :sa::
--------- -----------------
. ~ 09/,5/07 Barrioall. r.. U.S. 800.I.r. J.. ~Ier. Effect.ie ~ate uf Consent Ord.r 6
II
  ~~ . Enrle. G.. Cyanalid & Hoadl.y.  
  ~~PA G.. UH[STS  
~a iO/07ia7 ;Jh'. 0.. ER"-"idM'- aarriball. T.. U.S. ftodification to RI WorlDlan 2
  ~t [PA  
P vS,OC, ;0 :acobs Engineering U.S. ~PA Fi~al COilunily Relations Plan 29
  GruUD   
20 05, lis/'aa Kl~inrath. A.. U.S. :odaler. J.. ADProvai of ~I.nd.d RI Workplan 2
  [PA A..rican CYana.i~  
d 0o/~$"8a Ji:,.. A.. J.S. EPA cruce. ~.. U.5. ~rA Partial ~DDro~al of Quality Assurance Proj.ct 
    Plan for RI/FS (all activities aDProv.d 
    elcept saiDlin; & analysis of do.estic Mell 
    SaiD les ) 
,2 0dI jOt a8 Alca.o. T.. J.S. EPA Bodner. l.. Hotice of RI. Phase I Work Plan APproval 
   Alerican Cyana.id  
~3 09/00i03 J.S. EPA j)uDiic FACT SHEET: Vandale luakyard Site 6
24 .1I18,oa u.~. Public Health  Preli.inary Health Assess.ent 4
  Service   
25 04;00'89 U.S. EPA I'ublic Progress Report on the vandlle JUlkYlrd 2
    Superfund Site
" 04/11/89 Jc.~es. v.. u.~. EPA Hiedergang, H.. U.S. APproval of ~~PP. ~dd.ndu. 11 for Salpline' 223
   EPA Analysis of ResiJential well Wlter Salples 
    (QAPP attached) 
D .Q/31190 ftetcalf & Eddy U.S. EPA RI Work Plan Oocu.ents Package 418
:8 12/2"90 ~orris, K.. "etcalf Karobka, L.. U.S. CRL SalPle Data Reports, Traffic Reports' 9S
  . Eaoy EPA Chlin of Custody Reports for water, sedi.e.t 
    . soil 
Z9 01/23:n "orris. K.. "etcalf Korobka, L.. U.S. Revised CRl Salple Olta Reports' Corrected U8
  . Eddy EPA Origi..l Trlffic R.ports . ChaiR of Custody 
    Recoros 
30 ~1/31/71 ~orris. K.. "et~llf ftinnich, L, Sa.ple Sa.ple Oatl R.ports, OrieiDll Trlffic Reports 21
  & Eddy "I..".e.t Office , Corrected ChaiD of Custody Records 
31 i)4/25191 Hunkler. P., OEPA Schlitt, L., U.S. List of Ohio AAARs for Site 31
   EPA  
32 11/19/91 Schaitt. L.. U.S. HuDkler. L., Letter Providile Copies of Drift RI Report 1
  ,PA OEPA-OERR dated 11/18/91 
   2  
-------
~~" u,:,rc: AUTHOR ~mPIEHT riTLE/DESCRI~TIO" PAGES
--... ---- ------ --------- ----------------- ::u:
--------- -----------------
:i3 J2I18/92 lie tea If , Eddy U.S. EPA Final RI Recort 430
3~ 02, laIn ~etealf & Eddy U.S. EPA rinal RI Report: Acpendices 750
D   Schlitt. L., Ohio EPA Acoroval of Finil Report 
35 02/27/92 Blair. 8., OEPA 
3b ,j5, ~b' 12 Senlin. L.. U.S. Stello, II.. ~over Letter to Draft FS dated 5/4/92 1
  EPA OEPA-DERR   
37 Ob/oom U.S. EPA Public FACT SHEET; ~esuits Of Reledial Investigation 6
38 Oa/OO/12 U.S. EPA Public FACT SHEET: EPA KecoII.nds Cl.anup Plan 12
j~ 08/121 12 :letealf' Eddy U.S. EPA Final FS ReDort 342
40 08121/n Stelio.!'I. OEPA Schlitt. L. U.S. EPA Concurrance wit~ Final PrODos.d Plan & Final 
    FS  
41 001 V in U.S. EPA  Pro~osed Plan  24
3
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   u.s. EPA ADMINISTRATIVE RECORD  
    VANDALE JUNKYARD SITE ,;~ 
    MARIETTA~ OHIO   
     UPDATE #1    
     09/23/93    
 DOCI DATE AUTHOR RECIPIENT  TITLE/DESCRIPTION  PA6ES
L). ...--- ---- ==== =========  -----------------  
 -----------------  ----
  08/26/92 SChlitt, L., U.S. Clirt. R.,  Letter ./Copies of the FS and PrODosed Plin 
   EPA Environlental for Revie. for the Public COllent Period  
    !litigition 6roup     
 2 08/26/92 !larietta A.!I. Public   Public Notice Announcing the Public COllent 1
       Period on the Feasibility Study and Proposed 
       Plan    
 3 09/03/92 Clark, R., SChlitt, L.. U.S. Letter re: Septe.ber 11, 1992 "eeting and  
   Environlental EPA   RIQuest for an Extension of the Public  
   !litigation 6roup    COllent Period  
 4 09/09/92 Schaitt, L., U.S. Clark, R.,  Letter re: Approval for Extension of the  2
   EPA Environlental Public COllent Period to October 29, 1992  
    !litigation 6roup     
 S 09/09/92 !larieUa A.II. Public   Public Notice Announcing an Extension of the 1
       Public Co..ent Period on the Feisibility  
       Study and Proposed Plan  
 6 09/10/92 Booth-Bennett, S. U.S. EPA  Transcript of Public IIlfting Held Septelber 85
       10, 1992 re: thl Proposld Plan  
 7 09/13/92 Barnes, T. and Allin, C., U.S. EPA Citizens' COI.ents on the Proposed Plan  2
   SImes, P.        
 8 09/16192 Burke, H., Schaitt, L., U.S. Letter ind Inforlation re: Use of In Situ  7
   Roctinghal Inc. EPA   Vitrification Technology  
 9 10/09/92 Hoadley, 6., Mise' SChlitt, L., U.S. Letter Requesting an Additional 30 Days to 
   IIarsac EPA   Prepare Mritten COllents for the Public  
       eollent Period  
 10 10/09/92 Brant, T., Croler, Allen, C., U.S. EPA Letter Requesting an Extension of the Publj~ 
   Eaglesfield . IIaher    COIIent Period for the Proposed Reledial  
       Action P I an   
 11 10/10/92 Hardy, II., Tholpson, SChlitt, L., U.S. Letter Requesting an Additional E~tension of. 2
   Hine and Flory EPA   thl Public COlaent Period  
 12 10/14192 . Clark, R., SChlitt, L., U.S. Letter Requesting an Additional 30 Day  
   Environlental EPA   Extension of the Public Co..ent Period  
   !litigation 6roup        
 13 10/20/92 Clart, R., SChlitt, L., U.S. Letter Clarifying R~asons for Requesting in 2
   Environlental EPA ind Stello, II., Additional Extension of the Public COlaent 
   !litigation 6roup OhioEPA  Period    
-------
DOCI DATE AUTHOR RECIPIENT TITLE/DESCRIPTION PAGES
---- ---- ------ ========= ----------------- 
----------------- -----
14 10/21/92 Cbrt. R.. Sch.itt. l.. U.S. Follo'-UD letter to the October 14. 1992 Let- 
  Environ.ental EPA and Stello. "., ter ReQuestlng an Additional 30 Day ExtenSlon 
  . "i tigation Group OhioEPA of the Public Co..ent Period 
15 10/22/92 Sch.itt, l., U.S. Clart, R., letter Approving an Additional 15 Days for 2
  EPA Environlt!ntal the Public Co..ent Perlod Extendlng It to 
   "i tigation Group Nove.ber 13, 1992 
16 10/29/92 "arietta A.". Public Public Notice Announcing the Second Extenslon 
    of the Public Co..ent Period on the 
    . Feasibility Stu~y and Proposed Plan 
17 11/10/92 Hardy, "., ThOlpson, Allen, C., U.S. EPA Yandale Juntyard Steering Co..ittee's 7
  Hine and Flory  Requested Supple.ent to the Ad.inistrative 
    Record 
18 11/12/92 Ellis, "., Cro.er, Sch.itt, l., U.S. a.F. Goodrich Co.pany's Co..ents on the RI/FS 153
  Eaglesfield . "aher EPA, et a!. and the Proposed Re.edial Action Plan 
19 11/12/92 Cbrt, R., Sch.itt. l., U.S. Yanda Ie Juntyard Steering Co..ittee's 502
  Environ.ental EPA COI.ents on the Rl/FS and the Proposed Plan 
  "itigation Group   
20 11/13/92 Hardy, "., Tho.pson, Allen, C., U.S. EPA letter ./Copies of Ite.s "entioned in the 1202
  Hine and Flory  Yanda Ie Junkyard Steering COI.ittee's 
    Nove.ber 10, 1992 Request to Supple.ent the 
    Ad.inistrative Record 
21 12103/92 Carpenter, E., Allen, C., U.S. EPA Replace.ent Copy of B.F. 600drich Co.pany's 163
  CrOler, Eaglesfield  Nove.ber 13, 1993 Public CDllents 
  . !liher   
22 01128/93 "etcalf' Eddy Sch.itt, l., U.S. Errata Sheet for the Final Feasibility Study 2
   EPA  
2
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t>
~
APPENDIXC
STATE CONCURRENCE LETTER
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aiDEPL\
State of Ohio Environmental Protection Agency
P.O. Box 1049, 1800 WaterMark Dr.
Columbus, Ohio 43266-0149
(614) 644-3020
FAX (614) 644.2329
George V. Voinovich
Governor
.>
March 31, 1994
Mr. Valdas V. Adamkus
Regional Administrator
United states Environmental
Region V
77 West Jackson Boulevard
Chicago, IL 60604-3590
Protection Agency
Dear Mr. Adamkus:
The Ohio Environmental Protection Agency has reviewed the Record of
Decision (ROD) for the Vandale Junkyard Superfund site near
Marietta, Washington county, Ohio. Ohio EPA concurs with the
selected remedial alternative for this site, Alternative 2. The
selected remedy includes the following major components:
@ Primed on recycted ~
EPA 1613 (1/91)
*
Ground water restoration by source control, removal, and
containment, and natural attenuation.
*
Consolidation of contaminated site soils and
unsalvageable solid wastes, followed by construction of
a RCRA subtitle C cap.

Off-site treatment and/or disposal of drummed materials,
~ncluding liquid and solid industrial wastes and sludges
and other wastes, especially hazardous wastes. Soils
visibly contaminated with industrial wastes will also be
taken off-site for treatment and/or disposal.
*
*
In-situ bioremediation of organic contaminants in north
slope seep sediments.
*
Ground water, surface water, and sediment monitoring to
confirm the expeditious attainment of cleanup levels.
*
Institutional controls, including deed restrictions and
fencing, to prevent installation of drinking water wells
in contaminated ground water while cleanup levels are
being achieved, and to prevent dis~~rbance of capped
areas.
*
Operation and maintenance requirements
mowing, inspection and repair.
including cap
-------
Valdas V. Adamkus
Page 2
The estimated total net present worth cost fer the selec~ed remedy
is $4,564,880, which includes $3,709,650 for capital costs and
$855,230 for operation and maintenance costs.
The ROD specifies that if monitoring indicates that contaminant
levels in ground water, surface water, and sediment are not
diminishing sufficiently to achieve cleanup levels in a reasonable
timeframe, additional work may be required. Further, if the
selected remedy fails to demonstrate expeditious progress toward
meeting ground water cleanup levels at any or all of the monitoring
points, contingency measures such as additional source removal
activities or limited ground water extraction and treatment will be
considered, where feasible.
The ROD does not set forth clear criteria by which to make the
determination of what is a reasonable timeframe to achieve cleanup
levels. However, the ROD does indicate that information to be
obtained in remedial design and remedial action will affect this
determination. The ROD further indicates that reasonable
timeframes for assessing expeditious ground water attenuation will
be developed during remedial design, based in part on additional
ground water information to be collected. The effectiveness of the
selected ground water remedy will be further evaluated at the
required 5-year review period.
Ohio EPA .believes that it is very important that remedial design
include development of clear criteria and procedures for assessing
whether cleanup levels are being expeditiously achieved. Methods
for interpreting data collected over time and supporting rationale,
and actions based on those interpretations, should be fully defined
in the remedial design. Ohio EPA believes that the selected remedy
provides the best balance among the alternatives and. that, in
combination with the criteria and procedures to be defined in
remedial design, provides the best response to the conditions at
the Vandale Junkyard site.
Si7~ 0 ///7iaz~
D~ltfiZZ(~/~

Ohio Environmental prrze ion Agency

Distribution: !

Jan Carlson, Acting ief, DERR Mark Stello, DERR, SEDO
Jenifer Kwasni~wski, OEPA, DERR Fran Kovac, OEPA, Legal
stuart Hersh, u.s. EPA, ORC Larry Schmitt, u.S. EPA
-------
L>
APPENDIX D
FEDERAL ARARS
-------
.,
'AIlI IV-A
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-------
'AIlE I"A (continued)
SELEC'ED CIEMltAl-SPEClfIC PO'EI'IAL APPLltAllE II IELEV'" AID APPIOPIIA'E IEIUIIEME." .. 'EDERAl IDVEIlNEIt
aM ...t.r ou.I It, Crlterl.
for 'rottetlon of Iu88n "e.lth
CVA Alllal...t llettr ...tIty Crlt.rl.
for 'rottetlart of ~tfc Ltf. bI

'r.sh-ter
"cut.,Chrartic
(..'1)
'eder.I ...n-.&
't"reI (c.lcul.ted)
(..,k,)
U.ter end
'I.h I...tlon
(8111'1)
".h ConsUliptlan
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(.., )
"nt I~
"re...lc
ler,II'.
II.CZ-.th,Ih.a,I)phth.t.t.
c...l.
Chr.l.
COfJPIr
e,en I de
Chlorofo...
1,l'DlchlorOithene
I,Z-Dlchloroethene
Iron
L.ed
Mlrc...,
Ilchl
S.t...l.
Sit",
,.t,echlorOithene
'h.I t I.
1,1.1",IchlorOithene
,...1.
Vlnrl Chloride
Iinc
1.4 II 10'OZ
I.Z II 10-06
7.7 II 10-06
1.8 II lO.OJ
1.6 II 10-OZ
S.] II 10+01
I.S
0.7'0
S.7 II 10-OJ
5.7 II 10-OS
0.7'0
4.)
'.8 II to.OS
I.J II 10-04
5.9 II 10-OJ
0.17
6.7 . 10tOZ
9.0.,1.6'
0.85.,4.8 II 10'OZ'
O.I,.,S.J II 10-OJ.
8.0 II 10+04
0.l4
,., II 10-0).'1.1 II 10. OJ.
1.",O.llO.
1.8 II 10-OZ.,I.Z II 10'OZ+
Z.Z II 10.OZ,5.Z II 10-0'
,1.Z4
1t.6.' ..
1t.6" --
I.OU+
S.'I . 10-OZ.
l.6 II 10-OZ
5.45 II 10+01
l.Z . IO+OZ
0.47
S.Z II 10.OJ
1.4 II 10tOl
S.o II 10-OZ
1.4 II 10.04
0.61
0.10
0.105
8.0 II 10-04
1.7 II 10-OJ
).1
8.Z II 10-OZ.,J.Z II 10-0).
2.4 . .O-O),I.Z II 10-05
1.4+'0."+
2.0 II 10'02'5.0 II 10-OJ
4.1 II 10-0).'1.1 II 10-04+
5.28.,0.84.
1.4'0.04
].06 . 10+02
1.59 II 10+01.
6.0 . 10-0)
1.5 II lO.1M
4.6
6.8
65
8.85 II 10-0'
6.] II 10-0)
1.7 II IO+OZ
1.0 . 10. OJ
.5~
0.1'.'0. tI+
S.] II 10+01+
feder.I ...t., ..I It, c,lterl. (FUIIC) .,. not I...", enforc..l. .t"reII, bit er. potentl.", r.lenn' end ......-1.,. ,. aiel. ecll-. CEIUA

IUtCd)(IUI)(t) r..,I," c_Idtr.llon of four fector. "'... .t.,.I"'.. .......... fUQC .n ,.,.V'", end IfIPFCIPI'I.t.s t) the ..I..ted or potentl.I we of the

....fec. or Ircant -tv. I) ,he _1,-...1 8ed1. .ffected. ]) the.......... for "'Ich 8Uth c,lterl. ...,. dewlaped. 8hd 4) the I.t"t Infof88t1on .".It.I..

. l_t GbMrwd Effec' lewl

. c.lcul.llon of .edl--t .t"'" I. ,,"Idid In ......-Ia III of 'hi. report.

. I.,dnn. ~""'t c,lterl. (tOO .." ",ed): refer to epeelflc c,lttri. --t. for ..,.11- to c.lcul.t. crlttrl. _ed on othe, ...t" he...... vat""

lourn.: U.I. E'A, Off In of veter Ink I u.t., t.tlone end ..lth Advl.o .. 10velliJtr. 1991 8hd U.I. E'A t, EPA "0"-86-001,
..." '''' C5. ,.,.1 Iq"'" 4J66~). ... 0 . . er ,Ienderdt lIIUI..,on to 18t.II.\ . ~r c r u. or r or \, 'o.lc 'oUuten"
.te...." to Irl... "" It.t" Into COIIIptlenc. .lth Stetlart JOJCC)(lUI). 'rapoeM lul". loveIItJtr, '991 (56 feder.I 1..I.ter 58420).
bI
~
-------
tAilE IV . .
_lUtn lOCAfl08-IPrClfIC POTE.UAl APPUCAlLr . IlEUV.' AID """'IA'I 1lE8I1ft.1f1 .,
loutlan
IlCJIlrl8tnt
'r.recf".lto
Clt.tlan
Within too-,..r floodpl.ln
fecit It, 811St be desIgned
c_trutted, oper.ted and
.Int.lned to .vold ...haut
lelA h.r.rd0u8 ...te: tr..t-.nt
.tor..., or dl.pH.I
'0 Cfl Z64.18(b)
Within fioodPI.ln bl
ktlan to .vold 8dwr.. .ffect.,
.Inl.lro potent 1.1 h.,., r..tor.
and pr..erv. natur.I and
beneflcl.I veh...
Actlan thet Mill occur In .
floodPI.ln, 1.0., IOIIJI.. end
r.I.tlvely fl.t .r... adjoining
Inlend end coa.t.I ..t.r. end
other flood pr- .r...
'rotectlon .f fioodPI.lne bl
(40 Cf. 6, ~I. A):
"III end ""dllf. Coordlnetlon
Act (16 use 661 U...!!!P: '0 CII
6.30Z
-------
111lE IV - C
.lIt1" "CU..-SHtIFlC "fI."M. APPUCAllE .. IfLEVAl1 .. ......IAff IfClUI"'." .,
"ettona bI
1.I,"",t
',e,.I.It.. for Appllc8bllltr cl df
Clt.tton
CIfIIII",
CSee .1.0 CI08ure with u..t.
In ,Iece fo' 8ddltlonal
...ocleted ,.I'~tl)
Ptec-t of I cep - Ce.,..
ctOll", . 1""1". 0' clOII", . lurfece
I.......,.t or ..te pll. II . IIndtlli.
or .1."., _lion) ,.1,.. . cover
..1..-1 end conatructed to:
ICIA hl.I"" .It. pieced .t lit. .fter tIt.
,UKtt.. dlte of the ,.I,_tl, or .P'8C-'
of hl.lrdUut ..te Into enother unit Mill ..,.
,.Ir_tl IIfIPllc8bl. ...... .... .Ite II bel",
covered with e Clp for the purpoe. of I_I", It
behind Ifter the r~ I. cClllpIeteel. CWl",
Mlthout .ur:h pl__t MI" not ..'e
r.lr_tl Wi Ic8bl.. dI
. ',awldt lont-tena .Inl.l.ltion of
.I,r.tlon of"Iqui. through the
C..... .....;
. 'unction Mlth .Inl- ..lntetWlCe;
. ',c.-t. ..1.... end .Inl."e or-Ion
or ...1.. of the caver;
. Acc-*te ..UI I", end ..Iclence .0
th.t the caver" Inteerlt, I.
..Intelntel; end
. 118¥8'''''''''' It, I... then or -.el
to the """",I"t, of .. boU-
linor ey8t- or ..tur.I ""'0'"
pr888ftt.
40 Cfl Z64.ZZ8(8)
C Sur f -~ IlIIpIIUIIdIIent.)
40 Cfl Z64.ZSI(b) (V..t.
,,,..)
40 Cfl Z64.)10(8)
(lendtl ".)
Currentl, onl, leU. tUA, end .. ,...,I,......tl ere Inchalld. "eMillonai 8Ctton-8flKItlc ,.Ir_t. MI" be ecMed .1 8ddltlonal .tltutu .r. _I,.ed.
.,
action lit.......".. 're8lC11 '.,.,rd I"... "1986 R.ord of ..I.hln "'"'" I....,t. ....." 1981, 11..1"" lit. Control DI.lllon. I'A.
""en thHI ,..,Iotlona
bl
cl
lecJll,_to .... ...... pr..eeI but net prCl8lI..teel for el, It,Ipplne, hyIIrld ciOlure. "I collectl.. end .I.ce"-- unit t,..t8Mt.
ere pr-..I..tod. ...., MI" be Inc'uded In the ..t,hl.
dI
S- 8Ctian-IpKI"c ,.I,_tl ".tld .., be rel.".,.t end lfIP"aprllte own It ICIA dtflnlteona of .to,.... dlepoe.I. or ho.ordUu8 ..te .re not _t. or If 'the
..te .t the .It. I. .1."., to but not ldentltl8bl. .. . ICIA ho.,," _te. lee dlepter Z for Infonaltl.. .. ,.,.....t end lfIP"aprllto leu 'ecJll,_U.
-------
Aetl- bI
'AIlE IV . C
-ncuo ACfllII-mCUIC "If'flAl APPlICAlll ..IIUWAI' .. """IA'III8II_'" .,
I...I,-.t
".,...,I.lt.. for Appl le"'II It, cl d1
C8I'I»I". (eantl....)
Clt.tlan
CIOIIr. ..Ith 10 'Oit-CIOIur.
C.re (e..., Cleen CIOIur.)
dJ
'II.In.tl free 'Iqul~, .t...I.III ....t..
"fori cWl.. C,,'eel llIIpCUdIentl).
l"t,Ict poet'doeurl lIIe of prope,t, ..
neee..a" to prnent ..... to the cCWIr.
'rnent run-an ... ~-off f.-- d88tt1".
c...,.,.
'retect ... .Int.ln aurwyed e.ne.,te
UIId t. loc.tl Melte cIIII CI...'IIII,
-tl ,II...
Cene,.1 perf--.e. at"rct '.....1 r..
.II.In.tlan .f need for fur the,
.IntlnMCl ... cant,ol: 1".In.tlan of
poet-cIOIur. eec8pl of h....... ....te,
........ c_tltuent.. I e8dl8t e.
cant_ln.tld ".,-off, or hI.Ir'" 111"1
-.....Itlan procb:t..
AfIIIllc"'II to I"'-".ed WIlt cantalnl".
h'.lrd0u8 ..tl. «II AfIIIllcabll to .ClA hI.I'"
..t. (lI.ted or chereeterl.tlc) ,Ieeld .t lit.
aft., thl .ffectlve dati of the raqul'l8ent., or
,'Ked Into _the, Wilt. lot 81'1»lIc"'I. to
_terl.I tr.atld, .torld, or dl....... ani,
befo,. tho Iffectlve dati 0' the ,..II,-.tl,
or If t,..ted In-.ltu, or c_oll~tld .Ithln
.,.. of cant_ln.tlan. 0..1"" for deenup
th.t ..... not ,...1'1 I..-tl" -.II..II.t.
D"11fted for dl", to heeUh ..... It"""'.
40 CFI Z64.ZZlCa)
40 CF' Z64.117Cc)
40 CF' Z64.ZZ8Cb)
40 CF' Z64.S10Cb)
40 CFI Z64.JI0Cb)
40 CF' 164.111
40 CFI Z64.111
40 CFI 164.171
40 CFI 164.197
40 CFI Z64.Z88Co)Ct) ...
40 CFI Z64.Z58
t- _tlan-epeelflc ,equl,-... lI.tld -, lie '11."ent ... ...".,llt. I¥8n If KIA -flnltl- of .tor..., III...al, or hll"'" ....t. 1'1 not .t, or If tfle
..tl .t .... alt. I. 11.11., t. IIut not I~IfI"'I. .. . ICiA hl.I"" Melt.. ...~., Z for InflrMtian an '11.".t ... ...".,I.t. leu 'equl,-.ta.
11.....1 ., dleant_ln.tlon 0' ..,I--"t,
Itrue......, ... 801Ia.
"" ....1, to ..facl IlIIpIIIUftdaantl ... cant.l....
or tn . 1M" ... h...,... -tl ....1"", ...
to c.t_ln.tld ..II, Includl.. -II f,.
drlClll"8 ., 8011 IIIlturllled In .... ceur.. .f
drllll"8 ., oc..tlon, ... ,.turnld to I"'.
t...1 .. dlcent.ln.tlon of .18
,..1"", C81t.ln.tld cant.IMlnt .,et.
CD"J I -II. C...., II",", dl'..),
cant.I..tld ""'".~ ... .trur t.\!.. end
...I.-nt C81t-I..tld ..I'" ..tl ...
-------
Actl- bl
,., IV - C (conti.....)
IfUCflD ACflOI-IPIClflC NflllIM. APfIUCAllf .. .UV.' Ale """IA" ...1..1" .,
...,1 r.-nt
'r.r..".It.. f.. Aflpllcablt Ity cl dI
Cltot'on
Cloeuro "It II 10 'oat-Cloeuro
(contInued)
Cloeur. "Itll v..t. In "IC.
leech.t.. ... -"-A-...' of tll- ..
ho.ordDul Melto.
Reet h..Uh._eeI levol. ot WIlt.
III.lnet. fr.. 11..1. by u8Dv.I or
oolldlf Icotlon.
Aflpllcablo to land dl.po..1 .f ho.ord0u8
_to. dI Appllcabl. to .ClA ho..rd0u8 ..t.
(I,.ted .. chorectorl.t'c) pieced ot o't. of tor
tho .ffectlve dot. of tile ,..,Ir_to. ..
pIeced Into enotller WIlt. lot appllcabl. to
_ter'ol tr..ted. ot..ed. .. dlllpOled onl,
bef... tile .ffectlve dot. of tile r..,lr.-nto.
or If t,..ted In..ltu .. cone.lldoted ..ltllln
.r.. of cont.lnetlon
40 Cf. 244. ",
40 ef. 264.2Z8(0)(2)
40 cr. Z64.2Z8(.)(2)
40 cr. 264.158(b)
40 cr. Z64.51O
40 cr. 264.510
In .,., c"". tiler. or. no ."... ""It.- ot 0 U.nA oU.. lnoto"'. tiler. or. oro.. of cont.lnotlon ..Ita. dlff.,I", concentrotlon lowlo Clnel"'1", lIot IpGt.)
of 110..'" ...tonc... pollut..to, .. cant.lnento. "'In KIA h8l0r'" _t.. or. 8W8d Into or out of 1ft or.o of cont.lnotlon. IeIA dl...ol ,..,Ir--.t.
.... appllcablo to 1M .oto bollll .,...d ... c.,toln t,......t, otor"'. .. dl.poaol ,...,Ir.....to (1UdI - ,or cIoeur.) 0'. appllcabl. to tile or.o ..,. tho
Melto 10 rocol¥ld. .
fl
Stablt "otlon of ,_Inl", ....t. and
..to r..I.... to o"ftlOrt cover
,,.t.H.tlon .f flnel caver to provide
lone-tono.'"I.I..tlon of 'nflltrotlon
(...Cappl",).
JO.,.., poat-eloeur. c.r. and ,r"""
...to, ...ltorllll. 81
"
...1_1 ..'"Iot,ot.. .., ,evl.. lone'" of poet-cl.... cor. ,.,1041 (40 CF' 2M.1t7).
hI
landfill WIlt. ..tllII ta.. ,...I,....t. .f 40 CfI Z64.JOUn oro not "Joet to KIA .1"1- technol.., r..,I,_to.
'.
-------
Actl- bl
'All! IV . C (contilUld)
InlCIo. ACIICII-W'lCIfIC POI"HAL APft.ICAlLI .. .LEV., A8 """IAII ."IIUIU" .,
lequl rl8tftl
'rer..II".. for Aqltlclbillt, cl dI
C_olld.tlon belween unlll
Cltltlon
Contllner Itor...
Ulth r"pect to the Mllte Ihlt II MOVed,
I" requl"-'tl In Ihe foil_I..
lectlanl: CWl.., CI08...e ..Ith U88te In
"ec., Cont.lner Itor..., C_truellon 0'
. .... Llndtlll an-lite, Canllruetlon of .
.... lurfeee ''''''''''t an-Site,
Inclnerltlon (an-lit.), Lend Ir.lt-.nl,
ap.rltlon end _Inl*'-'ee, '" Itor.....
end Ir..I-.nI.
Ieoftrwnt of 1I1..rd0u8 Mille end ,Iee.....t Into
enoth.r unit.
Contllnerl of ICIA hllirdoul ....t. -t
Stor... of leu "...rd0u8 ...te (lIlted or
(hlreet.rlltlc) not ..tI.. -II ...-tlt,
.-r.tor crlt.,'. h.ld for . t-.or." perl'"
.r..t.r Ihen 98 dip be,or. tr.."""t, dllpll8ll,
or .tor... .I."""r. (40 CF. l64.IO), In.
(ont.'ner ct..., en, portlbl. ..Ici In ...Ich .
-t.rl.1 II ItOI'l", trlnlported, tll.,..... of, or
IIandled). A .......tor .... eeetallet.. or .tor..
II...rdoua MIlt. on-I". 'or 90 dip or 1..1 In
c~IIence ..Itll 40 CF. l61.J4(e)(I.4, II not
I.Jeet to 'ull ICIA Itor... r.."r""'liI.
'-II .,entlt, ..,.retorl Ir. not _'eet to the
90 d8y 1I.lt (40 CFI l61."(c), (d), iiiiI (e».
be:
. "IInt.lned In IOOd condition;
.0 C08p8tlble ..Ith II..8rdoul Mill. to be
Itored; end
o elOied _I.. Itor... . (OJlc:ept to 8dd
or r..". MIIte'..
INplCI cont.lner Itor... or... "'1,
for deterlorltlan.
lee CWl.., Cloeur. ..llh
11111. In 'Ieee, Cantelner
Itor..., Canltruetlan of
. .... Lend"11 an-'Ite,
C-truetlan 0' . ....
Iur'ee. 'IIIJOUI'IIIIent an.
lit., Inclner.tlan (an.
lito), Lend Ir..l88ftt,
ap.r.tlon ... ...InllfllnCo,
,.. Ilor..., end Irolt88ftt
'n Ihll e.hlblt.
40 CF. l64.17'
40 CFt l64. In
40 crl l64. In
40 CF. l64, '74
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tAilE IV . C (continued)
HLECtEO ACIIOI-IHCIFIC "'ElnAl APtUUIlE 01 I(LEVAIt .. .......1111 1(.,IIE.11I .,
Act'.. bI
....1 r8lftt
'r.requl.lt.. for appllc~IIIt, cl dV
CIt.tlon
Cont.lner Itor... (continued)
"ee. cont.,..... an . ,'oped. cr.'-fr..
"'" 8111 protect f,. conteet ..It II
eea81l.ted II...IeI. 'rew'. cont.l..-nt
.,.t- ..ltIt . c...-'t, of 10 percent of
tile wi... of cont.lner. of free' ,...,..
I.... .1"'" or I...ed ....t. 'n .
tI.'y ...., to prevent ewer". of the
cont.I..-nt .pt-.
40 CFI 264.175
I.., cont.I..... of ,,,,ltlb'. or r..tlft
....t. .t I...t SO feet fr. tile
f.I'lt," praperty line.
40 Cfl 264.116
I.., Inc..-tlbl. _terl.,. .eper.t..
'eper.t. InI:...tlb'. _t.rl.I. .tored
,.., each otller br . .... or otller
",,'er.
40 CF' 264.177
At ct....... r8W8 ." 1I...rd0u8 ......
8111 r..l.... fr. the cont.l..-nt .,.....
end dtcont_',.t. or r.-we .1'
cont.I....., I I,.,...
40 Cft 264.118
It or... of ....... ...... _t be In
eecordlnc. ..,... 40 CFI 268. lIIen euch
.tor... ocew. ..,.... .. "", the
_r/ope,.tor ...... tile ...... of
prew,,,, tllet .... .tor... I. ..,.1, for
tII. pur'IIOH of ICCU8lI.tI", eufflclent
.-tltI.. to .n... for proper ,eeewe".
t,..l8Mt. ... .1.....,.
40 Cft 268.50
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,tI- bI
I.r IY - C (contlnu8d)
RUCln acnC8-SP(CIf'C "'flf'Al "PUCARI .. IIlO.. - ......,,,,, -"'''1'' .,
1..,lr_,
".....,1.".. 'Of' Wllc.....ltr c/", CI,.Uon
,..t8lft' (llhen ""'1 ...., ..
.... lllp08ld) Ccon'hued)
,.tl '''I
8At I''''''' 'Of' ....' eo'wn' ..t..
Ind clIMln'con,.ln'... ..t.. .... _eel on
- .. 'OUI' 'ecMo'..I.. Of' c_l..tI_:
'Of' ..t. ..,..... (1) It.. .t,IAtI....
(2) 1t1.'..lc.' "..t8ftt. or CJ) c."""
"""tlon 1"- or In cael..tlon ..lth
(1) ., (2)1: ... 'or .U .,..... ..t...
(4) Incl.....tlon. "." tecMoiow .., lie
..Id. ho8I8wr. If I' ..II' ...1... thl
cone..".U.. ,...,. IpIClfild.
.... . .1...'. 'I.... Ind '8IChlt.
conlCtion ...t-.
IeIA "....... ..t.. nan.c..t.I...."'"
ICcwul.U... ., ..lIcI. non-U""'. hi.""
..t. t"" I. ..... 'or tr....., ... .t.......
1188'. put Int. -'I pll. "',oct '0 ,...
.... ,...".,1-
U Cft Me.5O
ICIA I8ctl- JOD6CcI)CJ).
CI)CJ)
42 U.I.C. '924CcI)(J).
(IUJ)
40 Cft *.151
40 Cft 268.2
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'''''1 IV - C CcantlnU8d.
SELEC'" ACflOI-SHCIFlC POnlflAL A"UCAILE .. ftLEV... - aP,.OPIUAfE ft"IIIIIIEI" .,
Actl- tJl
I...I,_t
'r.reef"a't.. for Appllc8blllt, cl ~
CIt.tlon
lu."atlon
1Iov_~" .f eU8Y8ted _t.,Ial. to nN
location ..a pl__t In or on I'" .111
tr'..., l..adl..al ,e.t,Ictl- for
for the e.c8Y8ted ..t. or cIoswe
....,I,-.,t. for the WIlt In ...IcIt the
_t. ,. "I,.. pI_ed.
I18t.,I.8e cont.lnh. ICIA he..rdau8 ..t..
."'Ject to I'" dl...1 ,..trlctl- er. pl_ed
In another WIlt.
..... f,. ...lcIt _terl.I. ere e.C8Y8ted
.., ,...,1,. cl..,.. '0 lewl. ..'8bll.heeI
.., ct..... '...1,....,..
ICiA "a..rdau8 ..,. placed ., .1,. after the
.ffectl". cia'. of ,he '...1,_,..
Inclne,.tlon
"'1,.. ,lie _'e feed.
ICiA h...rdau8 ..,..
II..... .f .U 1Ie..nIDuI ..'e ...
,..1..... Inch"I,.. -; ecnMer .'.'.
..a ecnMer .1....
.. fur...., ,...,1..-,. ....1, '0
Inclner.'ere .1Ie, onl, IIurn ..t.. ,lie,
.... I '.'ed . ....... .01.1, .., "I,t-
.f C81t1..U.. .1.. .,..... ..,... ... "
tile _'e _,,.1. ......,.... 'ha' m
......... VII ~tI'I8n' la pr....t the,
.,...' u.u..... .. .1Ip8C'ed '0 .. pr..ent.
""'--'c. a,""'" for Incl..,.'orel
latA h8.8rdau8 ..'e.
. ~I... . "'ruetl....a '8Oft1
.fflclency 8f "." perc.., for ~
principal ..-Ic he.......
~UI"'" In ,he ..,. feed ...
"."" percent for dlo.I..:
-
[
40 Cfl l69 1tfJpe,. D
1ft Cloeure In 'hi.
IRhlbl, .
40 Cfl l64.]41
40 Cft l64.S51
40 Cfl l64.S40
40 Ctt l64 .]4]
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tAilE IV - C (continued)
SElf ClEO actIOl-SPfCI'IC POIE.tIAL APPlICAILE at IfLEV..t AID APPtOPIIAIE IfGUIIfME.t. ./
Actl- bI
lecJI'r_t
'r.....I.lt.. for Afip"c8blllt, c/ dI
Cft.tlon
Inc'ner.tlon (continued)
. 1eci8c. '''0lI'l0 dalorl. .1..1- to
1.0 '.,..r .. I percent of tile lei In
t'" .t.' ..... before ent.,I", en,
polluUan controt ."Icn: !!!!I
40 Cft 264.542
. lot ,.1.... ..'lIcut.t. In .IIC... of
180 ..,.. c.rr~ted for -..t of
011"," In .tock ....
40 Cft 264.54)
llanltorl", of ..1- pe'_ter. ""1",
..,.Uan of t" Incinerator II requl,ed.
...... per_t", Include:
40 Cft 264.54)
. C-..Uan t....,..tur.:
. _t. feed rat.:
. An Indlc.tor of c.....tlon ...
.,.Ioelt,: end
. C8rtMn --I..
Control ""ltl.,. _1..1- .lther br:
40 Cft 264.545
. _..I", cCllbaU.. .- ...1... or
. 118lntolnl", cClllllul"an .- pI'08""
,.... then ''''''''',Ic ,....iuro
Utili.. ...-tlc cut.off .t. to .t.
..t. feed... ..aU", condlU-
_I.t..
...1., plrfOf8neO .t"l'd for
Incl""'''an .f ..."
liquid'" non- "quid PC81 .t cancentraU- of
SO ... or .....t.,.
40 Cft 761.70
. AdlI8¥I . "tnat Ian ... r--I
.fflcllncJ .f "."" percent;
-------
~,
"
'.1 IV . C CanUrued)
RUc,n ACYI.-RClflC NTI.flAl ~ICMlI .. IIlEY.. - ......IAtE IICIII..... .,
Actl- bl
1..,I,_t
Prer...,loU.. f. .. Ic.lllIy el dI
tlt.tI..
'Iee"',,, of ',..t.....t lyet-
Iffluent Cc..tlnued)
lee. .....
.. Pr8Ctlee.:
Dewlap ... ,..,I......t 0 Int "'.I.-"t
',.Uc. pr...- to prewnt the ,.I...e
.f tu'e c-tlIUIftt. 10 ....f.. .te,..
40 Cft 18.100
the letl ...........1, .,.tlc.. prOl'.
-I:
DI.che,.. to ..te,. of the U.S. "
40 crl 18.104
. lit."" 8P8Clflc procecb'.. ,. the
eant,.1 of tu'e ... "........
pollutant .""
. Include 8 predletl.. of dl,ectl_.
,.t. of fI_. ... totol .-ntttyof
t..le poHut.... """'0 ..,.,Ient.
Indlc.t.. 8 ,......-1. potentl.' fOf'
..,1...,.. f.1 lure.
. A....e........ -1IIt-A...1 of ..lid ...
........ _to In .cOl~e .1..
....,Iotl- ...-.I..tod under latA.
1IIII'I1.0f"" ....I,-t.:
11--18 -t ht I!I!!nltored to eeewe
CGIIIpIlInt.. DIICtIIr....", 8III'IUor:
40 cr. IlZ.4Icf)
. th. -. of eeca. po"utant
. tho w'", .f efflUint
. "...-cY of dlech,.. ... ot"',
-----. .. ....,.I.to.
"
Section IZI of lAtA .....,t. ....It. tUClA .tlvltl.. f,. abt.lnl,. ,.,.u.. 1IcIwftr. tho ""tantl" ,...,I,_t. of 8 I.. Of' ,..,I.tl.. -t be -to In
..,Ucul.... on-.lte d..cII.,... to ....f.. ..ter. er. .....,t f,. pr«""'ol .... ,.,.11 ,...I.tl_. Off-.llo dllcll.,... -.Id be '''''',od to ....1, for end
abt.ln an IPDII ,.,.11.
-------
'All! .V . e (cant .....d)
RUt'ED acn"-IPfC'f'C POTllnAl ",",ICAILI .. .LfV..' .. ........" .8.1'''''' .,
Actl- ItI
....,~
'r.requ'.It.. for app'Ic8bl"', cl dV
eu.tlan
".eII..... of 'r..'....' .,.,-
fffluent (contlnu8d)
.0V8CI toet _tIIodI for ..t.
cono"'''''' .. ... _Uorld _t ...
f."..... ..,.lIed requ'r_t. for
-,,"c., proc""" ond cp'It,
can'r.t. .. provided.
to tf. 1J6.1-'J6.4
...,. ".....U.. prec""". con,.1....
.torl.'.. ond ....... ., ,.....,. ""'dl",
tI- .. .....,......
r-.t, ..I'" ""1"_' .-t..tI"
c"""- IUd8 ..,
40 Cf. 1ZZ.41CI)
. ...., to .I"..te .. ....... .ffoct.
of .. dI--i8: ond
. ''''''' .,.,.tI.. ... .IntlnMC. of
.roe....t .,.t_.
Dredtl",
....,. .U cant.'.ted .011
IttU h...rdauo ..t. placed .t .It. .ftor tho
.ffoctl" dot. of tho ,,,,',_t.. or p'lCOd
Into enothe, ...It.
... e'..ur. In thl.
r"Ibit.
'redial", _t CCIIp" ..I'" tIC"an 10 .f
tho 'IWf'8 ond lerlMw. Act ond U.'. '''''
c.r,. of inti...,. ,....1."_.
D,edtl", In ...,"'" _tore of tho IMlted
. ".t...
n U.I.t. 40J
JJ Cft SZO. SSO
"
CIa 140) .....,Ir.. .t .. ... ""'t III I.8UId for dl..,.. Into .,1.. _tor.. 'nc'_1", tor,' tor'" ..... the cant''''' 1_. ond tho .18M. C40 Cf.
122.2'. . ,.,.,. .. lilt "",'nII If point .f dleella,.. I. an..I...
.,
DI.d..,.. '0 NfV8 t. conol"'ed .. .ff..lt. _",,'t, C... p. ),21 for dl_.lan of ,...I,_t..: therefore. ,...1'_.. ,o,..ed to dl8dlo,.. to . PaN .r. not
-'. but ... Included I" t.I. ""I"U.for r.f.,.ane.. Off..lto actlono _t c-..e, ..Ith ." I...", ",,"c8blo ,...Ir_to. both ..-t..tI" ond
""I"I..r.tl". rho cane. of -rel....t ... ....,..1.... I. not ..11.10 for off-.lt. .,,_.
:
;~
-------
Actt- bI
'AlLr IV - C (contt,....)
_LUtED ac:fI.-SPlCIFIC POfflltlAL ...'UCAllI . IIIl(V'" - ,,",""IAU 1118"_'" .,
lec,.elr--t
'rtr~I.lt.. for Appllc8blltt, c/ ~
CU.tlon
C_truetlon of !IN LBflt1
On-SU. (I.. CI.ur. ..Itll
118". In Plec.)
IlInl- techno..,. 1...I,.."t.:
.aA 1I.I.r'" ....t. (t I.ted or dI.rectort.tld
curren", bel", ,Ieced tn. nN, rtploc~t, or
Inot.1t t... liner. or .r., . top liner
tll.t prewnt. ...tl .I.,.t Ion tnto tll.
I tnor, .... lion. I tner tll.t prewnt.
....t. .t",.tton "'1'OUIh thl liner. II/
t.,..ttd londf tit .
tnot.1t 188dI8t. collection .rat- 8bow
... bet..... tII. I tnor..
CONtruet ....... ... rut..ff control
.,.t- cop8bl. of .....1 I", tlte
poet dllCh8r.. of . 8-,..r .t.....
Controt .tld dl1p8r881 of porttcul.t...
apor.tton .. -tnt8ftMCl.
CI.. 88dt c.1t .tth . flnot cover .fter
thl I.t ....t. .... been recllwd.
....... IIItor IIonftort,.
lit""" . .toctton 8Iftltorl",
(*.91). r.t"t"'. C,,"onel
8Iftft.,'... "...- elM.") ...
(lM.tOO) ..... r...,tred '" 40 CF' Z64.9I.
.u -.ttorl", fINIr- _t ...t leu
.....t ",.... ...tor 8Iftftor'",
,..ltr--t. (lM.97).
Cr..ttan of . .... 1....111 unit to tr..t, .torl,
or dllpDll of .eu 11.1--- ....t.. II port of .
r..,.... octlon.
40 CFt Z64.301
40 CF' Z64.301
40 CF' Z64.301
40 CF. Z64. 30t
40 CFI lM.3OJ-]04
40 CF. Z64.SlO
40 CFI Z64.9I.Z64.tOO
-------
Actl- bI
'AIlE IV - C CcontlftU8d)
SELECnD ACIICIt-'PfCIFIC "n"IAL APPLiCAlLE .. IlLEVAII' .. """'IA'I 1181._"'1 .,
.....,1 r8lftt
'r.requl.lt.. for Appilcabillt, cl dV
Clt.tlon
,.., Awnabl. '8dInolO8Y:
DI.dI.r.. of 'r..t...t '..t-
Efflumt
.,
u.. of "'t ..lIebl. technology (IAI)
ec_lc.II, edtl."abl. .. required to
control to.lc end nan-convent'-I
pollutont.. u.. of beet CGnftntl_I
pollutant control technol.., CICf) I.
requlr~ to control c--iUonol
pollutont.. 'KIInol..,-"'ed 11.1 t.t 1-
.." be .t...l"" on . c...'br-CH.
...1..
'oint Sourc. dl.ch.r.. to wet.,. 0' tho united
St.t... "JI
40 C,. 122.44(.)
...,... "'''tv It""r.:
."pllcabl. ,.....,.. !lflPl"owd It.t. _t.,
...Ift. .t....,. -t .. COllpUed ..lth.
,..... .t"'" .., be 'n 8ddltlon to or
.,. .tr,,-,t tll.. other '''r.1
.t""'" ....... the all. ./
40 C,. 122.44 end It.t.
r..,I.U- 8A"'owd
under 40 CF. 1)1
Olech.,... II.lt.lI- _t .. ..tabll8hed
.t ..... .trlftllllt '--I. tllon technol..,-
...ed .t"'" fM tOIle pollut...t..
40 C,. 122.44(0)
~t.,. of the U.I.8 I. ."... ......., 'n .0 C,. tZZ.Z ... 'nel"'" ".",U'''' .., wt... ~ end _nend.
JI
lectlon IZI of lAM ....t. .....It. ClIClA _tlwltl.. fr. abt.lnl"l ,.,.It.. IIoMewr. tho .-t...tI.. r.l.......t. of . I... or ,...I.tlon -t .. -to .n
pertlcu..... on..It. "11Ch.r... t.....fec. .t.r. .r. ....t fr. proc"".1 ..., ,.,.It r..,l.tlono. Off-.lt. d'oc:hortee lIOU'd .. r.lred to W" for ...
abt.'n on ...1 ,....It.
'"
,....,.. IIIIt... ...1 It, Crlterl. .." .. r.l--t end 8A"'eprl.t. """1"1 on the "'IMted or potentl.1 w. 0' the -t..., tho 8ed.. .ffeCted. tll. 1JUrpo8" of the
cr't.rl., end current Inf.,.tlon. Ccr.tLA 'I21(d)(Z)CI)(I)) 'eder.I IIIIt.r "'llt, Crlt.rl. for the protection 0' 8qU8tlc II'. ..'II .. r.I.....t end 8A"'epr'.t.
IIIten -'r---.t81 'octor. (..1., protection of ..p.tlc or....I_) .r. "1"1 c_'dered. (SO f8 J0184 1"",,29, ItI8SJ).
-------
'Aill IV - C (conti......)
.Lre,n M:flGI-SI'(elfie NfEiflU APPlleAlU .. .LEV.' .. .......1." 11..1..1" .,
let I CIM bI
.-.Ir_t
'r.....".lt.. f.. AlJpllclbllity cl dI
Cltltlan
. It... 1",1t"". ... r..U". ..t. 80 ..
to prevent tM ..t. fr. I",IU", or
r..tl",. 1",ltlbl. or reectf". .....
In cevered t". _t c..l, ..It" fluff.r
ICIM r-.I,_te In ."...ml. end
e...Ubl. U.I. Codt,- 'lbl.. 2-1
tIIrCIUIh 2.6 (letlCIMa ,fir. 'rotectlon
A8aocletlan, "16 or 1981).
40 eF. 264. I"
Itor... PrOhlbltlone:
It..... ., ....... ..... _t be In
ec:c:..".£. .1... .. ef. HI. lIMn 8Uth
et..... occure ....... - "", the
IIIIMr/.....tor bt8,e the IIurdIn 0'
prowl", tfMIt 8Uth .t..... Ie .ol.a, 'or
the purpoH 0' 8CCWIII.U", eufffcien.
Cf8I\tftf.. to .11.. for prape' ,ecoverJ,
t,._t ... dl.,..ea.
40 eF. 268.'0
rr..t88ftt (In. unit)
,..I", ... apereU", et"'" for unit
In "I~ ......... ..t. Ie t,.e.ed.
(S.. clt.tI- et ,1,1IIt 'or "I", ...
apereU", ,..Ir_.e for epeclflc
unit.)
".......t .f "'..rdau8 .... In . unit.
40 eF. 264.190-264.192
U".)
40 eF. 264.221 (SUrf..
IlIIpCIUftdIIent. )
40 eF. 264.251 cu.-..
"a..)
40 eF. 264.27J (lend
"..t8M ~ft)
40 ef. 264.54)-54'
(lncl.....tor.)
40 eF. 264.601
(IIIK."-- "..l88ftt
~I.e)
40 cr. 26~.J7J Uhe....a
'r.et....t ~'te)
-------
Act I.. b1
i_I IV . C CcentlllUld)
SEllC1ED AClIU.-SPECIFIC ",Ilnll APPUCMll .. .UVU1 .. .......111 .81'1.1111 .,
1..1 r.....t
'r.r..lolt.. for Appllc8bI'lt, cl dI
Citation
1r.ot8ent C"'''' Unto .111 be
l'" DI.,.eeI)
1reet.-nt .f ..to ""'eet to b8n on I'"
dl.,..., _t oUoln '-10 echlnebl. by
beet ""troted .".118111. tr.......t
t8dlno'..I.. C.II) for .eeh ho..rd0u8
c..tlt"",t In eedI 'Ioteel ...ot., If
r..I..' 10 to be ,end dl.,..eeI. If
r..I..' 10 to be .'urther tr.oteel,
'nltlo' tr.ot....t end 8F¥ etfJI..-nt
tr..t....t thet ....... r..I..' to be
tr..teel nHd not be .11, If It ... not
.xceed w'. In CtUI (C..t I t""'t
Cane..,tr.tlon In v..t. htreet) 18111. 'or
88dI ..... Ic8ll1. .t.... Cleo "U 4064Z,
I""'r 6, 1916.)
"""01 0' cont.lnated .0011 ... ....1.
rnultl". fr. alCl" r....... actl.. or ICU
correet Iw eet Ion 10 !!!!1 o.,eet to ,...
dl8p08al prolllbltl.. endJor tr.at.-nt at""'"
'or aolvento, dloxlna, or Collfornl. 'lot MIlt..
untl' love8ber 8, 1990 ('or certain flrot
third ...at.. W\tll Auguat I. 1990).
II I ..at.. Ilateel .. harard0u8 10 40 CFI plrt
Z6t oa of lovwbIr 8, 1084, .xe.,. for apent
aolvent ...at.. and dloxln-contolnl", ..t..,
have been ranked ..lth r88plCt to "I... ...
IntrlNlc "ala", ... ar. 1dt.,led for ''''
dlapolal prolllbition ""or tr..t....t .t-.lard
predetenalnatlon .. foil...:
Solvento ... dloalna
C.II'ornl. Ilot ...at..
One-third of .11 ranked ...
hOI.rdUua .at..
thter,round In,eetlon of
aolwnto ... dloalna ...
Collfornl. 'lot MIlt..
aiel" r..,.,.o action ...
leu correetlw action 0011
... deliria
1....thl... of oil rried ...
'Iated "I''''' ..t..
A" r_lnl,. rried ...
'Iated "I."" ..t..
I~tlfled by eh8ract.rl..
tic wder leu oeetlon
)001
... h.I"" MIlt. 'Ioted
or Iclarita fled under ,eu
oeetlon 1001 .'ter
Io~ inHr I, 1984
low. I, 1986
~ul. I, 1987
Aut. 8, 1988
Aut. I, 1988
10'1. I, 1988
"",. I, 1-
Illy I, 1990
"Ithl" 6 -.
.f tho data .f
l~t"lc.tlon
or 'Iatl,..
40 CFt Z68.IO
40 Cf' Z68. t1
40 Cfl Z68.12
40 CF' Z68.41 .
40 Cf'.Z6I Subpart 0
" U 40641
SZ U 15760
-------
ActiON bl
fA1l1 IV - C (conti.....)
I(lrCUD ACHCII-SPlClfIC PafE"IAl APtUtMlr l1li IfUV..f .. ......IATE ."1",,"" .,
'~I,_t.
',e'8ClU1.lt.. 'or app"e8bl'I., cI GV
Incl,.,.tlon (continued)
CIt.tlon
"K_t ., UHt. In Lend
Dl8p08a' ..It
tur'K. V.t.r Con.rol
. lI.he, I ........" .1. .. tzoo
....... cO C!tOO) end J percent .IIC...
all"'" I" a'KIl ...: or 1.' aecond
.." tI. ot tdOG "r... C ... 1
percent .IIC... all""" In .tKIl ...: ...
. 'er nen- I I..Id ~" ... olr
.1..1- ". .he Incl,.,..or ...."
be no .,..er then 0.001 . n per II.
.f .... pal ent...I.. the lnel"".tor.
LendDI8D0881 ....rletl_:
At..I" lend diepoa.I 8tr..t-.n.
a'''''''''. ""or. putt lne ..t. Into
lendtl" I".,... '0 eCl8lpl, ..8th ,... ban
,...rlctl_. A tr.at-.nt a.""rd can
be .Itherl (1) 0 concen.r..lon law' '0
be al"" (perf--.c.-baaed) or (1) .
...lfl... tedlnolow .ho. -t ... U8ed
(tedlnolOW-"""). If the a.""rd la
per'--.c..""". ...., tlClInoIow can be
UHd to ~Iewe the .."rd. CI88
'r....... IIIen Uao'a ..I" ... L'"
DI~).
"ee~t 0' leu ha.ard0u8 Ua8.. In . lendtl"
.urfee. llIIpCIUndIIIn.. ..... pll.. Injection .".
,... t,...~. 'KI'It,. a.'t du8t '0r88tlon.
.,a't bed 'o,..Ion. or under,round .1", or cave.
Prevent nn-an and cantrol ... col lee.
,...-off f,. . "'-hour 15-,.., atoro
(Melto pi'... ,and .r...88ftt focl"t'...
lendtl".).
laA "-."... ....ta .r..t"'. a.or'" er
dl"""" 0' att.r .he .ffectlve cIIt. of ....
r...I'--t..
Prevent ..,.,-t...I.. 0; ...fK.
I""""'t.
40 crl Z68 S~r' D
. 40 Cf. Z64.15Ue).Cd)
40 Cf. Z64.Z7J(d).(d)
40 ef. Z64.JOUe).Cd)
40 ef. 264.211Ce)
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'AILE IV . e (e...U....)
"lICUD AC'nle-MCIFIC "".nM .....ICUll .. IlElIV.' ... .....IAlI 1lE8I11M1" .,
AcU- "
'equl.--nt
".~I.lt.. for App'Ie8blll., el 41
40 Cf. 2M.I90
,.. Stor... (CIn-Slt.)
,... _t hew 8Ufflclent .truet....,
.t,..'" to ....... th.t th., .., not
coil.,.., rupt...., or '.1'.
'tor... 0' KIA h8..rduu8 _to U I.ted or
dI8,actorl.Uc) not ..tl", -U .,..Ut,
1Ifte,.tor c,It.,I. h.ld 'or . t...-ery pori'"
.,..tor th.. 90 d8y8 "'or. tr..t8Int, dl....I,
0' .tor... .1.eMhe,. (40 Cf. Z64.IO),. In . t-
(I ..., ~ port8bl. devlc. In ...Ice. . -tori.'
I. .tored, t,..,.,ted, dl...ed .f, or
...,"'ed). A ...-r.tor ""' acCU8Jt.t.. or .tor..
h...,.... _to .....It. 'or 90 d8y8 or I... In
eo.p'Ianc. Mlth 40 Cf. 262.J4(.)(I.4). I. not
"'eet to fuU ICU .tor... requlr_t..
.." .,..Ut, ...-r.tor. .... not "",eet to tho
90 do, 'I.It (40 Cf. Z6l.J4(e), (d), .... (.».
....t. -t not .. IncOlllp8Ub'. Mltll the
. t" _t.rl.' unl... the t" I.
proteeted tJr . lI..r or tJr otll.r 8HM.
'ri. _t .. provl~ Mlth aecar""
e...t.l~ .... c
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TABLEV.A
SELECTED CHEMlCAL-SPECU1C POTENTIAL APPUCABLE
OR RELEV~" ~1) APPROPRIATE REQUIREMDI,.S. STATE OF OHIO
 Ohio EP A Water Quality State of Ohio
Chemical Name Standards for Aquatic Sed.iment Standard
 LiCe Habitat(l) (~cu1ated)(2)
 (30 day Iycraae) (mJ.1) (mllka)
ADtimony 0.19 9$00
AncDic 0.19 0.95
Beryllium 2.3 z 10 - 02+ 
Bis(2~thylbexyl) phthalate 8.4 z 10.03 1.68 x 10 + 07
Di-n-but)'lpbthalate 0.19 3.23 z 10 + 04
Butylbenzylphthalate 4.9 z 10 - 02 2..45 x 10 + 03
2-ButaDono 7.1 x 10 - 03 1.28 x 10.02
Cadmium 1.4 x 10 . 03 + 
Cblorobenzene 2..6 x 10 - 02 8.58
Chloroform 7.9z 10.02 3.48
Chromium 0.207 + 1.03S+
Copper 1.18 x 10 - 02+ 5.89% 10 + 01 +
Cyanide 1.2 % 10 - 02 6.0 x 10 - 02
1,I-dichloroetbene 7.8z 10.02 
1;2~ich1oroethene 0.31 
Ethylbenzene 6.2 x 10 - 02 6.82% 10 + 01
Iron 1.0 
Lead 6.92 x 10 - 03+ 3.46 x 10 + 01 +
Mercury 2..0 x 10.04 0.1
4-Methylpbenol 6.2 % 10 - 03 0.215
Nickel 0.17+ 
Napbthalene 4.4z 10.02 
Selenium S.Ox 10 - 03 
Silver 1.3 x 10 - 03 
Styrene 5.6 x 10 - 02 4.45 x 10 + 01
Teuachloroethene 7.3 x 10 - 02 2..66 x 10 + 01
Toluene 1.7 4.2$ x 10 + 02
Thallium 1.6:1 10.02 
1.1.1- Trichloroetbane 8.8z 10-02 
Vanadium - 
ViDyl Chloride -
Zinc 0.1()6+ 5.30 x 10 +01 +
+ Hardness dependent criteria were calculated witb a bardness value of 100 ppm.
(1) Source: Obio EPA Water Ouality Standards, Chapter 374S.10AC.
(2) Calculation of Sediment Standards is prov;ded in Appendix m of this report.
-------
OAC
CITATION
PERTINENT
PARAGRAPHS
3734.05
10118111:1
3734.02
IFI
3734.02
IHI
3734.141
.
. TABlE V-8
8nECTID POTENTIAL APPlICAIlE OR RElEVANT AND APf'RCJIIRIATE REOUItIMENTS . STATE OF OHIO
OHIO ADMINISTRATIVE CODE lOACt
TITLE/
SUBJECT OF REGULATION
HAZARDOUS WASTE FACILITY
ENVIRONMENTAL IMPACT
UNAUTHORizeD STORAGE.
TREATMENT OR DISPOSAL OF HAZ
WASTE
-DIGGING- WHERE HAl OR SOLID
WASTE fACILITY WAS LOCATED
CONDITIONS FOR DISPOSAL OF
ACUTE HAZARDOUS WASTE
~
DESCRIPTION OF REGULATION
A HAZARDOUS WASTE FACILITY
INST AllA TlON AND OPERATION
PERMIT SHALL NOT BE APPROVED
UNLESS IT PROVES THAT THE
FACILITY REPRESENTS THE
MINIMUM ADVERSE
ENVIRONMENT AL IMPACT.
CONSIDERING THE STATE OF
AVAILABlE TECHNOlOGY. THE
NA TURE AND ECONOMICS OF
VARIOUS ALTERNATIVES AND
OTHER PERTINENT
CONSIDERATIONS
PROHIBITS STORAGE. TREATMENT
OR DISPOSAL Of HAZARDOUS
WASTE EXCEPT AT PERMITTED
FACILITIES
FILLING. GRADING. EXCAVATING.
BUILDING. DRILLING OR MINING ON
LAND WHERE HAZARDOUS OR
SOlID WASTE FACIlITY WAS
OPERA TED IS PROHIBITED WITHOUT
PRIOR AUTHORIZATION FROM THE
DIRECTOR Of THE OHIO EPA.
APPlICATION OF REGULATION
ARAR TYPECSt
PERTAINS TO All SITES AT WHICH
HAZARDOUS WASTE HAS COME TO
BE lOCATED AND/OR AT WHICH
HAZARDOUS WIlL BE TREATED.
STORED OR DISPOSED OF. MAY
FUNCTION AS SITING CRITERIA
PERTAINS TO ANY StTE AT WHICH
HAZARDOUS WASTE HAS COME TO
BE LOCATED
ACTION
PERTAINS TO ANY SITE AT WHICH
HAZAROOU.S OR SOlID WASTE HAS
COM£ TO BE LOCATED.
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APPENDIX E
STATE ARARS
-------
   TAIIlf V..  
  SEUCTED POTlNTIAl APft.1CA1lE OR RREVANT AND APPROPRIATE REQUlRfMENTI . .TATE OF OHIO 
  OHIO ADMINISTRATIVE CODE COACI  
'AC PERTINENT TlTLEI   
rATION PARAGRAPHS SUBJECT OF REGULATION DESCRIPTION OF REGULATION APPliCATION OF REGULATION ARAR TYPfISI
34.05 IDII811dl HAZARDOUS WASTE FACILITY A HAZARDOUS WASTE FACILITY PERTAINS TO ALL SITES AT WHICH ACTION
  MINIMUM RISK INS T ALL A nON AND OPERATION HAZARDOUS WASTE HAS COME TO 
   PERMIT SHALL NOT BE APPROVED BE LOCATED ANDIOR AT WHICH 
   UNLESS IT PROVES THAT THE HAZARDOUS WILL BE TREATED, 
   FACILITY REPRESENTS THE STORED OR DISPOSED OF. MAY 
   MINIMUM RISK OF ALL OF THE FUNCTION AS CITING CRITERIA. 
   FOLLOWING:  
   Iii CONT AMiNA TlON OF GROUND  
   AND SURFACE WATERS  
   liil FIRES OR EXPlOSIONS FROM  
   TREATMENT. STORAGE OR  
   DISPOSAL METHODS  
   liiil ACCIDENT DURING  
   TRANSPORT A TION  
   livllMPACT ON PUBLIC HEALTH  
   AND SAFETY  
   !vi AIR POLLUTION  
   lvil SOil CONT AMiNA TlON  
67.13  PROHIBITION OF NUISANCES PROHIBITS NOXIOUS EXHALATIONS PERTAINS TO ANY SITE THAT MAY ACTION
   OR SMEllS AND THE OBSTRUCTION HAVE NOXIOUS SMELLS OR CHEMICAL
   OF WATERWAYS OBSTRUCT WATERWAYS 
11.04  ACTS OF POLLUTION PROHIBITED POLLUTION OF WATERS OF THE PERTAINS TO ANY SITE WHICH HAS ACTION
   STATE IS PROHIBITED CONTAMINATED ON. SITE GROUND 
    OR SURFACE WATER OR WILL HAVE 
    A DISCHARGE TO ON-SITE SURFACE 
    OR GROUND WATER 
11.45  APPROVAL OF PLANS FOR THE DISPOSAL OF INDUSTRIAL PERTAINS TO ANY SITE AT WHICH ACTION
  DISPOSAL OF WASTES WASTE IS PROHIBITED WITHOUT INDUSTRIAL WAST£S ARE 
   PRIOR APPROVAL BY THE DIRECTOR PRODUCED OR lOCATED 
   OF THE OHIO EPA  
-------
OAC
CIT A TION
3734.02
3745-1-03
3745.1.04
3745-1-16
3745-1-32
PERTINENT
PARAGRAPHS
III
..:
TABlE V-8
SREerED POTENTIAL APPlICABlE OR AnEVAN' AND APPROPRIATE REQUIREMENTS. .TATE 0# OHIO
OHIO ADMINISTRATIVE CODE COACI
TlTLEI
SUBJECT OF REGULATION
AIR EMISSIONS FROM HAZARDOUS
WASTE FACILITIES
ANAL YTfCAL AND COLLECTION
PROCEDURES
THE "FIVE FREEDOMS" FOR
SURFACE WATER
WATER USE DES FOR SE OHIO TRIB
WATER USE DES FOR OHIO RIVER
DESCRIPTION OF REGULATION
NO HAZARDOUS WASTE FACILITY
SHALL EMIT ANY PARTICULATE
MATTER, DUST, FUMES, GAS, MIST,
SMOKE, VAPOR OR ODOROUS
SUBSTANCE THAT INTERFERES
WITH THE COMFORTABLE
ENJOYMENT OF LIFE OR PROPERTY
OR IS INJURIOUS TO PUBLIC
HEALTH
SPECIFIES ANALYTICAL METHODS
AND COLLECTION PROCEDURES FOR
SURFACE WATER DISCHARGES
ALL SURFACE WATERS OF THE
STATE SHALL BE FREE FROM:
AI OR.lfCTloNAL SUSPENDED
SOLIDS
BI FLOATING DEBRIS, OIL AND
SCUM
CIMA TERIALS THAT CREATE A
NUISANCE
DI TOXIC, HARMFUL OR LETHAL
SUBSTANCES
EI NUTRIENTS THAT CREATE
NUISANCE GROWTH
ESTABLISHES WATER USE
DESIGNATIONS FOR STREAM
SEGMENTS WITHIN THE
SOUTHEAST OHIO TRIBUTARIES
BASIN
ESTABLISHES WATER USE
DESIGNA TlON FOR STREAM
SEGMENTS WITHIN THE OHIO RIVER
BASIN
APPlICA "ON OF REGULATION
PERTAINS TO ANY SITE AT WHICH
HAZARDOUS WASTE WILL BE
MANAGED SUCH THAT AIR
EMISSIONS MAY OCCUR.
CONSIDER fOR SITES THAT WILL
UNDERGO MOVEMENT OF EARTH
OR INCINERATION
PERTAINING TO BOTH DISCHARGES
TO SURFACE WATERS AS A RESULT
OF REMEDIATION AND ANY ON-SITE
SURFACE WATERS AfFECTED BY
SITE CONDITIONS
PERTAINS TO BOTH DISCHARGES
TO SURFACE WATERS AS A RESULT
OF REMEDIATION AND ANY ON. SITE
SURFACE WATERS AFFECTED BY
SITE CONDITIONS
PERTINENT IF STREAM OR STREAM
SEGMENT IS ON-SITE AND IS EITHER
AffECTED BY SITE CONDITIONS OR
If REMEDY INCLUDES DIRECT
DISCHARGE. USED BY DWQPA TO
ESTABlISH LOAD ALLOCATIONS
PERTINENT IF STREAM OR STREAM
SEGMENT IS ON-SITE AND IS EITHER
AFFECTED BY SITE CONDITIONS OR
IF REMEDY INCLUDES DIRECT
DISCHARGE. USED BY DWQPA TO
ESTABLISH WASTE LOAD
ALLOCA TIONS
ARAR TYPEIS!
ACTION
CHEMICAL
ACTION
LOCA TlON
ACTION
LOCA TlON
-------
   .TABlE v..  
  SElECTED POTENTIAl APPlICABlE OR RElEVANT AND APPROPRIATE REQUIREMENTS. STATE 0# OHIO 
  OHIO ADMItftSTRATM CODE IOAC,  
,c PERTINENT TlnEI   
ATiON PARAGRAPHS SUBJECT OF REGULATION DESCRIPTION Of REGULATION APPlICATION OF REGULATION ARAR TYPfISI
45.15.07 A AIR POllUTION NUISANCES DEFINES AIR POlLUTION NUISANCE PERTAINS TO ANY SITE WHICH ACTION
  PROHIBITED AS THE EMISSION OR ESCAPE INTO CAUSES, DA MAY REASONABlY 
   THE AIR FROM ANY SOURCE IS' OF CAUSE, AIR POllUTION NUISANCES, 
   SMOKE, ASHES, DUST, DIRT, GRIME. CONSIDER FDA SITES THAT WILL 
   ACIDS, FUMES. GASES, VAPORS. UNDERGO EXCAVATION. 
   ODORS AND COMelNA TIONS OF DEMOLITION, CAP INSTAllATION. 
   THE ABOVE THAT ENDANGER METHANE PRODUCTION, CLEARING 
   HEALTH, SAFETY OR WElFARE OF AND GRUBBING, WATER 
   THE PUBLIC OR CAUSE PERSONAL TREATMENT, INCINERATION AND 
   INJURY OR PROPERTY DAMAGE. WASTE FUEL RECOVERY. 
   SUCH NUISANCES ARE PROHIBITED.  
745.17.02 A,B,C PARTICULATE AMBIENT AIR ESTABlISHES SPECIFIC STANDARDS PERTAINS TO ANY SITE THAT MAY CHEMICAL-
  QUALITY STANDARDS FOR TOTAL SUSPENDED EMIT MEASURABlE QUANTITIES OF 
   PARTICULA TES. PARTICULATE MATTER IBOTH 
    STACK AND FUGITIVE,. CONSIDER 
    FOR SITES THAT W1ll UNDERGO 
    EXCAVATION. DEMOlITION, CAP 
    INSTAllATION, CLEARING AND 
    GRUBBING, !HCINERA TlON AND 
    WASTE FUEL RECOVERY. 
1745.17-05  PARTICULA TE NON.DEGRADA TlON DEGRADATION OF AIR QUALITY IN PERTAINS TO SITES IN CERTAIN CHEMICAL
  POLICY ANY AREA WHERE AIR QUALITY IS lOCATIONS THAT MAY EMIT OR 
   BETTER THAN REQUIRED BY 3745. AllOW THE ESCAPE OF 
   17.02 IS PROHIBITED. PARTICULATES IBOTH STACK AND 
    FUGITIVE'. CONSIDER FDA SITES 
    THAT Will UNDERGO EXCAVATION. 
    DEMOlITION, CAP INSTAllATION. 
    CLEARING AND GRUBBING, 
    INCINERATION. 
3745.17'()8 A1. A2. B, 0 EMISSION RESTRICTIONS FOR ALL EMISSIONS OF FUGITIVE DUST PERTAINS TO SITES WHICH MAY ACTION
  FUGITIVE DUST SHAll BE CONTROI.UD HAVE FUGITIVE EMISSIONS INON- 
    STACk' OF DUST. CONSIDER FOR 
    SITES THAT WIll UNDERGO 
    GRADING, LOADING OPERATIONS, 
    DEMOLITION. CLEARING AND 
    GRUBBING AND CONSTRUCTION. 
-------
   TA8L£ v..  
  enECTED POTUtTlAl APt'ltCA8lE OR RElEVANT AND A""~TE RtQUIt£MENT. . .TATE OF OHIO 
  OHIO ADMINISTRATIVE CODE COACI  
OAC PERTINENT TITLE I    
CITATION PARAGRAPHS SUBJECT OF REGULATION DESCRIPTION OF REGULA TION APPlICATION Of REGULATION ARAR TYPE(SI
3745.17.09 A,B,C INCINERATOR PARTICULATE ESTABliSHES PARTICULATE PERTAINS TO ANY REMEDY ACTION
  EMISSION AND ODOR EMISSION LIMITATIONS AND INCORPORATING INCINERATION. 
  RESTRICTIONS DESIGN-OPERATION REQUIREMENTS  
   TO PREVENT THE EMISSION OF  
   OBJECTIONABlE ODORS.  
3745.18-02 A,B,C, D SULFUR DIOXIDE AMBIENT AIR ESTABliSHES PRIMARY AND PERTAINS TO ANY SITE THAT EMITS ACTION
  QUALITY ~T ANDARDS SECONDARY AMBIENT AIR QUALITY OR WILL EMIT SULFUR DlQXIDE. CHEMICAL
   STANDARDS FOR SULFUR DIOXIDE. CONSIDER FOR INCINERATION, FUEL 
    BURNING CWASTE FUEl RECOVERYI. 
3745-18-05 A SULFUR DIOXIDE AMBIENT THE DIRECTOR OF THE OHIO EPA PERTAINS TO ANY SITE THAT EMITS ACTION
  MONITORING REQUIREMENTS MAY REQUIRE ANY SOURCE OF OR WIlL EMIT SULFUR DIOXIDE. CHEMICAL
   SULFUR DIOXIDE EMISSIONS TO CONSIDER FOR INCINERATION, FUEL 
   INSTALL, OPERATE AND MAINTAIN BURNING CWASTE FUEL RECOVERYI. 
   MONITORING DEVICES, MAINTAIN  
   RECORDS AND FILE REPORTS.  
3745.18-08 A.S SULFUR DIOXIDE EMISSION LIMIT ESTABLISHES GENERAL LIMIT  PERTAINS TO ANY SITE THAT WILL ACTION
  PROVISIONS PROVISIONS FOR SULFUR DIOXIDE. EMIT SUlFUR DIOXIDE. CONSIDER CHEMll "l
    FOR SITES THAT WILL UNDERGO 
    INCINERATION OR FUEL BURNING 
    IWASTE FUEL RECOVERYI. 
3745.21.02 A,B,C AMBIENT AIR QUALITY STANDARDS ESTABliSHES SPECIFIC AIR QUALITY PERTAINS TO ANY SITE WHICH WILL CHEMICAL
  FOR CARBON OXIDES STANDARDS FOR CARBON EMIT CARBON OXIDES. CONSIDER 
   MONOXIDE, OZONE AND NON- FOR SITES THAT WIll UNDERGO 
   METHANE HYDROCARBONS. WATER TREATMENT, INCINERATION 
    AND FUEl BURNING IWASTE FUEL 
    RECOVERYI. 
3745.21.05  CARBON OXIDES PROHIBITS SIGNIFICANT AND PERTAINS TO ANY SITE WHICH WILL ACTION
  NONDEGRADA TlON POLICY AVOIDABLE DETERIORATION OF AIR EMIT CAR80N OXIDES. CONSIDER 
   QUALITY. FOR SITES THAT Will UNDERGO 
    WATER TREATMENT, INCINERATION 
    AND FUEl8URNING IWASTE FUEL 
    RECOVERYI. 
A
-------
OAC
:IT A TION
1"5-21-01
11"5-21-08
11"5-21-09
11"5-23-01
'1 "5- 23-0"
PERTINENT
PARAGRAPHS
A-J
A.E
\ ..
TA8lEV-8
SRECTED POTDlTIAl APPliCABLE OR RREVANT AND APflROPRIATE RfQUllfMfNTS . STATE Of OHIO
OHIO AOMINISTRATIVE CODE COACI
TITlE'
SUBJECT OF REGULATION
ORGANIC MAT EMISSION CONTROL:
STATIONARY SOURCE
CARBON MONOXIDE EMISSION
CONTROl.: STATIONARY SOURCE
VOC EMISSION CONTROL:
STATIONARY SOURCE
NITROGEN DIOXIDE AMBIENT AIR
QUALITY STANDARDS
NITROGEN DIOXIDE
NONDEGRADA TlON POLICY
DESCRIPTION OF REGULATION
REQUIRES CONTROL OF EMISSIONS
OF ORGANIC MATERIALS FROM
STATIONARY SOURCES. REQUIRES
BEST AVAILABlE TECHNOLOGY.
REQUIRES ANY STATIONARY
SOURCE OF CARBON MONOXIDE TO
MINIMIZE EMISSIONS BY THE USE
OF BEST AVAilABlE CONTROL
TECHNOlOGIES AND OPERATING
PRACTICES IN ACCORDANCE WITH
BEST CURRENT TECHNOlOGY.
REQUIRES ANY STATIONARY
SOURCE OF VOCS TO MINIMIZE
EMISSIONS BY USE OF BEST
AVAILABlE CONTROL
TECHNOlOGIES AND OPERATING
PRACTICES IN ACCORDANCE WITH
BEST CURRENT TECHNOlOGY-
ESTABlISHES A MAXIMUM
AMBIENT AIR QUALITY STANDARD
FOR NITROGEN DIOXIDE.
PROHIBITS THE SIGNIFICANT AND
AVOIDABLE DETERIORATION OF AIR
QUALITY BY THE RELEASE OF
NITROGEN OXIDE EMISSIONS.
APPLICATION OF REGULATION
PERTAINS TO ANY SITE WHICH IS
EMITTING OR WILL EMIT ORGANIC
MATERIAL. CONSIDER FOR SITES
THAT WILL UNDERGO WATER
TREATMENT, INCINERATION AND
FUEL BURNING (WASTE FUEL
RECOVERY,.
PERTAINS TO ANY SITE WHICH IS
EMITTING OR WILL EMIT CARBON
MONOXIDE. CONSIDER FOR SITES
THAT WILL UNDERGO WATER
TREATMENT, INCINERATION AND
FUEL BURNING «WASTE FUEL
RECOVERY,.
PERTAINS TO ANY SITE WHICH IS
EMITTING OR WILL EMIT VOCS.
CONSIDER FOR SITES THAT WILL
UNDERGO WATER TREATMENT,
INCINERATION AND FUEL BURNING.
PERTAINS TO ANY SITE WHICH IS
EMITTING OR WIll EMIT NITROGEN
DIOXIDE. CONSIDER FOR SITES
THAT WILL UNDERGO WATER
TREATMENT, INCINERATION AND
FUEL BURNING «WASTE FUEL
RECOVERY,.
PERTAINS TO ANY SITE WHICH IS
EMITTING OR Will EMIT NITROGEN
OXIDES. CONSIDER FOR SITES
THAT WILL UNDERGO WATER
TREATMENT, INCINERATION AND
FUEL BURNING «WASTE FUEL
RECOVERY,.
ARAR TYPE'S,
ACTION
CHEMICAL
ACTION
CHEMICAL
ACTl0I4
CHEMICAL
ACTION
CHEMICAL
ACTION
CHEMICAL
-------
OAC
CITATION
3145-23-08
3145-25-03
3145-21-05
3145-21-08
PERTINENT
PARAGRAPHS
A. B,C
B.C
TAId! V"
SELECTED POTEWTlAL APPLICABlE OR RfLEVANT AND APPROPRIATE IlEa_EN'. . .'ATE Of OHIO
OHIO ADMINISTRATIVE CODE COACt
TinE'
SUBJECT Of REGULATION
NITROGEN OXIDES EMISSION
CONTROL: STATIONARY SOURCE
EMISSION CONTROL ACTION
PROGRAMS
AUTHORIZED, LIMITED AND
PROHIBITED SOLD WASTE DISPOSAL
REQUIRED TECHNICAL INFO fOR
SANITARY LANDFILLS
DESCRIPTION Of REGULATION
REQUIRES THAT ALL STATIONARY-
SOURCES Of NITROGEN OXIDE
MINIMIZE EMISSIONS BY THE USE
Of LATEST AVAILABLE CONTROl
TECHNIQUES AND OPfRA TlNG
PRACTICES IN ACCORDANCE WITH
BUT CURRENT TECHNOLOGY.
PROHIBITS NITROGEN OXIDE
EMISSIONS FROM COMBUSTION.
REQUIRES PREPARATION fOR AIR
POlLUTION ALERTS, WARNINGS
AND EMERGENCIES.
ESTABLISHES ALLOWABlE
METHODS Of SOUD WASTE
DISPOSAL; SANITARY lANDFILL,
INCINERATION. COMPOSTING.
PROHIBITS MANAGEMENT BY OPEN
BURNING AND OPEN DUMPING.
SPECIFIES THE MINIMUM
TfCHNICAllNfORMA TlON
REQUIRED Of A SOLID WASTE
PERMIT TO INSTALL. INCLUDED
ARE A HYDROGEOlOGIC
INVESTIGATION REPORT, LEACHATE
PRODUCTION AND MIGRATION
INFORMATION, SURfACE WATER
DISCHARGE INfORMATION, DESIGN
CALCULATIONS, PlAN DRAWINGS.
APPlICATION Of REGULATION
ARAR TYPEfSl
PERTAINS TO ANY SIT WHICH WILL
EMIT NITROGEN OXIDES. CONSIDER
fOR SITES THAT WILL UNDERGO
WATER TREATMENT,INCINERATION
AND FUEL BURNING (WASTE FUEL
RECOVERY'.
ACTION
PERTAINS TO ANY SITE WHICH IS
EMlnlNG OR MAY EMIT AIR
CONTAMINANTS.
ACTION
PERTAINS TO ANY SITE AT WHICH
SOUD WASTES WILL BE MANAGED.
PROHIBITS MANAGEMENT BY OPEN
BURNING AND OPEN DUMPING.
AqlON
THIS PARAGRAPH PRESENTS
SUBSTANTIVE REQUIREMENTS Of A
SOliD WASTE PERMIT TO INSTALL.
PERTAINS TO ANY NEW SOliD
WASTE DISPOSAL FACILCTY
CREATED ON-SITE AND
EXPANSIONS Of EXISTING SOlID
WASTE LANDFILLS. ALSO
PERTAINS TO EXISTING AREAS OF
CONTAMINATION THAT ARE
CAPPED PER SOlID WASTE RULES.
THIS RULE ESTABLISHES THE
MINIMUM INFORMATION REQUIRED
DURING THE REMEDIAL -DESIGN
PHASE.
ACTION
-------
OAC
CIT A TION
PERTINENT
PARAGRAPHS
3745-27.07
A.B
3145.27.08
C, D. E
)745.27.09
C.F,I,l.O
)745.27.10
B,C,D
TA.. A
8El£C1ID POTENTIAL APPlICABlE OR RElEVANT AND APPROPRIATE REQUIREMENTS - STATE OF OHIO
OHIO ADMIMSTRATNE CODE COACI
TITlEI
SUBJECT OF REGULATION
lOCATION CRITERIA FOR SOLID
WASTE DISPOSAL PERMIT
CONSTRUCTION SPECIFIC A TlONS
FOR SANITARY LANDFIllS
SANITARY LANDFill OPERATIONAL
REQUIREMENTS
SANITARY lANDFill - GROUND
WATER MONITORING
DESCRIPTION OF REGULATION
SPECIFIES lOCATIONS IN WHICH
SOLID WASTE LANDFillS ARE NOT
TO BE SITED. INCLUDES
FLOODPlAINS, SAND OR GRA VEL
PITS, LIMESTONE OR SANDSTONE
QUARRIES, AREAS ABOVE SOLE
SOURCE AQUIFERS, WETlANDS,
ETC.
SPECIFIES THE MINIMUM
REQUIREMENTS FOR SOlllCLAY
LAYERS, GRANULAR DRAINAGE
LA YER, GEOS YNTHETICS,
LEACHATE MANAGEMENT SYSTEM,
GAS MONITORING SYSTEM, ETC.
ALSO ESTABLISHES CONSTRUCTION
REQUIREMENTS FOR FACILITIES TO
BE LOCATED IN GEOLOGICALLY
UNFAVORABLE AREAS.
SPECIFIES OPERATIONAL
REQUIREMENTS FOR SOLID WASTE
LANDFILLS. INCLUDES LEACHATE
AND AIR EMISSION MANAGEMENT,
FILLING OF NEW PHASE, ACCESS
ROADS, DAILY COVER, BURNING
WASTE, LAYER THICKNESS,
DISPOSAL OF LIQUIDS, AND
SURFACE WATER MANAGEMENT.
GROUND WATER MONITORING
PROGRAM MUST BE ESTABLISHED
FOR All SANITARY LANDfiLL
FACILITIES, THE SYSTEM MUST
CONSIST OF A SUFFICIENT NUMBER
OF WEllS THAT ARE lOCATED SO
THAT SAMPlES INDICATE BOTH
UPGRADIENT CBACKGROUNDt AND
DOWNGRADIENT WATER SAMPLES.
THE SYSTEM MUST BE DESIGNED
FOR THE MINIMUM REQUIREMENTS
SPECIFIED IN THIS RULE. SAMPliNG
AND ANALYSIS PROCEDURES MUST
COMPlY WITH THIS RULE.
APPlICA TlON OF REGULATION
ARAR TYPEISt
. THIS RULE PREVENTS THE
ESTABliSHMENT OF NEW SOLID
WASTE lANDFIllS AND
EXPANSIONS OF EXISTING SOUD
WASTE lANDAllS IN CERTAIN
UNFAVORABlE lOCATIONS. ALSO
MAY PROHIBIT THE lEAVING OF
WASTE IN.PlACE IN CERTAIN
UNFAVORABLE lOCATIONS.
lOCATION
PERTAINS TO ANY NEW SOLID
WASTE DISPOSAL FACILITY
CREATED ON.SITE AND ANY
EXPANSION TO EXISTING SOLID
WASTE LANDFillS. PORTIONS
ALSO PERTAIN TO AREAS OF
CONT AMiNA TlON THAT ARE
CAPPED PER SOUD WASTE RULES.
MAY SERVE AS SITING CRITERIA.
ACTION
PERTAINS TO NEW SOLID WASTE
DISPOSAL FACILITIES TO BE
CREATED ON-SITE AND EXISTING
lANDFillS THAT WIll EXPAND
DURING REMEDIATION. PORTIONS
ALSO MAY PERTAIN TO EXISTING
AREAS OF CONTAMINATION THAT
Will BE CAPPED IN-PlACE PER
SOLID WASTE RULES.
ACTION
PERTAINS TO ANY NEW SOliD
WASTE FACILITY AND ANY
EXPANSIONS OF EXISTING SOliD
WASTE lANDFillS ON.SITE. ALSO
MAY PERTAIN TO EXISTING AREAS
OF CONT AMiNA TlON THAT ARE
CAPPED IN-PlACE PER THE SOLID
WASTE RULES.
ACTION
-------
OAC
CITATION
PERTINENT
PARAGRAPHS
3745.27.11
A.B.S
3745.21-12
B.E
3145-21-13
A. E-G.J
TA8tE V"
8B.ECTED POTENTIAL APPlICAIIl! OR RElEVANT ANI) APMOfIRIAft REa_T8 . STAtE OF 0f80
OHIO ADMI'aSTRATIYE CODE COACt
TlnEI
SUBJECT OF REGUlATION
FINAL CLOSURE OF SANITARY
LANDFIlL FACILITIES
SANITARY LANDFILL-EXPLOSIVE
GAS MONITORING
DISTURBANCES WHERE HAZ OR
SOliD WASTE FAC WAS OPERATED
DESCRIPTION OF REGULATION
SPECIFIES THE MINIMUM
INFORMATION NECESSARY FOR
OHIO EPA TO DETERMINE
ADEQUACY OF CLOSURE MfTHODS
FOR SOliD WASTE LANDFILLS.
SPECIFIES ACCEPT ABlE CAP
DESIGN; SOIL BARRIER LAYER.
GRANUlAR DRAINAGE LAVER. SOIL
AND VEGETATIVE LAVER.
ESTABliSHES WHEN AN EXPLOSIVE
GAS MONITORING PLAN IS
REQUIRED FOR SOLID WASTE
LANDFILLS. SPECIFIES THE
MINIMUM INFORMATION REQUIRED
IN SUCH A PLAN. INCLUDING
DET AILED ENGINEERING PLANS.
SPECIFICATIONS. INFORMATION ON
GAS GENERATION POTENTIAL.
SAMPLING AND MONITORING
PROCEDURES. ETC. MANDATES
WHEN REPAIRS MUST BE MADE TO
AN EXPLOSIVE GAS MONITORING
SYSTEM. THIS RULE ONLV APPLIES
TO LANDFILLS WHICH RECEIVED
.PUTRESCIBlE. SOLID WASTES.
PROHIBITS ANY FILLING. GRADING.
EXCAVATING. BUILDING. DRILLING
OR MINING ON LAND WHERE A
HAZARDOUS WASTE FACILITY OR
SOLID WASTE FACILITY WAS
OPERATED WITHOUT PRIOR
AUTHORIZATION FROM THE
DIRECTOR. SPECIAL TERMS TO
CONDUCT SUCH ACTIVITIES MAY
BE IMPOSED BY THE DIRECTOR TO
PROTECT THE PUBliC AND THE
ENVIRONMENT.
APPLICATION OF REGUlATION
SUBSTANTIVE REQUIREMENTS
PERTAIN TO ANY NEW SOlID
WASTE LANDFIlLS CREATED ON.
SITE. ANY EXPANSION OF EXISTING
SOLID WASTE LANDFILLS ON.SITE
AND ANY EXIST1NG AREAS OF
CONTAMINA T10N THAT ARE
CAPPED IN.PLACE PER THE SOLIO
WASTE RULES.
PERTAINS TO ANV SITE WHICH HAS
HAD OR WILL HAVE PUTRESCIBlE
SOLID WASTES PLACED ON.SITE
AND WHICH HAS A RESIDENCE OR
OTHER OCCUPIED STRUCTURE
LOCATED WITHIN 1000 FEET OF
THE EMPLACED SOLID WASTE.
PERTAINS TO ANY SITE AT WHICH
HAZARDOUS OR SOLID WASTE HAS
BEEN MANAGED. EITHER
INTENTIONAll V OR OTHERWISE.
DOES NOT PERTAIN TO AREAS
THAT HAVE HAD ONE.T1M( LEAKS
OR SPIlLS.
ARAR TYP£lSt
ACTION
ACT10N
LOCATION
ACT10N
lOCATION
-------
   TABlE V-8  
  SELECTED POTENT1Al APPlICABlE OR RB.EVANT AND APPROPRIAn REQ""'ENTI . STAn OF OHIO 
  OHIO ADMINISTRATIVE CODE COAC'  
 PERTINENT TITlEI   
ON PARAGRAPHS SUBJECT OF REGULATION DESCRIPTION OF REGULATION APPlICA TION OF. REGULATION ARAR TYf'fISI
!1-14 A POST-CLOSURE CARE OF SANITARY SPECIFIES THE REQUIRED POST. SUBSTANTIVE REQUIREMENTS ACTION
  LANDFILL FACILITIES CLOSURE CARE FOR SOliD WASTE PERTAIN TO ANY NEWLY CREATED 
   FACILITIES. INCLUDES CONTINUING SOliD WASTE LANDFillS ON-SITE, 
   OPERATION OF LEACHATE AND ANY EXPANSIONS OF EXISTING 
   SURFACE WATER MANAGEMENT SOliD WASTE LANDFIllS ON.SITE 
   SYSTEMS, MAINTENANCE OF THE AND ANY EXISTING AREAS OF 
   CAP SYSTEM AND GROUND WATER CONTAMINATION THAT ARE 
   MONITORING. CAPPED PER THE SOLID WASTE 
    RULES. 
.21.18 A.D SOlID WASTE INCINERATOR AND ESTABLISHES OPERATIONAL PERTAINS TO ANY SITE AT WHICH ACTION
  COMPOSTING OPERATIONS REQUIREMENTS FOR SOliD WASTE SOliD WASTE WIll BE EITHER 
   INCINERATORS AND COMPOSTING INCINERA TED OR COMPOSTED ON- 
   FACILITIES SITE. 
).11-19 A.Q OPERATION OF SOLID WASTE SPECIFIES GENERAL OPERATIONAL PERTAINS TO ANY NEWLY CREATED ACTION
  DISPOSAL FACILITIES REQUIREMENT FOR SOUD WASTE SOliD WASTE lANDFILL OR ANY 
   LANDFILLS. EXPANSION OF AN EXISTING SOLID 
    WASTE LANDFILL ON-SITE. 
5.31-05  WATER AIR PERMIT CRITERIA FOR A PERMIT TO INSTALL lPn' OR PERTAINS TO ANY SITE THAT WILL ACTION
  DECISION BY THE DIRECTOR PlANS MUST DEMONSTRATE BEST DISCHARGE TO ON-SITE SURFACE 
   AVAILABlE TECHNOlOGY IBATI WATER OR WIll EMIT  
   AND SHAll NOT INTERFERE WITH CONTAMINANTS INTO THE AIR. 
   OR PREVENT THE ATTAINMENT OR  
   MAINTENANCE OF' APPlICABlE  
   AMBIENT AIR QUAUTY  
   STANDARDS.  
45-32-05  WATER QUALITY CRITERIA FOR SPECIFIES SUBSTANTIVE CRITERIA PERTAINS TO ANY SITE THAT HAS ACTION
  DECISION BY THE DIRECTOR FOR SECTION 401 WATER QUALITY OR WU AFFECT WATERS OF THE 
   CRITERIA FOR DREDGING, FILLING, STATE. 
   OBSTRUCTIONS OR Al TERINO  
   WATERS OF THE STATE.  
-------
   TARE V..  
  SElECTED POTENTIAL APPlICABlE OR RElEVANT AND APPROPRIATE REQUIREMENTS . STATE OF OHIO 
  OHIO ADMINIST1'A TIVE CODE 10ACI  
OAC PERTINENT TlTlEI   
CITATION PARAGRAPHS SUBJECT OF REGULATION DESCRIPTION OF REGUlATION APPlICATION OF REGULATION ARAR TYPEISt
3145.5C).221 A.B . PETITIONS TO EXCLUDE A LISTED ALLOWS FOR PETITIONS TO PERTAINS TO ANY SITE WHICH HAS ACTION
  WASTE AT A FACILITY EXCLUDE HAZARDOUS WASTES WASTES THAT WIlL BE DElISTED 
   FROM A PARTICULAR FACILITY BY USEPA. SHOULD OHIO LIST 
   FROM THE LISTS IN RULES 3145.51- WASTES NOT ADDRESSED BY 
   30 TO 3145.51-31 OF THE DAC. USEPA. THIS RULE WOULD ALLOW 
   ALSO STATES THAT OHIO EPA Will OHIO EPA THE OPPORTUNITY TO 
   RECOGNIZE USEPA'S DECISION TO DELIST THESE WASTES. 
   GRANT OR DENY SUCH PETITIONS  
   ON THE FEDERAL LEVEL.  
3145-5C).311 A.B.C RECYCLING VARIANCES FROM   
  CLASSIFICATION AS A WASTE   
3145.50.312 A.B.C STANDARDS AND CRITERIA FOR PRESENTS CRITERIA BY WHICH PERTAINS TO ANY SITE THAT HAS ACTION.
  VARIANCES FROM CLASS AS A DIRECTOR MAY GRANT REOUESTS WASTES THAT MAY BE RECYCLED CHEMICAL
  WASTE FOR VARIANCE FROM CLASSIFYING OR RECLAIMED. 
   CERTAIN MATERIALS AS WASTE.  
3145.5C).315 A AOO'l REG OF CERTAIN HAZ WASTE DIRECTOR MAY REGULATE PERTAINS TO ANY SITE THAT HAS ACTION
  RECYCLING ACTIVITIES HAZARDOUS WASTES OTHERWISE HAZARDOUS WASTES THAT WILL CHEMICAL
   EXEMPTED BECAUSE OF RECYCLING BE EXEMPTED FROM THE 
   ACTIVITIES AS HAZARDOUS WASTE HAZARDOUS WASTE RULES PER 
   ON A CASE.BY-CASE BASIS. THE OAC 3145-51-08 (RECYCLING 
   CRITERIA TO MAKE THIS DECISION EXEMPTIONSt. 
   ARE PROVID£D BY THIS RULE.  
3145.5C).44 A PERMIT INFO REQUIRED FOR ALL ESTABliSHES THE SUBSTANTIVE PERTAINS TO ANY SITE WHICH Will ACTION
  HAZ WASTE FACILITIES HAZARDOUS WASTE PERMIT HAVE TREATMENT, STORAGE OR 
   REQUIREMENTS NECESSARY FOR DISPOSAL OF HAZARDOUS WASTE 
   OHIO EPA TO DETERMINE FACILITY OCCURRING ON-SITE OR HAS 
   COMPliANCE. INClUD£S EXISTING AREAS OF HAZARDOUS 
   INFORMATION SUCH AS FACILITY WASTE CONTAMINATION ON-SITE 
   DESCRIPTION. WASTE THAT WILL BE CAPPED IN-PlACE. 
   CHARACTERISTICS. EQUIPMENT THIS, ALONG WITH OTHER 
   DESCRIPTIONS. CONTINGENCY PARAGRAPHS Of THIS RULE, 
   PlAN. FACILITY LOCATION, EST ABLISHES THE MINIMUM 
   TOPOGRAPHIC MAP. ETC. INFORMATION REQUIRED DURING 
    THE REMEDIAL DESIGN STAGE. 
-------
OAC
CITATION
PERTINENT
PARAGRAPHS
3745-50-44
B
3745-50.44
C1
3745-50-44
C2
TAIlEV..
BmCTED POTENTIAL APPlICAIlE OR RnEVANT AND AI'PROPRIAftRfOtMEMENT'- BTAft OF OHIO
OHIO ADMINISTRATIVE CODE COAC,
TlTlEI
SUBJECT OF REGULA TlON
PERMIT INFO REQ FOR ALL HAZ
WASTE LAND D'SP FACILITIES
ADD'L PERMIT INFO: HAZ WASTE
STORAGE IN CONTAINERS
ADD'l PERMIT INFO: HAZ WASTE
STORAGEITREAT IN TANKS
DESCRIPTION OF REGULATION
ESTABLISHES THE SUBSTANTIVE
HAZARDOUS WASTE LAND
DISPOSAL PERMIT REQUIREMENTS
NECESSARY FOR OHIO EPA TO
DETERMINE ADEQUATE
PROTECTION OF THE GROUND
WATER- INCLUDES INFORMATION
SUCH AS GROUND WATER
MONITORING DATA, INFORMATION
ON INTERCONNECTED AQUIFERS,
PlUMEIS, OF CONTAMINATION,
PlANS AND REPORTS ON GROUND
WATER MONITORING PROGRAM.
ETC.
ESTABliSHES THE SUBSTANTIVE
HAZARDOUS WASTE PERMIT
REQUIREMENTS NECESSARY FOR
OHIO EPA TO DETERMINE
ADEQUACY OF CONTAINER
STORAGE. INClUDfS INFORMATION
SUCH AS DESCRIPTION OF
CONTAINMENT SYSTEM, DETAILED
DRAWINGS, ETC. SEE OAC 3745-
55.70 THROUGH 3745-55.78 FOR
ADDITIONAL CONTAINER
REQUIREMENTS,
ESTABlISHES SUBSTANTIVE
HAZARDOUS WASTE PERMIT
REQUIREMENTS NECESSARY FOR
OHIO EPA TO DETERMINE
ADEQUACY OF TANK TREATMENT
AND STORAGE UNITS, INCLUDES
INFORMA TlON SUCH AS
ASSESSMENT OF STRUCTURAL
INTEGRITY, DETAILED PlANS OF
TANK SYSTEMIS,. DESCRIPTION OF
SECO,.coARY CONTAINMENT
SYSTEM, ETC. SEE OAC 3745-55.
90 THROUGH 3745-55.99 FOR
ADDITIONAL REQUIREMENTS.
APPlICATION OF REGULATION
ARAR TYPEISI
PERTAINS TO ANY FACIlITYISITE
WHICH WIll HAVE TREATMENT,
STORAGE OR DISPOSAL OF
HAZARDOUS WASTE OCCURRING
ON-SITE OR HAS EXISTING AREAS
OF HAZARDOUS WASTE
CONTAMINATION ON-SITE THAT
WILL BE CAPPED IN-PlACE. THIS,
ALONG WITH OTHER PARAGRAPHS
OF THIS RULE, ESTABlISHES THE
MINIMUM INFORMATION REQUIRED
DURING THE REMEDIAL DESIGN
STAGE.
ACTION
PERTAINS TO ANY SITE AT WHICH
STORAGE OF HAZARDOUS WASTE
ON-SITE WILL OCCUR IN
CONTAINERS. CONSIDER FOR
WASTES AND CONTAMINATED
SOILS THAT ARE STORED PRIOR TO
TREATMENT OR DISPOSAL, THIS,
ALONG WITH OTHER PARAGRAPHS
OF THIS RULE AND OAC 3745-55- 70
THROUGH 3745-55-78.
ESTA8llSHES THE MINIMUM
INFORMATION REQUIRED DURING
THE REMEDIAL DESIGN STAGE.
ACTION
PERTAINS TO ANY SITE AT WHICH
STORAGE OR TREATMENT OF
HAZARDOUS WASTE IN TANKS Will
qcCUR ON-Sift. THIS. ALONG
WITH OTHER PARAGRAPHS OF THIS
RULE AND OAC 3745-55-90
THROUGH 3745-55-91.
ESTABlISHES THE MINIMUM
INFORMA TlON REQUIRED DURING
THE REMEDIAL DESIGN STAGE.
ACTION
-------
OAC
CIT A TION
PERTINENT
PARAGRAPHS
3745.50-44
C4
3745.50-44
C8
. TA_I V"
8n£cno POTENTIAL APPLICABLE OR RREVANT AND APPROPRIATE REQUIREMENTS. STATE OF OHIO
ottO ADMINISTRATIVE CODE 100Ct
TITLEt
SUBJECT OF REGULATION
ADD'L PERMIT INFO: HAZ WASTE
STOREITREAT IN WASTE PILES
ADD'L PERMIT INFO:
ENVIRONMENTAL PERFORMANCE
STANDARDS
DESCRIPTION OF REGULATION
ESTABliSHES SUBSTANTIVE
HAZARDOUS WASTE PERMIT
REQUIREMENTS NECESSARY FOR
OHIO EPA TO DETERMINE
ADEQUACY OF WASTE PILES USED
TO TREAT OR STORE HAZARDOUS
WASTE. INCLUDES INFORMATION
. SUCH AS WASTE
CHARACTERISTICS, DETAILED
DESIGN PlANS AND REPORTS,
CONTROL OF RUN-ON AND RUN-
OFF. CLOSURE INFORMATION. ETC.
SEE OAC 3745-58-50 THROUGH
3745-58-80 FOR ADDITIONAL
WASTE PILE REQUIREMENTS.
ESTABliSHES SUBSTANTIVE
HAZARDOUS WASTE PERMIT
REQUIREMENTS NECESSARY FOR
OHIO EPA TO DETERMINE
ADEQUACY OF WASTE PILES USED
TO TREAT OR STORE HAZARDOUS
WASTE. INCLUDES INFORMATION
SUCH AS WASTE
CHARACTERISTICS. DETAILED
DESIGN PlANS AND REPORTS,
CONTROL OF RUN-ON AND RUN-
OFF. CLOSURE INFORMATION, ETC.
SEE OAC 3745.58-50 THROUGH
374S-58-80 FOR ADDITIONAL
WASTE PILE REQUIREMENTS,
APPI-ICA "ON OF REGULATION
ARAR TYP£ISI
PERTAINING TO SITE AT WHICH
HAZARDOUS WASTE WILL BE
STORED OR TREATED IN WASTE
PILES. THIS. ALONG WITH OTHER
PARAGRAPHS OF THIS RULE AND
OAC 3745-58-50 THR()UGH 3745.
58-80. ESTABliSHES THE MINIMUM
INFORMATION REQUIRED ,DURING
THE REMEDIAL DESIGN STAGE.
CONSIDER FOR SITES AT WHICH
STOCKPILING OF WASTES AND
CONT AMINATED SOILS PRIOR TO
TREATMENT OR DISPOSAL WILL
OCCUR.
ACTION
PERTAINS TO SITES AT WHICH
HAZARDOUS WASTE WILL BE OR
HAVE BEEN STORED. TREATED OR
DISPOSED OF IN SURFACE
IMPOUNDMENTS. WASTE PILES.
LAND TREATMENT UNITS.
lANDFillS OR UNDERGROUND
INJECTION WEllS, THIS. ALONG
WITH OTHER PARAGRAPHS OF THIS
RULE AND OAC 3745-58-50
THROUGH 374S-58-80.
ESTABliSHES THE MINIMUM
INFORMATION REQUIRED DURING
THE REMEDIAL DESIGN STAGE.
ACTION
-------
OAC
CITATION
3745-50-44
3745-50-44
PERTINENT
PARAGRAPHS
C7
C8
T AIlE V-8
SElECTED POTENTIAl APPlICABlE OR RElEVANT AND APPROPRIATE REQUIREMENTS. STATE OF OHIO
OHIO ADMINISTRATIVE COOE rOACt
TITlE'
SUBJECT OF REGULATION
ADD'L PERMIT INFO: HAl WASTE
DISPOSAL IN LANDFILLS
ADD'L PERMIT INFO: HAl WASTE
TREATMENT BY INCINERATION
DESCRIPTION OF REGULATION
ESTABLISHES SUBSTANTIVE
HAZARDOUS WASTE PERMIT
REQUIREMENTS NECESSARY FOR
OHIO EPA TO DETERMINE
ADEQUACY OF WASTE PILES USED
TO TREAT OR STORE HAlARDOUS
WASTE. INCLUDES INFORMATION
SUCH AS WASTE
CHARACTERISTICS, DETAILED
DESIGN PLANS AND REPORTS,
CONTROl OF RUN-ON AND RUN-
OFF, CLOSURE INFORMATION, ETC.
SEE OAC 3745-58-50 THROUGH
3745-58-80 FOR ADDITIONAL
WASTE PILE REQUIREMENTS.
ESTABLISHES SUBSTANTIVE
HAZARDOUS WASTE PERMIT
REQUIREMENTS NECESSARY FOR
OHIO EPA TO DETERMINE
ADEQUACY OF WASTE PILES USED
TO TREAT OR STORE HAZARDOUS
WASTE. INCLUDES INFORMATION
SUCH AS WASTE
CHARACTERISTICS, OfT AILED
DESIGN PLANS AND REPORTS,
CONTROL OF RUN-ON AND RUN.
OFF, CLOSURE INFORMATION, ETC.
SEE OAC 3745-58-50 THROUGH
3745-58-80 FOR ADDITIONAL
WASTE PILE REQUIREMENTS.
APPLICA TlON OF REGULATION
PERTAINS TO SITES AT WHICH
HAZARDOUS WASTES WILL BE OR
HA VE BEEN DISPOSED OF IN
LANDFILLS, THIS, ALONG WITH
OTHER PARAGRAPHS OF THIS RULE
AND OAC3745-58-50 THROUGH
3745-58.80, ESTABLISHES THE
MINIMUM INFORMATION REQUIRED
DURING THE REMEDIAL DESIGN
STAGE.
PERTAINS TO SITES AT WHICH
HAZARDOUS WASTES WILL BE
TREATED BY INCINERATION. THIS,
ALONG WITH OTHER PARAGRAPHS
OF THIS RULE AND OAC3745-56-SO
THROUGH 3745-58-80,
ESTABLISHES THE MINIMUM
INFORMATION REQUIRED DURING
THE REMEDIAL DESIGN STAGE.
, '
ARAR TYPElSt
ACTION
ACTION
-------
   TABlE V..  
  SnECffD POTENTIAL APPlICABlE OR RREVANT AND APPROPRlAff REQUIREMENTS. STAff OF OHIO 
  0..0 AOM..ISTRA11VE CODE COACI  
OAC PERTINENT TITlEt   
CIT A TlON PARAGRAPHS SUBJECT OF REGULATION DESCRIPTION Of REGULA TIO" APPliCATION OF REGULATIO" ARM TYPEISI
3745-50.44 C9 AOD'L PERMIT INFO: HAS WASTE ESTABliSHES SUBSTANTIVE PERT AINS TO SITES AT WHICH ACTION
  T tSlD IN MISC UNITS HAZARDOUS WASTE PERMIT HAZARDOUS WASffS WILL BE 
   REQUIREMENTS NECESSARY FOR STORED, TREATED OR DISPOSED OF 
   OHIO EPA TO DETERMINE IN MISCELLANEOUS UNITS. THIS, 
   ADEQUACY OF WASTE PILES USED ALONG WITH OTHER PARAGRAPHS 
   TO TREAT OR STORE HAZARDOUS OF THIS RULE AND OAC3746-58-5O 
   WASTE. INCLUDES INFORMATION THROUGH 3745-58-80. 
   SUCH AS WASTE ESTABliSHES THE MINIMUM 
   CHARACTERISTICS. DETAILED INFORMATION REQUIRED DURING 
   DESIGN PlANS AND REPORTS. THE REMEDIAL DESIGN STAGE, 
   CONTROl OF RUN. ON AND RUN.  
   OFF, CLOSURE INFORMATION. ETC.  
   SEE OAC 3745-58-50 THROUGH  
   3745.58.80 FOR ADDITIONAL  
   WASTE PILE REQUIREMENTS.  
3745.50-58 A, E, H.J HAZARDOUS WASTE FACILITY ESTABLISHES GENERAL PERMIT PERTAINS TO ALL ALTERNATIVES ACTION
  PERMIT CONDITIONS CONDITIONS APPliED TO ALL THAT WILL INCORPORATE 
   HAZARDOUS WASTE FACILITIES IN TREATMENT. STORAGE OR 
   OHIO. INCLUDES CONDITIONS DISPOSAL OF HAZARDOUS WASTE. 
   SUCH AS OPERATION AND  
   MAINTENANCE. SITE ACCESS,  
   MONITORING, ETC.  
3745-50.82 A,B,C,D TRIAL BURN FOR INCINERATORS SPECIFIES REQUIREMENTS OF A PERTAINING TO ANY ALTERNATIVE ACTION
   TRIAL BURN INCORPORATING ON-SITE 
    INCINERATION. 
3745.51.08 A,B REQUIREMENTS FOR RECYCLED DEFINES RECYCLED HAZARDOUS PERTAINS TO ANY SITE AT WHICH ACTION
  MATERIALS WASTES AND ESTABliSHES RECYCLING Of HAZARDOUS CHEMIcAL
   SPECIFIC EXEMPTIONS FOR THESE WASTES MAY TAKE PlACE. 
   WASTES FROM THE HAZARDOUS CONSIDER FOR SITES AT WHICH 
   WASTE REGULATIONS. THE FOLLOWING MATERIALS ARE 
    PRESENT: INDUSTRIAL ETHYl 
    ALCOHOL; USED BAnERIES;-USEO 
    OIL; SCRAP METAL: PETROLEUM 
    PRODUCTS; KOB7 COAL AND COKE 
    TAR SLUDGE, 
-------
   TAb&.iE V-I  
  SRECTED POTENTIAL APPlICABlE OR RElEVANT AND APPROPRIATE REQUIREMENTS. STATE OF OHIO 
  0..0 ADMINISTRATIVE CODE (OAC,  
OAC PERTINENT TlTlEI   
CITATION PARAGRAPHS SUBJECT OF REGULA TlON DESCRIPTION OF REGULATION APPLICATION OF REGULATION ARAR TYPE(SI
3745-51-07 A,B RESIDUES OF HAl WASTES IN EXEMPTS THE RESIDUES OF PERTAINS TO ANY ALTERNATIVE ACTION
  EMPTY CONTAINERS HAZARDOUS WASTES FROM EMPTY THAT INCORPORATES STORAGE OF 
   CONTAINERS FROM THE HAZARDOUS WASTE ON-SITE IN 
   HAZARDOUS WASTE REGULATIONS. CONTAINERS. 
   PROVIDES SPECIFIC DEFINITIONS  
   FOR THESE RESIDUES.  
3745.52-11 A-F EVALUATfON OF WASTES ANY PERSON GENERATING A PERTAINS TO SITES AT WHICH CHEMICAL
   WASTE MUST DETERMINE IF THAT WASTES OF ANY TYPE (BOTH SOLID 
   WASTE 15 A HAZARDOUS WASTE AND HAZARDOUS' ARE lOCATED. 
   (EITHER THROUGH LISTING OR  
   CHARACTERISTIC'.  
3745.54-13 A GENERAL ANALYSIS OF PRIOR TO ANY TREATMENT, PERTAINS TO ANY SITE AT WHICH CHEMICAL
  HAZARDOUS WASTE STORAGE OR DISPOSAL OF HAZARDOUS WASTE IS TO BE 
   HAZARDOUS WASTES, A TREATED, STORED OR DISPOSED OF 
   REPRESENT A JIVE SAMPLE OF THE (OR HAS BEEN DISPOSED OF'. 
   WASTE MUST BE CHEMICAllY AND  
   PHYSICAllY ANALYZED.  
3745.54-14 A,B,C SECURITY FOR HAZARDOUS WASTE HAZARDOUS WASTE FACILITIES PERTAINS TO ANY SITE AT WHICH ACTION
  FACILITIES MUST BE SECURED SO THAT HAZARDOUS WASTE IS TO BE 
   UNAUTHORIZED AND UNKNOWING TREATED, STORED OR DISPOSED OF 
   ENTRY ARE MINIMIZED OR (OR HAS BEEN DISPOSED OF'. 
   PROHIBITED.  
3745-54-15 A,C INSPECTION REQUIREMENTS FOR HAZARDOUS WASTE FACILITIES PERTAINING TO ANY SITE AT ACTION
  HAZARDOUS WASTE FACILITIES MUST BE INSPECTED REGULARLY WHICH HAZARDOUS WASTE IS TO 
   TO DETECT MALFUNCTIONS, BE TREATED, STORED OR DISPOSED 
   DETERIORATIONS, OPERATIONAL OF (OR HAS BEEN DISPOSED OF.. 
   ERRORS AND DISCHARGES. ANY  
   MALFUNCTIONS OR  
   DETERIORATIONS DETECTED SHAll  
   BE REMEDIED EXPEDITIOUSLY.  
3745-54-17 A,B,C REO FOR IGNITABLE, REACTIVE OR PRESENTS GENERAL PRECAUTIONS PERTAINS TO ANY SITE AT WHICH ACTION
  INCOMPATIBLE HAl WASTES TO BE TAKEN TO PREVENT POTENTIAllY REACTIVE, IGNITABLE lOCATION
   ACCIDENT AllGNITION OR OR INCOMPATIBLE WASTES ARE 
   REACTION OF IGNITABLE. REACTIVE PRESENT. 
   OR INCOMPATIBLE WASTES.  
-------
TAIlE V-8
8B.ECTED POTENTIAL APPlICABlE OR RREVANT AND APPROPRIATE REQUIREMENTS. STATE Of OlIO
ottO ADM..ISTRATIVE CODE COAC,
OAC
CITATION
PERTINENT
PARAGRAPHS
TITlEI
SUBJECT OF REGULATION
3745-54-18
A.B,e
LOCATION STANDARDS FOR
HAZARDOUS WASTE TlSID
FACILITIES
3745-54-31
DESIGN AND OPERATION OF
HAZARDOUS WASTE FACILITIES
DESCRIPTION OF REGULATION
RESTRICTS THE SITING OF .
HAZARDOUS WASTE FACILITIES IN
AREAS OF SEISMIC ACTIVITY OR
FLOODPlAINS.
HAZARDOUS WASTE FACILITIES
MUST BE DESIGNED,
CONSTRUCTED, MAINTAINED AND
OPERATED TO MINIMIZE THE
POSSIBILITY OF FIRE, EXPlOSION OR
UNPlANNED RELEASE OF
HAZARDOUS WASTE OR
HAZARDOUS CONSTITUENTS TO
THE AIR. SOIL OR SURFACE WATER
WHICH COULD THREATEN HUMAN
HEALTH OR THE ENVIRONMENT
APPliCATION OF REGULATION
ARAR TYP£ISI
PERTAINS TO ANY SITE AT WHICH
HAZARDOUS IS TO BE TREATED,
STORED OR DISPOSED OF COR HAS
BEEN DISPOSED Oft.
LOCA TlON
PERT AINING TO ANY SITE AT
WHICH HAZARDOUS WASTE IS TO
BE TREATED STORED OR DISPOSED
OF COR HAS BEEN DISPOSED OFt.
ACTION
3745-54-32 A,B,C,D REQUIRED EQUIPMENT FOR ALL HAZARDOUS WASTE FACILITIES PERTAINS TO ANY SITE AT WHICH ACTION
  HAZARDOUS WASTE FACILITIES MUST BE EQUIPPED WITH HAZARDOUS WASTE IS TO BE 
   . EMERGENCY EQUIPMENT, SUCH AS TREATED, STORED OR DISPOSED OF 
   AN ALARM SYSTEM, FIRE CONTROL COR HAS BEEN DISPOSED Oft. 
   EQUIPMENT AND A TELEPHONE OR  
   RADIO.  
3745-54-33  TESTING AND MAINTENANCE OF All HAZARDOUS WASTE FACILITIES PERTAINS TO ANY SITE AT WHICH ACTION
  EQUIPMENT: HAl WASTE FACILITIES MUST TEST AND MAINTAIN HAZARDOUS WASTE IS TO BE 
   EMERGENCY EQUIPMENT TO TREATED, STORED OR DISPOSED OF 
   ASSURE PROPER OPERATION. COR HAS BEEN DISPOSED Oft. 
3745-54-34  ACCESS TO COMMUNICATIONS OR WHENEVER HAZARDOUS WASTE IS PERTAINS TO ANY SITE AT WHICH ACTION
  ALARM SYSTEM: HAZ WASTE FAC BEING HANDLED, ALL PERSONNEL HAZARDOUS WASTE IS TO BE 
   INVOlVED SHALL HAVE IMMEDIATE TREATED, STORED OR DISPOSED OF 
   ACCESS TO AN INTERNAL ALARM COR HAS BEEN DISPOSED OF'. 
   OR EMERGENCY COMMUNICATION  
   DEVICE.  
-------
   TA8LEV-8  
  SB.ECTm POTENTIAl APPlICABLE OR RELEVANT AND APPROPRIATE REQUIREMENTS. STATE Of OttO 
  OHIO ADMINISTRATIVE COOE COACt  
OAC PERTINENT TITLE/   
CITA TlON PARAGRAPHS SUBJECT OF REGULATION DESCRIPTION OF REGULATION APPLICATION OF REGULATION ARAR TYPEISt
3145.54-35  REQUIRED AISLE SPACE AT HAZ ADEQUATE AISLE SPACE SHALL BE PERTAINING TO ANY SITE AT ACTION
  WASTE FACILITIES MAINTAINED TO ALLOW WHICH HAZARDOUS WASTE IS TO 
   UNOBSTRUCTED MOVEMENT OF BE TREATED. STORED OR DISPOSED 
   PERSONNEL, FIRE EQUIPMENT. SPILL OF lOR HAS BEEN DISPOSED OFt. 
   CONTROL EQUIPMENT AND CONSIDER FOR SITES WHERE 
   DECONTAMINATION EQUIPMENT WASTES WILL BE STORED IN 
   INTO ANY AREA OF THE FACILITY CONTAINERS. 
   OPERATION IN THE EVENT OF AN  
   EMERGENCY.  
3745.54-37 A ARRANGEMENTS/AGREEMENTS ARRANGEMENTS OR AGREEMENTS PERTAINING TO ANY SITE AT ACTION
  WITH LOCAL AUTHORITIES WITH LOCAL AUTHORITIES, SUCH WHICH HAZARDOUS WASTE IS TO 
   AS POLICE, FIRE DEPARTMENT AND BE TREATED. STORED OR DISPOSED 
   EMERGENCY RESPONSE TEAMS OF COR HAS BEEN DISPOSED OFt. 
   MUST BE MADE. IF LOCAL  
   AUTHORITIES WILL NOT  
   COOPER A TE. DOCUMENT A TlON OF  
   THAT NON.COOPERA TION SHOULD  
   BE PROVIDED.  
3745.54-52 A.F CONTENT OF CONTINGENCY PLAN; HAZARDOUS WASTE FACILITIES PERTAINS TO ANY SITE AT WHICH ACTION
  HAZ WASTE FACILITIES MUST HAVE A CONTINGENCY PLAN HAZARDOUS WASTE IS TO BE 
   THAT AODRESSES ANY UNPLANNED TREATED. STORED OR DISPOSED OF 
   RELEASE OF HAZARDOUS WASTES COR HAS BEEN DISPOSED OFt. 
   OR HAZARDOUS CONSTITUENTS  
   INTO THE AIR. SOIL OR SURFACE  
   WATER. THIS RULE ESTABLISHES  
   THE MiNIMUM REQUIRED  
   INFORMATION OF SUCH A PLAN.  
3745.54.54 A AMENDMENT OF CONTINGENCY THE CONTINGENCY PLAN MUST BE PERTAINS TO ANY SITE AT WHICH ACTION
  PLAN; HAZ WASTE FACILITIES AMENDED IF IT FAILS IN AN HAZARDOUS WASTE IS TO BE 
   EMERGENCY. THE FACILITY TREATED. STORED OR DISPOSED OF 
   CHANGES CIN ITS DESIGN. COR HAS BEEN DISPOSED OFt. 
   CONSTRUCTION, MAINTENANCE OR  
   OPERATIONt. THE LIST OF  
   EMERGENCY COORDINATORS  
   CHANGE OR THE LIST OF  
   EMERGENCY EQUIPMENT.  
-------
OAC
CITATION
3145.54-55
3145.54-58
3145.54-91
3145-54-92
3145.54-93
PERTINENT
PARAGRAPHS
A.1
A
A,B
TABlE v..
.ElECTED POTENTIAl APPUCAIlE OR RElEVANT AND APflROPRIA1£ REQUIREMENT. . STA1£ OF OHIO
OttO ADMINISTRATIVE CODE COACt
mlEl
SUBJECT OF REGULATION
EMERGENCY COORDINATOR;
HAZARDOUS WASTE FACILITY
EMERGENCY PROCEDURES;
HAZARDOUS WASTE FACILITIES
REQ GROUND WATER PROGRAMS
FOR HAl WASTE FACILITIES
GROUND WATER PROTECTION
STANDARD; HAZ WASTE FACILITIES
HAZARDOUS CONSTITUENTS IN
GROUND WATER, HAZ WASTE FAC
DESCRIPTION OF REGULATION
AT ALL TIMES THERE SHOULD BE
AT LEAST ONE EMPlOYEE EITHER
ON THE PREMISES OR ON CALL TO
. COORDINATE ALL EMERGENCY
RESPONSE MEASURES.
SPECIFIES THE PROCEDURES TO BE
FOLLOWED IN THE EVENT OF AN
EMERGENCY.
PRESENTS THE GROUND WATER
MONITORING AND RESPONSE
PROGRAMS REQUIRED OF
HAZARDOUS WASTE LAND-BASED
UNITS.
COMPliANCE MUST BE ATTAINED
WITH THE CONDITIONS SPECIFIED
IN THE PERMIT TO ENSURE THAT
HAZARDOUS CONSTITUENTS eSEE
3145-54.93t DO NOT EXCEED THE
PROMULGATED LIMITS eSEE 3145-
54-94t.
REQUEST THAT PERMIT SPECIFY
HAZARDOUS CONSTITUENTS TO
WHICH THE GROUND WATER
PROTECTION STANDARD OF 3145-
54-92 APPliES. HAZARDOUS
CONSTITUENTS ARE CONSTITUENTS
IDENTIFIED IN THE APPENDIX OF
THIS RULE THAT HAVE BEEN
DETECTED IN GROUND WATER IN
THE UPPERMOST AQUIFER
UNDERLYING THE UNIT eSt AND ARE
REASONABLY EXPECTED TO BE IN
OR OERIVED FROM WASTE
CONTAINED IN THE UNITeSt.
APPLICATION OF REGULATION
PERTAINS TO ANY SITE AT WHICH
HAZARDOUS WASTE IS TO BE
TREATED, STORED OR DISPOSED OF
eOR HAS BEEN DISPOSED OFI.
PERTAINS TO ANY SITE AT WHICH
HAZARDOUS WASTE IS TO BE
TREATED, STORED OR DISPOSED OF
COR HAS BEEN DISPOSED OFt.
PERTAINS TO ALL SITES WITH
LAND-BASED HAZARDOUS WASTE
UNITS eSURFACE IMPOUNDMENTS,
WASTE PILES, LAND TREATMENT
UNITS, LANDFILLSI. THIS INCLUDES
EXISTING LAND-BASED AREAS OF
CONT AMINA TION.
PERTAINS TO ALL SITES WITH
lAND-BASED HAZARDOUS WASTE
UNITS eSURFACE IMPOUNDMENTS,
WASTE PILES, LAND TREATMENT
UNITS, LANDFllLSI. THIS INCLUDES
EXISTING LAND-BASED AREAS OF
CONT AMiNA TION.
PERTAINS TO All SITES WITH
LAND-BASED HAZARDOUS WASTE
UNITS eSURFACE IMPOUNDMENTS,
WASTE PILES, LAND TREATMENT
UNITS, lANDRllSt. THIS INCLUDES
EXISTING LAND.BASED AREAS OF
CONTAMINATION.
ARAR TYPE eSt 
ACTION
ACTION
ACTION
ACTION
CHEMICAL
CHEMICAL
-------
   TAIlE V-8  
  SELECTED POTENTIAL APPLICABLE OR RREVANT AND APPROPRIATE REQUIREMENTS - STATE Of OHIO 
  OHIO ADMINISTRATIVE CODE COACt  
OAC PERTINENT TITlEI   
CIT A TION PARAGRAPHS SUBJECT OF REGULATION DESCRIPTION OF REGULATION APPliCATION OF REGULATION ARAR TYPEISI
2134.54.94 A,B CONCENTRA TlON LIMITS FOR PRESENTS THE METHODOLOGY FOR PERTAINS TO ALL SITES WITH CHEMCAL
  GROUND WATER. HAl WASTE FAC DETERMINING CONCENTRATION LAND-BAS~D HAZARDOUS WASTE 
   LIMITS AND Al TERNA TIVE UNITS CSURFACE IMPOUNDMENTS, 
   CONCENTRATION LIMITS WASTE PlLES,LAND TREATMENT 
    UNITS, LANDFILLS'. THIS INCLUDES 
    EXISTING LAND-BASED AREAS OF 
    CONTAMINATION 
3745.54-95 A,B POINT OF COMPliANCE FOR ESTABliSHES POINT OF PERTAINS TO ALL SITES WITH ACTION
  GROUND WATER, HAZ WASTE FAC COMPLIANCE AT VERTICAL LAND-BASED HAZARDOUS WASTE CHEMICAL
   SURFACE LOCATED AT THE UNITS CSURFACE IMPOUNDMENTS, 
   HYDRAULICAllY DOWNGRADIENT WASTE PILES, LAND TREATMENT 
   LIMIT OF THE WASTE UNITS, LANDFILLS'. THIS INCLUDES 
   MANAGEMENT AREA THAT EXISTING LAND-BASED AREAS OF 
   EXTENDS DOWN INTO THE CONTAMINATION. 
   UPPERMOST AQUIFER UNDERLYING  
   THE UNITIS,.  
3745-54-98 A.B,C COMPLIANCE PERIOD FOR GROUND A COMPLIANCE PERIOD DURING PERTAINS TO All SITES WITH ACTION
  WATER; HAZ WASTE FAC WHICH THE GROUND WATER LAND-BASED HAZARDOUS WASTE CHEMICAL
   PROTECTION STANDARDS APPlY UNITS CSURFACE IMPOUNDMENTS, 
   WILL BE SPECIFIED IN THE PERMIT. WASTE PILES, LAND TREATMENT 
    UNITS, LANDFILLS'. THIS INCLUDES 
    EXISTING LAND.BASED AREAS OF 
    CONTAMINATION. 
3745.54-97 A-H GEN GROUND WATER MONITORING PRESENTS GENERAL GROUND PERTAINS TO ALL SITES WITH ACTION
  REQUIREMENTS; HAZ WASTE FAC WATER MONITORING PROGRAM LAND-BASED HAZARDOUS WASTE CHEMICAL
   REQUIREMENTS. INCLUDES UNITS CSURFACE IMPOUNDMENTS, 
   NUMBER, LOCATION AND DEPTH OF WASTE PILES, LAND TREATMENT 
   WEllS, CASING REQUIREMENTS, UNITS, LANDFillS'. THIS INCLUDES 
   SAMPLING AND ANALYSIS EXISTING LAND-BASED AREAS OF 
   PROCEDURES, ETC. CONTAMINATION. 
-------
   TAbLE V..  
  SElECTED POTENTIAL APPlICABlE OR RnEVANT AND APPROPRIATE REQtRAEMENTS . STATE OF OHIO 
  OHIO ADMINISTRATIVE CODE COACt  
OAC PERTINENT TITLEI    
CITATION PARAGRAPHS SUBJECT OF REGULATION DESCRIPTION OF REGULATION APPlICATION OF REGULATION AMR I YPfISI
3745-54-98 A-I GROUND WATER DETECTION PRESENTS REQUIREMENTS OF PERTAINS TO ALL SITES WITH ACTION
  MONITORING PROG: HAZ WASTE GROUND WATER DETECTION LAND-BASED HAZARDOUS WASTE CHEMICAL
  fAC PROGRAM UNITS .SURFACE IMPOUNDMENTS, 
     WASTE PIlfS, LAND TREATMENT 
     UNITS,LANDFllLSI: AT WHICH 
     HAZARDOUS CONSTITUENTS HAVE 
     NOT BEEN DETECTED IN THE 
     GROUND WATER. THIS INCLUDES 
     EXISTING LAND-BASED AREAS OF 
     CONTAMINATION. 
3745-54-99 A-J GROUND WATER COMPliANCE PRESENTS REQUIREMENTS OF PERTAINS TO All SITES WITH ACTION
  MONITORING PROG: HAZ WASTE GROUND WATER COMPliANCE LAND. BASED HAZARDOUS WASTE CHEMICAL
  FAC MONITORING PROGRAM. UNITS CSURFACE IMPOUNDMENTS, 
     WASTE PILES, LAND TREATMfNT 
     UNITS, lANDFILlSI; AT WHICH 
     HAZARDOUS CONSTITUENTS HAVE 
     BEEN DETECTED IN THE GROUND 
     WATER. THIS fNCLJDES EXISTING 
     LAND.BASED AREAS Of 
     CONTAMINATION. 
3745.65-01 A-F GROUND WATER CORRECTIVE PRESENTS THE REQUIREMfNTS OF PERTAINS TO All SITES WITH ACTION
  ACTION PROGRAM; HAl WASTE A GROUND WATER CORRECTIVE LAND-BASED HAZARDOUS WASTE CHEMICAL
  FAC ACTION PROGRAM THAT PREVENTS UNITS CSURFACE IMPOUNDMENTS, 
   HAZARDOUS CONSTITUENTS FROM WASTE PIlES, LAND TREATMENT 
   EXCEEDING THEIR RESPECTIVE UNITS, lANDFILLS I AT WHICH 
   I ,.~I('ENTRATfON LIMITS AT THE HAZARDOUS CONSTITUENTS HAVE 
    . ANCE POINT BY EITHER BEEN DETECTED IN THE GROUND 
   AI' ".\l OR TREATMfNT OF WATER. THIS INCLUDES EXISTING 
   THI:!.1 IIAZARDOUS LAND-BASED AREAS OF 
   CONSTITUENTS. CONT AMfNATlON. 
-------
)AC
!M!Q!!
PERTINENT
PARAGRAPHS
745-55-11
A,B,C
3745-55-12
B
3745-55-14
3745-55-18
TA81E V"
8RECTED POTENTIAL APPlICA81E OR RelEVANT AND APPROPRIATE REQUIREMENT8 - STATE OF OHIO
01«0 ADMINISTRATIVE CODE COACI
TITlEI
SUBJECT Of REGULATION
GENERAL CLOSURE PERFORMANCE
STANDARD; HAZ WASTE FAC
CONTENT OF CLOSURE PlAN; HAZ
WASTE FACILITIES
DISPOSALIDECON OF EQUIPMENT.
STRUCTURES AND SOILS
SUBMISSION OF SURVEY PLAT
FOLLOWING CLOSURE .
DESCRIPTION OF REGULATION
REQUIRES THAT ALL HAZARDOUS
WASTE FACILITIES BE CLOSED IN A
MANNER THAT MINIMIZES THE
NEED FOR FURTHER MAINTENANCE.
CONTROLS. MINIMIZES, ELIMINATES
OR PREVENTS POST-CLOSURE
ESCAPE OF HAZARDOUS WASTE.
HAZARDOUS CONSTITUENTS.
LEACHATE. CONTAMINATED RUN-
OFF OR HAZARDOUS WASTE
DECOMPOSITION PRODUCTS TO
THE GROUND OR SURFACE WATER
OR THE ATMOSPHERE.
SPECIFIES THE MINIMUM
INFORMATION REQUIRED IN A
CLOSURE PlAN FOR OHIO EPA TO
DETERMINE THE ADEQUACY OF THE
PLAN.
REQUIRES THAT ALL
CONTAMINATED EQUIPMENT,
STRUCTURES AND SOILS BE
PROPERLY DISPOSED OF OR
DECONTAMINATED. REMOVAL OF
HAZARDOUS WASTES OR
CONSTITUENTS FROM A UNIT MAY
CONSTITUTE GENERATION OF
HAZARDOUS WASTES.
FOLLOWING CLOSURE, A SURVEY
PLAT INDICATING THE LOCATION
AND DIMENSIONS OF LAND
DISPOSAL UNITS WITH RESPECT TO
PERMANENTl V SURVEYED
BENCHMARKS MUST BE SUBMITTED
TO THE LOCAL ZONING AUTHORITY
AND THE DIRECTOR OF THE OHIO
EPA. THE PLANT MUST CONTAIN A
NOTE WHICH STATES THE
OBlIGATION TO RESTRICT
DISTURBANCE OF THE UNiTeS'.
APPliCATION OF REGULATION
ARAR TYPEISI
PERTAINS TO ANY SITE AT WHICH
HAZARDOUS WASTE IS TO BE
TREA TED, STORED OR DISPOSED OF
lOR HAS BEEN TREATED, STORED
OR DISPOSED OFI.
ACTION
SUBSTANTIVE REQUIREMENTS
PERTAIN TO ANY SITE AT WHICH
HAZARDOUS IS TO BE TREATED.
STORED OR DISPOSED OF COR HAS
BEEN TREATED, STORED OR
DISPOSED OFJi
ACTION
PERTAINING TO ANY SITE AT
WHICH HAZARDOUS WASTE IS TO
BE TREATED, STORED OR DISPOSED
OF lOR HAS BEEN TREATED,
STORED OR DISPOSED OFI.
ACTION
PERTAINS TO ALL SITES WITH
LAND-BASED HAZARDOUS WASTE
UNITS ILANDFILlS AND SURFACE
IMPOUNDMENTS, WASTE PILES,
LAND TREATMENT UNITS AND
TANKS THAT MEET REQUIREMENTS
OF lANDFILLS AFTER CLOSUREI.
THIS INCLUDES EXISTING LAND-
BASED AREAS OF CONTAMINATION.
ACTION
-------
   TAILE V..  
  SELECTED POTENTIAL APPUCAIlE OR RElEVANT AND APllROPRIATE REO&MEMENTS . STATE OF OHIO 
  ottO ADMINISTRATIVE CODE 100CI  
OAC PERTINENT TlTlEI   
CIT A TION PARAGRAPHS SUBJECT OF REGULATION DESCRIPTION OF REGULA TlON APPlICATION OF REGULA TlON ARAR TYPEISI
3745-55-17 B POST-CLOSURE CARE AND USE OF SPECIFIES THE POST-CLOSURE CARE PERTAINS TO All SITES WITH ACT10N
  PROPERTY REQUIREMENTS, INCLUDING LAND-BASED HAZARDOUS WASTE 
   MAINTENANCE, MONITORING AND UNITS ILANDFlllS AND SURFACE 
   POST-CLOSURE USE OF PROPERTY. IMPOUNDMENTS, WASTE PILES, 
    LAND TREA TM£NT UNITS AND 
    TANKS THAT MEET REQUIREMENTS 
    OF LANDFUS AmR CLOSUREI. 
    THIS INCLUDES EXISTING LAND- 
    BASED AREAS OF CONTAMINATION. 
3745-55-18 B POST.ClOSURE PlAN PRESENTS THE INFORMATION PERTAINS TO All SITES WITH ACTION
   NECESSARY FOR OHIO EPA TO LAND-BASED HAZARDOUS WASTE 
   DETERMINE THE ADEQUACY OF A UNITS IlANDFllLS AND SURFACE 
   POST-CLOSURE PlAN. IMPOUNDMENTS, WASTE PILES, 
    LAND TREATMENT UNITS AND 
    TANKS THAT MEET REQUIREMENTS 
    OF lANDFILLS AmR CLOSURE'. 
    THIS INCLUDES EXISTING LAND- 
    BASED AREAS OF CONTAMINATION. 
3745.55-19 B NOTICE TO lOCAL lAND  REQUIRES THAT A RECORD OF THE PERTAINS TO All SITES WITH ACTION
  AUTHORITY TYPE, lOCATION AND QUANTITY OF LAND-BASED HAZARDOUS WASTE 
   HAZARDOUS WASTES DISPOSED OF UNITS IlANDF1llS AND SURFACE 
   IN EACH UN'T BE SUBMlnED TO IMPOUNDMENTS, WASTE PILES, 
   THE lOCAL LAND AUTHORITY AND lAND TREATMENT UNITS AND 
   THE DIRECTOR OF THE OHIO EPA, TANKS THAT MEET REQUIREMENTS 
   ALSO REQUIRES THAT A NOTATION OF lANDF1LlS AFTER CLOSURE'. 
   TO THE DEED TO THE FACILITY  THIS INClUD£S EXISTING lAND- 
   PROPERTY BE MADE INDICATING BASED AREAS OF CONT AMiNA TlON. 
   THAT THE lAND WAS USED TO  
   MANAGE HAZARDOUS WASTES  
   AND THAT CERTAIN USE  
   RESTRICTIONS MAY APPlY TO THE  
   PROPERTY.  
3745.55-71  CONDITION OF CONTAINERS CONTAINERS HOlDING HAZARDOUS PERTAINS TO ANY SITE AT WHICH ACTION
   WASTE MUST BE MAINTAINED IN HAZARDOUS WASTE Will BE 
   GOOD CONDITION INO RUST OR STORED IN CONTAINERS. 
   STRUCTURAL DEFECTSI.  
-------
   TAIRE V-8  
  SELECTED POTENTIAL APPliCABlE OR RREVANT AND APPROPRIATE REQUMEMENTS - STATE Of OHIO 
  OHIO ADMINI8T'RATM CODE COACI  
OAC PERTINENT TlTlEI   
::IT A TION PARAGRAPHS SUBJECT OF REGULATION DESCRIPTION OF REGULA TlON APPLICATION OF REGULATION ARAR TYPE(SI
3145-55.12  COMPATIBILITY OF WASTE WITH HAZARDOUS WASTES PlACED IN PERTAINS TO ANY SITE AT WHICH ACTION
  CONTAINERS CONTAINERS MUST NOT REACT HAZARDOUS WASTE Will BE 
   WITH THE CONTAINER MATERIAL STORED IN CONTAINERS. 
   OR LINER MATERIAl.  
3145.55-13  MANAGEMENT OF CONTAINERS CONTAINERS HOLDING HAZARDOUS PERTAINS TO ANY SITE AT WHICH ACTION
   WASTE MUST BE CLOSED (EXCEPT HAZARDOUS WASTE WilL BE 
   TO ADD OR REMOVE WASTE I AND STORED IN CONTAINERS. 
   MUST NOT BE HANDLED IN A  
   MANNER THAT MAY RUPTURE THE  
   CONTAINER OR CAUSE IT TO LEAK.  
3145.55-14  CONT AINER INSPECTIONS REQUIRES AT LEAST WEEKLY PERTAINS TO ANY SITE AT WHICH ACTION
   INSPECTIONS OF CONTAINER HAZARDOUS WASTE Will BE 
   STORAGE AREAS. STORED IN CONTAINERS. 
3145-55-15 A,B,C,D CONTAINER STORAGE AREA REQUIRES THAT CONTAINER PERTAINS TO ANY SITE AT WHICH ACTION
  CONTAINMENT SYSTEM STORAGE AREAS HAVE A ItA1ARDOUS WASTE WilL BE 
   CONTAINMENT SYSTEM AND :. T ORED IN CONTAINERS. 
   SPECIFIES THE MINIMUM  
   REQUIREMENTS OF SUCH A  
   SYSTEM.  
3145-55-18  CONTAINER REQUIREMENTS FOR PRESENTS GENERAL PRECAUTIONS PERTAINS TO ANY SITE AT WHICH ACTION
  IGNITABLflREACTIVE WASTES TO BE TAKEN TO PREVENT POTENTIALL V REACTIVE OR CHEMICAL
   ACCIDENTAL IGNITION OR IGNITABLE WASTES THAT ARE 
   REACTION OF IGNITABLE OR STORED, OR ARE TO BE STORED, IN 
   REACTIVE WASTES THAT Will BE CONTAINERS. 
   STORED IN CONTAINERS.  
3145.55.11 A,B,C CONTAINER REQUIREMENTS FOR PRESENTS GENERAL PRECAUTIONS PERTAINS ;YO ANY SITE AT WHICH ACTION
  INCOMPATIBLE WASTES TO BE TAKEN WHEN DEALING WITH POTENTlAll V INCOMPA TIBt.E CHEMICAL
   INCOMPATiBlE WASTES. 'WASTES ARE PRESENT. 
3145-55-18  CONTAINER CLOSURE SPECIFIES CLOSURE REQUIREMENTS PERTAINS TO ANY SITE AT WHICH ACTION
  REQUIREMENTS FOR CONT AINERS AND HAZARDOUS WASTE WILL BE 
   CONTAINMENT SYSTEM. STORED IN CONTAINERS. 
-------
   TAIlEV-.  
  SB.Ectm POTENTIAL APPlICABlE OR RB.EVANT AND APPROPRIATE REQUIREMENTS. STATE OF OlIO 
  OtlO ADMINISTRATIVE CODE 10ACt  
OAC PERTINENT TlTLEI   
CITATION PARAGRAPHS SUBJECT OF REGULATION DESCRIPTION OF REGULATION APPlICA TlON OF REGULATION ARAR TYPEIS!
3745-55-92 A-I DESIGN AND INSTALLATION OF REOUIRES A SECONDARY PERTAINS TO ANY SITE AT WHICH ACTION
  NEW TANK SYSTEMS OR CONTAINMENT SYSTEM FOR TANKS HAZARDOUS WASTE WILL BE 
  COMPONENTS AND ASSESSMENT TO DETERMINE EITHER STORED OR TREATED IN 
   TANK INTEGRITY. TANKS. 
3745-55-93 A-G,I CONTAINMENT AND DETECTION OF REQUIRES SECONDARY PERTAINS TO ANY SITE AT WHICH ACTION
  RelEASES FOR TANK SYSTEMS CONTAINMENT AND LEAK HAZARDOUS WASTE WILL BE 
   DETECTION SYSTEMS FOR TANKS. EITHER STORED OR TREATED IN 
    TANKS. 
3745-55-94 A,B,C GENERAL OPERATING SPECIFIES GENERAL OPERATING PERTAINS TO ANY SITE AT WHICH ACTION
  REQUIREMENTS FOR TANK REQUIREMENTS FOR TANK HAZARDOUS WASTE WILL BE 
  SYSTEMS SYSTEMS. EITHER STORED OR TREATED IN 
    TANKS. 
3745-55-95 A-D INSPECTIONS OF TANK SYSTEMS REQUIRES INSPECTIONS AT LEAST PERTAINS TO ANY SITE AT WHICH ACTION
   ONCE EACH OPERATING DAY HAZARDOUS WASTE WILL BE 
    EITHER STORED OR TREATED IN 
    TANKS. 
3745-55-98 A,I,C,E RESPONSE TO LEAKS OR SPILLS OF REQUIRES THAT UNFIT TANKS BE PERTAINS TO ANY SITE AT WHICH ACTION
  TANK SYSTEMS REMOVED FROM USE AND FURTHER HAZARDOUS WASTE WILL BE 
   RELEASES BE PREVENTED. EITHER STORED OR TREATED IN 
    TANKS. 
3745-55-97 A,I CLOSURE AND POST.CLOSURE CARE SPECIFIES CLOSURE AND POST- PERTAINS TO ANY SITE AT WHICH ACTION
  FOR TANK SYSTEM CLOSURE REQUIREMENTS FOR TANK HAZARDOUS WASTE WILL BE 
   SYSTEMS. EITHER STORED OR TREATED IN 
    TANKS. 
3745-55-99 A,I TANK REQUIREMENTS FOR PRESENTS GENERAL PRECAUTIONS PERTAINS TO ANY SITE AT WHICH ACTION
  INCOMPATIBlE WASTES TO BE TAKEN WHEN DEALING WITH POTENTIALLY INCOMPATIBlE 
   POTENTIALLY INCOMPA TlaLE WASTES ARE STORED OR TREATED 
   WASTES THAT ARE STORED OR lOR TO BE STORED OR TREATEDt IN 
   TREATED IN TANKS. TANKS. 
-------
   TAIIl£ V-8  
  SElfCTm POTENTIAL APPlICABLE OR RELEVANT AND APPROPRIATE REQUIREMENTS. .TATE OF OHIO 
  OHIO ADMINISTRA 11VE CODE IOACt  
OAC PERTINENT TlTlEI   
:IT A TlON PARAGRAPHS SUBJECT OF REGULATION DESCRIPTION OF REGULATION APPliCATION OF REGULATION ARAR TYPE(St
1745.56-51 A-F DESIGN AND OPERATING SPECIFIES THE DESIGN AND PERTAINS TO ANV SITE AT WHICH ACTION
  REQUIREMENTS FOR WASTE PilES OPERA TlON REQUIREMENTS FOR HAZARDOUS WASTE Will BE 
   WASTE PILES. INCLUDES LINER EITHER STORED OR TREATED IN 
   SYSTEM,LEACHATE COllECTION WASTE PILES. 
   AND REMOVAL SYSTEM, WIND  
   DISPERSAL PREVENTION AND RUN.  
   ONIRUN.OFF CONTROl.  
3745-56-54 A.B MONITORING AND INSPECTION OF WASTE PILES MUST BE MONITORED PERTAINS TO ANY SITE AT WHICH ACTION
  WASTE PILES DURING CONSTRUCTION OR HAZARDOUS WASTE Will BE 
   INSTALLATION AND OPERATION. EITHER STORED OR TREATED IN 
    WASTE PILES. 
3745.56-56 A,B WASTE PILE REQUIREMENTS FOR PRESENTS GENERAL PRECAUTIONS PERTAINS TO ANY SITE AT WHICH ACTION
  IGNITABlEIREACTlVE WASTES TO BE TAKEN WHEN DEALING WITH POTENTIALLY IGNITABlE OR CHEMICAL
   POTENTIALLY IGNITABLE OR REACTIVE HAZARDOUS WASTE 
   REACTIVE HAZARDOUS WASTES WilL BE EITHER STORED OR 
   THA T ARE STORED OR TREATED IN TREATED IN WASTE PILES. 
   WASTE PILES,  
3745.56-57 A.B,C WASTE PILE REOUIREMENTS FOR PRESENTS GENERAL PRECAUTIONS PERTAINS TO ANV SITE AT WHICH ACTION
  INCOMPATIBLE WASTES TO BE TAKEN WHEN DEALING WITH POTENTlAllV INCOMPATIBlE CHEMICAL
   POTENTIAll V INCOMPATIBlE HAZARDOUS WASTE Will BE 
   WASTES THAT ARE STORED OR EITHER STORED OR TREATED IN 
   TREATED IN WASTE PILES. WASTE PILES. 
3745-56-58 A.B,C CLOSURE AND POST.ClOSURE CARE SPECIFIES CLOSURE AND POST. PERTAINS TO ANV SITE AT WHICH ACTION
  FOR WASTE PILES CLOSURE CARE REQUIREMENTS FOR HAZARDOUS WASTE WILL BE 
   WASTE PILES. EITHER STORED OR TREATED IN 
    WASTE PILES. 
3745.58-59 A CONSTRUCTION INSPECITONS FOR ALLOWS OHIO EPA THE PERTAINS TO ANY SITE AT WHICH ACTION
  WASTE PILES OPPORTUNITY TO INSPECT WASTE HAZARDOUS WASTE Will BE 
   PILES DURING CONSTRUCTION. EITHER STORED OR TREATED IN 
    WASTE PILES. 
-------
   TABu: V..  
  SRECTED POTENTIAL APPlICABlE OR RELEVANT AND APPROPRIATE REQUIREMENTS. STATE OF OHIO 
  0..0 ADM-TMTIVE CODE 100Ct  
OAC PERTINENT TlnEI   
CIT A TION PARAGRAPHS SUBJECT OF REGULATION DESCRIPTION OF REGULATION APPliCATION OF REGULATION ARAR TYPEISI
3745-57-01 A.D ENVIRONMENTAL PERFORMANCE SPECIAES LOCATION. DESIGN. . PERTAINS TO All SITES THAT ACTION
  STANDARDS: LAND-BASED UNITS CONSTRUCTION. OPERATION. EITHER HAVE OR WILL HAVE AT 
   MAINTENANCE AND CLOSURE LEAST ONE OF THE FOLLOWING 
   REQUIREMENTS FOR LANDFILLS. UNITS ON-SITE: LANDFILLS. WASTE 
   WASTE PILES, SURFACE PILES. SURFACE IMPOUNDMENTS, 
   IMPOUNDMENTS AND LAND TREATMENT FACILITIES AND 
   UNDERGROUND INJECTION WELLS. UNDERGROUND INJECTION WELLS 
    8THIS INCLUDES EXISTING lAND. 
    BASED AR[AS Of 
    CONT AMINA TlONI. 
3745.57-03 A-I LANDFilL DESIGN AND OPERATING PRESENTS DESIGN AND OPERATING PERTAINS TO All SITES AT WHICH ACTION
  REQUIREMENTS REQUIREMENTS FOR LANDFILLS. A HAZARDOUS WASTE LANDFILL 
   INCLUDES LINER. LEACHATE WHICH WILL EITHER BE LOCATED 
   COLLECTION AND REMOVAL. RUN. OR AN EXISTING lANDFILL WILL BE 
   ONIRUN.OFF CONTROL, ETC. EXPANDED. THIS RULE ALSO 
    PERTAINS TO EXISTING LAND. 
    BASED AREAS OF CONTAMINATION. 
3745-57-05 A,B MONITORING AND INSPECTIONS OF REQUIRES INSPECTION OF PERTAINS TO All SITES AT WHICH ACTION
  lANDFILLS LANDFILLS DURING CONSTRUCTION A HAZARDOUS WASTE LANDFILL 
   OR INSTALLATION AND OPERATION. WILL EITHER BE LOCATED OR AN 
    EXISTING LANDFILL Will BE  
    EXPANDED. THIS RULE PERTAINS 
    TO EXISTING LAND-BASED AREAS 
    OF CONT AMINA TlON. 
3745-57.10 A,S LANDFill CLOSURE AND POST. SPECIFIES CLOSURE AND POST. PERTAINS TO All SITES AT WHICH ACTION
  ClOSU~E CARE CLOSURE REQUIREMENTS FOR A HAZARDOUS WASTE LANDFILL 
   HAZARDOUS WASTE LANDFILLS. WILL EITHER BE lOCATED OR AN 
   INClUDES FINAL COVER AND EXISTING LANDFILL WILL BE 
   MAINTENANCE. EXPANDED. THIS RULE PERTAINS 
    TO EXISTING LAND-BASED AREAS 
    OF CONT AMiNA TlON. 
-------
   TAIIl£ V-I  
  SELECTfD POTDmAI. APPUCA8LE OR RElEVANT AND APPROPRIATE REQUIREMENTS. STATE OF OHIO 
  OHIO ADMMSTRATIVE CODE COACI  
OAC PERTINENT TITlE I    
CITATION PARAGRAPHS SUBJECT OF REGULATION DESCRIPTION OF REGULATION APPliCATION OF REGULATION ARAR TYPEISI
3745-57. I 2 A,B LANDFILL REOUIREMENTS FOR PROHIBITS THE DISPOSAL OF PERTAINS TO ALL SITES AT WHICH ACTION
  IGNITABLE/REACTIVE WASTES IGNITABLE OR REACTIVE WASTE IN POTENTIALLY IGNITABLE OR CHEMICAL
   A LANDFILL, UNLESS THE WASTE IS REACTIVE HAZARDOUS WASTE 
   TREATED, RENDERED OR MIXED SO MAY BE LANDFILLED. 
   THAT THE RESULT ANT MATERIAL  
   NO LONGER MEETS THE DEFINITION  
   OF IGNITABLE OR REACTIVE WASTE.  
3745-57-13  LANDFILL REQUIREMENTS FOR PROHIBITS THE DISPOSAL OF PERTAINS TO ALL SITES AT WHICH ACTION
  INCOMPATIBLE WASTES INCOMPATIBLE WASTE IN THE POTENTIALLY INCOMPATIBLE CHEMICAL
   SAME CELL OF A LANDFilL. HAZARDOUS WASTE MAY BE 
    LANDFILLED. 
3745-57-41 A,B WASTE ANALYSIS FOR REQUIRES WASTE ANALYSIS BE PERT AINS TO ANY AL TERNA TlVE ACTION
  INCINERATORS PERFORMED FOR TRIAL BURN AND THAT WilL INCORPORATE CHEMICAL
   FOR NORMAL OPERATION OF INCINERATION OF HAZARDOUS 
   INCINERA TOR. WASTE. 
3745.57-42 A,B,C PRINCIPAL ORGANIC HAZARDOUS ESTABLISHES METHOD BY WHICH PERTAINS TO ANY ALTERNATIVE ACTION
  CONSTITUENTS; INCINERATORS POHCS WilL BE SPECIFIED. THAT WILL INCORPORATE CHEMICAL
    INCINERATION OF HAZARDOUS 
    WASTES. 
3745-57-43 A,B,C PERfORMANCE STANDARDS FOR SPECIFIES PERfORMANCE PERTAINS TO ANY ALTERNATIVE ACTION
  INCINERATORS STANDARDS THAT All THAT WilL INCORPORATE CHEMICAL
   INCINERATORS MUST MEET INCINERATION Of HAZARDOUS 
   CDESTRUCTION REMOVAL WASTES. 
   EFFICIENCIES, HCl EMISSIONS,  
   PARTICULATE EMiSSIONSI  
3745-57-44 C INCINERATOR TRIAL BURNS. REQUIRES TRIAL BURN TO PERTAINS TO ANY AL TERNA TlVE ACTION
  AL TERNA TlVE DATA DETERMINE FINAL OPERATING THAT WILL INCORPORATE CHEMICAL
   CONDITIONS. INCINERATION OF HAZARDOUS 
    WASTES. 
3745-57-45 A-f INCINERATOR OPERATING SPECIFIES GENERAL OPERATING PERTAINS TO ANY ALTERNATIVE ACTION
  REQUIREMENTS REQUIREMENTS FOR ALL THAT Will INCORPORATE  
   INCINERATORS INCINERA TlON Of HAZARDOUS 
    WASTE. 
-------
   TABU: V-a  
  8nECTED POTENTIAL APPlICABlE OR RnEVANT AND APPROPRIATE REQUMEMENT8 . STATE OF OHIO 
  0..0 ADMINISTRATIVE CODE 100CI  
OAC PERTINENT TiTlE I    
CITATION PARAGRAPHS SUBJECT OF REGULATION DESCRIPTION OF REGULATION APPlICATION OF REGULATION ARAR TYP£ISI
3745.57.47 A,B,C MONITORING AND INSPECTION OF REQUIRES THE MONITORING OF PERTAINS TO ANY ALTERNATIVE ACTION
  INCINERATORS CERTAIN PARAMETERS ON A THAT Will INCORPORATE CHEMICAL
   CONTINUOUS BASIS AND INCINERATION OF HAZARDOUS 
   INSPECTIONS OF EQUIPMENT. WASTES. 
3745.57.51  CLOSURE OF INCINERATORS REQUIRES THAT ALL HAZARDOUS PERTAINS TO ANY ALTERNATIVE ACTIPN
   WASTE AND HAZARDOUS WASTE THAT WILL INCORPORATE 
   RESIDUES BE REMOVED FROM THE INCINERATION OF HAZARDOUS 
   INCINERATOR SITE. WASTES. 
3745.57.91 A,B,C ENVIRONMENTAL PERFORMANCE ESTABLISHES LOCATION, DESIGN, PERTAINS TO ANY ALTERNATIVE ACTION
  STANDARDS FOR MlSC UNITS CONSTRUCTION, OPERATION, THAT INCORPORATES TREATMENT, CHEMICAL
   MAINTENANCE AND CLOSURE STORAGE OR DISPOSAL OF 
   REQUIREMENTS FOR HAZARDOUS WASTES IN 
   MISCELLANEOUS UNITS USED TO MISCElLANEOUS UNITS. 
   TREAT, STORE OR DISPOSE OF  
   HAZARDOUS WASTES.  
3745.57.92  MONITORING, INSPECTING, REQUIRES THAT MONITORING, PERTAINS TO ANY ALTERNATIVE ACTION
  ANALYZING,... FOR MlSC UNITS ANALYSIS, INSPECTION, RESPONSE, THAT INCORPORATES TREATMENT, 
   REPORTING AND CORRECTIVE STORAGE OR DISPOSAL OF 
   ACTION BE CONDUCTED AS HAZARDOUS WASTES IN 
   NECESSARY AT MISCELLANEOUS MISCELlANEOUS UN1TS. 
   UNITS TO ASSURE THAT HUMAN  
   HEALTH AND THE ENVIRONMENT  
   ARE PROTECTED.  
3745-57.93  POST -CLOSURE CARE FOR MlSC REQUIRES POST.CLOSURE CARE OF PERTAINS TO ANY ALTERNATIVE ACTION
  DISPOSAL UNITS MISCElLANEOUS UNITS THAT ARE THAT INCORPORATES TREATMENT, 
   DISPOSAL UNITS AND OF THE STORAGE OR DISPOSAL OF 
   TREATMENT OR STORAGE OF HAZARDOUS WASTES IN 
   MISCElLANEOUS UNITS THAT MISCELLANEOUS UNITS. 
   LEAVE CONTAMINATED SOILS OR  
   GROUND WATER A"ER CLOSURE.  
3745-81-11 A,B MAXIMUM CONTAMINANT LEVELS PRESENTS MAXIMUM PERTAINS TO ANY SITE WHICH HAS CHEMICAL
  FOR INORGANIC CHEMICALS CONTAMINANT LEVElS FOR CONT AMINATED GROUND OR 
   INORGANICS. SURFACE WATER THAT IS EITHER 
    BEING USED, OR HAS THE 
    POTENTIAL FOR USE, AS A 
    DRINKING WATER SOURCE. 
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OAC
CITATION
3745-81.12
3745-81-13
3745-81-22
3745.81.23
3745-81-24
TAIlE V.a
8B.ECTfD POTENTIAL APPUCA8I.E OR RElEVANT AND APPROfRIATfREQUlRfMENTS. .TATf OF OHIO
OHIO ADMWISTRATIYf CODE COACI
PERTINENT
PARAGRAPHS
A. B. C
A.B
A
A
A-E
TITLE I
SUBJECT OF REGULATION
MAXIMUM CONTAMINANT LEVELS
FOR ORGANIC CHEMICALS
MAXIMUM CONTAMINANT LEVELS
FOR TURBIDITY
TURBIDITY CONTAINMENT
SAMPLING AND ANALYTICAL
REQUIREMENTS
INORGANIC CONTAMINANT
MONITORING REQUIREMENTS
ORGANIC CONTAMINANT
MONITORING REQUIREMENTS
DESCRIPTION OF REGULATION
PRESENTS MCLS FOR ORGANICS.
PRESENTS MClS FOR TURBIDITY.
PRESENTS SAMPLING AND
ANALYTICAL REQUIREMENTS FOR
TURBIDITY .
PRESENTS MONITORING
REQUIREMENTS FOR INORGANIC
CONT AMNANTS.
PRESENTS MONITORING
REQUIREMENTS FOR ORGANIC
CONT AMINANTS.
APPliCATION OF REGULATION
PERTAINS TO ANY SITE WHICH HAS
CONT AMINATED GROUND OR
SURFACE WATER THAT IS EITHER
BEING USED. OR HAS THE
POTENTIAL FOR USE. AS A
DRINKING WATER SOURCE.
PERTAINS TO ANY SITE WHICH HAS
CONTAMINATED GROUND OR
SURFACE WATER THAT IS EITHER
BEING USED. OR HAS THE
POTENTIAL FOR USE. AS A
DRINKING WATER SOURCE.
PERTAINS TO ANY SITE WHICH HAS
CONT ANINA TED GROUND OR
SURFACE WATER THIS IS EITHER
BEING USED OR HAS THE
POTENTIAL FOR USE. AS A
DRINKING WATER SOURCE.
PERTAINS TO ANY SITE WHICH HAS
CONT AMINATED GROUND OR
SURFACE WATER THIS IS EITHER
BEING USED OR HAS THE
POTENTIAL FOR USE. AS A
DRINKING WATER SOURCE.
PERTAINS TO ANY SITf WHICH HAS
CONTAMINATED GROUND OR
SURFACE WATER THIS IS EITHER
BEING USED OR HAS THE
POTENTIAL FOR USE. AS A
DRINKING WATER SOURCE.
ARAR TYPEISI
CHEMICAL
CHEMICAL
CHEMICAL
CHEMICAL
CHEMICAL
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TAIlE v.a
8ELECTED POTENTIAl APPLICAIlE OR RB.fVANT AND APPROPRIATE REOUIR£MENTI . STATE OF OHIO
OHIO ADMINISTRATIVE CODE COACI .
OAC P£RTINENT TITLEI   
CIT A TlON PARAGRAPHS SUBJECT OF REGULATION DESCRIPTION OF REGULA TION APPlICATION OF REGULATION ARAR TYPECSI
3745-81.27 A,B,C ANALVTlCAL TECHNIQUES PRESENTS GENERAL ANALYTICAL P£RT AINS TO ANY SITE WHICH HAS CHEMICAL
   TECHNIQUES FOR MCLS. CONTAMINATED GROUND OR 
    SURFACE WATER THAT IS EITHER 
    BEING USED OR HAS THE 
    POTENTIAL FOR USE AS A DRINkiNG 
    WATER SQURCE. 
3745-9'()4 A,B LOCA TlONISITING OF NEW GW MANDATES THAT GROUND WATER P£RTAINS TO ALL GROUND WATER LOCATION
  WELLS WELLS BE: AI LOCATED AND WElLS ON THE SITE THAT EITHER 
   MAINT AINEO SO AS TO PREVENT WILL BE INSTALLED OR HAVE BEEN 
   CONTAMINANTS FROM ENTERING INSTAllED SINCE FEBRUARY 15. 
   WELL; BI LOCATED SO AS TO BE 1975. 
   ACCESSiBlE FOR CLEANING AND  
   MAINTENANCE.  
3745-'.05 A1, B-H CONSTRUCTION OF NEW GW WELLS SP£CIFIES MINIMUM f'l "TAINS TO ALL GROUND WATER ACTION
   CONSTRUCTION REQUIREMENTS WELLS ON THE SITE THAT EITHER 
   FOR NEW GROUND WATER WELLS WILL BE INSTALLED OR HAVE BEEN 
   IN REGARD TO CASING MATERIAL, INSTALLED SINCE FEBRUARY 15, 
   CASING DEPTH, POTABlE WATER, 1915. 
   ANNULAR SPACE, USE OF DRIVE  
   SHOE, OP£NINGS TO ALLOW WATER  
   ENTRY, CONTAMINANT ENTRY.  
3145-'.()1 A,B,D,E CASING REOUIREMENTS FOR NEW ESTABLISHES SP£CIFIC P£RTAINS TO ALL GROUND WATER ACTION
  GW WELLS REQUIREMENTS FOR WElL WELLS ON THE SITE THAT EITHER 
   CASINGS, SUCH AS SUIT ABlE WILL BE INSTAllED OR HAVE BEEN 
   MATERIAL, DIAMETERS AND INSTAllED SINCE FEBRUARY 15, 
   CONDITION.  "15. 
3745-1'()1 A-F SURFACE DESIGN OF NEW GW ESTABliSHES SP£CIFIC SURFACE P£RTAINS TO All GROUND WATER ACTION
  WELLS DESIGN REQUIREMENTS, SUCH AS WElLS ON THE SITE THAT EITHER 
   HEIGHT AROVE GROUND, WELL WILL BE INSTALLED OR HAVE BEEN 
   VENTS.. L PUMPS, ETC. INSTAllED SINCE FEBRUARY '5, 
     1915. 
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,,'
TABLe; \I..
SRECTm POTfNTIAL APPliCABlE OR RRfYANT AND APPROPRIATE REQUlRfMfNTS . STATE OF OHIO
OHIO ADMINISTRATIVE CODE COACI
OAC PERTINENT TITlE'   
CIT A TION PARAGRAPHS SUBJECT OF REGULATION OESCRIPTION OF REGULATION APPliCATION OF REGULATION ARAR TYPE(SI
3745.9-08 A.C START.UP AND OPERATION OF GW REQUIRE DISINFECTION OF NEW PERTAINS TO ALL GROUND WATER ACTION
  WELLS WELLS AND USE OF POT ABLE WELLS ON THE SITE THAT EITHER 
   WATER FOR PRIMING PUMPS. WILL BE INSTALLED OR HAVE BEEN 
    INSTALLED SINCE FEBRUARY 15. 
    1975. 
3745.9.09 A.C. 01. E.G MAINTENANCE AND OPERATION OF ESTABLISHES SPECIFIC PERTAINS TO ALL GROUND WATER ACTION
  GW WELLS MAINTENANCE AND MODIFICATION WELLS ON THE SITE THAT EITHER 
   REQUIREMENTS FOR CASING. PUMP WILL BE INSTALLED OR HA VE BEEN 
   AND WELLS IN GENERAl. INSTALLED SINCE FEBRUARY 15. 
    1975. 
3745.9.10
A.B,C
3745.9.11
ABANDONMENT OF TEST HOLES
AND GW WEllS
USE OF GW WEllS FOR DISPOSAL
FOLLOWING COMPLETION OF USE.
WELLS AND TEST HOLES SHALL BE
COMPLETELY FilLED WITH GROUT
OR SIMILAR MATERIAL OR SHALL BE
MAINTAINED IN COMPLIANCE OF
ALL REGULATIONS.
PERTAINS TO ALL GROUND WATER
WELLS ON THE SITE TH~ T EITHER
Will BE INSTALLED OR HAVE BEEN
INSTALLED SINCE FEBRUARY 15.
1975
ACTION
DISPOSAL OF ANY SUBSTANCE
INTO A WELL WITHOUT A PERMIT IS
PROHIBITED.
PERTAINS TO ALL GROUND WATER
WEllS ON THE SITE THAT EITHER
WILL BE INSTALLED OR HAVE BEEN
INSTALLED SINCE FEBRUARY 15.
1975
ACTION
. l:.5. GO\'E;e~!1T PRI1lTISG OFFICE: 1994 - 386-541/03068
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