United States
Environmental Protection
Agency
Office of
Emergency and
Remedial Response
EPA/ROD/R05-89/094
June 1989
Superfund
Record of Decision
Miami County Incinerator, OH
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50272-101
REPORT DOCUMENTATION
PAGE
1. REPORT NO. «•
EPA/ROD/R05-89/094
4. 711* end SubtM*
SUPERFUND RECORD OF DECISION
Miami County Incinerator, OH
First Remedial Action - Final
7. AUhor<»)
«•
11 Sponaoflng Orgenlutton Nerne end Addne*
U.S. Environmental Protection Agency
401 M Street, S.W.
Washington, D.C. 20460
X Recipient1* Acceeaion No.
i. Report 0«t»
06/30/89
«.
1. Performing Orgwiiatlon Rept No.
10. Pro|*cVTMk/Work IMt No.
11. Contract(C) or QramtG) Na
(Q
(0)
IX Typ* ol Report I Pwlod Covered
800/000
14.
IS. Supptemenuiy NokM
it. AteMct(LMl: 200 word*)
The Miami County Incinerator site is in Concord Township, Ohio. The 65-acre site is
approximately 1500 feet west of the Great Miami River; the Eldean Tributory of the
river runs across the northwest corner of the site. The site consists of the
incinerator building and adjacent property, including a former scrubber wastewater
igoon, an ash disposal pit, an ash pile, a liquid disposal area, and trench and fill
andfill areas north and south of the Eldean Tributory. Operations began in 1968, when
large quantities of spent solvents, oils, and drummed and bulk industrial sludges were
accepted for disposal. The facility generated scrubber wastewater and ash quench
water, which were disposed of in the wastewater lagoon. Incinerator fly ash and bottom
ash, non-combustible materials, and unburned refuse were disposed of in a landfill
north of the tributary, and an estimated 104,000 to 150,000 barrel-equivalents of
liquid waste were dumped or buried onsite. After closure of the facility in 1983, the
Ohio EPA found detectable levels of chlorinated hydrocarbons in drinking water wells
near the site. Three residences, the Miami County Highway Garage, and the incinerator
facility were supplied with alternate water supplies in 1986. The primary contaminants
of concern affecting the soil and ground water are VOCs including PCE, toluene, and
TCE; other organics including PCBs, PAHs, dioxin, and pesticides; and metals including
lead.
(Seel Attached Sheet1
OH
17. Document Anetyei* a. Deecrlpuire
Record of Decision - Miami County Incinerator,
First Remedial Action - Final
Contaminated Media: gw, soil
Key Contaminants: VOCs (TCE, PCE, toluene)', organics (PAHs, PCBs, dioxin), metals
b. Wentlfiert/OpeivendedTerme
e. C03AT) FWoVOroup
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121 .
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SM Instruction* on At
(Formerly NTIS-3S)
Department ol Commerce
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EPA/ROD/R05-89/094
Miami County Incinerator, OH
First Remedial Action - Final
Abstract (continued) •
The selected remedial actions for this site are specific to each area of contamination
and include excavation and onsite consolidation of ash wastes and contaminated soils
onto the landfills with capping of landfills and previously excavated areas; pumping
and treatment of ground water with discharge to POTW; vapor/vacuum extraction of liquid
disposal area using carbon filters; continued testing of soils, ash, and tributary
sediment; and provision of an alternate water supply for area residents and businesses.
The estimated present worth for this remedial action is $19,400,000, which includes an
estimated O&M cost of $4,666,000.
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Record of Decision
Site Name and location
Miami County Incinerator
Troy, Ohio
of Bagjs and Purose
This decision document presents the selected remedial action for the Miami
County Incinerator site developed in accordance with the Comprehensive
Environmental Response, Compensation and Liability Act of 1980, as amended by
the Superfund Amendments and Reauthorization Act of 1986 and is consistent
with the National Oil and Hazardous Substances Pollution Contingency Plan to
the extant practicable.
This decision is based upon the contents of the administrative record for the
Miami County Incinerator site.
The State of Ohio concurrence with the selected remedy is expected.
Description of the Remedy
This site has seven areas of concern. The selected remedial alternative for
each of these areas is:
A. fi«rH^ TanHfiii - closure according to State sanitary landfill
requirements. Alternative A3 has been selected. The major
components of the selected alternative are:
- Fence landfill area and post warning signs
- Deed notifications/property use restrictions to prohibit use of
groundwater and prevent exposure to contaminants
- Ongoing monitoring
- Grade and cap landfill with single barrier cap
B. North Landfill - closure according to State sanitary landfill
requirements. Alternative B3 has been selected. The major
components of the selected alternative are:
- Fence landfill area and post warning signs
- Deed notification/property use restrictions to prohibit use of
groundwater and prevent exposure to contaminants
- Ongoing monitoring
- Grade and cap landfill with single barrier cap
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Ash Pile - remove to North or South Landfill.
Alternative C3 or C4 has been selected depending on the need for
treatanent. The major conponents of the selected alternative are:
- Excavation and consolidation of ash wastes and contaminated soils
onto the North or South Landfill
- Backfill and vegetate excavated areas
• Treatment if required under RCRA
D. t4g"4d Disposal Area and Groundwater - vapor extraction, groundwater
punp and treatment, capping. Alternative IMA which is modification
of Alternative 04 has been selected. The major conponents of the
selected alternative are:
- Ongoing monitoring
- Grade and cap site with double barrier cap
'- Vacuum extraction of VOCs from waste and soils
- Vapor phase carbon treatment or equivalent, catalytic oxidation
or other appropriate treatment of the exhaust
- Pump and treat contaminated groundwater with discharge to Troy
POIW with pretreatment, if necessary
- Continue connection of residential and commercial groundwater
users to a potable water supply
E. Former ScrnHrer w^^tewater T^goon Test soils/ash for complete CLP
organic/inorganic parameters including cyanide compounds. An
evaluation will then be conducted to determine if any further actions
axe required. The same type of evaluation as conducted in the
Endangerment Assessment (EA) for other site areas will be conducted.
If required, the contaminated material would be removed, treated if
necessary and placed in the North Landfill. Cleanup, if necessary,
would be to background levels of lead and any other contaminants of
concern which are identified.
F. Stained Soil Area - no action. This area has a low level of some
contaminants but the risks associated with these contaminants do not
warrant further action.
G. Eldean Tributary Testing of sediments will be conducted to
determine the source of contaminants in the area. Samples will be
analyzed for base-neutral compounds, pesticides, PCBs and cyanide.
An evaluation will then be conducted to determine if any further
actions are required. The same type of evaluation as conducted in
(55
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the Endangennent Assessment (EA) for other site areas will be
conducted. Results will be compared to standards and criteria to see
if there would be an effect on the aquatic community. Cleanup of
this area, if necessary, would be to a hazard index of less than one
for non-carcinogens and to a 10"6 total lifetime risk level for
carcinogens via direct contact. Cleanup would also be protective of
the aquatic community.
H. Groundwater Users - connection to City of Troy water supply.
Because of the contamination of residential wells by organic
chemicals, these residences are being connected to the City of Troy
water supply with the consent of the well owners. The wells with
higher levels of contaminants belonging to residences and business in
the area have been taken out of service because of the acute threat
involved. The remaining residences have water which poses a chronic
health threat that is clearly unacceptable over the longer term.
Once these residences are connected to city water, the wells should
be closed to prevent their use and possible cross contamination of
the city water supply. New wells should not be drilled until the
aquifer has been cleaned up and the groundwater can be considered
safe for human consumption. The length of time this will take cannot
now be estimated but it can be anticipated that it will take many
years.
Consistent with the Comprehensive Environmental Response, Compensation and
Liability Act of 1980 (CERdA), as amended by the Superfund Amendments and
Reauthorization Act of 1986 (SARA), and the National Oil and Hazardous
Substances Pollution Contingency Plan (NCP), 40 C.F.R. Part 300, I have
determined that, at the Miami County Incinerator site, the selected remedial
alternative is cost-effective, provides adequate protection of public health,
welfare and the environment, and utilizes treatment to the maximum extent
practicable.
The action will require operation and maintenance activities to ensure
continued effectiveness of the remedial alternative as well as to ensure
that the performance meets applicable State and Federal surface and ground-
water criteria.
I have determined that the action being taken is consistent with Section 121
of SARA. The State of Ohio has been consulted on the selected remedy and
their concurrence is expected.
Declaration
The selected remedy is protective of human health and the environment and
attains Federal and State requirements that are applicable or relevant and
appropriate to this remedial action and is cost effective.
This remedy utilizes permanent solutions and alternative treatment
technologies to the maximum extent practicable for this site. Treatment was
not found to be practicable for the landfill portion of the site, thus this
remedy does not employ treatment for this area.
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action to ensure that the
human health and
ubstanc^ ^naning on-site
a^er oonmencement of renSai '
t° PrOVide
of
Regional
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DBCISICN SUMMARY
I. SITE NAME,
The Miami County incinerator site is located on 65 acres of county-
owned land an concord Township, about 2 miles north of the City of Troy
and 5 miles south of the city of Piqua. (See figures l and 2). It is
in an area of rolling terrain about 1,500 feet west of the Great Miami
River. The Eldean Tributary enters the site just below the northwest
corner and exits just north of the Sheriff's Hall. From that point,
the creek flows east and discharges to the Great Miami River.
The site consists of the incinerator building and adjacent property.
Areas of interest include a former scnihhpr wastewater lagoon, an ash
disposal pit> an ash pile, liquid disposal area, and trench and fill
landfill areas north and south of the Eldean Tributary. The
surrounding county-owned land is occupied by the County Highway
Department garage and the Sheriff's Hall and Training Center. A road
salt storage building standing on a concrete slab is west of the County
Highway Department main building.
The Miami County Incinerator was constructed in 1967. Aerial
photographs indicate that uncontrolled waste fMgp"*^! had been taking
place at the site before that time. When the incinerator began
operating in 1968, it generated by-products that included scrubber
wastewater and ash quench water, which were rfigpr^ori of in the
wastewater lagoon, and incinerator fly ash, bottom ash, noncombustible
materials, and unturned refuse, which were disposed of elsewhere at the
site.
Baspri on review of historic aerial photographs, landfill operations at
the site appear to have begun in 1968 with the excavation of a pit (the
"North landfill") due west of the incinerator across the railroad
tracks. Incinerator fly ash and bottom ash, noncombustible materials,
and unbumed refuse are thought to have been rfjgpr>eari of in the North
T>ndfi|i and the Ash Disposal Pit. Early landfill operations appear to
have been limited to the area north of the Eldean Tributary, but by the
end of 1973 they had begun in the area south of the tributary. Neither
an engineered liner nor a leachate collection system were installed at
the site. The trench and fill operations continued into 1978.
The facility accepted large quantities of spent solvents, oils, and
drummed and bulk industrial sludges for disposal in an area bounded
roughly by the B&O Railroad tracks on the east and the property
boundary on the north. The liquid wastes were either dumped on the
ground or buried. Estimates of the total quantity of liquid waste
accepted vary from 104,000 to 150,000 barrel-equivalents.
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PIQUA
FIGURE 1
SITE LOCATION MAP
MIAMI COUNTY INCINERATOR
RECORD OF DECISION
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M
•CAll M NIT
** ,
•mat IM M3MTORMO WELLS
PHASE INMBirrORMa WELLS
(•)Ao
IWELLTOBEMSTAUED
M THE SHALLOW AQUIFER
(?) ADDITIONAL MONTTORmO WELL TO BE INSTALLED
M THE LOWER AQUIFER
(X) ADDITIONAL MOMTORINO WEIL CLUSTER. WITH
ONE WELL IN THE UPPER AQUIFER.
AND ONE WELL IN THE LOWER AQUIFER
NOTE: MJ»«M MSTALLED DURUM PHASE H »
.^» **»**-*•«•«-•"»'
r
<:;
. i
.'V
Y
ADDITIONAL MONtTORMO WEU
INSTALLATIONS
MAM COUNTY INCINERATOR
RECORD OF WCOKM
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In 1973, Ohio EPA found groundwater samples from onsite and nearby
water supply wells to be contaminated with organic solvents and ordered
the facility to cease disposal of liquid waste by April 19, 1974. Some
liquid waste disposal (packing house waste) continued until March 1975.
By 1976, the Liquid Disposal Area had been covered. After closure of
the facility in 1983, three residential wells on the east side of
County Highway 25-A across from the site were found to contain
detectable levels of chlorinated hydrocarbons. All three residences,
the Miami County Highway Garage, and the incinerator facility were
supplied with municipal water from the City of Troy in 1986.
Disposal of incinerator residue apparently continued at the northern
portion of the landfill into 1978. In 1978, the Scrubber Wastewater
Lagoon was closed and, according to the Miami County Sanitation
Department, the fly ash sludge was removed from the bottom of the
lagoon although testing was not conducted to determine that the
contaminants were removed from the area. Some of that material is
believed to have been spread on the northern portion of the landfill.
Some of the ash sludge was piled east of the lagoon, where it is still
present in the area referred to as the Ash Pile. In October 1978, the
incinerator facility was converted to a solid waste transfer station.
STATUS
On March 27, 1989, RD/RA special notice letters were mailed to
approximately 150 PRPs. The PRP steering committee, the Business and
Industry Environmental Committee (BIEC), notified U.S. EPA by letter
dated April 13, 1989, and presented a formal offer to voluntarily
undertake remedial action at the site. Negotiations between U.S. EPA
and the BIEC are ongoing.
III. COMMUNITY RELATIONS
A public meeting was held in Troy, Ohio on September 10, 1986 to
discuss the first phase of the Remedial Investigation. A second public
meeting was held on April 6, 1989. The final Remedial Investigation
(RI) report, the Endangerment Assessment, the Feasibility Study (FS)
report and the Proposed Plan were discussed at the meeting. Following
a question and answer session, a formal opportunity for making public
comments was held. All of these documents as well as the
administrative record were available for review at the Miami County
Public Library and at the Miami County Commissioner's Office.
A public comment period on the Proposed Plan was held from March 27,
1989 to April 26, 1989. Comments were accepted by mail as well as at
the .public meeting. All of these comments were considered when the
Record of Decision was prepared. A responsiveness Summary which
includes responses to all of the comments received, was compiled and
is attached.
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IV. SODPE AND POLE OF RESPONSE ACTION
The selected remedial alternatives for the Miami County incinerator
site will address all of the contaminant problems identified in the
Endangerment Assessment. The alternatives for the Former Scrubber
Wastewater lagoon and the Eldean Tributary involve additional testing.
Any actions required as a result of this testing will be completed as a
part of this Remedial Action.
V. SITE CHARACTERISTICS
Contaminants of potential concern for the endangerment assessment were
selected in a two-step process from the more than 80 chemicals detected
at the site during the RI.
The first step of the selection process entailed selecting all
chemicals that have either a published critical toxicity factor (i.e.,
cancer potency factor or reference dose) or an environmental media
standard or criteria. Fifty-three chemicals detected at the site that
met this selection criterion are presented in Table 1.
Thirty of the contaminants detected at the site are classified as
known, probable, or possible human carcinogens by the U.S. EPA
Carcinogen Assessment Group (Table 2). The EPA uses a weight-of-
evidence approach to classify the likelihood of a chemical to be a
human carcinogen. The potential for a chemical to be a human
carcinogen is inferred from the available information relevant to the
potential carcinogenicity of the chemical and from judgments as to the
quality of the available studies.
Nbncarcinogenic health effects include a variety of toxic effects on
organ systems (e.g., renal toxicity—toxicity to the kidney), on
chromosomal material (mutagenicity), and on developing fetuses
(teratogenicity). A classification of the contaminants of concern by
general category of noncarcinogenic effects is presented in Table 3.
Since chemicals classified as potential carcinogens are also capable of
causing noncarcinogenic effects, some chemicals identified as potential
carcinogens on Table 2 may be on Table 3 as well.
Exposure to these contaminants may occur when contaminants migrate from
the site to an exposure point (i.e., a location where receptors can
come into contact with contaminants) or when a receptor comes into
direct contact with waste or contaminated media at the site. An
exposure pathway is corplete if there is a way for the receptor to
take in contaminants through ingestion, inhalation, or dermal
absorption of contaminated media or waste.
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The actual and potential exposure pathways for the incinerator site
are:
FJ
- Contaminant migration through groundwater, resulting in exposure
of groundwater users downgradient from the site.
t>
- Contaminant migration through groundwater, resulting in the
discharge of contaminants to the Great Miami River and subsequent
exposure of aquatic organisms
- Development of the site, resulting in exposure of future onsite
groundwater users
- Exposure of trespassers through direct contact with surface
contaminants
- Exposure of wildlife through direct contact with surface
contaminants
- Development of the site, resulting in exposure of future site
users through direct contact with contaminants exposed during
development
Groundwater Use Exposure Pathways
A contaminant plume extends south and southeast of the landfill. Human
exposure to contaminants can occur through the use of contaminated
groundwater as a drinking water supply. In residences, people can be
exposed to contaminants through ingestion of the water used for
drinking and cooking. They may also be exposed through ri«r"«T
absorption of contaminants, primarily during bathing and showering, and
inhalation of volatile compounds released from the water into the
household air during showering, bathing, cooking, or by the use of
household appliances such as water heaters and washing machines.
Employees and patrons of businesses that use the groundwater may also
be exposed.
The earliest detection of contamination in groundwater was at the
incinerator production well in 1973. Subsequent sampling of monitoring
wells and residential wells has indicated that contaminants have
migrated offsite through the groundwater in an east-southeasterly
direction.
There are 27 residences between the site and the Great Miami River
along County Highway 25-A. There are also eleven non-residential water
users near the site (seven businesses along 25-A, the ball diamond,
incinerator building, county highway garage, and the sheriff's
department). Analysis of residential wells sampled in 1985 indicated
that contaminants were present in 15 area wells.
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Based en groundwater modelling, groundwater from the site discharges to
the Great Miami River within approximately 3/4 mile to l mile south of
the site. Consequently, groundwater related exposures should be
limited to those individuals within that distance from the site using
groundwater for water supply. The City of Troy well fields are 2.5
miles south of the site and would not be affected by contaminants
released from the site.
Surface Water Exposure Pathways
The shallow groundwater discharges to the Great Miami River.
Contaminants from the site are thought to be discharging to the Great
Miami River, although none has been detected in the river by sampling.
The discharge of contaminants to the river could result in the exposure
of the aquatic organisms as well as terrestrial wildlife. Aquatic
organisms in the river could come into contact with contaminants in
solution or sorted to solids. They may also be exposed when water
containing the chemicals passes over gill surfaces, when the water is
ingested, or when they ingest other organisms that have incorporated
contaminants.
The first mechanism is termed "bioccaTcentration"; the mechanism
associated with dietary intake may be termed "bioaccumulation.'1
Terrestrial organisms that feed on aquatic organisms that have
incorporated contaminants may also be exposed, as would people who
consume fish from the river.
Soil and S**liment Expogire Pathways
The direct contact exposure pathway involves the physical contact of
receptors with the waste material or contaminated soil. The routes of
exposure associated with direct contact are typically ingestion and
dpirmal absorption. Direct contact exposures can occur in several
situations at the site.
Conditions. Trespassers could be exposed to contaminants in
the site surface soil and sediments in the Eldean Tributary since the
creek is seasonally dry. Access to the site is limited somewhat by a
fence across the entrance to the transfer station and by the operation
of the transfer station. Although the public is not allowed on the
site during the hours of operation of the transfer station, they might
trespass after hours or on the weekend. During the RI field work,
people were observed entering the site along the railroad tracks that
traverse the site. There was also evidence of hunting (e.g. , spent
shells and signs with bullet holes) . It is possible that children play
at the site although there is no documentation of this.
Terrestrial wildlife, such as small mammals, can come into contact with
contaminated soil, sediments, ingest plants that have taken up
contaminants or become coated with contaminated dust, or ingest other
organisms previously exposed to contaminants.
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Site Development. Development of the site for residential,
recreational, or ocntnercial purposes could present situations in which
people would have direct contact with contaminants, The degree of
exposure potential any of these situations depends on the specific use
of the site.
If the site is used for recreation, such as a park, exposure could
occur from contact with contaminants on the site surface. Such
exposure would be similar to that expected under the trespass setting
with two major differences. Park development may require landscaping,
including the laying of sod for play fields, which could limit contact
with contaminated soil. However, a park may attract more people to the
site than the number who would come to an undeveloped piece of land.
Both commercial and residential development of the site would require
the excavation of subsurface material for building foundations and
utility lines. Excavation could expose buried waste and contaminated
soil.
The degree of potential contact with contaminants resulting from site
development depends on:
- The location and extent of the excavation
- The deposition of excavated material (left onsite or taken
offsite for disposal)
- The amount of material excavated
- The particular type of site use
Commercial or light industrial development such as a shopping plaza,
office park, or warehouse would have a relatively low direct contact
potential. Access to contaminants would be limited because much of the
site would be covered by buildings and parking lots. Potentially
exposed individuals would most likely be maintenance personnel.
A residential site use would have a greater potential for direct
exposure than other uses. Gardens and lawns may provide ready access
to contaminants present in the surface soil. People can be exposed
through a variety of outdoor activities including gardening by adults
and play activities by children. Studies at other superfund sites have
indicated that contaminant levels in indoor dust are similar to these
found in contaminated outdoor soil. Therefore, direct contact
exposures may occur year round. Small children (toddlers) are most
likely to be exposed in the indoor setting.
VI. StMCVRY OF SITE RISKS
The Miami County Incinerator site is releasing contaminants to the
environment. Chapter 7 of the RI entitled "Endangennent Assessment"
presents the results of a comprehensive risk assessment that addresses
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the potential threats to public health and the environment posed by the
Site under current and future conditions assuming that no remedial
actions take place and that no restrictions are placed on future use of
the site.
Over fifty contaminants of concern were evaluated in the risk
assessment. These contaminants are listed in Table l. The risk
assessment also summarized the toxicity of and hazards associated with
exposure to contaminants of concern. These hazards are summarized in
Tables 2 through 11.
ACTUAL AND POTENTIAL EXPOSURE PATHWAYS
The endangerment assessment identified actual and potential exposure
pathways associated with the site under current site uses and pathways
associated with site development. The following exposure pathways were
identified as pathways of actual and potential concern for the site
under the no-action alternative:
- Exposure through use of contaminated groundwater as a water
supply
- Direct contact with contaminated surface soil by trespassers onto
the site
- Exposure of future site occupants to contaminants currently in
the subsurface soil if, as part of site development, the
contaminated media are excavated and left on the site surface.
GROUNDWATER EXPOSURE
A zone of contaminated groundwater extends from the site east and
southeast toward the Great Miami River. Based on an evaluation of
groundwater concentrations detected during the RZ, use of both the
upper and lower aquifers as water supply sources east and southeast of
the site pose an actual and potential health risk.
Excess lifetime cancer risks based on the mean (arithmetic) contaminant
Ttrations detected were 3 x 10"2 (ingestion) to 5 x 10"3
(inhalation) for the groundwater onsite to 6 x 10"~3 (ingestion) to 1 x
10~3 (inhalation) for the upper aquifer downgradient from the site and
3 x 10~3 (ingestion) to 5 x 10"4 (inhalation) for the lower aquifer
downgradient from the site. Onsite is defined as inside the property
boundary. The primary chemicals contributing to the risk levels are
vinyl chloride, trichloroethene, methylene chloride and tetrachloro-
ethene. Nbncarcinogenic risk, as evaluated by onrjTariisnn of estimated
daily intakes to reference dose, is limited to the onsite area. The
noncarcinogens present in concentrations of concern are toluene,
antimony and barium (detected once in round 1).
-------
TABLE 1
CONTAMINANTS OF POTENTIAL CONCERN
MIAMI COUNTY INCINERATOR SITE
• Acetone
• Aldrin
• Antimony
* Arsenic
' Barium
* Benzene
Benzo(a]anthracene
Benzo[b]fluoranthene
Benzo[k]fluoranthene
* Benzo(a]pyrene
* Beryllium
* Bis(2-ethylhexyl)phthalate
* 2-Butanone
* Cadmium
' Carbon disulfide
* Chlorobenzene
" Chlordane
* Chromium
Chyrsene
* Copper
ODD
ODE
* DDT
Dibenzo[a,h]anthracene
* Dibutyl phthalate
* 1,1 -Dichloroethane
* 1,2-Dichloroethane
* 1.1-Dichloroethene
* 1,2-Oichloroethene
* Dieldrin
* Diethyl phthalate
* Dioxins
' Ethylbenzene
* Hexachlorobenzene
lndeno[l ,2.3-cd]pyrene
* Isophorone
• Lead
* Manganese
• Mercury
* Methylene chloride
* 4-Methyl-2-pentanone
• 2-Methylphenol
* 4-Methylphenol
* Nickel
* N-Nitrosodiphenylamine
* Pentachlorophenol
• Phenol
• PCS
* Selenium
• Silver
* Styrene
* Tetrachloroethene
* Thallium
• Toluene
* 1,2,4-Trichlorobenzene
• 1,1.1 -Trichloroethane
* Trichloroethene
* Vanadium
* Vinyl chloride
* Xylenes
• Zinc
Contaminants of potential concern selected based on availability of cancer
potency factor, reference dose, or environmental criteria.
-------
-12-
The greatest risk levels are directly dcwngradient fron the Liquid
Disposal Area. Areas of lower risk are south of the site between Route
25-A and the Great Miami River. The groundwater directly east of the
South Landfill does not appear to be contaminated.
Wells. Potential noncarcinogenic risks and carcinogenic
risks for residential wells were estimated and the results are
summarized in Table 4. Only the incinerator well, which is no longer
in use, had a hazard index greater than one for ingestion of toluene.
Seven wells had detectable concentrations of carcinogens. The excess
lifetime cancer risk associated with a lifetime exposure to carcinogens
at the concentrations detected in the walls ranged from 1 x 10~4 to
2 x 10~7 for ingestion and from 4 x 10~4 to 4 x 10~8 for inhalation.
Monitoring Wells. The risk evaluation was based upon highest detected
concentration in an aquifer or area, the mean concentration for the
aquifer or area, and individual well concentrations. For some wells
there are several rounds of monitoring data, in which case data were
averaged together because there are no clear, consistent temporal
trends. The carcinogenic risk associated with the highest detected and
mean concentrations are summarized in Table 5.
Risk estimates for the source area groundwater range from 1 x 10'1 to
1 x 10~3 for ingestion and 2 x 10~2 to 3 x 10"4 for inhalation. Risk
estimates for both dcwngradient groundwater systems range from 7 x 10~2
to 4 x 10"4 for ingestion and 1 x 10~2 to 9 x 10"5 for inhalation. The
primary carcinogen determining the risk estimates is vinyl chloride.
Methylene chloride, bis(2-ethylhexyl)phthalate, n-nitrosodiphenylamine,
tetrachloroethene, and trichloroethene »l^o are present at levels
greater than 1 x 10"6.
Noncarcinogenic risks are summarized in Table 6. Hazard indices for
antimony and toluene are above unity in the source area for the highest
detected concentrations, and above unity for mean concentrations of
antimony. In the downgradient zones, the hazard index for highest
detected concentration is above unity because of barium. However,
barium was detected only at elevated levels in the first rounds. In
the latest round, the barium concentration was below any level of
concern.
Residential wells concentrations which exceed drinking water standards,
criteria and guidelines are summarized in Table 7. Monitoring well
Ttrations which exceed drinking water standards, criteria and
guidelines are summarized in Table 8.
Potential Q.trrent Soil Expos* VP?S
Exposures under current conditions (i.e., resulting from trespassing)
would be limited to exposure to contaminants present in the surface
soil. For this evaluation, the site was divided into two major
subareas—the areas north and south of the Eldean Tributary. The north
-------
TABLE 2
POTENTIAL CARCINOGENS
MIAMI COUNTY INCINERATOR SITE
Chemical
Aldrin
Arsenic
Benzene
Benzofajanthracene
Benzo[b]fluoranthene
Benzo[k]fluoranthene
Benzo(g.h.i]peryiene
Benzofalpyrene
Beryllium
Bis(2-ethylhexyl)phthalate
Cadmium
Chlordane
Chromium
Chrysene
000
DOE
DOT
1 ,2-Oichloroethane
1,1-Oichloroethene
Dieldrin
Hexachlorobenzene
lndeno[1 ,2.3-cd]pyrene
Methytene chloride
N-Nitrosodiphenylamine
Nickel
PCS
2.3.7.8-TCDD
Tetrachloroethene
Trichloroethene
Vinyl chloride
U.S. EPA Carcinogen
Assessment Group Classification
Ingestion
82
A
A
B2
B2
82
B2
B2
B1
B2
0
B2
0
82
B2
82
B2
B2
C
B2
82
C
82
82
0
B2
82
82
82
A
Inhalation
B2
A
A
B2
B2
B2
B2
82
81
B2
B1
82
A
82
B2
82
B2
B2
C
B2
82
C
82
B2
A
B2
B2
82
82
A
NOTE: U.S. EPA Carcinogen Assessment Group (CAG) Classification.
Group A Human carcinogen - Sufficient evidence from epidemioiogical studies.
Group 81 Probable human carcinogen - At least limited evidence of
carcinogenicity to humans.,
Group B2 Probable human carcinogen - Combination of sufficient evidence in
animals and inadequate data in humans.
Group C Possible human carcinogen - Limited evidence of carcinogenicity in
animals in the absence of human data.
Group O Not classified - Inadequate animal evidence of carcinogenicity.
-------
TABLES
NONCARCINOGEN CRITERIA
MIAMI COUNTY INCINERATOR SITE
(a)
REPRODUCTIVE
CHEMICAL TOXICITYOR
TERATOGENICITY
(b) (c)
MUTAGENICITY ACUTE
TOXICITY
(d)
1
CHRONIC
EFFECT
Acetone - - .
Aldrin
Antimony
Arsenic
Barium
Benzene
Benzo(a|anthracene
X
X
X
X
X
-
X X
X X
X X
X
X
X
X i
—
X
-
X
—
Benzo(b|fluoranthene - -
Benzo(k]fluoranthene - - -
Benzojajpyrene
Beryllium
Bis(2-ethylhexyl)phthalate
2-Butanone
Cadmium
X
-
X
X
X
X
— . -
- . -
-
-
—
X
—
— '
X
Carbon disulfide - -
Chlordane
X
X
X
Chlorobenzene
Chromium
X
-
X
Chrysene -
Copper - •• • -
DOE
DDD
DDT
Dibenzo[a,h]anthracene
Dibutylphthalate
X
X
X
-
X
-
- . -
-
X
• - -
X
X
X
-
X
1,1-Oichloroethane - - -
1 ,2-Oichloroethane
1 , 1 -Oichloroethene
-
X
X
X
X
-
1 ,2-Dichloroethene -
Dieldrin
Diethyl phthalate
Ethylbenzene
Hexachlorobenzene
Lead
Manganese
Mercury
Methylene chloride
X
X
X
X
X
-
X
-
X
X
' • - •-
-
-
X
X X
X
-
-
-
X
X
-
X
'
4-Methyl-2-pentanone - - - -
(See page 2 for footnotes)
-------
TABLES
NONCARCINQGEN CRITERIA
MIAMI COUNTY INCINERATOR SITE
(a)
REPRODUCTIVE
CHEMICAL TOXICITY OR
TERATOGENICITY
(t>) (c)
MUTAGENICITY ACUTE
TOXICITY
(d)
CHRONIC
EFFECT
Methyl phenol - - - -
Nickel
Pentachlorophenol
X
X
- —
-
X
—
Phenol - - - .
PCB
Selenium
Silver
X
X
•
-
X
X
-
-
-
Styrene - - - -
2.3.7.8-TCDO
Tetrachloroethene
Thallium
Toluene
X
X
• -
X
X
X
X
-
X
. -
-
-
Trichlorobenzene - - ' - - '
1,1,1 -Trichloroethane
Trichloroethene
Vanadium
Xylene
-
-'
-
X
X -
X
X
-
-
-
-
-
Zinc -
NOTE: Adopted from 'Chemical, Physical, and Biological Properties of Compounds Present at Hazardous
Waste Sites.* Office of Waste Programs Enforcement (OWPE), U.S. EPA 1985. Criteria presented
below is that of OWPE. An 'X* indicates the chemical meets the criteria outlined by OWPE for the
particular toxic effect classification. The lack of an 'X' under a classification does not
necessarily imply that the chemical cannot have a toxic effect. Note, not all chemicals of concern
were evaluated in the OWPE document
(a) Chemicals are classified as teratogens and reproductive toxins if there is suggestive evidence of
an effect in humans or if at least one study in whole animals is dearly positive. Unsupported in
vitro evidence is considered sufficient to classify a chemical as as a reproductive
toxicity/teratogenicity hazard.
(b) A chemical is classified as mutagenic if it has given a positive result in at least one of the
mammalian in vivo or mammalian cell in vitro assays for mutagenitity.
(c) A compound is considered to be acutely toxic if it has an oral L050 < or « 100 mg/kg, an
inhalation LC50 < or» 400 mg/cubic meter, or a dermal LD50 < or * 400 mg/kg.
(d) Chemicals will be considered to cause chronic toxicity if they cause serious irreversible
effects other than cancer or reproductive effects after extended exposure to oral doses of less
than 100 mg/kg/day, inhalation concentrations < 100 mg/kg/day, inhalation concentrations less than
400 mg/cubic meter, or dermal doses less than 100 mg/kg/day.
2 of 2
-------
TABLE 4
SUMMARY OF RISKS - RESIDENTIAL WELLS
MIAMI COUNTY INCINERATOR SITE
wei
RW01
RW05
RW07
RW08
RW11
RW13
RW14
RW17
RW19
RW20
RW2S
RW31
RW34
RW36
HAZARD
•cot
0.760
0.120
0.002
0.057
2.200
Toiuena (a)
0.370
0.370
0.140
0.004
0.004
0.029
0.180
0.370
0.008
HAZARD
MDEX
0.042
0.031
0.003
0.016
0.910
0.002
0.008
0.006
0.005
0.006
0.043
0)
(b)
0.012
EXCEHUFCTWE
CANcstnat
1E-04
8E-07
-
2E-07
-
-
-
• - •
-
-
2E-07
3E-07
2E-06
4E-07
9E-07
2E-OS
BOCEHLFEnuE
CANCS*RHK
4E-04
1E-06
-
3E-07
-
-
-
-
-
.
3E-07
4E-07
2E-07
4E-08
2E-06
2E-06
OBIICAL
1,1-Ofchloroethene [82]
Trichloroethene [82]
No Carcinogens Detected
Trfchloroethene [82]
No Carcinogens Detected
No Carcinogens Detected
No Carcinogens Detected
No Carcinogens Detected
No Carcinogens Detected
No Carcinogens Detected
Trichloroethene [82]
Trichloroethene (82]
Tetrachloroethene [82]
Tetrachloroeihene [B2]
Trichloroethene (B2J
Tetrachloroethene [82]
coNcerrHATOM
(uo/n
7.5
2.6
0.6
0.5
0.8
1.2
0.3
3.0
15.0
NOTE: Residential well assessment based on highest concentrations detected in residential well. See
Volume II of the Remedial Investigation Report. Appendix I, Tables 1-1 through I-20A.
Exposure assumptions: 70kg body weight; daily exposure; ingestion of 2 liters/day; inhalation
exposures are assumed to be 150% of ingestion exposures.
(a) Estimated daily intake of toluene greater than its RfO by a factor of 1.6
(b) No volatile noncarcinogens, consequently no inhalation hazard index calculated.
-------
TABLE 5
SUMMARY OF CANCER RISKS FOR GROUNDWATER BASED ON MONITORING WELLS
MIAMI COUNTY INCINERATOR SITE
Chamtealand
Group ClaaihVaHon
Mghaal IneMHon:
(Maetatf f — rtt
(tlfA) Mound CaneaiRM
Inhalation: AiMim
r»rin U
••a k
•an
Eacaa*
Canoaf Ha* (ug/l) CanoM RM
Mialatan: Oaomalilo InflMaga:
Cfloaaa Maan Eaoaaa
Utokna CanoamraMon LNakn*
CanowHM (ugA.) CanoMRWi
MiaUikm:
IN* Dm*
SOURCE AREA GROUNDWATEH (a)
Ai tank |A|
Uathytana chtalda |B2|
Titehlofotlhtna |B2|
Vinyl chtald. |A|
Tola! •/ At icnte
Total M/OUI AfMnfc (b)
14.7
3*0
•2
IUO
_
-.
UPPER GROUNDWAtfA AUUIFER DOWNGRADIENT
ArtantelA]
Bt^2-»lhylh««yl)phlh»l«l» |B2|
l.2-CHchkxolh»n» |B2|
Mclhyton* chloikJ* |B2|
N-Nillo«odlph«n,l»mm« |fl?|
T*uachloio*ih*n« |H2|
Titchk»o*lh*n» |B2|
Vinyl chkvld* |A|
Total ml Aracnte
Total v/oul Aitonlc (b)
27.9
21
3
92
20
130
* 7
1100
-
-
LOWER GROUNDWATER AQUIFER DOWNGRADIENT
Actanlc |A|
Bla(2-«inylh*iiyl)phihalaM |B2|
aUthytona chloilda |B2|
N-Nllio*odlph*nylamlna |B2|
TricMoroalnana |B2|
Vinyl cfikvM* |A|
Total ml AtMnfc
Total w/out AfMnlc (b)
19.4
370
21
10
3*
790
'
-
CH9A/3
CH9A/3
CHItA/3
CH9A/3
(c)
CHIOA/3
MWD7A/2
WWD4A/3
MWD4A/I
UWD1A/3
CHIOA/3
UWD4A/I
CIII1A/3
(d)
MWOSC/3
UWD4B/3
MW09C/I
MWMC/3
MW04B/3
CHI4B/3
7E-O4
7E-OS
2E-OS
IE-OI
IE-OI
IE-OI
1E-03
9E-09
9E-09
IE-OS
3E-09
2E-04
IE -06
7E-02
7E-02
7E-02
IE -01
IE-O4
4E-09
1E-06
IE-0&
6E-02
6E-02
6E-02
-
2E-04
4E-O6
2E-02
_
2E-02
-
' -
IE -06
4E-0&
-
2E-OS
SE-09
IE -02
-
IE -02
-
-
IE-OS
'
2E-OS
IE-02
-
IE -02
NOTE: See Volume II ol the Remedial Investigation Report. Appendix 1. Tables 1-82 through 1-84.
Exposure assumptions: 70 kg body weight; daily exposure; ingestion ol 2 liters/day; inhalation Is
(a) Source area groundwater
estimated Irom wells: CH09A. CH18A
. CH08B.
CH18B.
(b) Evaluation ol carclnogenicity ol arsenic in drinking water Is currently being evaluated by U.S EPA.
(c) Upper aquiler estimated
Irom wells: MW04A.
(d) Lower aquiler estimated Irom wells: MW04B.
MW05A. MW06A. MW07A.
MW05B. MW05C.
MW06B.
7.4
94
17
390
.
-
7.4
-
-
93
-
-
16
99
-
-
7.3
29
4.6
-
6
39
-
-
4E-O4
2E-05
6E-06
IE -02
3E-02
3E-02
4E-04
-
-
2E-09
-
-
IE -06
6E-01
6E-O1
6E-03
4E-O4
IE-OS
IE-06
-
2E-06
3E-03
3E-03
IE -03
150% ol intake through
-
SE-OS
IE-OS
6E-03
.
6E-03
-
-
-
6E-06
-
-
2E-09
IE -03
-
IE -03
-
-
3E-06
-
3E-06
6E-04
-
6E-04
ingestion.
All arsenic concentrations are below current
66 3E-04
9.6 26-06
66 2E-09
21 16-01
2E-03
IE-O3
63 3E-O4
-
-
36 tE-O7
-
-
32 IE 06
10 7E-04
IE -03
7E-04
83 3E-04
74 3E-06
3.3 7E-07
-
3.4 IE -06
9.7 4E-04
8E-04
4E-04
MCL ol 50 ug/l.
_
6t 06
lfc-08
IE -04
.
IE -04
-
-
-
2E-06
-
-
2E-08
It CM
-
IE 04
-
-
2E-O6
-
2E-OA
•E-0&
-
et 05
CH10A. CH13A. CH13B. CH14A.
MW06C. MW07B. MW07C. CH10B.
CH14B. CH16A. CH16B.
-------
SUMMARY OF NONCARCINOGENIC RISKS FOR GROUNDWATER BASED ON MONITORING WELLS
MIAMI COUNTY INCINERATOR SITE
CtMO**
DtMctod
CanowHrukM
*»o*)
lAjvaJ
v^wv
Hound
ArMumlto
IngMftM . Inhitadaa UMA
ttaurd Huwd ConoMUMIon
Iftd^K Index (uo/Lk
toflMHan
HuMd
Imtoi
QcanMttto
hilMUaan Wun big****
Huod ConawtkuhM Hurnl
lnd*i (ua/L) kidcx
Miriam
H*a»d
kvl.*
SOURCE AREA GROUNDWATER (a)
TOTAL
Tofcww
n
14600
CHUM
CN»AO
•.1 (d) it (•)
(.4 - 41
14 0.41 3000
3.7
2.0
0.34
0.07 - 20
30 2.7
O.I . 22 0.002
0.03
01XXM
UPPER GROUNDWATEH AQUIFER DOWNGRADIENT (b)
TOTAL
-
-
0.17 0.21
0.24
0.04 - 0.10
0017
LOWER GROUNDWATER AQUIFER DOWNGRADIENT (C)
TOTAL
avfam
-
3160
-
MW04MI
32 0.03
1.0 - 440
0.34
0.26
0.006 - 0.212
2W 017
0.004
-
NOTE: See Volume II ol Ihe Remediallnvestlgallon Report. Appendix I. Tables 1-85 through 1-87.
Exposure assumptions: 70 kg body weight; dally exposure: Ingestlon of 2 liters/day; Inhalation Is 150% ol Intake through Ingeslion.
(a) Source area ground water estimated from wells: CH09A. CH18A. CH08B. CH18B.
(b) Upper aquifer estimated from wells: MW04A. MW05A. MW06A. MW07A. CH10A. CH13A. CH13B. CH14A.
(c) Lower aquifer estimated from wells: MW04B. MW05B. MW05C. MW06B. MW06C. MW07B. MW07C. CH10B. CH14B. CH16A. CH16B.
(d) Hazard index lor all chemicals, not just those listed as exceeding Individual hazard Indexes.
(e) Hazard Index lor sum of chemicals is greater than 1. however, no Individual chemical's hazard Index is greater than 1. Aggtregallng and
and summing chemicals by similar effect does not yield a hazard Index greater than 1.
-------
TABLE 7
SUMMARY OF RESIDENTIAL WELL CONCENTRATIONS THAT EXCEED
DRINKING WATER STANDARDS, CRITERIA, AND GUIDELINES
MIAMI COUNTY INCINERATOR SITE
WELL
RW01
RW02
RW03
RW04
RW05 '
RW08
RW11 *
RW13
RW14
RW25
RW31
RVV34
RW36
DATE
Oct. 1985
Nov. 1984
Nov. 1984
Nov. 1984
Nov. 1984
Nov. 1984
May 1985
May 1985
May 1985
May 1985
May 1985
Oct. 1985
Oct. 1985
Oct. 1985
CHEMICAL
1 , 1 -Dichloroethene
Lead
Lead
Lead
Lead
trans- 1 ,2-Oichlorethene
Trichloroethene
Trichloroethene
Arsenic
4-Metrtyfphenol
Nickel
Toluene
Ethytbenzene
Xylene
Nickel
Arsenic
Trichloroethene
Tetrachloroethene
Trichloroethene
Tetrachloroethene
Tetrachloroethene
Trichloroethene
CONCENTRATION
(ug/i)
7.5
5.7
6.1
10.4
6.4
350
2.2
0.6
14
45
59
18,000
1,200
3,700
22
5.2
0.5
1.2
0.8
0.3
15
3
CRITERIA
EXCEEDED
MCL
MCLG
WQC-RISK
MCL-PROP
MCLG-PROP
MCL-PROP
MCLG-PROP
MCL-PROP
MCLG-PROP
MCL-PROP
MCLG-PROP
MCLG-PROP
MCLG
MCLG
WQC-RISK
WQC-TOX
WQC-TOX
MCLG-PROP
WQC-TOX
DWHA
MCLG-PROP
MCLG-PROP
DWHA
WQC-TOX
WQC-RISK
MCLG
MCLG-PROP
WQC-RISK
MCLG
MCLG-PROP
MCLG-PROP
WQC-RISK
MCLG
WQC-RISK
CRITERIA
LEVEL
7
7
0.033
5
0
5
0
5
0
5
0
70
0
0
0.0025
0.1
15.4
2,000
15,000
10,100
680
440
400
15.4
0.0025
0
0
0.88
0
0
0
0.88
0
2.8
NOTE: Comparison based on highest delected concentration in residential well.
CRmERIAKEY
MCL Maximum Contaminant Level
MCLG: Maximum Contaminant Level Goal
MCLG-PROP: Maximum Contaminant Level Goal - Proposed
WQC-TOX Water Quality Criteria - Toxfcity Protection - Drinking Water
WQC-RISK: Water Quality Criteria €> 1E-06 Cancer Risk - Drinking Water
DWHA: Drinking Water Health Advisories (Lifetime)
0 Well no longer in service.
-------
TABLES
SUMMARY OF MONITORING WELL CONCENTRATIONS
THAT EXCEED DRINKING WATER STANDARDS, CRITERIA, AND GUIDELINES
MIAMI COUNTY INCINERATOR SITE
Rl
Well Round Chemical
MW03-A 3 N-Nitrosodipnenylamine
MW04-A 1 Vinyf chloride
Trichloroethene
Benzene
Tetrachloroethene
Arsenic
2 Trichloroethene
Arsenic
Lead
3 1 ,2-Dichloroethane
Arsenic
MW04-B 1 Vinyl chloride
Trichloroethene
Barium
Concentration
(ug/i)
20.0
55.5
8.7
2.7
4.5
5.5
7.5
10.2
12.0
3.0
14.4
13.0
8.0
3150.0
Criteria
Exceeded
WQC-RISK
MCL
MCLG
WQC-RISK
MCL
MCLG
WQC-RISK
MCLG
WQC-RISK
MCLG-PROP
WQC-RISK
WQC-RISK
MCL
MCLG
WQC-RISK
WQC-RISK
OWHA
MCL-PROP
MCLG-PROP
MCLG
WQC-RISK
WQC-RISK
MCL
MCLG
WQC-RISK
MCL
MCLG
WQC-RISK
MCL
MCLG-PROP
DWHA
Criteria
Level
4.9
2
0
2
5
0
2.8
0
0.67
0
0.8
0.0025
5
0
2.8
0.0025
10
5
0
0
0.94
0.0025
2
0
2
5
0
2.8
1000
1500
1800
Page 1 of 4
-------
TABLES
SUMMARY OF MONITORING WELL CONCENTRATIONS
THAT EXCEED DRINKING WATER STANDARDS, CRITERIA, AND GUIDELINES
MIAMI COUNTY INCINERATOR SITE
Well
MW05-C
MW06-A
MW06-B
MW06-C
MW07-B
MW07-C
CH9A
Rl
Round
2
3
2
3
1
2
3
1
1
3
2
1
3
3
Chemical
Cadmium
Vinyl chloride
Trichloroethene
Barium
Trichloroethene
Arsenic
Arsenic
Trichloroethene
Trichloroethene
Lead
N-Nitrosodiphenylamine
Arsenic
Arsenic
N-Nitrosodiphenylamine
Lead
Beryllium
N-Nitrosodiphenylamine
Vinyl Chloride
Concentration
(ug/0
6.5
10.0
17.0
1630.0
36.0
17.0
19.4
4.5
3.0
5.6
8.0
4.1
8.5
10.0
13.0
1.1
9.0
1550.0
Criteria
Exceeded
MCLG-PROP
MCL
MCLG
WQC-RISK
MCL
MCLG
WQC-RISK
MCL
MCLG-PROP
MCL
MCLC
WQC-RISK
WQC-RISK
WQC-RISK
MCL
MCLG
WQC-RISK
MCL
MCLG
WQC-RISK
MCL-PROP
MCLG-PROP
WQC-RISK
WQC-RISK
WQC-RISK
WQC-RISK
DWHA
MCL-PROP
MCLG-PROP
WQC-RISK
WQC-RISK
MCL
MCLG
WQC-RISK
Criteria
Level
5
2 i
0
2
5
0
2.8
1000
1500
5
0
2.8
0.0025
0.0025
5
0
2.8
5
0
2.8
5
0
4.9
0.0025
0.0025
4.9
10
5
0
0.39
4.9
2
0
2
Page 2 of 4
-------
TABLES
SUMMARY OF MONITORING WELL CONCENTRATIONS
THAT EXCEED DRINKING WATER STANDARDS, CRITERIA. AND GUIDELINES
MIAMI COUNTY INCINERATOR SITE
Well
CH10A
CH10B
CH13B
Rl
Round Chemical
Trans-1 ,2-Dichloroethene
1.1.1 -Trichloroethane
Toluene
Ethylbenzene
Xylenes (total)
4-Methylphenol
Arsenic
Nickel
3 Trichloroethene
Tetrachloroethene
Arsenic
3 Tetrachloroethene
Arsenic
3 Vinyl chloride
Trans-1 ,2-dichloroethene
Nickel
Concentration
(ug/i)
3150.0
1250.0
14500.0
910.0
7450.0
14.5
14.7
35.5
5.0
130.0
27.6
7.0
17.5
1100.0
2500.0
26.0
Criteria
Exceeded
MCLG-PROP
DWHA
MCL
MCLG
DWHA
MCLG-PROP
DWHA
MCLG-PROP
MCLG-PROP
DWHA
WQC-O.C.
WQC-RISK
WQC-TOX
MCL
MCLG
WQC-RISK
MCLG-PROP
WQC-RISK
WQC-RISK
MCLG-PROP
WQC-RISK
WQC-RISK
MCL
MCLG
WQC-RISK
MCLG-PROP
DWHA
WQC-TOX
Criteria
Level
70
350
200
200
1000
2000
10100
680
440
2200
0.1
0.0025
15.4
5
0
2.8
0
0.8
0.0025
0
0.8
0.0025
2
0
2
70
350
15.4
Page 3 of 4
-------
TABLE 8
SUMMARY OF MONITORING WELL CONCENTRATIONS
THAT EXCEED DRINKING WATER STANDARDS, CRITERIA, AND GUIDELINES
MIAMI COUNTY INCINERATOR SITE
Well
CH14A
CHUB
CH16A
CH16B
CH18A
CH18B
Rl
Round
3
3
3
3
3
3
Chemical
Vinyl chloride
Trans- 1 ,2-dichloroethene
Vinyl chloride
Nickel
Nickel
Trichtoroethene
Nickel
Concentration
(ug/i)
200.0
2000.0
760.0
37.0
39.0
62.0
33.0
Criteria
Exceeded
MCL
MCLG
WQC-RISK
MCLG-PROP
DWHA
MCL
MCLG
WQC-RISK
WQC-TOX
WQC-TOX
MCL
MCLG
WQC-RISK
WQC-TOX
Criteria
Level
2
0
2
70
350
2
0
2
15.4
15.4
5
0
2.8
15.4
CRITERIA KEY
MCL:
MCLG:
MCLG-PROP:
WQC-TOX:
WQC-RISK:
WQC-O.C.:
DWHA:
Maximum Contaminant Level
Maximum Contaminant Level Goal
Proposed Maximum Contaminant Level Goal
Water Quality Criteria - Toxic Protection - Drinking Water
Water Quality Criteria @ 1E-06 Cancer Risk - Drinking Water
Water Quality Criteria - Organoleptic Criteria
Drinking Water Health Advisories (Lifetime)
Page 4 of 4
-------
-13-
area includes the North landfill, the Liquid Disposal Area, and the Ash
Pile.
Risks associated with soils under the trespass route are summarized in
Table 9.
The evaluation of noncarcinogenic risks suggested a potential concern
over soil ingestion because of lead concentrations, Comparison of
estimated intakes to RfDs indicated that the estimated intakes for
children based on highest detected and average lead concentrations in
the northern area would exceed the RfD for lead. Estimated adult
intakes of lead exceed the RfD based on the highest detected
Three surface samples (SS14 in the Liquid Disposal Area and SS19 and
SS20 from the Ash Pile) contribute most significantly to this risk. If
those samples are separated from the average for the north area of the
site, the estimated average intake would be below any level of concern.
This indicates that the Ash Pile and the Liquid Disposal Area are the
areas of potential concern for direct contact.
There are no U.S. EPA soil criteria for lead or most other chemicals.
The Centers for Disease Control (CDC) have said that soil lead
Ttrations greater than 500 to 1,000 mg/kg can cause increased
blood lead levels in children in residential settings. The lead levels
detected in the samples mentioned above exceed the CDC warning levels.
Although the site is not a residential setting, residences are nearby
and there is no restriction to access to the site.
The potential carcinogens aldrin, benzo [a] anthracene, chrysene,
dieldrin, DDE, DDD, and chlordane were detected in the surface soil.
Except for dieldrin, which was detected in two samples, each chemical
was detected only once; therefore it is not possible to estimate an
average surface soil concentration for these chemicals. Excess
lifetime cancer risks from direct contact (by ingestion) with surface
soils are based on the highest detected contaminant levels. Risks
estimated by this approach would be conservative because of the limited
distribution and generally lew concentration of these chemicals. The
excess cancer risk level estimates range from 3 x 10~8 (for the more
frequent exposure) to 2 x 10~10 (for a one-time exposure) .
Potential ^^ Sediment Exos' i
Trespassers may come into contact with the sediments in the Eldean
Tributary. The ability to estimate risks from the sediment is limited
by two factors: the limited number of tributary sediment samples (3)
taken adjacent to the site and the inability to positively attribute
the contaminants present in the sediment to site activities.
-------
Table 9
SUMMARY OF RISKS - DIRECT CONTACT
WITH SOIL AND SEDIMENT - TRESPASS SETTING
MIAMI COUNTY INCINERATOR SITE
Chemical
Target Hazard Exceeding
Area Concentration Population Index RfO
CARCINOGENIC RISK
Entire Site (a)
(North and South
Landfill)
Eldean Tributary (d)
Sediments
NON CARCINOGENIC RISK (e)
North Landfill
Sncluding Liquid
isposal Area and Ash Pile)
North Landfill
(excluding Liquid
Disposal Area and Ash Pile)
South Landfill
Eldean Tributary
Sediments
Highest
Detected
Highest
Detected
Highest
Detected
Mean
Highest
Detected
Mean
Highest
Detected
Mean
Highest
Detected
Mean
Highest
Detected
Mean
Highest
Detected
Mean
Highest
Detected
—
—
Adult 2.7 Lead
Adult 0.63
Child 5.4 Lead
Child 1.3 Lead
Adult 0.16
Adult
Child 0.32
Child
Adult 0.21
Adult
Child 0.42
Child
Child 0.006
Adult 0.003
txcess
Lifetime Primary
Cancer Risk Chemical
3E-08 (b) PAHs. Dieldrin
2E-10 (c)
2E-09 (b) PAHs, PCS
3E-07 (c)
—
—
__
—
—
—
—
—
— •
—
—
NOTE: See Volume II of the Remedial Investgation Report. Appendix I, Tables 1-88 through 1-94.
(a) Cancer risk from direct contact with soil during trespass is based on highest concentrations
of carcinogens detected in soil across the entire site because of the limited number of surface
soil samples containing carcinogens.
(b) Risk estimated assumed ingestion of 0.1 g of soil/day. Exposure assumed to occur for 5 years.
26 weeks per year.
(c) Risk estimated assumed ingestion of O.ig of soil/day. Exposure assumed to occur once.
(d) Cancer risk from direct contact with sediment during trespess is based on highest concentrations
of carcinogens detected in sediment because of the limited number of carcinogens detected in sediment.
This estimate assumes chemicals are due to site activities.
(e) Noncarcinogenic risks estimated by comparing estimated daily intake to reference dose (RID)
value. Adult exposure assumed a body weight of 70-kg and a soil! ingestion rate of O.lg/day.
Child exposure assumed a body weight of 35-kg (10-year old) and a soil ingestion rate of O.lg/day.
-------
-14-
The evaluation of noxarcinogenic risks indicate that under the defined
exposure conditions the hazard index would not exceed one. Hie excess
lifetime cancer risk estimate ranges from 2 x 10"9 for one-time
exposure to 3 x 10~*7 (for more frequent exposure).
Future Soil Exposures
Soil exposures might occur if the site is developed, if the site is
unused but left open for trespass/ or if the site is used as a park.
Residential site use could produce the greatest exposures. Development
of the site could result in the excavation of soil for building
foundation and utility lines. Contaminated subsurface material could
be left on the site surface when future residents could come into
contact with it. The contaminant concentrations to which future
residents may be exposed to would depend on what portions of the site
are excavated, the depth of excavation, and the ultimate deposition of
the material. These concentrations cannot be predicted precisely,
especially since the RI soil sampling efforts were focused on potential
source areas (i.e., liquid disposal area and ash pit).
The evaluation of noncarcinogenic risk suggest a potential risk from
soil ingestion under residential development due primarily to lead.
Ihe excess lifetime cancer risks range from 2 x 10~3 (based on the
highest detected concentrations) to 3 x 10~5. (based on the geometric
mean concentrations). Ihe primary chemicals contributing to the risk
estimates are dioxins, arsenic, hexachlorobenzene, EAHs, and FCBs.
Future development soil risks are summarized in Table 10.
VII. DISCUSSION OF CHANGES FRCM PROPOSED PIAN
CERCIA Section 117 (b) requires that the final selected remedial action
plan be accompanied by a discussion of any significant changes from the
proposed plan and of the reason for such changes. U.S. EPA has
received ^rMjt>i
-------
Table 10
FUTURE DEVELOPMENT - SOIL RISK SUMMARY
MIAMI COUNTY INCINERATOR SITE
Concentration
Highest Detected
Arithmetic Mean
Geometric Mean
Target
Population
Residents (a)
Adult (b)
Child (c)
Residents
Adult
Child
Residents
Adult
Child
Hazard
Index
8.2
38
--
0.65
3
.
0.1
0.49
Chemical Excess Lifetime
Exceeding RfO Cancer Risk
2E-03
Chromium (»6)
Lead
Chromium (+6)
Lead
Antimony
1E-04
—
Lead
3E-05
_.
_.
Primary
Chemical
Dioxms, Arsenic.
Hexachlorooenzene,
PCS, PAHs
~ ~
PAHs, Oioxins
— '
—
PAHs, Dioxins
--
--
NOTE: See Volume II of the Remedial Investigation Report, Appendix I, Tables I-95 through 1-103.
(a) Carcinogenic risk estimates assume ingestion of 0.1 g soil/day for 70 years. Body
weight of 70-kg is assumed.
(b) Adult noncarcinogenic risk estimated by comparing estimated daily intake to
to reference dose (RfO) value. Assumes a soil ingestion rate of 0.1 g soil/day
and a 70-kg body weight.
(c) Child noncarcinogenic risk estimated by comparing estimated daily intake to reference
dose (RfO) value. Assumes a soil ingestion rate of O.tg soil/day and a 15-kg (toddler)
body weight.
-------
VIII.
-15-
sinoe the cost of treating the groundwater has been greatly reduced.
Thus, more groundwater can be treated at a lower cost and little
dewatering prior to vapor extraction need occur.
In response to the BIEC Garments and other comments, U.S. EPA
reconsidered and analyzed sane of the information already in its
possession. Specifically, it revisited the "applicable or relevant and
appropriate" issue of the cap for the North landfill including the
Liquid Disposal Area basfri on (40 CFR Part 265) . While as much as 30
percent of the waste placed in the North landfill was industrial, the
amount of hazardous substances placed in this area is estimated to be
only a small percentage of the total waste. Therefore, capping this
area in accordance with the State sanitary landfill closure regulations
is deemed relevant and appropriate.
The Liquid Disposal area had a substantial amount of Hagarrv«va
substances including some hazardous wastes placed in it and therefore,
will be closed according to RCTJA subtitle C. It will be closed with a
double barrier cap which will meet provisions on 40 CFR part 265.310
and the U.S. EPA minimum technology guidance for ha%arrv*is waste
landfills.
The BIEC public comment submittal and subsequent submittals proposed
capping the Ash Disposal pit in place and covering the cap with an
asphalt parking lot. The proposed cap would meet State closure
requirements and be equally protective of human health and the
environment for this type of a waste area and is thus considered on
equivalent alternative to the selected remedy.
In general, the additional information based on use of the Troy POIW,
the ability of the single barrier cap to comply with State sanitary
landfill closure requirements for the North landfill, and the ability
of the double barrier cap to comply with 40 CFR 265 and minimum
technology guidance for the Liquid Disposal area, all support a
modification of the proposed remedy.
QCMMDN TO AT^' FMEDAL^ ACTIONS
Response actions that will be required for sane or all of the operable
units include flood control, access restrictions, and groundwater
monitoring.
FD30D
Part of the incinerator site lies within the 100-year flood plain. The
100-year flood is a flood that has a 1 percent change of being equalled
or exceeded in any given year. The proposed flood protection measure
associated with containment alternatives is to grade the final cover or
cap to a maximum slope of one vertical to three horizontal, install
erosion matting along potential flood areas, and establish dense
-------
-16-
yegetation on the cover or cap. Earth berms and rip-rap would result
in greater modifications to the floodway, so they were not considered.
Minimum alteration of the floodway could be achieved by balancing the
materials removed or placed below the 100-year flood elevation.
Access restrictions include regulation of site land use by zoning, by
restrictive covenants in the deed, and by fencing the site. A 6-foot-
high chain link fence with warning signs to trespassers would be placed
around the North and South Landfills including the Liquid Disposal
Area. Fencing would also enclose any treatment or storage facilities
constructed onsite.
Future land use at the site would be restricted under all remedial
alternatives. Restrictions would prevent onsite development or other
activities that might compromise protective measures or interfere with
long-term site monitoring.
The purpose of deed notifications is to record a note on a deed or some
other instrument examined during a title search that would notify any
potential purchaser that the land had been used for waste flispngal and
that land use is restricted. Deed restrictions would prevent
disturbance of the final cover or cap and control future property use.
Offsite groundwater withdrawal restrictions would be necessary to
prevent any adverse impact to the proposed extraction well system.
Groundwater users located within the pathway of groundwater
contaminant migration would continue to be offered access to the City
of Troy's public water supply and existing wells would be properly
GPOUNDWAJTR MDKITORDIG
Groundwater monitoring will be performed to evaluate the effectiveness
of remedial actions. Monitoring will focus on the effectiveness of
actions designed to control contaminant release from the Liquid
Disposal Area and to control the existing groundwater contaminant
plume. Monitoring will also include evaluation of the long-term
effectiveness of remedial actions taken at the North and South
Landfills, and the Ash Pile and the Ash Disposal Pit. The ground
water monitoring program is Higr»ig.cpri below.
In addition to the monitoring network that is in place, additional
groundwater monitoring will be required. At a minimum, this will
include monitoring locations as presented in Figure 3.
-------
-17-
A monitoring well cluster (one monitoring well in the
upper aquifer, and one monitoring well in the lower aquifer will be
installed on the south edge of the south landfill, see Figure 3) . An
additional monitoring well will be installed in the upper aquifer at
the location (31-06. A monitoring well will also be installed in the
lower aquifer at location CH-07.
Contaminant Plume. Three monitoring well clusters (one monitoring well
in the upper aquifer, and one monitoring well in the lower aquifer)
will be installed along the northern bank of the Eldean Tributary to
monitor the southern component of contaminant movement. A fourth
monitoring well cluster will be located at the corner of Lytle Road,
and County Road 25-A.
Groundwater Q»V*IJ^YT All monitoring wells including upgradient wells
and those hydraulically downgradient from both the north and south
landfills and Liquid Disposal Area, and completed in either the upper
or lower aquifers will be sampled immediately before and after start-up
of the extraction system, on a quarterly basis at least for the first
year and on a semi-annual basis at a minln*m thereafter. Groundwater
samples will be analyzed quarterly for the full CLP list of compounds
for the first year, at which time a site-specific parameter list will
be developed. Subsequently, groundwater samples will be analyzed for
the site-specific parameter list. At the end of the second year, and
every two years thereafter, selected monitoring wells (to be determined
later) within the network will again be sampled and analyzed for the
full CLP list.
SOUIH LANDFiri- OPERABLE UNIT
The surface area of South TandfUi is approximately 17 acres and would
require clearing, grubbing, regrading, filling, and compaction before
installation of a soil cover or cap. Three-parallel mounds from
landfill tuanii and fill operations run from east to west and occupy
approximately one half the landfill. The slopes of the mounds range
from 6 to 23 percent. The remaining half of the landfill area is
relatively flat with slopes averaging less than 1 percent. Minimum
final slopes of 3 percent were assumed for the cover and cap
alternatives. Because this is a sanitary landfill, allowances in
design, construction, and maintenance must be made for differential
settlement to maintain required final slopes.
The South Landfill was in operation for approximately 10 years and
reportedly accepted general municipal refuse. As a result, the
landfill may generate methane gas in sufficient quantities to cause the
migration and accumulation of gases in explosive concentrations if not
property vented. Therefore, installation of landfill gas vents for any
of the containment alternatives will be evaluated during predesign or
design. In any case, a plan for monitoring explosive gases to satisfy
the requirements of QAC 3745-27-12 will be implemented.
-------
»CAI § m rair
FKMIRE2
SHE VICINITY MAP
nccono OF DECISION
-------
-18-
The 100-year flood plain extends along the Eldean Tributary and may
approach the northern boundary of the South landfill. Slopes along
that boundary would be stabilized with soil stabilization matting as
necessary.
The South landfill would remain as it is under the no action
alternative.
Alternative A2— Compacted Soil Cover
Under Alternative A2, the landfill would be cleared, graded, and
covered with 2 feet of camion fill, six inches of topsoil would be
placed on the fill to support grassy vegetation. Gas vents would be
installed throughout the landfill, if necessary. Erosion control
matting would be placed along the embankment of the Eldean Tributary.
The soil cover would reduce exposure to surface contaminants, control
surface water runoff:, minimize erosion, and reduce (but not prevent)
groundwater infiltration.
Cover maintenance would consist of regular mowing, inspection for signs
of erosion, settling and burrowing by animals, and performing necessary
repairs. Periodic replacement of topsoil and reseeding is expected.
A3~Sincrle PaTTi"'i*ar' Cap
The single-barrier cap system would require 2 feet of clay compacted
to a maximum permeability of 1 x 10~7 cm/s. This low permeability
complies with a performance standard for closure of sanitary landfills
in accordance with the Ohio Administrative Code as interpreted by Ohio
EPA policy. Sufficient soil and topsoil will be placed over the cap to
provide frost protection and promote vegetation. A drainage layer will
be evaluated during design. The mnJJ^n" final slope will be 3 percent.
Topsoil, vegetation, active or passive gas vents, erosion control
matting, and maintenance would be similar to those for Alternative A2.
Either containment alternative would require construction of a
decontamination pad and installation of temporary office facilities at
the site.
NORTH lANDFTTJ- OPERABLE UNIT
Three containment alternatives were developed for the North landfill:
a compacted soil cover, a single-barrier cap, and a double-barrier cap.
No treatment technologies were retained from technology screening
because of the danger to workers, the nuisance to the community, and
the prohibitively high costs associated with treating such large
quantities of waste.
-------
-19-
The North Landfill, excluding the Liquid Disposal Area, is about 17
acres and would require clearing, grubbing, regrading, filling, and
compaction before installation of a soil cover or cap. it is
relatively flat from north to south through the middle of the landfill.
From east to west, slopes range from less than 1 percent to 8 percent,
but they are generally 2 to 3 percent. Minimum final slopes of 3
percent are selected for all containment alternatives.
The general components of the containment alternatives with regard to
the 100-year flood plain protection, landfill gas venting, explosive
gas monitoring, and decontamination facilities would be the same as
those for the South Landfill.
Alternative Bl—No Action
The North Landfill would remain as it is under the no-action
alternative.
The compacted soil cover would be similar to that rllsnisqpri for the
South Landfill. Two feet to fill, 6 inches of topsoil, active or
passive gas vents, and soil stabilization matting along the tributary
embankment would be installed. A dense vegetative cover would be also
established.
Cap
The single-barrier cap would be similar to that for the South landfill.
Passive or active gas vents, if necessary, and soil stabilization
matting along the tributary embankment would be installed. A dense
vegetative cover would be established.
Alternative B4~~Dc>'|ble— FfeTTi^r Cap
The double-barrier cap system would consist of 6 inches of topsoil over
1 foot of fill; 18 inches of sand and perforated drain pipe as a
drainage layer; a geotextile filter between the cover fill and sand; a
40-oil high density polyethylene (HOPE) synthetic liner; and 2 feet of
clay compacted to a maximum permeability of 1 x 10~7 cm/s. Active or
passive gas vents would be installed through the capping system.
Maintenance would be similar to that for the single-barrier cap.
ASH DISPOSAL PIT AND ASH PITR
The general response actions for both the Ash Disposal Pit and the Ash
Pile are containment, removal, treatment, and disposal. Removal and
consolidation of wastes was considered both with and without
stabilization/fixation treatment. Stabilization/fixation may be
necessary for compliance with proposed RCRA land disposal restrictions
that may be in effect at the time of action. Stabilization/ fixation
will be necessary if the ash fails the EPTox test and is thus a RCPA
-------
-20-
hazardous waste by characteristic and will be placed in a nan RCRA
facility such as the North or South Landfill including the Liquid
Disposal Area. Samples taken from the Ash Disposal Pit and the Ash
Pile will be analyzed for appropriate waste characteristics for
consolidation alternatives with or without treatment.
Alternative Cl — NO Action
The Ash Disposal pit and Ash Pile would remain as they are under the
no-action alternative.
Alternative C2-*—SirKrle~pa trier Cap
Single-barrier caps for the Ash Disposal Pit and Ash Pile would consist
of 2 feet of clay compacted to a maximum permeability of 1CT7 cm/s and
sufficient fill and topsoil to provide frost protection and promote
vegetation. Additional fill may be required for the Ash Disposal Pit
to provide a minimum 3 percent slope. The Ash Pile is believed to
exhibit sufficient load-bearing strength to support the weight of the
proposed cap. Existing slopes may be too steep for a cap without minor
regrading. Should the ash fail the EPToxic test, it would be
considered a FCRA hazardous waste and a double barrier cap would be
required. This cap is described under the North Tr»™^ii 1 1 section.
The Ash Disposal Pit does not appear to lie within the 100-year flood
plain, so no flood protection was assumed. Because the Ash Pile lies
entirely within the 100-year flood plain, the vegetative cover would be
stabilized with erosion control matting to minimize the potential for
washout. Erosion control matting would be installed over the entire
cap before seeding to stabilize vegetation. A drainage system of
earthen berms and swales may be required to prevent site drainage from
running across the cap.
The BEBC has proposed capping the Ash Disposal Pit in place. The cap
would be covered by a drainage layer and paved with asphalt and
utilized as a transfer station parking lot. The cap will consist of 2
feet of clay compacted to a maximum permeability of 10~7 cm/s overlain
by 14 inches of granular material overlain by four inches of asphaltic
concrete. The asphaltic concrete will have a permeability of 10~7
cm/s and will be maintained in such a manner that this permeability is
continued. Sufficient additional granular material or fill to a
minimum depth of 2 feet over the cap must be utilized for frost
protection. The ash must be tested for EP Tbxicity and if it fails, a
double barrier cap, as described in the North Landfill section, must be
utilized. Provisions must be made to provide for testing in and below
the cap to determine its effectiveness in reducing infiltration into
the waste on an annual basis at a minimum. Deed notification/property
use restrictions to prohibit use of groundwater and excavation of the
ash will be required. This alternative is considered equally
protective to alternatives C3 or C4 which have been selected by U.S.
EPA depending on results of EFToxic testing.
-------
-21-
Alternative a—Consolidation without Treatngnt:
Alternative C3 involves excavation, loading, and hauling of wastes
directly from the Ash Disposal Pit and the Ash Pile to the North or
South landfill. Consolidated wastes would be used to grade the North
or South Landfill surface to slopes required for a cover or cap. Waste
staging would not be required. Daily cover and erosion protection of
wastes would prevent the migration of wastes and contaminated runoff.
Appropriate measures will be taken to prevent dust generation.
Approximately 22,000 cubic yards of waste and soil would be removed,
assuming excavation depths of 12 feet for the Ash Disposal Pit and 2
feet for the Ash Pile. At a productivity rate of 320 cubic yards per
day for excavation, it would take about 3 months to consolidate the
wastes. Closure of the Ash Disposal Pit and Ash Pile would require
20,000 cubic yards of cannon backfill and 1,000 cubic yards of topsoil
to establish a vegetative cover.
Alternative C4*~^onsolidation with Trea'tanent
Alternative C4 assumes that waste stabilization/ fixation would be
performed before consolidation. Waste mixing could be accomplished in
the Ash Disposal Pit and Ash Pile with earthmcving equipment (e.g.,
backhoes) or in batches with pugmills. In-place treatment would
progress from one end of the pit to the other end. Better mixing would
be achieved through the use of pugmills rather than in-place mixing, so
batch mixing was assumed to be the most representative approach.
The stabilization/fixation treatment would require the addition of lime
and water to the ash to produce a material resembling a cohesive soil.
Quantities of specific additives would be determined during
treatability studies before or during remedial design. Waste sampling
and analysis must be performed to verify and document sufficient
treatment to comply with land Hjgpncai restrictions. The
stabilization/fixation process was assumed to increase the volume of
material to be d-jj*yinfi«*^ of by approximately 30 percent. Stabilized
material would be placed in the North or South Landfill. Appropriate
dust control measures would be utilized.
LIQUID DISPOSAL AREA AND GRJUNDWATER
Alternatives for the Liquid Disposal Area and groundwater were
developed by identifying independent alternatives for the Liquid
Disposal Area and for the groundwater, identifying possible
combinations of alternatives for the operable unit, and screening to
reduce the number of alternatives to a reasonable range for detailed
evaluation.
Alternative Dl—No Action
The Liquid Disposal Area and groundwater would remain as they are under
the no-action alternative.
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Altemative D2—cap with Natural Groundwater ...
Alternative D2 consists of constructing a double-barrier cap over the
Liquid Disposal Area to minimize the infiltration of precipitation
through wastes and subsequent leachate generation. Contaminant
migration would be assessed through a regular groundwater monitoring
program.
Double-Barrier Cap. The double-barrier cap would consist of 6 inches
of topsoil over 1 foot of fill; 18 inches of sand and perforated drain
pipe as a drainage layer; a geotextile filter between the fill and
sand; a 40 mil HOPE synthetic liner over 2 feet of clay compacted to a
maximum permeability of l x 10"7 cm/s or its equivalent. Active or
passive gas vents as appropriate would be installed through the capping
system. Maintenance of the cap would consist of regular mowing,
inspection for signs of erosion, settling and burrowing by animals, and
performing necessary repairs.
Natural Groundwater Attenuation. Natural attenuation is the tendency
of contaminant concentrations to decrease through physical, chemical,
and biological processes. Thus, the natural attenuation alternatives
do not involve groundwater collection or treatment, but do include
monitoring, institutional control, and possibly an alternative water
supply for nearby residents.
Natural attenuation satisfies the remedial objectives only by
establishing alternative concentration limits for groundwater
contaminants and verifying installation of an alternative water supply
for private water supply wells that could become contaminated.
Groundwater monitoring is required to track movement of the contaminant
plume.
Contaminant concentrations obtained from monitoring wells located near
the Great Miami River were used to estimate contaminant loadings to the
river and resulting instream concentrations. Expected river
Ttrations of 1,1-dichloroethane, 1,2-dichloroethene, and vinyl
chloride are estimated to be 0.13 ug/1, 1.86 ug/1, and 0.46 ug/1
respectively for the lowest 7-day flow occurring every 10 years (7Q10) •
The 7Qjn flow is 27 cfs and the estimated groundwater discharge is 0.1
cfs. Concentrations in the river of 1,1-dichloroethane, 1,2-
dichloroethene, and vinyl chloride are estimated to be 0.003 ug/1,
0.046 ug/1, and 0.011 ug/1 respectively for the average groundwater
discharge into the annual average low flow for the Great Miami River.
An analytical program was used to estimate contaminant migration after
placement of the cap. Contaminant losses due to volatilization and
bicdegradation were not estimated due to the difficulty in establishing
loss rates. The contaminant migration calculations showed that the
vinyl chloride concentrations near the river would increase over the
next 25 years. The concentrations of vinyl chloride would begin to
decrease until a uniform concentration was achieved (approximately 20
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to 50 ug/1) after about 80 years. This time period represents the
nt of approximately 4 pore volumes of water through the
contaminant plume area. Based on a 7Q10 ^•aw of 27.c£s, concentrations
of 1,1-dichloroethane, 1,2-dichloroethene, and vinyl chloride were
calculated at 0.77 ug/1, 2.27 ug/1, and 1.09 ug/1, respectively, during
the highest contaminant discharge to the river occurring in about 25
years. Similarly, contaminant dilution using 1986 average flow of
1,088 cfs resulted in contaminant concentrations of 0.019 ug/1 of 1,1-
dichloroethane, 0.056 ug/1 of 1,2-dichloroethene, and 0.027 ug/1 of
vinyl chloride.
Alternative D3— Double-Barrier Cap with Groundwater Treatment
The major components of Alterative 03 include a double-barrier cap over
the Liquid Disposal Area, a groundwater collection and treatment system
that would intercept the contaminant plume and prevent migration to the
Great Miami River, or toward off site receptors and to restore aquifer
quality. An air stripping tower to treat the combined flow prior to
surface water discharge is also included.
Double-Barrier Cap. The double-barrier cap would be the same as that
described for Alternative D2.
Groundwater Collection. Be/^t'ige of the high variability in both the
geologic and hydrologic characteristics of the site, a groundwater
model was developed to aid in the analysis of groundwater extraction
alternatives. The model was calibrated to potentiometric data obtained
in September 1987 and verified using data obtained in March 1988. A
full description of how the model was constructed, its sensitivity, and
its calibration/verification is presented in Appendix G of the RI
report*
To analyze the groundwater extraction alternatives, each alternative
was designed for the low water table condition observed in September
1987, then tested using the model under the high water table condition
observed in March 1988 to evaluate whether the influence of the
proposed pumping scheme resulted in changes to the basic conditions
in the model. All drawdowns shown graphically in connection
with the modeled alternatives are in reference to the September 1987
data.
The groundwater extraction system, referred to as the "representative
groundwater collection system,11 includes several extraction wells
placed near the Liquid Disposal Area for source control and
downgradient extraction wells to intercept contaminants migrating
toward the Great Miami River or toward offsite receptors. In
developing the representative collection system, drawdown within the
aquifer was minimized so that a large portion of the aquifer remains
saturated to maximize the efficiency of the extraction system. This
reduces the possibility of leaving contaminants absorbed to the aquifer
matrix after pumping has been shut down.
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The representative groundwater opllection system includes four upper
aquifer contaminant migration extraction wells near the Liquid Disposal
Area, five upper aquifer and five lower aquifer onsite downgradient
wells, and two upper aquifer and two lower aquifer off site downgradient
wells. This extraction well configuration was selected because it
would provide an inward gradient within the plume boundary and
minimize drawdown. Based on this configuration, the estimated flow for
the system is 80 gpm. This estimate is based on the limited data
available from the RI. The flow rate may increase depending upon
conditions actually encountered as the extraction system is installed
and brought on line.
The estimated time to remediate the aquifer is based on the removal of
four pore volumes. The four extraction wells near the Liquid Disposal
Area and screened in the upper aquifer are expected to operate for more
than 30 years. The onsite downgradient wells screened in the upper and
lower aquifer would pump for about 15 and 8 years, respectively. The
off site downgradient wells would operate for about 5 years. These
cleanup period estimates are provided for comparative purposes. Actual
time to achieve MCLs or other health-based or risk based levels may be
longer.
Black, oily, stained soil in the upper 2 to 10 feet of the saturated
zone was observed at some locations in the Liquid Disposal Area.
Extraction of organic contaminants in the area could be accelerated ii
surfactants were injected into the groundwater. The surfactants reduce
surface tension properties of less soluble compounds, thus increasing
their mobility. This option is not included in Alternative D3 but
should be considered further in predesign.
Groundwater Treatment. The groundwater treatment system was developed
on the basis of existing site data and conditions. Several assumptions
were made to present details concerning the process sequence, equipment
size, groundwater flows, and extracted groundwater concentrations.
Pilot-testing may be required during design to verify the accuracy of
these assumptions or identify changed conditions.
The combined flew fron the representative groundwater collection system
would be treated using an air stripping tower. Preliminary sizing
requirements were based on likely surface water discharge limits. A 95
percent removal efficiency for total VOCs is expected using one
stripping tower about 4 feet in diameter with a 20-foot packing depth.
The overall height of the tower would be 30 feet, but could vary
depending on the height of the emissions control or exhaust stack and
the VOC removal efficiency desired.
The extracted groundwater would be pumped directly to the tower without
pretreatment. An equalization tank with a 4-hour holding time would be
used to detain groundwater during periodic rinsing of the tower packinr
with a mild acid solution. Precipitation, sedimentation, and
filtration could be necessary because packed towers are subject to
fouling biological growth and precipitation of metals.
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If surf actants are used to improve removal of contaminants from beneath
the Liquid Disposal Area, additional treatanent processes will probably
be required to treat the surfactants and the increased contaminant
concentrations.
Alternative D4—Vapor Extraction and Cap with Groundwater Treatment
Alternative D4 would consists of soil vapor extraction and vapor phase
carbon treatment, groundwater pumping and onsite air stripping, and
closure of the .Liquid Disposal Area with a double-barrier cap.
Evaluation of the soil samples obtained from the 18 test pits suggests
that the Liquid Disposal Area may extend east and south of the area
investigated. The liquid disposal area will be further defined by soil
gas testing or other appropriate methods before implementation of the
remedy.
On the basis of the RI results and the cost sensitivity analysis, the
area for soil vapor extraction was identified as the Liquid Disposal
Area (100,000 square feet). The VOC contaminant mass was estimated at
33,000 pounds based on an estimated average concentration of 120,000
ug/kg total VOC over the 2.3-acre area to a depth of 25 feet (92,000
cubic yd). The average concentration of total VOCs obtained from the
Liquid Disposal Area investigation is about 240,000 ug/kg. However,
120,000 ug/Xg was assumed to be more representative of the entire area
because the observed average of total VOCs may have been biased high by
nonrandom sample collection and very high levels of total VOCs detected
in a limited number of samples.
Vapor Extraction^ System. Pilot testing would be required to optimize
the design for the vapor extraction and vapor phase carbon treatment
units. The pilot test would determine:
- The effective radius of influence of the vacuum extraction system
along with the vapor flow rate and vacuum/pressure relationship
at each well.
- The vacuum/pressure distribution in the vadose zone, particularly
in waste zones, during vacuum extraction.
- The VOC loading rate from individual wells, as a function of
vacuum/pressure and flow rate.
The effective radius of influence is assumed to be 30 feet. Control of
oxygen levels within the fill is important because oxygen within refuse
increases aerobic microbial activity with resulting increased landfill
temperatures and potential for landfill fires. Based on a conservative
radius of influence of 30 feet, 36 vacuum wells would be required for
the 2.3-acre area.
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The system would consist of a network of 4-ineh PVC extraction wells
and 2-inch inlet wells with slotted screens from approximately 5 feet
below grade to the upper till unit. The wells would be packed with
gravel or sand in the screened zone and sealed with bentonite and
grout. The entire area proposed for vapor extraction would be sealed
at the surface by a temporary 1-foot clay cap. The temporary cap and
inlet wells would control air flow radially through contaminated soil.
The extraction wells would be connected by a header system. To monitor
and control system performance, each vapor extraction well would
contain a valve, sample port, and vacuum/ pressure gauge. The header
system would be connected to a vapor phase treatment system. The
outlet of the vapor phase treatment system would be piped to a blower
that induces the airflow through the subsurface to the extraction
wells. Placement of the vapor phase treatment system on the negative
pressure side of the blower was assumed because VOCs would not leak out
under vacuum.
The time necessary to achieve effective VOC reduction by vapor
extraction is affected by many variables. It is assumed that the vapor
extraction system would operate long enough to reduce the total mass
of soil VDCs in soil by 90 percent or more. This will be measured by
determining that at least a 90 percent reduction of indicator VOCs was
achieved over levels found during pilot testing. Should this not prove
practical, the levels will be graphed and VOC extraction will continue
until a leveling of the curve occurs and removal is no longer found to
be cost effective by U.S. EPA. If the curve does not level off until
greater than 90 percent removal occurs, extraction will continue until
the curve does level off.
During pilot testing and design the appropriateness and size of the
Vapor Extraction system will be evaluated. If such a system is not
found to be effective another treatment method such as incineration or
active soil flushing will be evaluated and implemented. Active soil
flushing will involve adding water to the Liquid Disposal Area to
percolate through the soil column.
Vapor Efras** Tfraatroent. The vapor phase treatment system would consist
of a vapor/water separator, a preheater, and carbon adsorption system.
The separator and preheater would remove moisture and dissolved
organics from the vapor stream and lower the relative humidity of vapor
to improve carbon treatment efficiency. The expected relative humidity
of near 100 percent would be reduced to 40 to 50 percent for optimal
carbon usage. The carbon adsorption system would consist of two
stainless steel carbon canisters connected in series. The second
canister would serve as a backup unit in the event of VOC breakthrough
in the primary ranfgiw- The canisters would each hold 2,000 pounds of
granular activated carbon. A sampling port, vacuum/ pressure gauge,
and temperature gauge would be installed upstream and downstream of
each carbon unit. A carbon monoxide meter would be installed after
each carbon unit to detect whether combustion is occurring in the
carbon units.
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The exhaust discharge f ran vapor phase treatment was assumed to comply
with air permit discharge requirements established during design of the
vapor phase treatment.
The vapor phase treatment system will be evaluated during design and
the most appropriate system implemented which will meet relevant
standards.
A temporary clay cap would be installed before operation of
the vapor extraction system began. The temporary cap would limit the
vertical movement of air from the ground surface to the extraction
wells so that radial airflow would maximize the migration of air
through contaminated wells. After vapor extraction operation is
completed, a final double-barrier cap would be installed to close the
Liquid Disposal Area. It is assumed that the earth materials for the
temporary cap would be used in the construction of the final cap after
completion of soil vapor extraction. If gas venting is required, the
vapor extraction or inlet wells may be converted to landfill gas
vents.
Construction of the temporary cap would require grading the surface of
the Liquid Disposal Area in a manner consistent with final cap design.
A 1-foot barrier of compacted clay would be installed and covered by 1
foot of cover soil, and then be vegetated to protect the clay and
prevent erosion.
Groundwater Collection. Modifications to the representative collection
system were necessary for Alternative D4 to improve vapor extraction
performance. Groundwater pumping modifications include adding six
aquifer dewatering wells in the Liquid Disposal Area and eliminating
the four extraction wells near the Liquid Disposal Area during vapor
extraction. The total flow for the system is expected to increase from
80 gpm to about 100 gpm. The vapor extraction system is expected to
operate for about 2 years. After vapor extraction is completed,
dewatering of the Liquid Disposal Area will no longer be necessary.
After vapor extraction, some of the aquifer dewatering wells may be
abandoned and the remaining extraction wells on the east side of the
Liquid Disposal Area will serve as blocking wells similar to the
representative groundwater collection system.
Groundwater Treatment. The air striping treatment system discussed
above would also be implemented for this alternative. The groundwater
collected during the initial dewatering of the Liquid Disposal Area may
not be amendable to air stripping because its composition could be more
characteristic of landfill leachate as a result of decomposing
municipal refuse buried there. As a contingency, an alternate
treatment method will be utilized which meets all regulatory
requirements if groundwater from the Liquid Disposal Area is not
ameanable to Air Stripping. For instance, concentrations of 8005 and
COD and possibly of inorganic constituents could be higher than those
observed in groundwater samples. The quality of the groundwater
extracted during the initial dewatering is difficult to predict
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accurately because many variables can affect leachate generation, such
as the composition of the waste, the percolation of rainwater, and the
dilution with groundwater.
Alternative IMA—•Modified Vapor Extraction and Cap with Groundwater
Alternative D4A was developed after consideration of public comments on
the RI report, FS report, and Proposed Plan. Alternative D4A is
similar to 04 although each of its major components has sane
modifications. It includes soil vapor extraction in the Liquid
Disposal Area and treatment of the resulting air emissions, groundwater
pumping and treatment at the City of Troy publicly owned wastewater
treatment plant (POTW), and closure of the Liquid Disposal Area with a
double-barrier cap.
Vapor Extraction System. The vapor extraction system would be
installed in the same area as under Alternative D4. The system would
be designed to remove volatile organic compounds (VOCs) from the
unsaturated zone. Dewatering wells would not be used to increase the
depth of VOC removal as in Alternative D4. VOCs present below the
water table would be removed as they migrate to the groundwater
extraction wells at the downgradient boundary of the Liquid Disposal
Area.
The components of the vapor extraction system would be as described for
Alternative D4 with the exception that air inlet wells and a temporary
clay cap would not be used. Air would be allowed to infiltrate from
the surface downward to the air extraction wells. This would reduce
the potential for increased microbial activity near air inlet wells
that could result in unacceptable temperature increases and possible
fires. It also eliminates the cost of a temporary clay cap. Short
circuiting of air from the surface downward along the outside of the
air extraction well casing would be controlled by carefully sealing the
borehole during construction. Pilot testing and VOC reduction would be
the same as that described for Alternative D4.
A vapor phase treatment of the emissions system may be required. The
need for and type of treatment would be determined in the design. For
costing purposes, activated carbon adsorption was included, as
described for Alternative D4.
Capping. Following soil vapor extraction the Liquid Disposal Area
would be capped with the double-barrier cap consistent with the
requirements of RCRA Subtitle C. The cap was assumed to consist of
2 feet of clay compacted to a maximum permeability of 1 x 10"' cm/s, a
40-mil high density polyethylene (HOPE) synthetic liner, 1 1/2 foot of
sand drainage layer, a filter fabric, 1 foot fill, and 6 inches of
topsoil. If methane gas venting is necessary, the vapor extraction
wells may be converted to landfill gas vents.
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:ion. The groundwater collection system would be
identical to the representative collection system described for
Alternative D3. As mentioned in the discussion of vapor extraction,
dewatering wells are not part of this alternative.
Evaluation of the most efficient method of vapor extraction will be
considered in the design. It is possible that results of design
analysis may include provisions for partial dewatering to maximize the
cost-effectiveness of VDC removal.
Groundwater Treatment. Extracted groundwater would be treated off site
at the City of Troy POTW. The groundwater would be discharged to the
sanitary sewer force main being designed parallel to County Highway 25
A.
Discharge to the POIW may require pretreatment to comply with the
discharge requirements or to meet U.S. EPA and OEPA requirements for
effective treatment. Provisions of the sewer use ordinance that may be
applicable to the site restrict the discharge of:
- Any slug load of pollutants, including BODs, that would interfere
with the POTW operation or cause the City to violate its NPDES
permit
- Any toxic pollutant in sufficient quantity to interfere with the
treatment process or pose a hazard to operators
- Metal-contaminated wastewater for a 24-hour composite sample that
exceeds the following daily maximum discharge concentrations:
Arsenic 0.37 mg/1
Cadmium 0.69 mg/1
Chromium 5.0 mg/1
Copper 3.0 mg/1
Cyanide 0.88 mg/1
Iron 30.0 mg/1
Twl 0.68 mg/1
Mercury 0.0037 mg/1
Nickel 5.0 mg/1
Zinc 2.0 mg/1
For cost estimating purposes, it was assumed that pretreatment of
groundwater will not be necessary before discharge to the POIW.
Alternative D5 — Incineration with Groundwater Treatment
Alternative 05 would consist of excavating the contaminated wastes and
soil from the Liquid Disposal Area and incinerating them at the site
using a portable rotary kiln incinerator. The residual ash would be
placed back in the Liquid Disposal Area and a cap would be placed over
the area once treatment was complete. The groundwater extraction and
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treatment system for this alternative is similar to that for
Alternative D3 except shorter operating times are expected,
particularly for the extraction wells near the Liquid Disposal Area,
of the source control measures.
Excavation (Xant^ties. The area requiring excavation is defined on the
basis of RI field observations and analytical results, hazards
identified in the endangerment assessment , historical information, and
sensitivity analysis. The volume of soils of the area to be treated
will be further evaluated before or during waste removal and soil
excavation
The U.S. EPA does not have standards for the cleanup of contaminated
soil or refuse. Target concentrations were estimated in the
endangerment assessment for both carcinogenic and noncarcinogenic
health risks from exposure by direct contact with contaminants as a
result of site development. Samples collected from 14 of the 18 test
pit locations exhibited contaminant concentrations that exceeded target
levels. The four test pit locations with sample concentrations below
the target levels are located near the northern and western boundaries
of Liquid Disposal Area investigated.
of the uncertainty associated with identifying the qr*^*1 extent
of the Liquid Disposal Area, a sensitivity analysis was performed on
the volume to be removed. The volume estimates used to evaluate the
sensitivity of the incineration costs were based on the following areas
for excavation:
- Area 1 is approximately 100,000 square feet and includes the
Liquid Disposal Area investigated in the RI and characterized by
the test pit sampling data. The volume for removal is about
81,500 cubic yards.
- Area 2 is about 50,000 square feet. The areal estimate reflects
the possibility of partial excavation, but assumes that there is
insufficient information to identify specific areas for partial
excavation at this tine. The volume for removal is about 40,700
cubic yards.
- Area 3 is about 150,000 square feet. This estimate assumes, on
the basis of historical information, that the boundary of the
Liquid Disposal Area is beyond the outer limit of the area
investigated in the RI. The volume for removal is approximately
122,200 cubic yards.
In all three volume estimates, the excavation depth extends into the
saturated soil, about 2 feet below the water table. According to soil
boring results, the water table is about 20 feet below grade.
In addition to conventional construction equipment, excavation may
require specialized machinery for the removal of drums and bulky pieces
of refuse. Extensive safety procedures and monitoring would be
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required for protection of workers. Control of fugitive dust and
vapors may be of concern. Workers would wear level B protective gear
for much of the subsurface excavation. A vapor suppressing foam or
water spray may need to be applied to control dust or vapors.
The following assumptions have been made regarding the proportions of
wastes to be excavated from the Liquid Disposal Area based on the test
pit lithologic logs:
- Thirty percent is municipal refuse (60 percent of which is
combustible household trash, wood, and partially incinerated
refuse and 40 percent noncombustible drums, wire, and metal
scraps).
- Forty percent is soil or sand and gravel.
- Thirty percent is ash or ashy fill.
The refuse and soils are assumed to have a moisture content of about 20
percent. Wastes and soils excavated below the water table or from
perched zones may require dewatering and treatment. Leachate from
temporary storage would also require treatment.
Thermal Treatment. The portable rotary kiln would be used to
incinerate material from the Liquid Disposal Area. The incinerator
system would consist of a kiln, an afterburner for solids destruction,
and a venturi scrubber for emissions control. Incineration of the
Liquid Disposal Area contents will require extensive material
handling. Wastes must generally be crushed or shredded to 2 inches or
less for efficient combustion. Wastes would be segregated to remove
noncombustible material and incompatible wastes. Noncombustible waste
material would be steamed cleaned and shredded, if necessary and
redisposed of in the Liquid Disposal Area prior to its closure.
An enclosed building would be constructed near the feel line of the
incinerator for staging and sorting excavated wastes. A shredder,
vibrating screen, and electric magnet would be provided to separate and
reduce the size of wastes. The building would also provide a stockpile
area for the processed waste because wastes can be excavated at a rate
faster than the rate of incineration. The size of the stockpile
building will limit the quantity of waste material that can be safely
stored, thus limiting the length of time that waste can be excavated.
Schedules must be carefully planned and periodically adjusted so that
material is always available for incineration without exceeding
stockpile capacity* The actual size of the stockpile building should
strike a balance between costs incurred by mobilization/demobilization
and building cost, while assuring that project schedule will be met.
Municipal refuse usually has sufficient heating value to sustain
combustion, but blending of refuse with contaminated soil may require
supplemental fuel to maintain operating temperatures. The heating
value of the municipal waste and soil was assumed to be about 3,400
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Btu/lb. Liquids found in seeps or drums would be sampled and then
incinerated. Burner blocks would be used for firing liquids into the
kiln or afterburner. The residual ash would be collected, stabilized,
and placed back in excavated areas. The Liquid Disposal Area would
then be capped with a double-barrier cap once all the wastes have been
incinerated.
The time to incinerate the wastes was estimated assuming continuous
operation of the kiln at a feed rate of 3.4 tons per hour for 290 days
annually (80 percent operating efficiency). Continuous operation would
reduce thermal stress on the refractory lining in the kiln although
downtime for failure, repair, and maintenance was allowed. A single
unit would take the following number of years to treat following
volumes of combustible wastes and solids:
Volume Weight
Incinerated Incinerated Operation
Area feu vd^ (tans) fyr)
1 81,500 68,400 2.9
2 . 40,700 24,200 1.4
3 122,200 102,600 4.3
The time estimates do not include time for siting, meeting technical
requirements of permitting, mobilization, and startup of the treatment
facility, which could take 1 to 2 years. The overall economy of scale
from multiple units is generally not significant, but if desired, the
operating schedule could be shortened.
High levels of nitrogen oxide and sulfur oxide emissions are commonly
formed when a rotary kiln is operated at high temperatures. Emissions
and particulate matter depend on the waste material and the auxiliary
fuel. A wet scrubber is assumed to be necessary for control of
emissions and particulates.
The scrubber blowdown treatment system would consist of precipitation,
flocculation, sedimentation, and filtration. Hydroxide precipitation
would be accomplished by adding lime to the influent. Heavy metal
hydroxides would precipitate from solution along with calcium,
magnesium, iron, manganese, and barium. A coagulant such as alum or a
polymer could be added to agglomerate particles and enhance settling.
Flocculation and clarification (sedimentation) would follow and could
be accomplished in one basin. Sludge removed from the clarifier could
be thickened or dewatered for disposal in the Liquid Disposal Area and
some could be recycled back into the sedimentation basin to enhance
settling. A sand or multimedia filter would remove most of the
remaining suspended solids. Effluent from the filter could be used for
filter backwashing, and the filter backwash wastewater could be added
to the clarifier.
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Qperaticns of the kiln would require approximately 150 gallons of
supplemental fuel per hour because of the moderate heating value of the
waste. Power requirements for the complete system would be 250 kW per
hour. Water requirements would vary depending on the type of kiln,
quenching requirements, and emissions control system. Approximately 24
gpm was assumed for a venturi scrubber system.
lection and Treatment. The representative groundwater
collection and treatment alternative discussed previously would be
implemented for this alternative.
DC. SUMMARY OF OCMPARMTVE ANM^VSTg OF
SO7IH LANDFILL
Noise, dust, and risk to the surrounding immunity from vehicular
accidents would occur during construction of soil cover or cap. The
nuisance impacts and safety concerns vary between the alternatives with
the amount of truck traffic. Alternative A2 would require 7,300 truck
trips and Alternative A3 would require about 10,000.
Oust control (e.g., water spray) may be necessary to manage inhalation
risks during cap or cover construction for Alternatives A2 and A3.
General construction safety precautions would be taken for all
construction alternatives to protect workers. Greater protection may
be required when boring through landfill refuse for installation of gas
vents. The timft required for designing, procurement, and construction
may increase slightly with increasing complexity of the containment
alternative. The quality of the aquatic habitat may be temporarily
diminished as a result of erosion from construction.
Erosion control measures would be taken to minimize this impact.
Dikes, matting and berms could be used.
D3NG-THM EFFijurxVENESS
In general, long-term effectiveness increases from Alternative Al to
A3. Assuming proper maintenance of the containment systems described
in alternatives A-2 and A-3, the risk from direct contact would
decrease only slightly with increased containment system thickness.
Under the no-action alternative, contaminants could be transported
through the landfill contents into the groundwater. Infiltration and
leachate generation would decrease with increasing containment
ttrols.
Evaluations of cover and cap efficiencies for all the alternatives were
performed using the Hydrologic Evaluation of landfill Performance
(HELP) model. Based on HELP model evaluations. Alternatives A2 would
reduce infiltration by 70 percent and Alternative A3 by 90 percent
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relative to Alternative Al. Hie long-term effectiveness of eacii
alternative is proportional to the impermeability of the containment
system. All alternatives can adequately meet their performance
specifications assuming proper installation and maintenance of the
containment system and enforcement of property use restrictions.
pfJUCTION OF TO3QXTTY. ^P^TjT/T^, AMP W3IUME
Treatment alternatives were not considered for the South Landfill
because of the high costs to remove large volumes of wastes and the
risks to workers associated with excavation of landfill contents. The
short-term risks and remedial costs may be greater than the long-term
risk reduction benefits from treatment-
OVERATI. PROUJCriON OF HUMAN HFAT.T|V AND THE ENVIRONMENT
Protection against the likelihood of direct contact with contaminated
surface soils increases from alternative Al to A3. The protection
against potential risks from exposure to subsurface waste and soil
would be the same for all alternatives and would depend on the
enforcement of property use restriction to prevent site development.
The potential for migration of contaminants from the waste and soil to
the groundwater decreases with increased containment layers and layer
thickness.
All construction alternatives could be implemented to meet required
performance standards with few difficulties. However, as the
complexity of the containment system increases, so does the time and
effort required to implement it. The materials for construction are
generally available from local suppliers. Construction activities and
institutional restrictions for all alternatives would be coordinated
with the Ohio EPA and the Miami County Development Department.
COST
Cost estimates and the present worth analysis are summarized on Table
11.
WITH ARARs
On the basis of site history and analytical evidence, the South
landfill meets the definition of a sanitary landfill and will be closed
accordingly. State of Ohio rules concerning final cover and monitoring
of sanitary landfills are considered the key applicable regulations for
the South landfill.
The most notable and applicable rules in the Ohio Revised Code are OAC
3745-27-09 Sanitary landfill Operations, OAC 3745-27-10 Closure of
Sanitary landfills, and OAC 3745-27-12 Explosive Gas Monitoring for
Sanitary landfills. OAC 3745-27-09 contains most of the substantive
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(design-related) requirements, especially final cover requirements for
sanitary landfills, stating under 3745-27-09 (f) (3) :
A well compacted layer of final cover material shall be applied to
all exposed surfaces of a cell upon reaching final elevation. The
final cover material shall be applied in such amounts that all waste
materials are covered to a depth of at least 2 feet.
The nature of the required final cover is described under 3745-27-
09 (F) (3) . Other notable requirements are included under 3745-27-
09 (G) , (H) , and (I) , which outline procedures for post-closure
maintenance and monitoring.
In addition to these regulations, proposed regulations which are
expected to be fully promulgated before cap design reaches 60 percent
complete, are to be considered in the cap design.
Substantive rules regarding closure under QAC 3745-27-10 largely
parallel those found in OAC 3745-27-09. However, QAC 3745-27-10
contains several administrative requirements regarding permits,
licenses, files, and so on. Such administrative rules are not
considered applicable or relevant and appropriate to CERCXA actions
that occur entirely onsite.
Alternative Al — No Action
RI data did not indicate that chemical -specific ARARs for water on
health-based action levels for soil were exceeded in the South
Landfill. However, Alternative Al fails to satisfy minimum Ohio
sanitary landfill closure regulations (discusspd above) and does not
comply with action-specific ARARs.
Alternative A2~""O3ipactvgr'l Soil Cover
Alternative A2 would not meet the minimum substantive requirements of
the Ohio Administrative Code pertaining to closure of a sanitary
landfill (QAC 3745-27-09 and -10) . Therefore, Alternative A2 does not
comply with ARARs for closure of the South Landfill.
A3— —Single—Barrier
Site records indicate that materials placed in the landfill were
industrial and municipal wastes. The State sanitary landfill closure
law is the primary ARAR for this area of the site.
The single-barrier cap would include 2 feet of clay contacted to a
maximum permeability of 1 x 10~7 cm/s. This permeability would
satisfy current State of Ohio policy regarding performance of sanitary
landfill cover. The state design policy does not have the status of an
ARAR (i.e., it is not a promulgated rule in the Ohio Administrative
Code) , but is a widely-applied state landfill design standard to be
considered.
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NORIH LANDFILL
The short-term effectiveness of remediation of the North Landfill would
be the same as that of the South Landfill. Emissions of hazardous
constituents are not expected to be great since excavation of landfill
materials would be limited and significant amounts of hazardous wastes
outside the liquid disposal area are not suspected. Alternative B4 has
about
double the truck traffic (15,000 loads) of Alternative B2 and would
produce greater nuisance impacts and safety concerns.
LONG-ThlM
The long-term effectiveness of remediation of the North Landfill would
be the same as that for the South Landfill. In general, long-term
effectiveness increases from Alternative Bl to Alternative B4.
Infiltration and leachate generation were evaluated for all containment
alternatives using KELP mode. Based on HELP model evaluations,
Alternatives B2, B3, and B4 would reduce infiltration by 70 percent, 90
percent, and more than 99.99 percent, respectively, relative to the no-
action alternative. The redundancy of a double-barrier cap offers
greater reliability in reducing infiltration and subsequent contaminant
leaching to groundwater if one barrier fails.
Although Alternative B4 would be the most effective alternative for
reducing the potential for contaminant migration to the groundwater,
the amount of contaminants in the North Landfill (excluding the Liquid
Disposal Area) is not expected to be significant. Historical and
sampling evidence obtained thus far indicates, the greater
effectiveness of Alternative B4 in reducing infiltration may not result
in discernible groundwater contaminant reductions compared to
Alternatives B2 and B3.
The reduction of toxicity, mobility, and volume is not applicable to
the North Landfill because no treatment alternatives were considered
for that operable unit.
Overall protection of human health and the environment would be the
same for the North Landfill as for the South Landfill. The potential
for migration of contaminants from the waste and soil to the
groundwater would decrease with increasing cap layers and layer
thickness from Alternatives B2 to B3, and B3 to B4.
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The implementability of remedial alternatives for the North Landfill
would be the sane as that for the South Landfill. As the complexity of
the containment system increases, so does the time and effort required
to implement the alternative. Alternative B4 would require the
greatest exercise of quality control during construction to ensure that
synthetic liner seams are properly sealed. This may require a
specialty contractor, but such services are reasonably available.
Cost estimates and the present worth analysis for the North Landfill
alternatives are summarized on Table 12. The general inspection and
maintenance costs are the same for the three containment alternatives.
The total present worth of each alternative increases with the greater
degree of protectiveness.
OOMPT.TANQE WITH ARARS
Historical records suggest that disposal of liquid wastes in the North
Landfill (outside the Liquid Disposal Area) was limited. This evidence
is not conclusive however, and the volume and toxicity of hazardous
substances in the North Landfill is unknown.
The North Landfill is adjacent to the Liquid Disposal Area. The poorly
defined boundary of the Liquid Disposal Area creates additional
uncertainty about the nature and distribution of buried wastes in the
North Landfill. Also, the North Landfill reportedly contains large
volumes of incinerator ash, which, if comparable to ash found in the
Ash Pile and Ash Disposal Pit, may fail EP toxicity hazardous waste
characteristic tests under 40 CFR 261 (based on metal concentrations
found in other onsite wastes containing ash).
Compliance with action-specific ARARs for the North Landfill is
dependent on information and assumptions regarding the nature of buried
wastes. Primarily, nonhazardous wastes are assumed to be present
throughout the North landfill, and the State of Ohio regulations
pertaining to closure of sanitary landfills are relevant and
appropriate (QAC 3745-27-09 and -10). Those regulations are discussed
under the evaluation of alternatives for the South Landfill.
Alternative Bl—No Action
RI data did not indicate that chemical-specific ARARs for water or
health-based action levels for surface soil were exceeded in the North
Landfill. However, Alternative Bl fails to satisfy the minimum state
landfill closure regulations and does not comply with ARARs.
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TABLE 11
COST ESTIMATE SUMMARY
FOR THE SOUTH LANDFILL
MIAMI COUNTY INCINERATOR SITE
DESCRIPTION
Soil Cover
Single-Barrier Cap (a)
Allowances (b)
Contingencies (c)
Other Indirect Capital Costs (d)
Engineering/Design
TOTAL CAPITAL COST
PRESENT WORTH OF O&M COSTS (e)
TOTAL PRESENT WORTH ESTIMATE (0
ALTERNATIVE
A2
S 980,000
0
118,000
275,000
206,000
146.000
$1.725.000
574,000
$2.300,000
A3
$ 0
1,929,000
232,000
540,000
405,000
279,000
$3,385,000
751 ,000
$4,100.000
(a) The configuration of the single-barrier capping system described in
the FS has been modified as described in the ROD. These estimated
costs are for the modified cap system.
(b) Mobilization/demobilization, bond and insurance, temporary facilities,
and field detail allowance.
(c) Bid and scope contingencies.
(d) Administrative, legal, and permitting services to meet substantive
requirements and services during construction.
(e) Present worth estimate assumes a discount rate of 5 percent annually
over 30 years.
(0 Cost estimate is order-of-magnitude level with expected accuracy of
+50 percent to -30 percent. Total present worth estimate is rounded to
two significant figures.
NOTE: More detailed capital cost and O&M cost estimates are presented in
Appendix 8 of the FS Report.
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Alternative K>~- comacted Soil Cover
Alternative B2 would not meet the minimum substantive requirements of
the Ohio Administrative Code pertaining to closure of a sanitary
landfill (OAC 3745-27-09 and -10) .
B3—*Sinqle— Barrier Ca
Alternative B3 uses a cap design identical to that specified for
Alternative A3 for the South landfill. The evaluation of compliance of
Alternative A3 with ARARs applies similarly to the North Landfill. The
single-barrier cap design is more stringent than that required by Ohio
solid waste regulations alone and complies fully with commonly applied
State of Ohio design policy for capping of a sanitary landfill. It
also complies with minimum federal regulations for hazardous waste
landfill cover design as outlined under 40 CFR 265.310. However, it is
less stringent than current federal guidance outlined in RCRA Guidance
Document for Landfill Design - Liner Systems and Final Cover.
Alternative B4— Double— Barrier Cap
Alternative B4 would comply with ARARs if the North Landfill were
closed as a hazardous waste landfill. Available evidence does not
suggest that it warrants such treatment, the double-barrier cap would
meet current performance requirements under 40 CFR 265.310 and current
U.S. EPA minimum technology guidance.
ASH DISPOSAL PIT AND ASH PILE
SHORT— T^Wl
None of the alternatives poses short-term risks to the community or the
environment that cannot be controlled with routine precautions. Dust
control may be required, particularly with Alternatives C3 and C4 when
ash wastes are excavated, loaded into dump trucks or mixing equipment,
and unloaded into the North landfill. Dust generated during
implementation of Alternative C4 would be reduced once wastes are
stabilized. Workers may require personal protection against dust
inhalation only for Alternatives C3 and C4. The time required to
implement alternatives increases from Alternatives C2 and C4. However,
all alternatives could be implemented within 2 years.
LONG-TERM t»'l*'H'if *!' I V^MRSfi
Alternative C2, capping the Ash Pile and the Ash Disposal Pit, would
reduce the potential risks from direct contact with lead.
The potential for severe erosion or washout was addressed because the
Ash Pile lies within the 100-year flood plain. The degree of flood
protection provided by remedial alternatives increases from no
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TABLE 12
COST ESTIMATE SUMMARY
FOR THE NORTH LANDFILL
MIAMI COUNTY INCINERATOR SITE
.
DESCRIPTION
Soil Cover
Single-Barrier Cap (a)
Double-Barrier Cap
Allowances (b)
Contingencies (c)
Other Indirect Capital Costs (d)
Engineering/Design
TOTAL CAPITAL COST
PRESENT WORTH OFO&M COSTS (e)
TOTAL PRESENT WORTH ESTIMATE (0
ALTERNATIVE
B2
$1 .001 ,000
0
0
120,000
280,000
210,000
149,000
$1 ,760,000
586,000
$2.300,000
B3
$ 0
1.955.000
$ o
235.000
548,000
41 1 ,000
282,000
$3.431 ,000
766,000
$4.200.000
B4
$ 0
0
2,546.000
306.000
713.000
535.000
365,000
$4,465,000
1.471.000
$5.900,000
(a) The configuration of the single-barrier capping system described in the FS
has been modified as described in the ROD. These estimated costs are for the
modified cap system.
(b) Mobilization/demobilization, bond and insurance, temporary facilities, and field
detail allowance.
(c) Bid and scope contingencies.
(d) Administrative, legal, and permitting services to meet substantive requirements and
services during construction.
(e) Present worth estimate assumes a discount rate of 5 percent annually over 30 years.
(0 Cost estimate is order-of-magnitude level with expected accuracy of +50 percent
to -30 percent. Total present worth estimate is rounded to two significant figures.
NOTE: More detailed capital cost and O&M cost estimates are presented in Appendix B
of the FS Report.
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protection for Alternative Cl to soil stabilization with erosion
control matting for Alternatives C2, and complete removal of wastes
from the flood plain for Alternatives C3 and C4.
The leachability of ash waste is limited by the relatively immobile
nature of the oontaminants. Die effective long-term prevention of
leachate migration from ash sources increases marginally from
Alternatives Cl to C4. The incremental risks posed by consolidating
wastes in the North Landfill (Alternatives C3 and C4) are insignificant
compared to existing risks.
Alternative C2 would require the greatest degree of long-term
inspection and maintenance to prolong the cap integrity. No operations
or maintenance is associated with either Alternative C3 or C4 because
the wastes from the Ash Disposal pit and Ash Pile would be consolidated
with those in the North Landfill and would not require special care
beyond that provided for the landfill contents.
REDUCTION OF TOXTCITY,. MOBILITY. AND "VOLUME
No treatment process would be used in Alternatives Cl through C3, so
they would not reduce toxicity, mobility or volume of contaminants.
The fixation treatment in Alternative C4 would reduce the potential for
contaminants to leach or migrate from the treated wastes. Fixation was
assumed to increase the volume of ash by 30 percent and cause no
reduction in toxicity.
The low mobility of the inorganic contaminants and the consolidation of
wastes into the North Landfill beneath a cap make this a minor
advantage over Alternative C3.
tWi'EL'lTON OF WtyOM fffifVLTH AND TOE ENVIRONMENT
The effectiveness of reducing the potential for erosion or washout of
the Ash Pile from floods is a good indicator of overall protection.
Alternative C2 would reduce the potential for erosion or washout and
alternatives C3 and 04 would reduce those risks even further.
Treatment of the wastes offers further protection, however, existing
risks from the North Landfill must be evaluated when considering the
incremental protection -of treatment.
All alternatives can be routinely constructed with conventional
construction equipment. Alternatives C4 would require laboratory and
pilot-scale studies before or during remedial design to determine the
quantities of stabilization/fixation reagents required. Services and
materials for each alternative are readily available. Institutional
actions require coordination with local authorities and capping
requires state participation and enforcement. Coordination with
governmental agencies would not be necessary following implementation
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of Alternatives C3 and C4 assuming they would result in clean closure
of the Ash Disposal Pit and Ash Pile.
Cost estimates and present worth analysis for the Ash Pile and Ash
Disposal Pit alternatives are summarized on Table 13. the total
present worth of Alternative C2 is an order of magnitude less than that
of Alternative C3. Alternative C2 includes post-closure costs, but the
consolidation alternatives do not include annual O&M costs for the Ash
Pile or Ash Disposal Pit. Treating the ash before consolidation
(Alternative C4) doubles the cost of consolidation without treatment
(Alternative C3) .
QCMPr.TANCE WITH ARARs
Concentrations of inorganics in surface soil samples from the Ash Pile
and subsurface soil samples from the Ash disposal Pit exceeded health-
based action levels. Concentrations of organics in subsurface soil
samples from the Ash Disposal Pit also exceeded health-based action
levels.
Since the Ash Pile is located on the 100-year flood plain, two
location-specific requirements apply:
- 40 CER 265. 18 (b)— Locational Standards, Flood Plains, which
requires that hazanimis waste management facilities be designed,
constructed, operated, and maintalnpd to avoid washout.
- 40 CFR 6 Appendix A — Statement of Procedures on Flood Plain
Management and Wetland Protection, which sets forth U.S. EPA
policy on flood plain management and protection of wetlands.
Compliance with action-specific ARARs for the Ash Pile and Ash Disposal
Pit is governed by the assumption that the wastes are hazardous.
Closure performance standards under 40 CER 265.111, landfill cap design
requirements under 40 CFR 265.111, and post-closure maintenance and
monitoring requirements under 40 CFR 265.117 are relevant and
appropriate to actions that allow the ash to remain in place. Several
substantive rules under 40 CFR 265 Subpart L— Waste Piles are
considered relevant and appropriate to actions at the Ash Pile.
Closure of a waste pile under the regulations of Subpart L requires
removal and subsequent disposal of the hazardous material. According
to 40 CFR 265.258— Closure and Post-Closure Care, all contaminated
media at the location of a former ha/arrinus waste pile must be
decontaminated or the area must be closed and managed in accordance
with regulations for landfills under 40 CFR 265 Subpart N — landfills.
A discussion of landfill closure regulations can be found within the
evaluations for the North and South landfills.
/OS
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Other substantive actions-specific ARARs for the Ash Pile and Ash
Disposal Pit apply to the subsequent handling of excavated ash. These
requirements are ^jgcussed below under the applicable remedial
alternatives.
Removal of ash and soils from the Ash Pile and Ash Disposal pit will be
accomplished to background levels for lead, cadmium, chromium, barium,
arsenic, zinc, PCBs and dioxins provided that all other contaminants
present will in no case exceed a 10"6 total lifetime risk level for
carcinogens and must have a hazard index of less than one for non-
carcinogens. Background levels for inorganics can be found in Appendix
J Tables J-l and J-2 of the RI report. Background levels for organics
are considered to be nondetectable.
Cl— —No Action
Alternative Cl fails to comply with applicable ARARs identified for the
Ash Pile and Ash Disposal Pit operable unit. RI data indicate that
health-based action levels for contaminated soil were exceeded at those
locations, and Alternative Cl would not address the potential health
risks and fail to satisfy substantive regulations for closure of waste
piles and landfilled hazardous waste. It would also leave the Ash Pile
in a location that is vulnerable to washout during floods.
Alternative C2—Single—tVmrier Cap
Alternative C2 would comply with ARARs for landfilling of a hazardous
waste. The single-barrier cap would comply with the minimum
regulations for hazardous waste landfill cap design under 40 CFR
265.310. It would not comply with the minimum technology guidance for
hazardous waste cap design.
The erosion control matting used under Alternative C2 would comply with
the requirements of 40 CFR 265.18 (b)—locational Standards, Flood
Plains.
Alternative C3—Consolidation Without Treatment
Alternative C3 would comply with the requirements for closure and post-
closure care of waste piles under 40 CFR 265.258 if the waste is not
EPToxic. The use of common backfill to cap former ash-containing areas
assumes that the locations will have been cleaned up to background.
If hazardous materials remain, the locations would have to be closed
according to ARARs applicable to closure of a hazardous waste landfill.
Regulations regarding land disposal restrictions of characteristic
hazardous waste under 40 CFR 268 may be promulgated by 1990. If land
disposal of the ash is restricted, then some form of treatment—
probably stabilization—would be required before land disposal if the
waste fails the EPToxic test.
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TABLE 13
COST ESTIMATE SUMMARY
FOR THE ASH PILE AND ASH DISPOSAL PIT
MIAMI COUNTY INCINERATOR SITE
DESCRIPTION
Health and Safety Program
Single-Barrier Cap (a)
Remove and Consolidate
Remove, Solidify, and Consolidate
Backfill
Allowances (b)
Contingencies (c)
Other Indirect Capital Costs (d)
Engineering/Design
TOTAL CAPITAL COST
PRESENT WORTH OF O&M COSTS (e)
TOTAL PRESENT WORTH ESTIMATE (0
ALTERNATIVE
C2
$ 0
151,000
0
0
0
169,000
42,000
32,000
22,000
$ 265,000
79.000
$ 340,000
C3
$ 37,000
0
606.000
0
208,000
122,000
389,000
204,000
137.000
$1,703,000
0
$1 ,700,000
C4
$ 48,000
0
0
1 ,489,000
208,000
255.000
800,000
420,000
314,000
$3,534,000
0
$3,500.000
(a) The configuration of the single-barrier capping system described in the FS
has been modified as described in the ROD. These estimated costs are for the
modified cap system.
(b) Mobilization/demobilization, bond and insurance, temporary facilities, and field
detail allowance.
(c) Bid and scope contingencies.
(d) Administrative, legal, and permitting services to meet substantive requirements and
services during construction.
(e) Present worth estimate assumes a discount rate of 5 percent annually over 30 years.
(0 Cost estimate is order-of-magnitude level with expected accuracy of +50 percent
to -30 percent. Total present worth estimate is rounded to two significant figures.
NOTE: More detailed capital cost and O&M cost estimates are presented in
Appendix B of the FS Report.
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Alternative C4—Consolidation with Treatment
Considerations regarding ARAR compliance under Alternative C4 are
identical to those flisaisspri under Alternative C3 except that
Alternative C4 includes a plan for treating the ash before placement in
the North Landfill. If land disposal restrictions are promulgated
before the remedial action begins, waste analysis and testing would be
necessary to ensure compliance with the treatment standards specified
under 40 CFR 268 Subpart D.
SHORT—TEKM
Impacts on the surrounding communities during construction activities
are not expected to be great. Noise and dusts resulting from truck
traffic would be similar under Alternatives D2, 03, and 134. Impacts
to the community from Alternative 05 may be greater because of the
excavation and handling of the wastes in the Liquid Disposal Area.
Likewise, risk to workers would be substantially greater under
Alternative 05 than the other alternatives because of potential
exposure to hazardous wastes during excavation staging and
incineration. If proper health and safety precautions for protective
clothing and air monitoring are taken, those risks can be minimized.
Health and safety protection would also be necessary for workers
involved in groundwater or soil vapor treatment. Greater operations
controls and monitoring would be required to verify that implementation
does not pose unacceptable risks to the community, site workers, or the
environment. As waste handling increases, the time until remedial
action objectives are achieved also increases.
Risks to personnel operating the onsite air stripper for groundwater
treatment are not expected to be significant. Proper health and safety
precautions as well as air monitoring would minimize risks. Likewise,
risks to operators at the City of Troy POTW are not expected to be
significant because the concentrations of VDCs will be low when diluted
with the normal plant influent flow.
In general, long-term effectiveness increases from Alternative 01 to
Alternative 05. Alternative 02, which relies on institutional
restrictions, containment, and monitoring, would be the least reliable
in its long-term effectiveness. While all alternatives rely on
controls to some degree or for some time period, reliance on controls
is the least for Alternative 05, followed by Alternatives 04 and 03.
The time required to achieve 90 percent reduction in groundwater VOC
contamination by pumping the onsite downgradient wells would be the
same for Alternatives 03, 04, and 05—about 15 years for the upper
aquifer and 8 years for the lower aquifer. The time estimates for
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oontaminant reduction are presented only for comparison. Since they
are based on many simplifying assumptions, actual times may be
different. The time necessary to achieve 90 percent VOC reduction in
groundwater downgradient of the Liquid Disposal Area under Alternatives
Dl and D2 was not estimated because the source of contamination would
remain under those alternatives. While capping could result in a
substantially reduced contaminant load to groundwater compared to no
action, the presence of significant VDC contamination near the water
table may result in a continuing source of contamination to the aquifer
as the water table fluctuates over time. VOCs could continue to exceed
MCLs in the aquifer for more than 70 years under Alternatives Dl and
D2.
The time necessary to achieve 90 percent reduction in groundwater VOCs
beneath the Liquid Disposal Area varies between Alternatives D3, D4,
and D5. Capping alone, as in Alternative D3, may not effectively
control the source of VOC contamination to the groundwater. Thus, the
time to achieve 90 percent reduction in VOCs cannot be estimated and
pumping may be required indefinitely. Under Alternative D5 the source
of contamination would be effectively removed by excavation, and the
time to achieve 90 percent reduction of groundwater contamination is
estijnated at 6 years for those wells located near the Liquid Disposal
Area. Under Alternative D4, the source of VDC contaminants is removed
from both the unsaturated and saturated zones. Vapor extraction is
expected to enhance groundwater pumping and the achievement of 90
percent reduction in groundwater VOCs; however, it is difficult to
quantify the effectiveness of vapor extraction and the influence on the
groundwater collection system.
Under Alternative D4A, contaminants would not be removed from below the
water table with the soil vapor extraction system. As a result the
time necessary to achieve 90 percent reduction in groundwater VOCs
beneath the Liquid Disposal Area may be similar to Alternative D3.
The potential for the future release of additional contaminants to the
groundwater decreases with greater reduction of waste toxicity,
mobility, and volume. For example, vapor extraction may remove a high
percentage of VOCs but will not remove all VOCs and will not remove
significant amount of nonvolatile contaminants. While VOCs represent
the greatest groundwater contamination concern, contaminants not
removed by vapor extraction could be released in the future if the cap
failed. Incineration would destroy VOCs and nonvolatile organic
contaminants but would not destroy metals, which would remain in the
ash.
REDUCTION OF TOXTCTTY. MOBILITY. AND VOLUME
Alternative D4 and D5 involve treatment operations that achieve
reductions of toxicity, mobility> and volume of contaminants in the
Liquid Disposal Area. Alternatives D3, D4 and D5 include groundwater
treatanent, which would reduce contaminant mobility. The toxicity of
VOCs in the collected groundwater is reduced when the air stripper
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emissions of Alternatives D3, D4, and D5 are absorbed onto carbon and
later destroyed during carbon regeneration. The POIW treatment of
groundwater would also reduce the concentrations and toxicity of the
contaminants, although not all contaminants would be destroyed. Seme
would be volatilized during aeration in the activated sludge tanks, and
sane would be adsorbed onto the sludge of the POIW. Because the VOC
mass loading contributed from the site is expected to be a small
percentage of VOCs in typical POIW influents, volatilization and
adsorption are not expected to be a concern. Alternatives Dl and D2
have no provisions for treatment.
Alternative D4 would decrease VOC concentrations in waste and soil
(including aquifer media) by approximately 90 percent. The estimated
VOC mass in the Liquid Disposal Area is 33,000 pounds. Assuming these
preliminary VOC mass and removal efficiencies are correct, an estimated
30,000 pounds of VDGs would be removed. Based on available literature
from field experience, vapor phase carbon treatment would remove more
than 98 percent of the VOCs in the air stream. If the adsorptive
capacity of activated carbon is assumed to be 0.15 pound of VOCs per
pound of carbon, approximately 200,000 pounds of carbon would require
regeneration at an offsite facility.
Alternative D4A wculd decrease VOC concentrations in the unsaturated
zone by about 90 percent. The mass of VOCs removed by the vapor
extraction system would be less than the amount removed under
Alternative D4 because dewatering is not being considered. The VOCs
adsorbed on the aquifer matrix would be removed through groundwater
extraction only. Estimates of the VOC mass adsorbed on the aquifer
matrix beneath the Liquid Disposal Area were not made because of
limited data.
Alternative D5 would destroy more than 99 percent of the volatile and
nonvolatile organic contaminants in an estimated 78,000 cubic yards of
contaminated waste and soil (assuming the Liquid Disposal Area is
100,000 square feet). Incineration would reduce the volume of
contaminated materials by approximately 20 percent. Incineration
residues would consist of approximately 61,000 cubic yards of ash and
soils and an undetermined volume of scrubber fly ash.
OVERATJi PROTECTION OF HUMAN HFAT.T^ ftNQ THE ENVIRONMENT
All of the alternatives would protect human health and the environment.
The overall degree of protection takes short-and long-term
effectiveness into consideration. The difference between alternatives
in short-term risks to workers, the oumimnity, and the environment are
not great relative to differences in long-term effectiveness.
The principal protection benefit of treating the wastes in the Liquid
Disposal Area would be reduced leaching of contaminants to the
groundwater, resulting in more rapid long-term remediation of
contaminated groundwater and reduced reliance on containment or
institutional restrictions. The permanence of source controls and
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TABLE 14
COST ESTIMATE SUMMARY
FOR THE LIQUID DISPOSAL AREA AND GROUNDWATER
MIAMI COUNTY INCINERATOR SITE
DESCRIPTION
.
Health and Safety
Site Preparation
Cap (a)
Groundwater Collection System
Groundwater Treatment
Temporary Cap
Soil Vapor Extraction System
Vapor Phase Treatment
Excavation
Material Processing
Onsite Incineration
Backfill
Miowances (b)
3c sncies (c)
Dther indirect Capital Costs (d)
Engineering/Design
"OTAL CAPITAL COST
'RESENT WORTH OF O&M COSTS (e)
OTAL PRESENT WORTH ESTIMATE (0
ALTERNATIVE
D2
$ 0
0
423,000
0
0
0
0
0
0
0
0
0
51.000
119.000
89.000
60,000
$ 742,000
1.822.000
$ 2,600.000
03
$ 37.000
145,000
423.000
251.000
126,000
0
0
0
0
0
0
0
161,000
457.000
288.000
161.000
$ 2.049,000
4.213.000
$ 6.300,000
D4
$ 46.000
165.000
348.000
295.000
126.000
85.000
342,000
980.000
0
0
0
0
231.000
1,309.000
707.000
514.000
$ 5.148.000
4.213,000
$ 9,400,000
04A
$ 46.000
106.000
423.000
276.000
3,000
0
254.000
980.000
0
0
0
0
181.000
1,135.000
613.000
461.000
• $ 4.478,000
3,149.000
$ 7,600,000
05
$ 362,000
643;000
398,000
251,000
126,000
0
0
0
3.445,000
1.836,000
18.350.000
565,000
3.191,000
14.584,000
7.875.000
4,469.000
$ 56,095.000
4,213,000
$ 60,000.000
i) Alternatives 02 through OS include a double-barrier cap system.
)) Mobilization/demobilization, bond and insurance, temporary facilities, and field detail allowance.
:) Bid and scope contingencies.
:) Administrative, legal, and permitting services to meet substantive requirements and services during
construction.
) Present worth estimate assumes a discount rate of 5 percent annually over 30 years.
) Cost estimate is order-of-magnitude level with expected accuracy of +50 percent to -30 percent. Total
present worth estimate is rounded to two significant figures.
GTE: More detailed capital cost and O&M cost estimates are presented In Appendix B of the FS
Report for Alternatives 02, 03, 04 and 05. Alternative D4A was developed after receipt of
public comments and was not part of the FS.
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reductions in time required to remediate groundwater serve as the
primary indicators of overall protection.
The estimated time required to achieve 90 percent reduction in
groundwater VOC contamination was discussed above. In summary,
Alternatives Dl and D2 would require restrictions on the use of the
aquifer for drinking water for as much as 70 years. Onsite cleanup of
groundwater contamination would be achieved most quickly under
Alternative D4, and Alternative D4A, followed by Alternatives D5 and
03. These predictions are based on available site data, technology
literature, and models that require certain assumptions in the absence
of data. While they serve as valuable indicators, their precision has
limitations. Actual times required to reduce groundwater contamination
beyond the property boundary, below Safe Drinking Water Act Maximum
Contaminant Levels (MCLs) or other health or risk based levels can be
determined only through monitoring of the implemented remedies.
IMPTfMENTABILITY
All of the Liquid Disposal Area and groundwater alternatives are
technically and administratively feasible and require services or
materials that are available. In general, waste treatment
alternatives, particularly incineration, require more specialty
contractors than containment. While those services are available, in
most cases they are not unlimited. The actual availability of services
required to implement a particular remedy may result in scheduling
delays but will not eliminate the feasibility of that alternative.
The implementability of groundwater treatment under Alternative D4A at
the Troy POTW is dependent on the City of Troy's willingness to accept
the discharge and its ability to continue to meet NPDES requirements.
If the City does not agree to accept the discharge, onsite treatment as
described for Alternative D4 would be implemented.
COST
Cost estimates and the present worth analysis for the Liquid Disposal
Area and groundwater alternatives are summarized in Table 14. In
general, costs increase with increased long-term effectiveness and
overall protection, but the relationship of incremental effectiveness
and protection to cost is not linear. Costs depend on assumptions made
regarding waste characteristics and volume, conceptual plans for
implementing alternatives, and operation and maintenance requirements.
Therefore, careful evaluation of costs and cost-sensitive assumptions
is necessary.
The sensitivity analysis was intended to assess the effect of variation
of key assumptions associated with the cost of any remedial
alternative. The cost sensitivity analyses performed for Alternatives
04 and 05 are presented in Appendix B of the Feasibility Study. The
analysis for Alternative 04 illustrates the effect associated with
changing the surface area of the Liquid Disposal Area, which varies the
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contaminant loading to the vapor extraction system. The analysis for
Alternative D5 focused on variations in the volume of wastes to be
incinerated.
WITH ARARs
Groundwater samples from monitoring wells downgradient of the Liquid
Disposal Area indicate that concentrations of several contaminants
exceed MCLs. One residential well sample contained 1,1-dichloroethene
at a concentration that exceeded the MCL. Health-based action levels
for contaminated soils were also exceeded in some subsurface soil
samples from the Liquid Disposal Area. These results indicate that the
Liquid Disposal Area and groundwater operable unit does not comply with
chemical-specific ARARs for drinking water and other ambient
environmental standards to be considered. MCLs are considered relevant
and appropriate for the Liquid Disposal Area and groundwater operable
unit because of three key analytical results:
- The aquifer containing contaminated groundwater is used as a
source of drinking water.
- Analytical data for the Liquid Disposal Area and information
about the groundwater contaminant plume indicate that continued
contaminant releases and further plume migration are likely.
- Analytical modeling showed that contaminant concentrations in
groundwater near the Great Miami River may increase during the
next 25 to 30 years if no action is taken.
Substantive action-specific requirements for permanent closure of the
Liquid Disposal Area involve many of the same regulations discussed
above regarding closure of the North and South landfill and Ash Pile
and Ash Disposal Pit operable units. Use of other remedial
technologies, however, such as water treatment and incineration,
involve additional requirements, which are dlsnisspd below.
The aquifer in this area has been designated a sole-source aquifer
under the Safe Drinking Water Act by the U.S. EPA. Implementation of
the proposed remedy would serve to greatly reduce the contribution of
contaminants from the site to this aquifer.
Alternative Dl—Mb Action
Alternative Dl fails to comply with ARARs identified for the Liquid
Disposal Area and groundwater operable unit. RI data indicate that
MCLs in groundwater and health-based action levels for contaminated
soil are exceeded in this operable unit. No action would fail to
address potential health risks and fail to satisfy minimum substantive
regulations for closure of hazardous waste landfills.
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Alternative D2—Cap with Natural Grouhdwater Attenuation
Alternative D2 would comply with ARARs for closure of landfilled
hazardous wastes. The double-barrier cap would meet current
performance requirements under 40 CFR 265.310 and minimum technology
guidance for covering of hazardous waste.
The natural groundwater attenuation strategy in Alternative 02 is based
on SARA 121(d)—Degree of Cleanup. Subsection 121(d) (2) (B) (ii) of this
rule outlines "a process for establishing alternate concentration
limits" that is considered applicable to conditions observed at the
Miami County Incinerator Site. The specific site conditions that
apply—found under SARA 121 (d) (2) (b) (ii) (I) and (III)—are:
- There are known and projected points of entry of contaminated
groundwater into surface water.
- Statistically significant increases in contaminant concentration
in the Great Miami River are not expected.
- The remedial action includes enforceable measures that will
preclude human exposure to the contaminated groundwater at any
point between the facility boundary and all known and projected
points of entry of contaminated groundwater into surface water.
Under the new SARA criteria, Alternative D2 is considered a groundwater
cleanup strategy that complies with both chemical-specific and action-
specific ARARs. The conditions listed above appear to be satisfied
given the specific groundwater contamination circumstances and the
measures built into Alternative D2 to provide groundwater monitoring
and alternative residential drinking water supply when needed.
Alternative D3—Do^le-Barrier Cap with Groundwa^r Treatment
Alternative D3 would comply with ARARs because it includes a cap that
meets both current federal regulations (40 CFR 265.310) and minimum
technology guidance, while it responds fully to the groundwater
contamination issue. Relationships between ARARs and cap configuration
are itfamsstx* above. However, the groundwater collection and treatment
system, presents the need to examine sane additional regulations.
Permit regulations under the NPDES (40 CFR 122) provide a set of rules
related to treatment system discharges and therefore would greatly
influence the design and operation of the groundwater treatment system.
State NPDES regulations under QAC 3745-33 and Ohio Permit System
Regulations under QAC 3745-31 are considered applicable to Alternative
D3. Many administrative rules under those regulations are considered
applicable to this action because it would affect offsite surface
waters. The key requirement common to all these regulations is
consultation with the state regarding use of best available technology
for water treatment systems.
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Key regulations considered applicable to air pollutant emissions from
the proposed air stripping tower include 40 CFR 52 and 40 CFR 61.
These regulations impose limits on VOC emissions and provide a
procedure for review of reasonably available control technology for
cases where the limits are exceeded. Regulations under 40 CFR 52
require coordination with the state regarding review of new air
pollution sources. Proposed standards for VOC emissions under 52 FR
3748 do not yet have the status of ARARs but may serve as guidance to
be considered for the design of the air stripping tower. Ohio's
interim Air toxics Policy is also to be considered.
Alternative D4-—Vapor Extraction and Cap with Groundwater Treatment
Regulations regarding groundwater treatment under Alternative D4 are
applicable to the same extent as discnsspd under Alternative 03.
Requirements pertaining to capping and closure of a hazardous waste
landfill apply to final closure of the Liquid Disposal Area and
groundwater operable unit. The double-barrier cap, installed following
completion of vapor extraction, would comply with ARARs. Ihe double-
barrier cap is considered appropriate for final closure because the
soil vapor extraction process—while effectively reducing the volume of
VOCs—would not effectively remove nonvolatile contaminants from the
operable unit.
The performance standards considered applicable to the soil vapor
extraction technology are set forth under 40 CFR 264 Subpart X—
Miscellaneous Units. These standards (40 CFR 264.601) generally
require that the treatment technology be designed to reduce the volume
the potential for migration of contaminants posing a risk to human
health and the environment. The specific requirements of this
performance standard, based on the review conducted for this FS, are
consistent with the intent and design of Alternative 04. Therefore,
the soil vapor extraction technology is considered to comply with
ARARs.
VOC emissions from the soil vapor extraction unit would be similar to
those from the air stripping technology described under Alternative 03,
so the air emission regulations discussed under Alternative 03 would
apply to Alternative 04.
Treatment
Alternative 04A would comply with ARARs because it includes a single-
barrier cap that meets current federal regulations (40 CFR 265.310) and
state regulations (OAC 3745-27-09, 10, and 12 and proposed closure
regulations 3745-27-11) while also responding fully to groundwater
contamination. Performance standards applicable to the soil vapor
extraction technology and groundwater cleanup would be as described for
Alternative 04.
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Discharge to the Troy POIW must meet the provisions of the Troy Sewer
use ordinance described earlier. Pretreatment would be required if the
provisions cannot be met. Discharge to the POIW must also meet state
requirements for permitting (QAC 3745-31) and pretreatment regulations
(OAC 3745-03) . In addition, the discharge must meet pretreatment
requirements of the federal Clean Water Act (40 CFR 403) .
Alternative D5 — Incineration with Groundwater Treatment
Regulations pertaining to groundwater treatment are discussed under
Alternative D3. Actions unique to Alternative D5, including excava-
tion, temporary storage, and incineration of hazardous materials
require consideration of other regulations.
Substantive regulations under 40 era 264 Subpart I — Storage Containers-
-should be considered applicable when they concern temporary storage of
hazardous wastes prior to incineration. Regulations related to
permanent storage of hazardous wastes may be considered relevant and
appropriate when they are deemed necessary for short-term protection of
public health and the environment during cleanup. Regulations under 40
CPU 264 Subpart O— Incinerators would be considered applicable for
incineration of hazardous wastes. Hazardous waste incinerator
performance standards under 40 CFR 264.33 are considered prominent
rules for this action. These standards require a 99.99 percent
destruction and removal efficiency for principle organic hazardous
constituents.
State of Ohio air pollution control regulations considered applicable
to this action include rules under OAC 3745-15, -16, -17, and -21.
GROUNDWATER
A. Determination of Cl^^nup
In accordance with EPA policy (See "Interim Guidance on Compliance with
Applicable or Relevant and Appropriate Requirements," dated July 9,
1987) the Maximum Contaminant Levels (MCLs) established under the Safe
Drinking Water Act are generally the applicable or relevant and
appropriate requirements for determining cleanup levels for
groundwater. MCLs are first considered as cleanup standards for the
groundwater. However, because of cumulative health risks, the MCLs may
not be sufficiently protective of human health. Also, MCLs do not
exist for many compounds. Therefore, health based standards of 1 x 10~
5 cumulative excess lifetime cancer risk and a chronic hazard index not
to exceed 1, are set as the groundwater cleanup standard at the waste
boundary. A 1 x 10~5 risk level is considered appropriate only within
the waste boundary where deed restrictions will prevent installation of
wells. A 1 x 10~S excess lifetime cancer risk must be met at the
nearest receptor. In addition, the MCLs must, at a minimum, be met for
a particular compound at both compliance points.
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Althcugh specific concentration levels required for
cleanup are not established at this time, the cumulative risk
calculation and the chronic HI calculation are dependant upon the
concentrations present in the ground water. The health based standard
allows for evaluating different contaminants at different
concentrations that may be present in the groundwater at the time when
the groundwater extraction system may be terminated. Different
cxxpounds will be removed from the groundwater preferentially. The
mobility and original concentration of a contaminant will be among the
factors that determine the time required for removal from the
groundwater. Arriving at specific concentration levels for individual
contaminants based on the cumulative health risk is consistent with the
requirement for an ACL under RCRA because they are protective of human
health and the environment and because of the direct relationship
between the health based standard and an associated concentration
level. The factors in 40 CFR Part 265.94 (b) were considered when the
cleanup standards were determined.
The cleanup standards are consistent with and more stringent than the
water quality criteria for protection of human health for consumption
of water only. U.S. EPA considers a cumulative excess cancer risk of
1 x lO"4 to 1 x 10~7 to be an acceptable risk range. The cleanup
standard requires a cumulative excess cancer risk of 1 x 10~5 at the
waste boundary, so excess cancer risks for all compounds must
necessarily be within the 1 x 10~4 to 1 x 10~7 or below range
identified in the water quality criteria document.
B. Compliance Points
The point of compliance for the ARARs, the 1 x 10~"5 cumulative excess
lifetime cancer risk level and the chronic HI of 1 is at and beyond the
waste boundary; or from a practical standpoint, the edge of the cap.
The remedial action includes a multi-media cap over the site. Deed
restrictions restricting use of the site are a part of the remedial
action. Therefore, the aquifers do not become actual or potential
sources of drinking water until they reach the waste boundary. The
waste boundary is therefore, an appropriate point of compliance for
groundwater cleanup standards and is consistent with 40 CFR Section
264.95. A second compliance point for the MCLs, the 1 x 10"6
cumulative excess lifetime cancer risk and the chronic HI of less than
1 in the groundwater is the nearest receptor. Because use of the
groundwater can occur beginning adjacent to the waste boundaries,
compliance points are the same. The compliance points apply to both
the shallow and deep aquifers.
C. Technical Impi'dctifAbility
The possibility exists of not being able to technically meet the
cleanup levels. Therefore, provisions for making such a claim must be
carefully developed. Section 121 (b) (2) of SARA allows for a waiver.
Generally the approach to a waiver of the cleanup levels based on
technical impracticability should be based on information developed
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during the operation of the selected groundwater extraction and
treatment system. A monitoring program must be carefully designed to
develop needed information. This information must then be evaluated
from both an overall qualitative perspective and a quantitative
perspective. The qualitative evaluation should include, among other
things, water quality at extraction and monitoring wells, possible
modifications to the extraction system that could help achieve cleanup
levels, and an endangerment assessment of the impact of discontinuing
operation of the extraction system. The quantitative evaluation should
consider, among other things, a statistical analysis of contaminant
concentrations over time and the cumulative mass of contaminants being
removed by the extraction system compared to the mass of contaminants
remaining in the aquifer. The groundwater model developed as a part of
the RI must be calibrated and verified for contaminant mass transport
to aid in predicting aquifer behavior and determining if cleanup levels
are met at the determined compliance points.
Air
An evaluation of the air emissions must be made to determine if they
present an unacceptable threat to human health and the environment.
Three components of the selected remedy emit to the air: 1. the air
stripper in the groundwater treatment system if required for
pretreatment 2. the vapor extraction system and 3. the explosive gas
venting system. These three sources must be considered in combination
and the potential human impacts from the total air emissions from the
site evaluated. As with the groundwater cleanup standard, air
emissions must not exceed a 1 x 10"6 excess lifetime cancer risk level
or a chronic hazard index (HI) of 1 at the nearest receptor. BAT or
other Olio standards must be met.
In accordance with the Ohio Administrative Code 3745-27-12 Explosive
Gas Monitoring for Sanitary Landfills, the methane level at the site
will be monitored and if necessary a venting system will be designed
and implemented.
Radiation
At another Superfund Site in Region V radon was discovered accumulated
on carbon absorbers used in treatment of groundwater. Radon was
present at levels that posed a potential threat to human health and the
environment. The radon was naturally occurring.
Because of this finding, radon will have to be considered in
implementing the selected remedy. For example, soil gas sampling
during the pre-design investigation phase must be performed and
monitoring of air emissions and carbon used in any treatment process
must be performed.
Radon must be factored into the calculations to determine if the
cleanup standards for air, described above, are met.
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Badoaround
Background levels for inorganics can be found in Appendix J Tables J-l
and J-2 of the RI report. Background levels for organics are
considered to be nondetectable.
STATE
The State of Ohio has indicated that it supports the selected remedy
for the Miami County Incinerator site. A letter to this effect from
the Director of Ohio EPA is expected.
COMMUNITY ACCEPTANCE
Strong community support has been indicated for the remedy proposed by
the Business and Industry Environmental Committee (BIEC) . Local
industries and elected officials strongly supported the Business and
Industry Environmental Committees' cleanup proposal presented at the
public meeting on April 6, 1989 and also included in an April 11 BIEC
evaluation of the BIEC and U.S. EPA proposed plans that was submitted
during the public comment period. At the public meeting and in the
April 11, 1989 evaluation, the BIEC proposed cleanup included soil
vapor extraction treatment for the Liquid Disposal Area. The BIEC
proposal dated April 26, 1989 did not include soil vapor extraction
for the Liquid Disposal Area. Instead the April 26, 1989 BIEC comments
proposed ground water removal and natural attenuation for the area.
EPA has selected vapor extraction for this area because of the
preference for treatment expressed in SARA.
Because the remedy proposed in the Record of Decision for the overall
site, is close to the BIEC proposal, the remedy is expected to be
acceptable to the community. A detailed discussion of the BIEC plan is
included as part of the Responsiveness Summary.
X. THE ST?
This site has seven areas of concern. The selected remedial
alternative for each of these areas is:
A. fimrt-h Tarrifitt - closure according to State sanitary landfill
requirements. Alternative A3 has been selected. The major
components of the selected alternative are:
- Fence landfill area and post warning signs
- Deed notifications/property use restrictions to prohibit use of
groundwater and prevent exposure to contaminants
- Ongoing monitoring
- Grade and cap landfill with single barrier cap
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B. North Tandfjii - closure according to State sanitary landfill
' requirements. Alternative B3 has been selected. The major
components of the selected alternative are:
- Fence landfill area and post warning signs
- Deed notification/property use restrictions to prohibit use of
groundwater and prevent exposure to contaminants
- Ongoing monitoring
- Grade and cap landfill with single barrier cap
C. Ash Disposal Pit and Ash Pile - remove to North or South landfill.
Alternative C3 or C4 has been selected depending on the need for
treatment. The major components of the selected alternative are:
- Excavation and consolidation of ash wastes and contaminated soils
onto the North or South Landfill
- Backfill and vegetate excavated areas
- Treatment if required under RCRA
D. T liquid Disposal Area and Groundwa't'iay — vapor extraction, groundwater
pump and treatment, capping. Alternative D4A which is a
modifdication of Alternative D4 has been selected. The major
components of the selected alternative are:
- Ongoing monitoring
- Grade and cap site with double barrier cap
- Vacuum extraction of VDCs from waste and soils
- Vapor phase carbon treatment or equivalent, catalytic oxidation
or other appropriate treatment of the exhaust
- Pump and treat contaminated groundwater with discharge to Troy
POTW with pretreatment, if necessary
- Continue connection of residential and commercial groundwater
users to a potable water supply
E. Former Scrubber Wastewater Lagoon Test soils/ash for complete CLP
organic/inorganic parameters including cyanide compounds. An
evaluation will then be conducted to determine if any further
actions are required. The same type of evaluation as conducted in
the Endangerment Assessment (EA) for other site areas will be
conducted. If required, the contaminated material would be removed,
treated if necessary and placed in the North Landfill. Cleanup, if
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necessary, would be to background levels of lead and any other
contaminants of concern which are identified.
F. Stained Soil Area - no action. This area has a low level of seme
contaminants but the risks associated with these contaminants do not
warrant further action.
G. Eldean Tributary Testing of sediments will be conducted to
determine the source of contaminants in the area. Samples will be
analyzed for base-neutral compounds, pesticides, PCBs and cyanide.
An evaluation will then be conducted to determine if any further
actions are required. The same type of evaluation as conducted in
the Endangerment Assessment (EA) for other site areas will be
conducted. Results will be compared to standards and criteria to
see if there would be an effect on the aquatic connunity. Cleanup
of this area, if necessary, would be to a hazard index of less than
one for non-carcinogens and to a 10"6 total lifetime risk level for
carcinogens via direct contact. Cleanup would also be protective
of the aquatic community.
H. Groundwater Users - connection to City of Troy water supply.
Because of the contamination of residential wells by organic
chemicals, these residences are being connected to the City of Troy
water supply with the consent of the well owners. The wells with
higher levels of contaminants belonging to residences and business
in the area have been taken out of service because of the acute
threat involved. The remaining residences have water which poses a
chronic health threat that is clearly unacceptable over the longer
term. Cnce these residences are connected to city water, the wells
should be closed to prevent their use and possible cross
contamination of the city water supply. New wells should not be
drilled until the aquifer has been cleaned up and the groundwater
can be considered safe for human consumption. The length of time
this will take cannot now be estimated but it can be anticipated
that it will take many years.
XI. STATUTORY DETERMINATIONS
A. Protection of Human Health and the Environment
This remedy will eliminate the exposure to contaminants by the
groundwater users downgradient from the site waste areas. Residents
and businesses which were using groundwater from the contaminated
aquifers will be connected to the city of Troy water supply. Vapor
extraction of the liquid rH^p"*"*! area, pumping and treating the
groundwater and capping the north and south landfills and liquid
disposal area will serve to cleanup the contaminated aquifers. These
actions will also serve to eliminate the discharge of contaminants to
the Great Miami River.
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The deed ratification/property use restrictions will prevent a
development of the site and possible use of groundwater beneath the
site. These restrictions will also prevent the potential exposure of
future site users to contaminants in soils which could occur during
development of the site.
Fencing and capping the north and south landfills and the liquid
disposal area and removing the ash to the north landfill will prevent
exposure both to trespassers and wildlife through direct contact with
surface contaminants.
B. The remedy will attain all applicable or relevant and appropriate
Federal and State requirements (ARARs). ARARs specific to the
selected alternatives are disoisspd in greater detail in the
Summary of Comparative Analysis of Alternatives section. Other
ARARs for this site are:
Law, Regulation
or Starykynd Source of Law/R«=»g"i ation
FEDERAL .
Clean Water Act CWA Section 301 (b) (2)
The treatment of extracted groundwater prior to discharge to publicly
owner treatment works is regulated by Section 301 (b) (2) which requires
the application of Best Available Technology (BAT) economically feasible.
BAT is determined on a case-by-case basis pursuant to Section 402 (a) (1)
of the Clean Water Act using guidelines in 40 CFR 125.3
Resource Conservation and
Recovery Act 40 CFR Subpart G
RCRA Section 265.310, Subpart N, specifies the performance based
standards for cover at final landfill closure.
After closure is corpleted, the substantive monitoring and maintenance
post-closure requirements contained in Section 265.117 through 265.120 of
Subpart G will be conducted.
Safe Drinking water Act Safe Drinking Water
Act, 40 CFR 141
through 143
The SDWA and corresponding State standards specify maximum contaminant
(MCLs) for drinking water at public water supplies. Contaminants for
which MCLs are specified must, at a minimum, achieve MCLs.
Xntergovernment
National Pollutant Discharge CWA Section 402,
Elimination System (NPDES) 40 CFR 122, 123,
Permit 125 Subchapter N
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Law, Regulation
or Standard Source of law/Ragula-Hnn
Pretreatjnent Regulations 40 CFR 403 Subchapter
for Existing and New N, FWPCA
Sources of Pollution
Pretreatment of extracted groundwater to oontrol discharge of toxic
pollutants to municipal treatment system.
Occupational Safety and 29 CFR 1910
Health Act (OSHA)
The selected remedial action contractor must develop and implement a
health and safety program for its workers if such a program does not
already exist. All on-site workers must meet the minimum training and
medical monitoring requirements outlined in 29 CFR 1910.
AIR ACT
The Clean Air Act identifies and regulates pollutants that could be
released during earth-moving activities associated with regrading and cap
installation. CAA Section 109 outlines the criterial pollutants for
which National Ambient Air Quality standards have been established.
RCRA Guidance Document landfill Design Liner Systems and Final Cover.
Ohio NPDES Permit OAC 3745-31-05
Ohio NPDES Regulations Ohio Administrative
Code: 3745-33-01
through 3745-33-10.
Authority granted by
Ohio Water Pollution
control Act, ORC 6111.03.
ORC 6111.042
Ohio Permit to
Install New Sources OAC 3745-31-02
Ohio Water Quality Ohio Administrative
Standards Code: 3745-1.
Authority granted by
Ohio Water Pollution
Control Act, ORC 6111.041.
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Law, Regulation
or Standard
Source of law/Regulation
Ohio Pretreatanent
Regulations
Ohio Water Pollution
Control Act
Ohio General and
Miscellaneous Air
Pollution Regulations
Ohio Air Pollution
Control Laws
Ohio regulation on Air
Permits to Operate
and Variances
Nuisance prevention
Pollution of "Waters
of the State"
Explosive Gas Monitoring for
Sanitary Landf ills
Ohio Administrative
Code: 3745-3.
Authority granted by
Ohio Water Pollution
Control Act, ORC 6111.03.
Ohio Revised Code:
6111.01 to 6111.08.
Ohio Administrative
Code: 3745-15-04.
Ohio Administrative
Code: 3745-15-07.
Ohio Administrative
Code: 3745-15-08.
Ohio Revised Code:
3704.03
Ohio Administrative
Code: 3745-35
Ohio Revised
Code: 3767
Ohio Revised Code:
6111.04
Ohio Administrative Code:
3745-27-12
In addition to these promulgated regulations certain state policy and
proposed regulations outlined below are to be considered:
Draft State Regulations
Final Closure of Sanitary Landfill
Facilities
OAC 3745-27-11
Expected to be fully promulgated by October 1989.
Sets forth minimum design standards for sanitary landfill closure.
State landfill design standard widely applied regarding 1 x 10~7 on/s
soil permeability of single barrier 24" compacted - clay cap.
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C. Post Effectiveness
The selected remedy for the north and south landfill and the ash pile
and pit once the ash has been placed in the north landfill is
prescribed by conpliance with State solid waste landfill closure ARARs.
The range of alternative actions to meet closure requirements is very
limited. Therefore, the selected alternatives are essentially cost-
effective because it is the least expensive alternative which satisfies
said regulations.
The selection of vapor extraction for the liquid disposal area is
deemed cost effective since it is one of two remedies which could be
effectively used for this area. The other alternative is incineration
of the material. This would cost six to seven times as much without
producing a proportionate benefit. Incineration would leave a residue
which would need to be disposed of on site or taken to an appropriate
landfill offsite.
The pumping and treating of the groundwater is the only viable
alternative to deal effectively with this contamination problem. It is
therefore, cost-effective by definition. This is the standard method
for groundwater cleanup and is widely applied at Superfund sites.
D. Utilization of Permanent Solutions and Alternative Treatment
Technolocfi«=>s to the Maximum Extent Practicable
The alternatives selected were determined to be the most appropriate
ones for each area of the site where they are being utilized. The
liquid disposal area and the groundwater required alternatives which
were compatible with both areas. Vapor extraction, groundwater pumping
and treating and capping will provide a permanent remedy for the areas.
They also exhibit a preference for treatment as a principal element of
the remedy.
A permanent remedy involving treatment or recovery technologies was not
selected for the landfill areas. Permanent remedies involving
treatanent or incineration were evaluated and were judged to be not
practicable for the site.
Application of treatment and incineration technologies would be
impracticable for the following reasons:
- Hazardous substances were apparently placed haphazardly within
the landfill waste mass during operation. Segregation of
hazardous from non-hazardous waste would be impractical.
Therefore, treatment would be required for the entire waste mass.
This was considered: 1) not technically practicable, 2) not
prudent because of the potentially greater risk to human health
and environment caused by excavation.
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-59-
Ihe estimated cost of thermal treatment would be extremely high
and require many years to complete.
Full ARAR compliance would be achieved by landfill closure which
would be protective of human health and cost effective.
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,:-!l_ £0 or. !•*•!- 'jr;i-j t.r^ •'.'._ • • '
APPENDIX A
Sttt* at Ohio Environmental Protection Agency
. F
0 .nous, Ohio 43266-0149 Governor
July 5, 1989
Mr. valdas V. Adamkus
Regional Administrator
U.S. EPA, Region V
230 S. Dearborn Street
Chicago IL 60604
Dear Mr. Adamkus: -
In response to your June 30, 1989 letter the Ohio Environmental Protection
Agency (Ohio EPA) has reviewed the draft Record of Decision for the H1am1
County Incinerator site 1n Troy, Ohio.
Ohio EPA concurs with the selected remedial action presented 1n the June
21, 1989 ROD, with modifications discussed June 27 and 28 between the
Region's Remedial Project Manager and Ohio EPA's Project Coordinator.
If you have any questions or concerns regarding this Issue, feel free to
call me.
Slncer
Richard L. Shank, Ph.D.
Director
RLS/KAO/lZ
cc: Hike Starkey, SWDO
Jenny T1ell, OCA
Dave Straycr, OCA
(Catherine Davidson, OCA
Tony Rutter, U.S. EPA
Craig Uska, U.S. EPA
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APPENDIX B
RESPONSIVENESS SUMMARY
MIAMI COUNTY INCINERATOR SITE
Troy, Ohio
U.S. EPA
June 29, 1989
GLT883/015.50
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INTRODUCTION
The United States Environmental Protection Agency (U.S. EPA) with the Ohio
Environmental Protection Agency, has completed a Remedial Investigation and
Feasibility Study (RI/FS) for the Miami County Incinerator Site at 2200 North
County Highway 25-A, Troy, Ohio. During the RI, information was gathered on
the nature and extent of contamination: as part of the FS, alternatives for
remedial action were developed and evaluated. At the conclusion of the FS, the
U.S. EPA prepared a Proposed Plan that identified recommended alternatives
for remedial action at the site. At a public meeting on April 6, 1989, the U.S.
EPA presented the findings of the RI/FS arid issued its Proposed Plan.
This Responsiveness Summary addresses the comments received during the
recent public comment period, presents U.S. EPA's response to the comments,
and describes how they were incorporated into the decisionmaking process. AJ1
comments received from the public were considered before the U.S. EPA
selected its final remedy for the site.
The Responsiveness Summary is divided into three sections:
o Overview-outlines the proposed remedial alternatives presented in
the FS and at the public meeting.
o Background on Community Involvement-provides a brief history of
community interest and of concerns raised during the planning
activities.
o Summary of Public Comments-presents both oral and written
comments and the U.S. EPA's responses to them.
OVERVIEW
. On March 26, 1989, the U.S. EPA released the Miami County Incinerator Site
Final Remedial Investigation and Public Comment Feasibility Study reports to
the public for review. The public comment period ended on April 26. During
"the FS, remedial action alternatives were developed and evaluated for the South
Landfill, the North Landfill, the Ash Pile and Ash Disposal Pit, and the Liquid
Disposal Area and Groundwater. The array of alternatives considered are
presented in Table 1 and described in detail in the FS report.
After careful consideration, the EPA issued its recommended remedial
alternative, as identified in its Proposed Plan, consisting of:
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GENERAL RESPOSE ACTIONS
AND TECHNOLOGIES /|, ,
« / J/«
5
OPERABLE UNIT AND
ALTERNATIVES
^
SOUTH LANDFILL
Al NO ACTION
A2 SOIL COVER
A3 SINGLE BARRIER CAP
NORTH LANDFILL
81 NO ACTION
B2 SOIL COVER
B3 SINGLE BARRIER CAP
84 DOUBLE BARRIER CAP
ASH PILE AND ASH DISPOSAL PIT
Cl NO ACTION
C2 SINGLE BARRIER CAP
C3 CONSOLIDATION WITHOUT
TREATMENT
C4 CONSOLIDATION WITH TREATMENT
LIQUID DISPOSAL AREA AND
GROUNDWATER
01 NO ACTION
02 CAP WITH NATURAL GROUNDWATER
ATTENUATION
03 DOUBLE BARRIER CAP WITH
GROUNDWATER TREATMENT
04 VAPOR EXTRACTION AND CAP
WITH GROUNOWATER TREATMENT
OS INCINERATION WITH GROUNDWATER
TREATMENT
/ / '
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•
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LEGEND
|/ TECHNOLOGY TO BE IMPLEMENTED
NOTE:
Refer to Chapter 4 of the Feasibility Study Report for descriptions
of requirements common to all alternatives such as institutional
actions, flood control, and groundwater monitoring.
TABLE 1
SUMMARY OF ALTERNATIVES
MIAMI COUNTY INCINERATOR
RESPONSIVENESS SUMMARY
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o A single-barrier cap for the South Landfill
o A double-barrier cap for the North Landfill
o Consolidation with treatment, if necessary, of the contents of the
Ash Pile and Ash Disposal Pit (subject to the Land Disposal
Restrictions of RCRA)
o Vapor extraction, groundwater pumping and treatment, and
capping for the Liquid Disposal Area and Groundwater
o Access restrictions, groundwater monitoring, and alternative water
supply
Numerous oral and written comments on the Proposed Plan and the RI and FS
reports were submitted to the U.S. EPA during the public comment period.
Comments were received from:
o Thirty-seven area residents, businesses, and industries
o Sixteen local governmental agencies
o The Ohio EPA
o The Business and Industry Environmental Committee (BIEC)
representing a group of potentially responsible parties (PRPs)
Many of the public comments acknowledge similarities in the U.S. EPA
recommended alternatives arid those submitted by BIEC during the public
comment period. Others expressed support for the BIEC plan because it is
perceived to be more cost-effective and to encourage local involvement. After
consideration of the BIEC plan and other public comments, the proposed
alternative was modified and presented in the Record of Decision (ROD) as the
selected remedial action.
BACKGROUND ON COMMUNITY INVOLVEMENT
A Community Relations Plan for the incinerator site was prepared in September
1984. As part of the plan, a mailing list of all interested persons was developed
early in the RI. The list includes about 100 names. To date, four fact sheets
have been distributed to the community to advise local citizens of the Superfund
activities at the site. The fact sheets summarize site activities, findings, and
future plans.
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A public meeting-was held in Troy, on September 10, 1986, to discuss the first
phase of the RI. A second public meeting was held on April 6, 1989. The final
RI report, the endangerment assessment, the FS report, and the Proposed Plan
were discussed at the meeting followed by a question and answer session. These
documents are included in the Administrative Record, and were available for
review at the Miami County Public Library and at the Miami County
Commissioner's Office.
The public comment period lasted from March 27 to April 26. Comments were
accepted by mail and at the public meeting. All comments were considered
when the ROD was prepared.
The BIEC represents businesses, industries, and county and city governments in
Miami County. It was formed in 1984 when the incinerator site was placed on
the National Priorities List (NPL). The purpose of the committee is to
coordinate a privately funded, cost-effective response to the cleanup at the site.
SUMMARY OF PUBLIC COMMENTS
Comments received during the Miami County Public Comment period have been
organized and paraphrased to facilitate U.S. EPA response. The actual
comments are retained in the Administrative Record available for public
inspection from the U.S. EPA Region V in Chicago.
COMMENTS FROM THE BIEC
Comments prepared by the BIEC were received in the form of two documents:
the first dated April 11 and the second on April 26. The U.S. EPA has decided
to address the earlier document only briefly, since many of these comments are
the same as those from the later report titled Comments on RJ/FS and Proposed
Remedial Plan, Miami County Incinerator Site, Miami County, Ohio. The EPA
responses to the report are organized to follow the organization, section
headings, and page numbers of the BIEC report.
BIECs Cover Letter to U.S. EPA dated April 26. 1989
1. Comment, page 2, paragraph 2: Over 99 percent of the waste disposed
of at the incinerator site can be characterized as municipal waste.
U.S. EPA Response: The EPA agrees that the facility was operated as a
municipal landfill but does not concur that 99 percent of the waste is
municipal (residential and commercial) in nature. The Miami County
monthly waste tonnage records and ledgers identify daily amounts of
"residential" and "industrial" wastes received. A preliminary review of
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those records indicates that approximately 30 percent (by weight) of the
monthly wastes received was classified as industrial tonnage. However,
the reported tonnage and types of wastes are of little consequence when
considering the analytical findings of the RI. The data indicate that many
hazardous substances are present in the subsurface soil and wastes in the
Liquid Disposal Area and in the groundwater downgradient from that
area.
2. Comment, page 2, paragraph 3: Liquids were disposed of for only 1 year
and "in the RI/FS, U.S. EPA's consultant stated that over 30,000 gallons
of hazardous waste were disposed of at the site on a weekly basis." This
figure is "a gross exaggeration of the volume. ... To rely on that wholly
inaccurate estimate of liquid wastes disposed of at the site in light of
known facts, would be irresponsible, arbitrary, and capricious."
The EPA did not base the remedy on the reported volume estimate of
liquid waste disposal at the site as suggested by the reviewer but upon the
degree of contamination and the public health and environmental risks
posed by the contamination documented in the RI report.
U.S. EPA Response: The estimate of 30,000 gallons of industrial liquid
waste per week is from a statement signed on October 31, 1973 by
Donald Hiser, who was the Miami County Sanitarian. The commentor is
incorrect in claiming that both the RI and the FS reports state that
"30,000 gallons of hazardous waste" were disposed of at the site
Mr. Miser's memorandum is cited in both reports along with the
statement that "it was estimated that nearly 30,000 gallons of liquid waste,
primarily waste ail, were being accepted weekly." The EPA did not base
the remedy on the reported volume estimate of liquid waste disposal at
the site as suggested by the reviewer but upon the degree of
contamination and the public health and environmental risks posed by the
contamination documented in the RI report.
The EPA acknowledges Mr. Brookhart's affidavit signed in April 1989
stating that liquids were accepted at the site for 1 year in the early 1970s,
but the EPA has information refuting that claim. The data base and
Liquid Waste Report prepared by Techlaw/Resource Application, Inc.
and based on a review of 87,000 weight tickets indicates that liquid waste
transactions were reported over several years. BIEC has access to that
data base. In addition, statements from those who have disposed of
waste at the site gathered under the provisions of Section 104(e) of
CERCLA indicate liquid wastes were disposed of at the site as late as
1977.
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3. Comment, page 2, paragraph 4: There is a probability that there are
offsite sources of groundwater contamination that should have been
investigated.
U.S. EPA Response: The EPA believes the groundwater contamination
documented in the RI report is the result of disposal practices at the site.
The area of contamination is hydraulically downgradient of the site, a
large plume of contamination consistently occurs between the site and the
farthest limits of contamination, and the specific contaminants are
generally consistent within the plume. It is not known, but possible that
offsite sources of contamination may exist.
4. Comment, page 2, paragraph 5: There is serious doubt that the site
should have been listed on the NPL.
U.S. EPA Response: The RI report and endangerment assessment
sufficiently documented threats to the public health and environment from
contaminants present at the site. The field sampling and analysis
conducted during the RI/FS substantiate the Hazard Ranking System
scoring and NPL listing.
5. Comment, page 2, paragraph 6: BIEC has submitted a remedial plan
that it believes is superior to the U.S. EPA's preferred remedy.
U.S. EPA Response: While many of the BIEC suggestions merit
consideration, the EPA has found deficiencies in the BIEC proposed plan
that are identified in responses to the specific BIEC proposed actions.
6. Comment, page 2, paragraph 7: BIEC states that its proposal is based
on analytical data that is "not assailable," whereas the U.S. EPA's
"preferred remedy is based on inaccurate information which leads to
selection of unnecessary technologies that . . . could cause uncontrolled
landfill fires."
U.S. EPA Response: To the EPA's knowledge, BIEC had not collected
analytical data independent of the EPA's RI. In fact, BIEC and
U.S. EPA used identical analytical data presented in the RI report in
developing their respective remedial actions. It is not clear how BIEC's
data are "unassailable" and EPA's are. The EPA acknowledges the
concern about landfill fires but believes that proper implementation of the
soil vapor extraction system (based on results of onsite pilot tests) could
greatly reduce the possibility of landfill fires.
7. Comment, page 2, paragraph 8: BIEC proposes that groundwater be
treated at the City of Troy POTW.
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U.S. EPA Response: Discharge to the City of Troy POTW was
considered a potential treatment option (FS report, p. 3-20). The U.S.
EPA considers it a viable treatment option.
8. Comment, page 3, paragraph 2: BIEC's proposed plan is more consistent
with the requirements of CERCLA, the NCP, and federal and state
regulations than the U.S. EPA's.
U.S. EPA Response: The EPA disagrees. The EPA's Proposed Plan
meets all federal and state Applicable or Relevant and Appropriate
Requirements (ARARs). The BIEC plan does not meet all ARARs.
Specifics on which ARARs are not met by the BIEC plan are discussed
in subsequent responses.
9. Comment, page 3, paragraph 3: The BIEC plan is more cost-effective
while providing the same level of protection to public health and the
environment.
EPA Response: The U.S. EPA believes the BIEC plan provides a lower
level of protection and fails to meet specific ARARs.
10. Comment, page 3, paragraph 5: Ownership of the site by Miami County
would provide a continuous ability by a responsible party to respond to
inadequacies in the remedy.
U.S. EPA Response: The EPA will continue to evaluate the adequacy of
the remedy during and after implementation and will pursue all
responsible parties either to implement necessary changes or to pay all
cost incurred by the EPA in implementing any necessary changes,
regardless of who owns the site.
11. Comment, page 3, paragraphs 6 and 7: The BIEC plan will result in a
faster cleanup of the site. BIEC requests that the U.S. EPA adopt
BIEC's proposed plan.
U.S. EPA Response: The length of cleanup is a function of the ability of
the designed system to achieve agreed upon goals. The EPA does not
accept the BIEC plan as providing sufficient protection of human health
or the environment or meeting all ARARS. The EPA feels it was
premature for BIEC to make such predictions.
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Section 1.0— Introduction
1. Comment, page 2. paragraph 2, sentence 3: The Miami County
Incinerator site was established primarily for municipal refuse.
U.S. EPA Response: The EPA agrees with this statement but notes that
the facility was established for the disposal of solid wastes, including
byproducts of industry or commerce in addition to residential waste
(Board of Commissioners of Miami County 1968). In 1970, the Miami
County Sanitary Engineer estimated that about 70 tons/day (45 percent)
daily waste received was industrial, 53 tons/day (35 percent) municipal,
and 30 tons/day (20 percent) nonmunicipal (Brookhart 1970).
2. Comment, page 2, paragraph 2, sentence 3: Liquid wastes were accepted
by the facility for approximately 1 year (1973-74) and disposed of in a
Liquid Disposal Area.
U.S. EPA Response: See response to Comment 2 in the previous
section.
3. Comment, page 3, paragraph 2, sentence 1: On March 27, 1989, the
RI/FS reports were made available for public comment.
U.S. EPA Response: Although above comment is accurate, the EPA
provided BIEC with draft copies of the RI report in July 1988 and the FS
report before the beginning of the public comment period.
4. Comment, page 3. paragraph 1: Citizens representing various businesses,
governments, and civic groups made comments at the public meeting in
April. They "unanimously" supported the BIEC plan over the EPA's.
U.S. EPA Response: There is some question as to which BIEC plan was
endorsed at the public meeting. In a written comment (dated April 25,
1989) supporting the BIEC plan, American Plasma Tech included as an
attach'ment the BIEC proposed plan titled "Miami County Incinerator Site
Joint Cleanup Proposed by Miami County, City of Troy, City of Piqua,
Tipp City, and Business and Industry Committee for Miami County." The
BIEC proposal included a cover letter dated April 11, 1989, soliciting
assistance from local industries and businesses in making public comments
in support of the joint cleanup plan. That plan appears to be an earlier
version of the BIEC plan submitted to the EPA on April 25, 1989.
Although the two plans are similar in many respects, the first plan
includes soil vapor extraction treatment for the Liquid Disposal Area.
Thus, other persons submitting written or verbal support for the BIEC
-------
plan may have been referring to the April 11 BIEC plan, which included
vapor extraction for the Liquid Disposal Area.
5. Comment, page 4, paragraph 3: The BIEC plan is consistent with the
requirements of CERCLA and the NCP, is as protective of public health
and the environment as the U.S. EPA's proposed remedy, provides a
more beneficial use of the site, and is more cost-effective.
U.S. EPA Response: The EPA disagrees. See responses to
Comments 8, 9, and 11 in the previous section regarding BIEC's letter to
U.S. EPA.
Section 2.0~General Discussion
1. Comment, page 5, paragraph 1, section 1: The most important fact to be
considered in developing a remedial action plan is that more than
99 percent of waste disposed in the two landfills was municipal waste.
U.S. EPA Response: The EPA disagrees. The threat to public health
and environment documented in the endangerment assessment is more
important. The EPA also disagrees with BIEC's estimate that the wastes
are 99 percent municipal. The EPA's review of site records indicates
about 30 percent of waste received was industrial waste. See response to
comment 1 regarding the BIEC letter of April 26, 1989.
2. Comment, page 5, paragraph 1, sentence 5: The EPA had access to all
waste-in documentation but a similar analysis of wastes disposed of at the
MCI site was not performed during the RI/FS.
U.S. EPA Response: The EPA has performed a detailed examination of
87,000 weight tickets from MCI, including an evaluation of waste types.
However, records describing the type of materials that were disposed of
were not consistently maintained. The EPA has not performed a similar
evaluation of the additional 128.000 weight tickets obtained and held by
the BIEC to avoid unnecessary expenses. As mentioned, the weight ticket
documentation is incidental to the analytical data gathered during the RI.
3. Comment, page 5, paragraph 2: The statement in the FS report that
hazardous wastes were probably disposed of in the North Landfill is not
supported.
U.S. EPA Response: The EPA believes that hazardous substances were
more likely to be disposed of in the North Landfill than in the South
Landfill because the Liquid Disposal Area is within the North Landfill
8
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and because of the uncertainty associated with identifying the areal extent
of the Liquid Disposal Area.
4. Comment, page 5, paragraph 3: BIEC believes the estimate of
30,000 gallons of liquid waste received weekly at the site and the estimate
of total quantity of liquid waste between 104,000 to 150,000 barrel
equivalents to be incorrect and misleading.
U.S. EPA Response: See response to comment 2, BIEC letter of
April 26, 1989.
5. Comment, page 6, paragraph 2: If estimates of quantities were correct,
the RI would have detected a large pool of oil beneath and downgradient
of the Liquid Disposal Area.
U.S. EPA Response: The EPA agrees that RI results do not support the
estimate of 150,000 barrel equivalents being discharged if it is assumed
that all was waste oil. However, even using the best available
information, it is possible that the full extent of the Liquid Disposal Area
was not defined.
6. Comment, page 7, paragraph 1: Discontinuities that may exist in the till
east of the site would affect aquifer remediation alternatives.
U.S. EPA Response: It is correct that discontinuities may exist in the till
unit east of the site and that they would effect remediation. However, all
stratigraphic data compiled for that area of the site suggest that the till
unit is continuous along the eastern boundary of the site.
7. Comment, page 8, paragraph 2: The RI and FS reports do not report
pump test drawdown data from piezometers and monitoring wells
completed in the upper aquifer. Such data would show the degree of
interconnectedness of the upper and lower aquifer east of the site.
U.S. EPA Response: Data collected from piezometers completed in the
upper aquifer and monitored during the pump test did not show
measureable head change over the duration of the test. Those data were
admittedly not included with RI report but are available for review upon
request.
8. Comment, page 8, paragraph 3: Figures 4-10 and 4-12 of the RI have
incorrectly drawn groundwater level contours. Water level elevations for
monitoring wells CH13B and RW11 as presented in the RI were not
taken into account.
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U.S. EEA Response: These water level measurements appeared to be
outlying data points and were intentionally excluded in preparing the
contours on Figures 4-10 and 4-12. Even so, their inclusion would not
affect the overall gradients calculated for the lower and upper aquifers.
9. Comment, page 10, paragraph 3: The RI/FS erroneously used isolated
zones of contamination to characterize the entire Liquid Disposal Area.
U.S. EPA Response: Test pits were located randomly throughout the
suspected Liquid Disposal Area to minimize bias in determining the
horizontal extent of contamination. As described in the work plan and
the RI and FS reports, vertical sampling was performed in zones of the
cross section determined to be more contaminated on the basis of
screening. This bias was described in the RI and FS reports. Where
data were extrapolated to calculate contaminant mass in the Liquid
Disposal Area, the vertical bias was noted and considered in the
calculations.
10. Comment, page 11, paragraphs 1 and 2: The U.S. EPA's inclusion of
solidification in the remedy for the Ash Disposal Pit and Ash Pile is
unjustified because extraction procedure (EP) toxicity tests were not
conducted.
U.S. EPA Response: The EPA's Proposed Plan included EP toxicity
testing to determine whether the waste is subject to the Land Disposal
Restrictions under RCRA and to determine if treatment, such as
solidification, is required before consolidating the waste in the North
Landfill.
11. Comment, page 13, paragraph 1: Inconsistent scattered values for VOCs
suggest that offsite contaminant sources may exist.
U.S. EPA Response: See response to comment 3, BIEC letter of
April 26, 1989.
12. Comments, page 13, paragraph 3 and page 14, paragraph 1: The RI did
not conform to the guidance in the Superfund Public Health Evaluation
Manual. BIEC is concerned with the selection of chemicals of concern.
The BIEC appears to be concerned that the RI, instead of evaluating
indicator chemicals, evaluated a broader range of chemicals and "that the
failure to identify the most significant chemicals did lead to some
misleading, if not erroneous conclusions." BIEC specifically states the use
of maximum reported concentrations was misleading and, further, that the
endangerment assessment followed a worst case analysis.
10
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U.S. EPAJlespohse: The endangerment assessment evaluated a range of
risks. One set of risks was based on the highest detected contaminant
concentration, but a second set of risks was based on average
concentrations. This approach was taken for several reasons. First, no
effort can define perfectly the nature and extent of contamination at a
site. Consequently, the one time occurrence of a chemical in a sample
does not guarantee that the chemical may not appear elsewhere at the
site. Because of the uncertainty associated with this effort, it was
reasonable to estimate risks for a range of concentrations and to decide
upon which risks to base remedial decisions. This approach is consistent
with the Superfund Public Health Evaluation Manual. It should be noted
that while the highest detected concentrations for all chemicals were used
to calculate one set of risk estimates, the second set (based on mean
concentrations) had estimated risks for only those chemicals that were
detected in 10 percent or more of the samples analyzed.
Chemicals of concern were identified after the risks were estimated.
Because antimony was detected in one well does not suggest it is not a
chemical of concern. There are several possible sources of contamination
at the site. Well CH10B is downgradient from the Ash Pile and the
Scrubber Wastewater Lagoon. It is possible that the antimony in the well
is related to those sources. Similarly, toluene is not unimportant just
because it was found only once at a concentration that exceeded the
reference dose (RfD) based limit. The well in which it was found
(CH09A) is downgradient from the Liquid Disposal Area. While the
EPA agrees that the primary principal contaminants in the groundwater
associated with the site are trichloroethene, vinyl chloride, and
tetrachloroethene, that does not mean that other contaminants are not
important on a localized basis.
13. Comment, page 14, paragraph 3: Arsenic is below its MCL, so it
probably should not be included as an indicator chemical.
U.S. EPA Response: The endangerment assessment discussed some of
the concerns about risk estimation for arsenic; however, just because any
chemical is below its MCL does not exclude it from consideration in an
endangerment assessment. MCLs are not strictly risk based and have
technical and economic feasibility components in their development;
therefore MCLs cannot be used as a risk evaluation criteria by
themselves.
14. Comment, page 15, paragraph 3: The endangerment assessment used a
"worst case" approach instead of the prescribed conservative approach.
11
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U.S. EPA Response: The endangerment assessment presented a range of
risks, including risks based on the highest detected concentrations and
risks based on mean concentrations. While it may be debated whether
use of highest detected concentrations necessarily reflects worst case
conditions, the risks estimated using mean concentrations also indicated
that the risks from the site were high enough to consider remedial action.
15. Comment, page 16, paragraph 1: Careful examination of RI groundwater
data suggests there are additional sources of groundwater contamination.
U.S. EPA Response: See response to comment 3, BIEC cover letter of
April 26, 1989.
Section 3.0--Operable Unit
1. BIEC added the Scrubber Wastewater Lagoon and Stained Soil Area to
the list of operable units.
U.S. EPA Response: The above modifications are recognized.
Section 4.0--South Landfill
1. Comment, page 19 through page 21: The single-barrier cap of
Alternative A3 exceeds the requirements for Ohio Sanitary Landfill
Closure (OAC 3745-27-10). BIEC proposes an alternative cap design for
12 inches of clay, 6 inches of sand, 6 inches of fill, and 6 inches of
topsoil. BIEC believes its proposal is more cost-effective, results in less
infiltration, and meets Ohio requirements.
U.S. EPA Response: BIECs proposal does not meet the Ohio
requirements (OAC 3745-27-9 and -10) for at least 2 feet of well-
compacted cover material having low permeability to water since it
includes only 12 inches of compacted clay.
Section 5.0--North Landfill
1. Comment, page 23, paragraph 1: The EPA's selection of a double-barrier
cap for the North Landfill is based on speculation that hazardous waste
may have been deposited in this area.
U.S. EPA Response: See response to comment 1, BIEC letter dated
April 26, 1989. As stated in the Proposed Plan, a double-barrier cap was
recommended for the North Landfill because it is difficult to determine
whether contaminants detected in the groundwater downgradient from the
North Landfill originate solely from the Liquid Disposal Area or other
12
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areas of the North Landfill, and the possibility of future release of
contaminants from the landfill to groundwater cannot be ruled out. After
consideration of public comments and upon further examination of state
and federal regulations, the EPA has determined that a single^barrier cap
as described in the ROD is sufficient.
2. Comment, page 23, paragraph 2: RI groundwater data indicate virtually
all the waste placed in the North Landfill is municipal.
U.S. EPA Response: Groundwater data cannot be used to determine
whether hazardous wastes were disposed of in the North Landfill. Less
mobile hazardous substances or wastes contained in drums would not
necessarily have reached monitoring wells downgradient of the North
Landfill.
3. Comment, page 23, paragraph 2: Data collected during the RI illustrate
that groundwater quality downgradient of the Liquid Disposal Area is
distinctly different from that downgradient of the North Landfill. The RI
data also show that groundwater quality downgradient of the North
Landfill is very similar to groundwater quality downgradient of the South
Landfill.
U.S. EPA Response: The RI data have been misinterpreted. BIEC has
based its conclusions on data for one well downgradient of the southern
end of the North Landfill (Well CH08B). It is not sufficient to make
such a definitive statement based on the limited data available and
recognizing the complexity of the hydrogeologic conditions at the site.
For instance, the quantity and number of VOCs detected in.May 1985
from the incinerator well (RW11),-which is about 200 feet directly
downgradient from the North Landfill, do not support BIEC's conclusions.
4. Comment, pages 24 to 26: The single-barrier cap proposed by BIEC
would satisfy the design requirements for final closure of existing
hazardous waste landfills, and there is no justification to attempt to
eliminate all infiltration.
U.S. EPA Response: The EPA recognizes that a single-barrier cap could
meet the minimum requirements of 40 CFR 265.310 for final closure.
However, the cap configuration proposed by BIEC does not meet the
state regulation for landfill closure, which requires 2 feet of a well
compacted, low permeability cover material (OAC 3745-27-9 and -10).
5. Comment, page 27, paragraph 3: The use of high density polyethylene
synthetic liner in a double-barrier cap is technically inappropriate for the
North Landfill because of potential for differential settlement.
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U.S. EPA Response: The EPA recognizes the potential for ripping of
synthetic liners placed over sanitary landfills. However, the potential for
differential settlement sufficient to cause tearing in the liner is not great
for the North Landfill. The shallow depth of fill (about 17 feet) and the
age of the landfill are two factors that support the EPA's position that
excessive settlement is not expected.
Section 6.0-Ash Disposal Pit and Ash Pile
1. Comment, page 29, paragraph 1: The volume of ash is about
12,000 cubic yards rather than the 20,000 cubic yards used in the RI and
FS.
U.S. EPA Response: The volume of ash determined in the RI/FS is an
estimate. The actual volume of ash to be removed will be determined
through sampling during design and construction.
2. Comment, page 29, paragraph 3: No data were collected during the RI
that indicate the materials have released or will release hazardous
substances in concentrations that will affect the environment adversely.
U.S. EPA Response: Impacts on the environment do not require
quantification if risks to public health sufficient to require remediation are
documented. This is the case for the Ash Pit and the Ash Pile.
3. Comment, page 30, paragraph 3: No data were collected during the RI
to determine if solidification/fixation would reduce the rate of
contaminant release.
U.S. EPA Response: See response to comment 10, Section 2.0.
4. Comment, page 32, paragraph 2: Construction of a new solid waste
transfer station at the site would be beneficial to the county.
U.S. EPA Response: Refer to the response to comment 10, BIEC letter
of April 26, 1989.
5. Comment, page 33, paragraph 4 and page 34: BIEC's proposed remedy
for the Ash Pile is excavation and consolidation of its contents under the
North Landfill cap. Leachate extraction testing would be done to
demonstrate that the ash is suitable for disposal without solidification.
Even if the waste is a characteristic hazardous waste (fails EP toxicity
testing), disposal would be done prior to May 1990, and solidification
would not be done.
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U.S. EPA "Response: Solidification of the Ash Pile contents would be
necessary only if its contents fail EP toxicity tests. If excavation is
performed before land disposal restriction requirements for solidification
are imposed, disposal beneath the landfill cap without solidification would
be considered if the pile contents pass EP toxicity testing.
Section 7.0--Scrubber Wastewater Lagoon and
Visibly Stained Soils
1. Comment, page 35, paragraph 1: BIEC proposes to investigate the
Scrubber Wastewater Lagoon to determine whether residuals that require
remediation are present. If necessary, remediation would consist of
excavating and consolidation in the North Landfill.
U.S. EPA Response: The EPA notes that BIEC agrees on the need for
investigating the lagoon area for residuals as stated in EPA's Proposed
Plan. The need for treatment _before consolidation will be determined as
pan of the design investigation.
2. Comment, page 35, paragraph 3: BIEC proposes to excavate the Stained
Soil Area and remove its contents to the North Landfill for aesthetic
reasons.
U.S. EPA Response: The EPA will not object if BIEC elects to remove
the Stained Soil Area for aesthetic reasons.
3. Comment, Table 6: Current regulations for municipal incinerator fly ash
do not require solidification for landfilling.
U.S. EPA Response: BIEC's comment is correct but irrelevant. See the
response to comment 10 Section 2.0.
Section 8.Q--Liquid Disposal Area
1. Comment, page 36, paragraph 1: BIEC notes that according to the RI
report perched groundwater is present below the waste materials and that
traces of waste oils were observed in the perched groundwater.
U.S. EPA Response: It appears the information in the RI report has
been misinterpreted. Perched groundwater was observed within the waste
materials at one location, possibly two. The water table was encountered
at several locations, particularly in the eastern portions of the Liquid
Disposal Area. Refuse was observed below the water table at several
locations. Data collected during the RI indicated a slight but measurable
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layer of waste_oils on water samples collected at the water table and not
a trace in the perched groundwater as stated by BIEC.
2. Comment, page 36, paragraph 2: BIEC states that the FS report
identified four alternatives for the Liquid Disposal Area.
U.S. EPA Response: It appears the information in the FS report has
been misinterpreted. The FS identified five alternatives for the Liquid
Disposal Area. In addition to the four listed by BIEC, incineration with
groundwater treatment was identified as a fifth alternative.
3. Comment, page 37, paragraph 2: BIEC lists a number of items that it
states are components of the EPA's remedy associated with dewatering
and vapor extraction for the Liquid Disposal Area.
U.S, EPA Response: The purpose of the FS was to develop feasible
alternatives for remediating the release or threat of release of
contaminants at the site and to develop order-of-magnitude cost estimates
for those alternatives. To achieve that objective it was necessary to make
some assumptions. The selected alternative will be further developed
during predesign and design to determine appropriate materials,
quantities, and other design criteria. The items BIEC listed are simply
assumptions used to develop order-of-magnitude cost estimates in the FS
and are not presented as components of the vapor extraction design.
4. Comment, page 37, paragraph 3: BIEC states the EPA proposed remedy
is inappropriate, did not adequately evaluate the RI data, and did not
address implementation problems.
U.S. EPA Response: Vapor extraction is an appropriate, proven
technology for reducing concentrations of VOCs in the unsaturated zone
of the waste materials. As mandated by SARA, it is the EPA's intention
to reduce the toxicity and volume of contaminants in the Liquid Disposal
Area through treatment. It is the EPA's determination that vapor
extraction will help achieve that goal.
The EPA maintains that the RI data were adequately evaluated in the FS
process. The FS report acknowledged the problems associated with
installing a soil vapor extraction in municipal refuse. Both the FS report
and the Proposed Plan acknowledge the need for predesign pilot testing
of a vapor extraction system to address those concerns. This step will be
necessary before an effective vapor extraction system can be designed and
implemented.
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5. Comment: page 37, paragraph 4: BIEC claims that the quantity of
VOCs in the unsaturated zone is too high.
U.S. EPA Response: Alternative D4 includes dewatering wells to lower
the water table beneath the Liquid Disposal Area. This allows the vapor
extraction system to remove VOCs in the existing unsaturated zone as
well as those adsorbed on the aquifer matrix. As a result, the estimate of
VOC mass removed included samples from the unsaturated zone and the
zone to be dewatered. The removal of one pore volume during
dewatering will remove a portion of the contaminant mass adsorbed on
the aquifer matrix, but much of the mass will likely remain. EPA also
notes that actual VOC mass removed may be substantially more than
estimates based on laboratory analysis of soil samples.
6. Comment, page 39, paragraph 1: The FS did not adequately address the
required dewatering system, nor did it consider the time required to
achieve drawdown of 10 feet with the proposed pumping rates. To
achieve this drawdown in a reasonable time (60 days), the six wells would
have to be pumped at a combined rate of 150 to 180 gpm.
U.S. EPA Response: In calculation of drawdown and time required to
achieve it, the BIEC used the site average hydraulic conductivity for the
upper aquifer of 9.7 x 103 cm/s instead of the value measured at
monitoring well CH09 (1.07 x 10"J cm/s), which is located nearest the
Liquid Disposal Area. This is a difference of nearly one order of
magnitude. While it is acknowledged that it will take approximately
1 year to develop the cone of depression depicted in Figure D-3 of the
FS report, it should also be noted that suitable dewatering to begin vapor
extraction is estimated to be accomplished within 30 days. Using the
value of hydraulic conductivity measured at CH09, a drawdown of
approximately 9 feet can be accomplished in approximately 30 days, at a
distance of 100 feet from the pumping center. This distance encompasses
the entire Liquid Disposal Area.
7. Comment, page 39, paragraph 2: BIEC states the EPA proposed vapor
extraction rate of 3,000 cfm does not take the landfill contents into
account and that it would probably turn the interior of the landfill from
an anaerobic to an aerobic environment resulting in the risk of a landfill
fire.
U.S. EPA Response: The EPA did not propose a vapor extraction rate
of 3,000 cfm. That blower rate was used only to develop the order-of-
magnitude cost estimate. As stated in the FS report, the vapor extraction
rate will be determined during pilot testing. It will take into consideration
the effect on microbial activity and waste temperatures.
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8. Comments, page 40, Items ii and iii: BIEC refutes the EPA's alleged
proposed design of the vapor extraction system. They state that vapor
extraction could be accomplished with fewer extraction wells, and should
be operated at lower VOC removal rates, thereby increasing the
operating time.
U.S. EPA Response: The quantities stated in the FS report were only
for the purpose of estimating costs and were not intended as design
elements. Quantities, materials, and configuration of the vapor extraction
system and the monitoring system must be developed during design based
on results of pilot testing. The period of operation will be reevaluated
based on pilot tests and would be a factor in determining the
effectiveness of vapor extraction.
9. Comment, page 40, paragraph 4: BIEC states that its proposed
alternative remedy of soil flushing and groundwater capture would
effectively remove VOCs from the Liquid Disposal Area.
U.S. EPA Response: Because of the lack of information presented in the
BIEC proposal with respect to a soil flushing system, it is the EPA's
opinion that BIEC fails to substantiate its point. The BIEC plan refers to
a passive soil flushing system consisting of percolation through the single-
barrier cap and subsequent collection through the groundwater extraction
system. This passive soil flushing system is not an acceptable treatment
alternative. Vapor extraction with pilot testing was selected in the ROD;
however, if the pilot test is not successful, active soil flushing would be an
acceptable treatment alternative for the Liquid Disposal Area.
10. Comment, page 40, paragraph 5, and page 41: BIEC states that one
extraction well pumping at a rate of 15 gpm for 10 years at the eastern
end of the Liquid Disposal Area would be sufficient to remove
90 percent of the VOCs in the Liquid Disposal Area.
U.S. EPA Response: BIEC's proposed plan does not accomplish the
same objectives as the vapor extraction system and dewatering techniques
outlined in the FS. It does not address the source of contaminants in the
unsaturated zone. Without remediation of the unsaturated zone source,
continued release of VOCs to the aquifer is likely, causing continued
contamination of the aquifer.
In BIEC's proposal, the mean value of hydraulic conductivity for the
upper aquifer across the site was used and not the measured value at
monitoring well CH09, located approximately 100 feet east of the Liquid
Disposal Area, which is a more appropriate value. Pumping a single well
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at 15 gpm»_in an aquifer with material exhibiting a hydraulic conductivity
1.07 x 10"J cm/s as measured at CH09 would cause the well to dewater
completely in less than 45 minutes. As a result, the EPA does not agree
that one well could create a capture zone large enough to control
groundwater flow in the Liquid Disposal Area or produce enough to
achieve a 90 percent contaminant reduction after 10 years as proposed.
The actual number of wells and pumping rate must be determined during
design.
11. Comment, page 42, paragraph 1: BIEC requests that the U.S. EPA
adopt its proposed method of remediation for the Liquid Disposal Area.
U.S. EPA Response: For reasons previously mentioned, the EPA cannot
accept BIEC's proposed plan for remediation of the Liquid Disposal
Area. We summarize our position as follows:
o Information collected during the RI demonstrates unacceptable
concentrations of VOCs in the unsaturated zone of the Liquid
Disposal Area. It is the EPA's intent to reduce the mass (and
consequently the mobility) of VOCs to reduce possible future
recontamination of the aquifer. The EPA has selected vapor
extraction, a proven, effective technology, as the method to achieve
that objective. The EPA acknowledges BIEC's concerns relative to
subterranean landfill fires that could develop during vapor
extraction. Recognizing this concern, the EPA proposes pilot
testing to evaluate the effectiveness of the system and to determine
the design operating conditions.
o BIEC does not provide sufficient information on soil flushing as an
acceptable alternative to reduce the volume of VOCs in the
unsaturated zone. The EPA believes vapor extraction is more
appropriate.
o BIEC used an inappropriate value of hydraulic conductivity when
calculating the drawdown from its single pumping well and
proposes a system too small to achieve its stated goal. However,
the EPA recognizes that the number of wells and flow rates must
be determined during the design.
Section 9.0-Groundwater Operable Unit
1. Comment, page 43, paragraph 2: BIEC states that the FS report lists
Alternative D5-Incineration, Groundwater Pumping and Treatment,
Capping-as an alternative addressing groundwater contamination.
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U.S. EPA .Response: It appears that information in the FS report has
been misinterpreted. In the FS report, the Liquid Disposal Area and the
groundwater were treated as a single operable unit. In Alternative D5
incineration was applied to the contents of the Liquid Disposal Area but
not the groundwater, which would be collected and treated through other
means. BIEC, in its comments, has elected to separate the Liquid
Disposal Area and groundwater into two operable units and to address
each individually.
2. Comment, page 44, paragraph 2: BIEC states the EPA's conceptual
design criteria of minimizing aquifer drawdown to maximize aquifer
remediation is inappropriate, and dewatering the upper aquifer will not
significantly reduce the effects of remediation because the area of VOCs
attenuated on the aquifer matrix is small.
U.S. EPA Response: Minimization of drawdown to maximize aquifer
remediation is an appropriate design criterion. The EPA's concern is that
the proposed BIEC plan of rapidly dewatering the upper aquifer,
particularly in the area of the Liquid Disposal Area, could result in
unacceptable quantities of VOCs remaining adsorbed in the aquifer
matrix after remediation has met cleanup criteria. These remaining
constituents could serve as a continuing source of aquifer contamination.
Before accepting such an aquifer remediation plan, BIEC must
demonstrate to the EPA's satisfaction that the plan is capable of
achieving the cleanup criteria. Also, if drawdown is not minimized,
groundwater monitoring would be necessary for a longer period of time
after cleanup criteria are met to determine if desorption from the
dewatered aquifer matrix will cause cleanup criteria to be exceeded.
3. Comment, page 45, paragraph 1: BIEC states that offsite extraction wells
are not required because groundwater that discharges to the Miami River
will not affect surface water quality and that pumping close to the river
will result in induced infiltration to the detriment of the system.
U.S. EPA Response: It is the intent of SARA and EPA's position to
reduce the toxicity and volume of contaminants in the groundwater. The
Great Miami Valley Fill Aquifer has been designated a sole source
aquifer in that it is the only source of drinking water to neighboring
residents and communities. The EPA cannot permit the aquifer to
remain contaminated regardless of the related effects on surface water
quality.
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4. Comment, page 45, paragraph 2: BIEC again questions the low pumping
rates assumed in the FS report and the EPA's concern for minimizing
drawdown and describes what it considers to be a more appropriate
alternative.
U.S. EPA Response: Minimization of drawdown, particularly in the
central and western portions of the site that are being remediated, is a
legitimate concern. Quickly dewatering a highly contaminated portion of
the aquifer can cause contaminants to be left behind on the soil matrix,
only to recontaminate the aquifer once the wells are shut down and the
water levels in the aquifer recover. Drawdown achieved in the extraction
wells in the upper aquifer at the site boundary, taking into account
recharge, effects from other upper aquifer wells, and effects from lower
aquifer wells, is approximately 3 feet. This was calculated using the
hydraulic conductivity value (6.01 x 10"* cm/s) obtained from piezometer
P-5, which is located nearby, and not the site mean hydraulic conductivity
(9.7 x 10"J cm/s) that BIEC prefers to use. The self-induced drawdown of
. an upper aquifer well, pumping at 10 gpm, assuming no recharge, and
assuming a site mean hydraulic conductivity (as the BIEC proposed), is
great enough to cause that well to completely dewater in approximately
1 hour. Combined with the drawdown induced by other upper aquifer
and lower aquifer wells, it would frequently be necessary to shut down the
system to allow it to recharge.
The EPA recognizes that the FS is not a design. The final number of
extraction wells and the pumping rates will be determined during the
remedial design.
5. Comment, page 46, paragraph 3: BIEC states that its proposed system
will result in a shorter cleanup period than the EPA's proposed method
but cannot directly compare the two because the FS report does not
present the pore volumes used. BIEC also claims it cannot back
calculate pore volumes because pumping rates presented on page D-3 do
not match those on page D-7.
U.S. EPA Response: The exact length of the cleanup period cannot be
determined at this time. The cleanup period required will be a function
of the final design and the cleanup criteria to be established. Therefore,
the EPA feels that BIEC is premature in its conclusion that its proposed
scheme will clean up the aquifer faster than the system presented in the
FS report.
The EPA acknowledges that the number of pore volumes used were not
presented in the FS report but sees no reason why BIEC cannot back
calculate the pore volumes from the data presented in Appendix D of the
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FS report^. Page D-3 of the FS report states a total withdrawal of
12 gpm from the upper aquifer and 60 gpm from the lower aquifer. On
page D-7, in calculating cleanup periods, it is stated that 7 gpm is
withdrawn from the upper aquifer and 27.5 gpm from the lower aquifer,
west of County Highway 25-A. East of County Highway 25-A, a total of
35.5 gpm is withdrawn from both aquifers. The 35.5 gpm can be broken
into a withdrawal of 5 gpm from the upper aquifer and 30.5 gpm from
the lower aquifer. This reflects a total withdrawal of 12 gpm from the
upper aquifer and 58 gpm from the lower aquifer (rounded to 60 gpm).
6. Comment, page 47, paragraph 1: Based on its analysis, BIEC requests
that the U.S. EPA adopt its proposed groundwater extraction system as
the remedy for its groundwater operable unit.
U.S. EPA Response: BIEC's analysis is insufficient to warrant acceptance
of its proposed plan as presented. The final extraction system will need
to be determined in the design. Again, the numbers of wells and
extraction rates presented in the FS report were developed to prepare
order-of-magnitude cost estimates. The groundwater extraction system
presented in the FS report was never intended as the EPA's final design.
The appropriate system will be developed in the design stage and may
require additional field investigations.
Section 10.0-Groundwater Treatment
1. Comment, page 48, paragraph 1: BIEC disputes the EPA's assertion that
physical-chemical pretreatment of groundwater before air stripping will be
temporary. BIEC states that such treatment will likely be needed over
the life of the extraction system.
U.S. EPA Response: The EPA has concluded that pretreatment would
probably not be necessary over the life of the extraction system on the
basis of low BOD5, suspended solids, and inorganic constituent
concentrations anticipated for the extracted groundwater. Routine
maintenance cost estimates for the air stripper included acid washing to
remove precipitated solids and chlorination to control biological growth.
However, the need for permanent pretreatment will be reconsidered
during the design if onsite treatment of groundwater is required.
2. Comment, pages 48 to 50: As an alternative to onsite treatment BIEC
proposes that the Troy POTW be used to treat the extracted
groundwater.
U.S. EPA Response: The EPA does not object to BIEC's proposed
treatment alternative providing BIEC can, over the life of the remedial
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action, demonstrate to the EPA's satisfaction that the Troy POTW can
accept the quantity and quality of extracted groundwater and continue to
meet all federal, state, and local regulations regarding acceptance,
treatment, and discharge of wastewater (and resultant residuals).
Section ll.Q-Summarv of ElEC Plan
1. Comment, page 51, subsection 11.1: BIEC states that its proposed plan is
fully protective of human health, consistent with the NCP and CERCLA
as amended by SARA, and cost-effective. BIEC also states that its plan
closely parallels the EPA's but differs in that BIEC proposes more
reliable and cost-effective technologies.
U.S. EPA Response: The EPA recognizes that BIEC's plan has many
similar items to its own Proposed Plan. However, the EPA believes
BIEC's plan is deficient in several areas as discussed throughout this
Responsiveness Summary.
2. Comment, page 53, subsection 11.2: BIEC proposes a perimeter fence to
prevent direct access to the site and deed restrictions to control potential
future development of the site.
U.S. EPA Response: This is consistent with the final remedy in the
ROD.
3. Comment, page 53, subsection 11.3: An alternative water supply has
been or will be provided to the affected properties downgradient of the
site.
U.S. EPA Response: This is consistent with the final remedy in the
ROD.
4. Comment, page 53, subsection 11.4: A single-barrier cap should be
provided for the South Landfill.
U.S. EPA Response: Please see the response to BIEC comments in
Section 4.0.
5. Comment, page 54, subsection 11.5: BIEC proposes a single-barrier cap
for the North Landfill.
U.S. EPA Response: Please see our responses to BIEC comments in
Section 5.0.
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6. Comment, pages 54 to 55, subsection 11.6: BIEC presents its proposed
remedy for the Ash Disposal Pit and Ash Pile Operable Unit.
U.S. EPA Response: Please see our responses to BIEC comments in
Section 6.0.
7. Comment, page 55, subsection 11.7: BIEC presents its proposed remedy
for its Scrubber Wastewater Lagoon and Stained Soil Area Operable
Unit.
U.S. EPA Response: Please see our responses to BIEC comments in
Section 7.0.
3. Comment, page 55, subsection 11.8: BIEC presents its proposed remedy
for the Liquid Disposal Area.
U.S. EPA Response: Please see our responses to BIEC comments in
Section 8.0.
9. Comment, page 56, subsection 11.9: BIEC. presents its proposed remedy
for its groundwater operable unit.
U.S. EPA Response: Please see our responses to BIEC comments in
Section 9.0.
10. Comment, page 56, subsection 11.10: BIEC proposes treatment of
extracted groundwater at the Troy POTW instead of onsite treatment.
U.S. EPA Response: Please see our responses to BIEC comment 2
Section 10.0.
11. Comment, pages 57 to 64, subsection 11.12: BIEC presents an
"effectiveness monitoring program" for its proposed remedial action
program.
U.S. EPA Response: The EPA appreciates the efforts BIEC has taken
to present its proposed long-term monitoring plan. The EPA considers
this a design issue and will reserve its final judgment on any monitoring
plan until that time.
12. Comment, subsection 11.14: BIEC presents a contingency plan to be
followed should monitoring indicate the system is not operating as
planned or should other developments occur that would compromise the
effectiveness of the system.
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U.S. EPA Response: Again, the EPA appreciates BIEC's efforts at this
stage, but will reserve additional comments until later.
COMMENTS FROM THE PUBLIC MEETING
Technical Questions/Concerns Regarding Remedial Alternatives
1. Comment: Mr. Huffman's question was about the southerly flow of
groundwater and contaminants. He was concerned that, while under
normal flow conditions in the Great Miami River groundwater and
contaminants are capable of flowing approximately three-quarters of a
mile prior to discharge into the river, during high flow conditions the
southerly flow of contaminants would extend further south and
contaminate additional residential wells.
U.S. EPA Response: It is true that during high flow conditions the
southerly component of flow in the groundwater is increased, but it is also
true that during low flow conditions the southerly component to flow is
decreased. That is why the normal flow conditions were used: they
represent the long-term process that is occurring. Flow of groundwater
and contaminants at the site is governed by the hydraulic conductivity of
the aquifer material and the hydraulic gradient measured across the
aquifer. Assuming the hydraulic conductivity in the aquifer is fairly
constant, the gradients will have the greatest effect on the flow of
contaminants. Gradients across the site range from 0.002 to 0.003 ft/ft
(1 foot per 333 feet to 1 foot per 500 feet) and are governed generally by
recharge west of the site. Gradients in the aquifer below and nearest the
Great Miami River are governed by the gradient of the river,
approximately 1 foot per 1,500 feet or three to four times less than that
of groundwater at the site.
Although the gradient in the river is not constant, it is fairly stable and
likely to decrease during high flow conditions. This means that
contaminants move in the aquifer from the site to the river three to four
times faster than they are able to move in the aquifer once they get to
the river. Using a gradient of 1 foot per 1,500 feet and the average
hydraulic conductivity for the site, groundwater flow velocities range from
30 to 40 feet per year under the river. Given such a low velocity,
seasonal fluctuations in flow direction have only a very minor effect on
the movement of the contaminants. The timely changes in the movement
of contamination can be seen by comparing residential well data obtained
in November 1984 and May 1985 with those collected by the Ohio EPA
in October 1988, a 3-year span. These comparisons show that the
contaminant distribution south of the site has changed very little, and, in
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fact, many contaminant concentrations have decreased to the south of the
site during this 3-year period.
2. Comment: Mr. Pence asked how many gallons or barrels of waste were
disposed of in the North Landfill. He also wondered what knowledge the
EPA has regarding the generators of those wastes.
U.S. EPA Response: Refer to the response to comment 2 for the BIEC
letter dated April 26 for a discussion of the quantity of waste disposed in
the landfills. As mentioned at the public meeting, the EPA has a list of
tentatively identified responsible parties and is seeking information about
parties who may have left industrial waste liquids at the site.
3. Comment: Mr. Brown asked the cost of the proposed alternatives.
U.S. EPA Response: The total present worth of proposed
Alternatives A3, B4, C4, and D4 is $21.9 million, and the total estimated
capital cost is S15.6 million. Cost estimates are presented in the FS
report under each of the different alternatives.
4. Comment: Mr. Brown also asked if the people of Troy could be given
more than 60 days to respond to the EPA.
U.S. EPA Response: The EPA is following a procedure set forth in
Section 122(e) of CERCLA that specifies a 60-day time period for the
PRPs to submit a proposal to the EPA to conduct or finance the
remedial activities.
Remedial Alternative Preferences
1. Comment: Mr. Carlton (speaking for BIEC) summarized BIEC's
preferred alternatives and highlighted their differences from the EPA's
Proposed Plan.
U.S. EPA Response: The EPA has carefully considered the preference
of the BIEC in deciding on final remedy described in the ROD.
2. Comment: Representatives from the following local governmental
agencies presented resolutions endorsing BIEC's plan:
City of Piqua, William Cruse. Mayor
City of Troy, Doug Campbell. Mayor
Miami County Commission. Don Hart, Chairman
Tipp City, Jess Chamberlain, City Council member
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U.S. EPA Response: The EPA recognizes the support of these local
governments for the BIEC plan.
3. Comment: The following citizens expressed their support for the BIEC
plan:
Roy Carlson, Troy Chamber of Commerce
Robb Howell, Hobart Brothers
Jim Rasback, Hobart Brothers
Art Haddad, City of Troy
Rex McClure, Miami Industries
Greg Horn, Tipp City Manager
Larry Baker, Piqua Chamber of Commerce
Richard Adams, Upper Valley Joint Vocational
School District
Bill Lukens, Stillwater Technologies
Keith Roeth, Edison State Community College
U.S. EPA Response: The EPA acknowledges the support for the BIEC
plan.
OTHER WRITTEN COMMENTS RECEIVED
1. Comment: Resolutions were submitted on behalf of BIEC by:
Bethel Township
City of Tipp City
Miami County and Troy City Boards of Health
Miami County Council
Newton Township
Piqua Area Chamber of Commerce
Troy Area Chamber of Commerce
Union Township Board of Trustees
Village of Bradford
Village of Covington
Village of Ludlow Falls
Village of Pleasant Hill
Washington Township
U.S. EPA Response: The EPA appreciates tne efforts made on the
behalf of BIEC.
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2. Comment:_ Written comments in support of the actions proposed by
BIEC were received by the following residents, businesses, and industries:
Dr. R. N. Adams, Upper Valley Joint Vocational
School District
David L. Ault, Star Bank
Roy Baker, B-K Photo Products Company
Erich Borden
John P. Coleman, The Ohio Municipal League
John L. Dillon, French Oil Mill Machinery Company
W. McGregor Dixon Jr., City of Troy
James H. Dotson, French Oil Mill Machinery Company
William B. Eckstein
Thomas L. Elberson, Dinner Bells Foods, Inc.
R.J.M. Fisher, PMI Food Equipment Group
Dick Force, Jackson Tube Service, Inc.
Daniel P. French, French Oil Mill Machinery
Company
John G. Grubb, Upper Valley Medical Center
Arthur D. Haddad, City of Troy
James R. Hartzell, Hartzell Industries, Inc.
Randall Hefelfinger
William H. Hobart, Hobart Brothers Company
Robb F. Howell, Hobart Brothers Company
John Hunt, Jackson Tube Service, Inc.
Charles F. Jacobs, RT Industries
William H. Kadel, The Fifth Third Bank of
Miami Valley
Ray L. Loffer
Donald E. Lukens, Member of Congress,
House of Representatives
Rex A. McClure, Miami Industries
Fred Meitz, American Plasma Tech
Norman Osting, Stanton Township Trustees
Aaron B. Parker, Friendly Ice Cream Corporation
Ernest F. Schaub, B.F. Goodrich Aerospace
John Suber, Ebberts Field Seeds, Inc.
Wilbur Sussman, Sussman, Inc.
James D. Utrecht, Shipman, Utrecht, and Dixon
Company, L.P.A.
U.S. EPA Response: The EPA has taken the widespread support for the
BIEC plan into consideration in selecting the final remedy described in
the ROD.
28
-------
3. Comment: __The following people submitted written comments that
claimed their inclusion in the list of PRPs was mistaken and stated that
they were opposed to the PRP steering committee's (BIEC's) allocation of
responsibility:
Richard E. Pence, Pence Refuse Service
Council of the Village of Pleasant Hill
Thomas L. Elberson, Dinner Bell Foods, Inc.
Theodore A. Boggs, Attorney for the Village of
Covington
U.S. EPA Response: As one of the commentators explained, "The
CERCLA regulatory scheme is designed so that those responsible for the
creation of hazardous sites will be required to pay for the resulting
remedial response activities." CERCLA holds four categories of PRPs
jointly and severally liable for toxic-material site cleanup costs: owners
and operators of the site, owners and operators when the site received
hazardous substance, those who produced and disposed of the hazardous
substances, and transporters of the hazardous substances.
The definition of "hazardous substance" contained in CERCLA Section
101(14) is very broad and requires only that a substance be designated as
hazardous or toxic under one of several federal statutes. Further, if a
waste material contains any hazardous substances, then the waste material
is itself a hazardous substance under CERCLA The quantity or
concentration of the hazardous substance within the waste material is
irrelevant to its hazardous substance designation.
Unfortunately, it is unusual if not exceptional for municipally operated
waste disposal operations to keep careful records concerning the disposal
of materials containing hazardous substances. The weight tickets removed
from the site are a primary source of information about the parties and
nature of the wastes at the Miami County Incinerator site. Other sources
of information linking PRPs with the site include various Miami County
records, studies of municipal solid waste composition, and, of course,
information obtained through CERCLA Section 104(e) information
requests.
Generally, PRPs prefer to develop a rationale for allocation of cleanup
costs through the steering committee associated with the site rather than
rely upon the U.S. EPA's assignment of liability. The basis for the
allocation is usually worked out between the steering committee and other
PRPs. At this site, the amount of hazardous substances contributed by
individual PRPs may be difficult to ascertain because of the limited
information provided by the site records. A consistent feature of the
29
-------
Miami County records is the disposal costs stated on the weight tickets.
The PR? steering committee may have proposed this method of
allocation, in part, because determining the toxicity or exact amounts of
hazardous substances individual parties disposed of may be not possible
because of the nature of the site records. Therefore, any other method
of allocation might be no more equitable than the present allocation
system the BIEC recommends.
4. Comment: Mr. Pence's letter also mentioned he was informed that "the
County had the ash pit [i.e., the Scrubber Wastewater Lagoon] cleaned
out and dug it too deep, and tore the foot clay barrier out the bottom.
One week later the well at the County Garage went bad."
U.S. EPA Response: Historic documentation also supports the above
claim that "while working on a settling lagoon the seal was broken; this
eventually contaminated the incinerator well" (Brookhart, et al. 1976). As
mentioned in the Proposed Plan, the Scrubber Wastewater Lagoon area
will be tested during the remedial design activities to select a course of
action to protect public health and the environment.
5. Comment: Keith L Roeth expressed the need for prompt action.
U.S. EPA Response: Pending the signing of a Consent Decree or the
availability of federal funding, predesign and design activities will begin
immediately.
6. Comment: Gary Wick expressed a concern with allowing the BIEC to
perform the cleanup because many members of the BIEC are potentially
responsible parties.
U.S. EPA Response: Section 122(a) of CERCLA authorizes the EPA to
enter into an agreement with any person, including any potentially
responsible person, to perform any response action provided that the
PRPs commit to such actions in a consent decree. The EPA encourages
PRPs to conduct the response actions. The EPA will, however, provide
review and oversight of such actions in accordance with Section 104(a)(l)
of CERCLA.
7. Comment: One anonymous commentator expressed the desire for the
EPA to test groundwater near a former open landfill located at 10315
North Springcreek Road near Piqua because of the high incidence of
cancer deaths in the neighborhood near the former dump.
U.S. EPA Response: U.S. EPA acknowledges the citizen's concerns, but
this comment is not relevant to the RI/FS or Proposed Plan for the
30
-------
Miami County Incinerator site. This matter has been referred to the
Miami County Health Department.
COMMENTS FROM OHIO EPA
Comments from Ohio EPA were received in a letter dated April 4, 1989, and
have been grouped by issues to facilitate response to them in this document.
The reader is referred to the actual comments in the Administrative Record.
RI Data Evaluation
1. Comment: "Determination of background values for inorganics in
groundwater (and for that matter, background values for soils) based on
the upper 99.9% confidence interval of the mean is very misleading. For
example, several monitoring wells which contain contaminated
groundwater have values of specific conductance which are below
'background.' Background would be more appropriately established by
using water quality data from monitoring wells located hydraulically
upgradient of the site."
U.S. EPA Response: Groundwater inorganic background concentrations
were derived from wells located hydraulically upgradient of the site. As
stated on page 5-13 of the RI report, "Background inorganic
concentrations were determined using Phase I and Phase II RI results
from upgradient monitoring wells MW01A, MW02A, and CH17A in the
upper aquifer and MW01C and MW02C in the lower aquifer."
The U.S. EPA acknowledges that there are various approaches to
determining background concentrations for inorganic chemicals. We
consider the approach taken (calculating the upper 99.9 percent
confidence limit to the mean concentration for each constituent) an
effective method for indicating the nature and extent soil or groundwater
inorganic contamination. As stated in Appendix J of the RI report, 'The
final determination of acceptable inorganic concentrations is based on
health effects as well as on background concentrations. Thus, the
99.9 percent confidence interval is used only in evaluating whether the
presence of chemicals is a result of site activities and not as a final
determination of acceptable concentrations."
The U.S. EPA disagrees with the comment that implies that the
determination of background concentrations is misleading because
contaminated wells have specific conductance below background
concentrations. Specific conductance indicates the presence of charged
ionic species in solution, such as magnesium, calcium, iron, aluminum,
potassium, bicarbonate, sulfate, and so on. These particular constituents
31
-------
were not presented in Figures 5-18 and 5-19 in the RI report because
they are not indicative of health effects. Specific conductance provides an
indication of total ion concentration and was presented to provide
supplemental information with respect to water quality. It is incorrect to
relate specific conductance to only a few of the ionic species detected in
the groundwater.
The selection of soil samples used to derive background concentrations of
inorganic chemicals is described on page 5-1 of the RI report. Although
soil samples were collected from locations hydraulically downgradient from
the Liquid Disposal Area, most were collected from the unsaturated zone
and located away from known or suspected waste disposal areas.
Therefore, no influence of waste disposal on soil inorganic chemistry
should occur. This approach is considered valid and adequate to meet
the objectives of the RI, namely site characterization.
2. Comment: Ohio EPA believes that since the proposed remediation of
the Ash Pile, Ash Disposal Pit, and possibly the Scrubber Wastewater
Lagoon would involve the excavation and consolidation of surface and
near-surface soils, background concentrations for inorganic chemicals in
those soils would be more appropriately determined by surface and near-
surface soils in areas unaffected by site activities. "The RI lumped soils
together from a wide range of depths and soil horizons to determine
background concentrations. Ohio EPA feels it is inappropriate to
determine background concentrations in this manner, and therefore,
additional surface and near-surface soil sampling during predesign is
warranted."
U.S. EPA Response: The determination of background inorganic soil
concentrations is used to assess the relative nature and extent of
contamination. The determination of background as calculated in the RI
adequately serves as a measure for the comparison and evaluation of soil
data. U.S. EPA acknowledges that additional sampling will be necessary
to define the extent of removal.
3. Comment: Ohio EPA questioned why water level measurements were
not obtained from wells CH08A and CH08B on April 18, 1988, and
requested an explanation for an earlier water level measurement of
828.96 feet, which is below the bottom of the well screen at 829.23 feet.
U.S. EPA Response: Clarification with regard to this comment was
inadvertently omitted from the RI report. No water level measurements
were obtained at CH08A because the well was dry at the time of
sampling. At CH08B, complications with the lock on the protective
casing prevented obtaining a water level measurement. Monitoring well
32
-------
CHOSA^as constructed with a 3- to 4-inch end cap on the bottom of the
well screen, as were most of the wells installed at the incinerator site.
The water measured in CH08A on October 19, 1987, is believed to have
been trapped in the end cap and, thus, not reflective of the actual water
table.
4. Comment: Ohio EPA states that groundwater flow in the upper aquifer
during flood conditions is to the southwest, and not "southerly," as stated
on page 1-5 of the FS report and illustrated in Figure 4-7 in the RI
report.
U.S. EPA Response: Figure 4-7 in the RI report is a hydrogeologic cross
section that does not indicate groundwater flow direction. Figure 4-14
presents water level contours for the upper aquifer based on data
obtained in November 1985 during flood conditions. As seen on
Figure 4-14, the flow direction changes under flood conditions and flows
in a southwesterly direction from the river toward the site. Flow direction
changes back to the east and southeast after flood stages subside.
Endangerment Assessment
1. Comment: Ohio EPA expressed concern that Figures 7-4 and 7-5 "do not
give a complete picture of carcinogenic risks for exposure to groundwater
since they do not include a summation of the excess lifetime cancer risks
for inhalation and ingestion. These maps, aside from being inconsistent
with Figures 2-1 and 2-2 of the feasibility study, are also inconsistent with
USEPA's own risk assessment guidance and directives which call for,
among other things, the summation of risks across exposure routes."
U.S. EPA Response: The two figures are intended to illustrate the risks
associated with groundwater ingestion. They are labeled as a summary of
ingestion risk and not a summary of total risk. Inhalation risks are
presented in the text and may be summed with the ingestion risk.
Combined risks for the various exposure settings are presented on
Table 7-19. These figures are not inconsistent with the FS figures, they
merely illustrate somewhat different issues.
2. Comment: Ohio EPA feels that Table 7-17 is misleading because it
provides what appear to be acceptable levels of chemicals that could be
left in soils at the site. "While target concentrations may be useful for
the identification of 'hot spots', they should not be used as cleanup goals."
U.S. EPA Response: The intent of the table, as stated in both the text
and the table, was to illustrate health-based target concentrations for
33
-------
single chemicals in a single media as a way of indicating "hot spots." The
values presented are not cleanup goals.
3. Comment: Table 1-27 of the draft and RI report, entitled "Well
MW03C~Comparison of Daily Intakes to RfDs," should have been
included in the final RI report.
U.S. EPA Response: The table was inadvertently excluded from the final
report and is included in Attachment A.
4. Comment: Tables I-88B and I-89B, "Comparison of Daily Intakes to
RfDs for the North Landfill Excluding Ash Pile" and "Comparison of
Daily Intakes the RfDs for the Liquid Disposal Area," should also have
been included in the final RI report.
U.S. EPA Response: The tables were inadvertently excluded from the
final report and are included in Attachment A.
Remedial Alternative Preferences
1. Comment, FS report, page 2-4: Ohio EPA states that the remedial action
objectives for the Liquid Disposal Area to minimize further contaminant
migration from the soil or wastes to a drinking water aquifer should not
be to solely prevent the degradation of groundwater to levels exceeding
Maximum Contaminant Levels (MCLs). Emphasis should be on
preventing degradation beyond levels sufficiently protective of human
health and the environment.
U.S. EPA Response: The U.S. EPA has not restricted the remedial
objectives to attainment of MCLs, but has specified MCLs in one of the
several Liquid Disposal Area objectives because MCLs are an enforceable
standard for drinking water aquifers. The EPA believes that the remedial
action objectives for both the Liquid Disposal Area and the groundwater
adequately address the reviewer's concern for the protection of human
health and the environment.
2. Comment: Several comments from Ohio EPA state that cleanup of
groundwater to levels more stringent than MCLs is warranted and that
cleanup of groundwater should be to background, to MCLGs, or to a
1 x 10'6 lifetime cancer risk level.
U.S. EPA Response: The U.S. EPA acknowledged these comments and
took them into consideration in establishing the cleanup goals described in
the ROD. The EPA would like to clarify that cleanup goals were not set
in the FS report, as implied by some of Ohio EPA's comments. The area
34
-------
targeted for groundwater remediation was defined as the area where
groundwater contaminant concentrations exceeded MCLs, but that should
not be interpreted as the cleanup criteria for the extracted groundwater.
Similarly, calculations based on a 90 percent contaminant reduction of
selected compounds were used to estimate the length of time required to
remediate the aquifer system. This was done for comparison of
alternatives and was not intended to suggest that MCLs are the cleanup
criteria.
3. Comment: Ohio EPA stated with respect to Table A-2 in the FS report
that it is misleading to use "target" concentrations for determining cleanup
levels for soil "because they do not take into account exposures from
multiple chemicals or multiple exposure routes. These target
concentrations also do not account for potential leaching of contaminants
from soils and their release into the groundwater."
U.S. EPA Response: The U.S. EPA acknowledges the comment and
would like to point out that, as the title of the table says, they are
"guidelines to be considered." The FS report does not establish the
concentrations as cleanup levels. The basis for the extent of soil removed
is addressed in the ROD.
4. Comment: Ohio EPA states that the Proposed Plan should specify the
cleanup levels for soils that will remain after wastes from the Ash Pile,
Ash Disposal Pit, and possibly the Scrubber Wastewater Lagoon area are
consolidated into the North Landfill.
U.S. EPA Response: The extent of soil removal is defined in the ROD.
It is the intent of EPA to protect human health and the environment.
5. Comment: Ohio EPA understands that for costing purposes the FS
assumed a passive landfill gas venting system, but feels a passive system
may not be sufficiently effective for venting landfill gases.
U.S. EPA Response: EPA recognizes this comment and notes that the
appropriateness of a passive or active landfill gas collection system will be
evaluated during predesign or design.
6. Comment: Ohio EPA does not feel that the groundwater monitoring
proposed on page B-7 of the FS report is adequate for a number of
reasons. "First, to establish baseline water quality in both aquifers, most
if not all of the monitoring wells, both on and off-site, will need to be
sampled and analyzed for TCL organics and inorganics including cyanide.
(Cyanide was never analyzed for in any site media during the RI.)
Second, with the need to monitor two aquifers under any selected
35
-------
alternative, the monitoring of only nine wells would appear to be grossly
inadequate to track plume movement, ensure capture, and measure
shrinkage of aquifer contaminant concentrations. Adequate groundwater
monitoring of the south landfill unit is also important since sampling of
soils from below the water table in borings adjacent to the south landfill
showed levels of toluene ranging from 65 ug/kg to 1600 ug/kg. This is a
strong evidence for indicating a release of organic contaminants to the
groundwater from the south landfill and emphasizes the need for
adequate groundwater monitoring. Third, Ohio EPA feels that due to the
lack of groundwater quality data in the area between the southern
property boundary and well clusters MW-03 and MW-06, additional wells
must be installed and sampled in this area."
U.S. EPA Response: As stated, the groundwater monitoring program
discussed was presented for cost estimating purposes. The monitoring
program is defined in the ROD and addresses Ohio EPA's concerns.
Editorial Remarks
1. Comment, FS Report, page 1-11, paragraph 1: Ohio EPA states that 11
residential wells and not 10 as stated in the FS report were sampled in
October 1988. The reviewer questions why the Miami County Health
Department was the reference for this information rather than the Ohio
EPA.
U.S. EPA Response: The data indicate that 12 samples were collected
from 11 different residential wells. One sample was a duplicate. The FS
report referenced the County Health Department because the EPA
contractor writing the FS initially received the information from that
agency.
2. Comment, FS report, page 1-12, paragraph 3: Ohio EPA states that the
results of the endangerment assessment indicate that the Ash Pile, Ash
Disposal Pit, Liquid Disposal Area, and groundwater are sufficiently
contaminated to present "actual risks" to the public as well as potential
risks.
U.S. EPA Response: As stated in Chapter 7 of the RI report, it is
necessary to make several assumptions (e.g., exposure concentrations,
exposure setting human intake, population characteristics, toxicity) to
estimate human health risk for carcinogenic and noncarcinogenic effects.
The risk assessment is subject to uncertainty with respect to estimating
risk and regarding the understanding of site conditions. Thus, "potential"
36
-------
is a more appropriate term than "actual" when referring to calculated risk
values.
3. Comment, FS report, page 1-12, paragraph 5: Compounds such as PCBs
and the pesticide dieldrin were also found in the sediment of the Eldean
Tributary in addition to polynuclear aromatic hydrocarbons (PAHs).
"Therefore, predesign sediment sampling should also include analysis for
pesticides and PCBs to determine if these compounds are attributable to
the site and could pose a risk to public health or the environment."
U.S. EPA Response: The comment is correct and recognized by EPA.
4. Comment, FS Report, page 2-5, paragraph 3: Trichloroethene was
detected in MW06A in rounds 1 and 2, not 1 and 3. Also, N-
nitrosodiphenylamine was detected in well MW03A during sampling
round 3.
U.S. EPA Response: The comment is correct and recognized by EPA.
5. Comment, FS report, page 2-6, paragraph 2: Figures 2-1 and 2-2 show
the excess lifetime cancer risks estimated for both ingestion and inhalation
of groundwater.
U.S. EPA Response: The comment is correct and recognized by EPA.
6. Comment, FS report, page 3-6, paragraph 1: The second to last sentence
mentions the "EPA guidance document" but does not name the document.
U.S. EPA Response: The reference "(U.S. EPA 1982)" should be added
to the second to last sentence.
7. Comment, FS report, page 3-20, paragraph 2: It is unclear what "Agency"
is being referred to in this sentence.
U.S. EPA Response: The word "Agency" refers to the U.S. EPA.
8. Comment, FS Report, page 4-2, paragraph 4: The last sentence is
unclear.
U.S. EPA Response: The word "overloaded" should read "reviewed."
9. Comment, FS report, Table A-1: The following chemicals were omitted
from the column "compounds detected in groundwater": 1,1-
dichloroethene (1,1-dichlorethylene), 1,2-dichloroethene, and 2-methyl
37
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10.
11.
naphthalene. The footnote stating that the SDWA MCLs indicated by an
asterisk are proposed values as of October 1986 is misleading since those
values have been promulgated as final standards.
U.S. EPA Response: The comment is correct and recognized by the
EPA.
Comment, FS report, Table A-2: This table is inconsistent with
Table 7-17 in the RI report with respect to carcinogenic risk levels for the
compounds bis(2-ethylhexyl)phthalate, chlordane, 1,1-dichloroethane,
dieldrin, and PCBs.
U.S. EPA Response: The inconsistencies are noted; Table 7-17 is correct.
Comment, FS report, Attachment B-l: A key to the unit quantity
symbols is requested.
U.S. EPA Response:
CF
CY
DY
EA
GAL
HR
KW
LB
cubic foot
cubic yard
day
each
gallon
hour
kilowatt
pound
LF = linear foot
LS = lump sum
MG = million gallons
MO = months
F = square foot
SY = square yard
YR = year
12. Comment, FS report page D-10: Figure D-5 was omitted from the report.
U.S. EPA Response: The reference in the text to Figure D-5 should
read "(refer to Figure 4-5)."
13. Comment, Proposed Plan, page 14: It is unclear what is considered to be
offsite in the statement that "VOC groundwater contamination offsite is
expected to be reduced by 90 percent or more within 15 years in the
upper aquifer and about 8 years in the lower aquifer."
U.S. EPA Response: The Proposed Plan and Table 5-8 of the FS report
need to be clarified. The pumping of the onsite downgradient wells (see
Figure 4-2) was estimated at about 15 years for the upper aquifer and
about 8 years for the lower aquifer. The offsite downgradient wells were
estimated to operate for about 5 years. As stated in the FS report,
estimates of time to achieve contaminant reductions are presented for
comparative purposes. They are based on many simplifying assumptions
38
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and, as a. result, actual times may be substantially different than those
presented.
REFERENCES
Board of Commissioners of Miami County, Ohio. Resolution Establishing Rules
and Regulations for Disposal of Solid Wastes in Miami County Garbage and
Refuse Disposal District Number 1, September 6, 1968.
N. Brookhart. Miami County, Ohio, Miami County Incinerator Cost Analysis,
March 25, 1970.
N. Brookhart, W. T. Burkhart, and J. L. Shoemaker. Memorandum from a
Miami County Incinerator general information meeting, September 20, 1976.
GLT883/013.50
39
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Attachment A
TABLES 1-27, I-88B. AND I-89B FOR THE
REMEDIAL INVESTIGATION REPORT
MIAMI COUNTY INCINERATOR SITE
TROY, OHIO
GLT883/014.50
-------
table i • 27
COMPARISON OF ESHMAIED DAIIY INIAKE IO REFERENCE DOSE
MONI1ORINC Mil JC: ROUND I
MIAMI COLINIV INCINERATOR SUE
a ingest ion:
Reference §st(mated Dal ly Exceed
Dose (RIO) Concent i allon intake (Di) Releience
Chemical ng/kg/day ug/l rag/kg/aay DI/RID Dose
BarlUM O.OS 130 0.0037 0.074 NO
Manganese 0.22 169 0.0048 0.022 NO
Methyiene Chloride 006 6.7 0.0002 o 001 NO
zinc 0.21 34 o.ooio o oos NO
Hazaid index (Sum ol DI/RID) 0.104
EXPOSURE ASSUMPTIONS
Exposure Setting Residential
Exposed individual Adult
waiei intake (iiteis/day) 2
Body weight (kllogiams) 70
a inhalation:
Releience (si(mated Dally Exceed
Dose (RID) Concentration intake (DI) Releience
Chemical mg/kg/day ug/l mg/kg/day DI/RID Dose
Meihylene Chioilde 0.06 b 6.7 0.0003 0005 NO
Hazaid index (Sum ol DI/RID) o.oos
EXPOSURE ASSUMPIIONS: Assumes inhaiai Ion exposures are 140* ol Ingest ion exposures.
a. Source': IRIS database (U.S. EPA 1988). nf A/HEED Quar tci iy update (U.S. EPA 1988);
or Super luno PtiDlic Health Evaluallon Manual (Sl'illw) (U s. (PA 1986).
b. NO Inlialailon exposure, based on luges MOM KID.
-------
table i aae
COMPARISON Or fSIIMAKD OAIIV INfAKi lORIIIRINCi DOS I (RIO)
SOU INCiSIICN - AOUI IRiSPASS
MIAMI COWIV INONIRAIOR SI If
AIM (excluding ash pile and liquid disposal a>M>
cneouai
•arluB
ClUOBlUB III
cmoBlua vi
copper
ie*d
Manganese
Mercury ulkyl>
Meicurv (inorganic)
Nickel
vanMiui (penioxide)
IIK
Muard index (SUB oi oi/*lo)
IXPOSUM ASSIMPIIONS
fiiposure selling
riooiad individual
soil miake (araM/dav>
aodv veloni ikiioorui)
• a
•el wenc*
MS* (BIO)
•g/ko/dav
o.os
i
0 DOS
O 017
0.0014
0 JJ
0 000]
0 OOJ
O O]
O OJ
0 11
Hlgnen
oeiaciad
concenirailon
ug/kg
10)000
S400O
S4000
laooo
1 10000
•41000
• M
aw
J7OOO
MOOO
M4000
ireipats
AdUII
O.I
70
(Slimed Mlly
imake (on
aa/kg/dav
0 000146
0 000077
0 000077
0 OOOOS4
0.000171
0 001 Ml
0 OOOOOI
0 OOOOOI
0 OOOO4J
O OOO04I
0 000414
01 /RIO
0 001
0 OOO
0 OIS
0 001
0 111
0 DOS
O 004
O OOI
0 001
0 001
0 001
0 IS»
fuoed
nereience
oose
NO
NO
NO
NO
NO
NO
NO
NO
NO
NO
NO
source: IRIS dau bate (us IP* i«aa>; WA/KIO ojjarieriv tixiaie (u s IPA i«aa>.
or stverlurd nt>nc HMIIH ivaiuiiion naruai ISFMM) 10 s. IPA i«a»>.
-------
i-MB
COMPARISON Of CSIIIMUO OAIIV INIAKi IO RHIRfNCf DOM (RIO)
SOU INttSIION - OHIO IRfSPASS
U>tMI CAMIV INC INI RAICH SI If
Noun AIM (excluding nn pile and nviid diipoui tiati
CTMICal
Mflua
chfOBlua in
cntoBluB vi
coppei
lead
Manganese
MBICUIV (alkyl)
H8KUIV (inotdtnio
Nickel
varvdlua (penioxldel
line
tmitia index CSUB of oi/RIO>
IXPOSURl ASSUIPIIONS
iKposu'e selling
luposed individual
son initkt (gti»/o»v)
•ody wlghi (kllogfuui
.
Mf of once
DOM (RIO)
•g/kg/dty
o.os
I
o.oos
0.017
0.0014
0.11
0 0001
o 001
0 01
0 01
O.ll
HIOHBII
oeiecied i
concentration
ug/ko
IOJOOO
I400O
S400O
uooo
120000
•41000
•M
•JO
17OOO
wooo
104000
iietMit
Oil Id
01
IS
illlMied oally
intake (on
•0/ko/dtv
o ooom
0 OOOIS4
O.OOOIS4
O OOOIOf
O OOO141
0 001401
O OOO001
O OOOOO1
O OOOIM
o ooooa*
o oooet*
OI/RIO
o oo*
o ooo
O Oil
o 001
O.14S
0 Oil
0 OO*
O OOI
0 DOS
O OO4
0.004
0 lit
fxceed
Reference
oote
NO
NO
M)
NO
NO
NO
HO
NO
NO
NO
NO
• . $OU(C« IRIS dilt M>» (U.S. IM IMII. HfA/HifO QMflOflV IDdtl* (US IP*. IM«):
or supcdum MMlc HMiih tvciuiiion MMIMI (sncni (us IPA
-------
APPENDIX C
ige Jo. 1
72
cns/mits PMIS om
rms
mmsmrm mono mm mm
mm coifirr miimm sirs
rm, OHO
MTROR mmssr
oocnur rm
oocmm
2 00/00/00 flesponse Co Reguest
for Inforiation.
1 00/00/00 Response Co Seguest
for Inforiation.
2 (6/10/28 Dipt, of ffealtn oas
approred plans for a
proposed iaciaentot
and facilicits for
crtaCKOC of Jigoid
NJCes ;eaerac«d froi
tie operacioo of tfte
iaeioeracor sodjecc to
listed conditions.
2 72/10/17 foticc tftit the laodfilj
areas at toe rear of toe
ioeioeracor are no lore
cian open doips at tie
tiie of toe iospeccioo.
/I refoest is lade for
tie jubiisjion of a
rricceo piaa of action
statin? toe counties
intention for op-jradiny
tne JandfiJ] operation.
j 72/12/01 flecoiieudation tnat toe
ffiaii Coootf ffealtn
District reiaio on the
list of approred solid
riite disposal prograis.
1 sonarr of findings
aad recoiiendacions is
inchded la this letter.
2 73/05/11 Haiti of the landfill
operation as proipted
Of a citizens coiplaiot.
An inspection deteriined
tnat tne conditions
coiplained aooot
continue to exist.
Also, tne aotnor states
tnat unless tne landfill
is designed and operated
ai an engineering plan
continoal pronleis coold
Caarles Bobatt-Sobart Cabinet ffSJPA Correspondence
Co.
S S H Construction Co. USIPA Correspondence
f.f Jrnold-Obio 0ept. of Kiati Co. Correspondence
ffealta Coiiissioners
0ept
CoJeaitb lie* Correspondence
Brootnart-ffiaii Co.
Jlicnard 5iiis-om
r.Bedcer-ffiaiiCo.Jre Correspondence
altnDe
ticnard Siis-OSf*
Orlef-HiaiiCo.fealt Correspondence
nOept.
-------
fagt la. 2
06/29/69 •
tmunm tms om
3 73/9S/11
Tint
bt expected.
lotiet of iiproreieots
tad corrections that
baft btea Hit it tbe
Hiaii Co. Solid fastt
Disposal Site. Sertral
suggestions art lade
tbat should farther
itprort tbt titt
conditions.
mono itm mm
coffirr ncmmm sir*
OHIO
AUTHOR
Charles torsthott-OSPA
ffiaii Co. Board of
Con.
rrpr
Correspondence
nocmm
3 75/02/2S
Coarles Oilef-ffiaii Co. Seal tn fioias foorpe
Coil.
X.Joe Soort-Om
I 73/19/15 Kgreeteat tbat Caere
appears to oe soie
contaijoatiofl in a
ditch aerosi froi
ietter reeipieots ooie
aad tbtf till iasptct
tbt area again in toe
tatare.
2 73/ll/H lotiet tbat tbt present
taste disposal practices
present ao 'eitreie
hazard to qrooadtater'
aad daipers last bt
iaforttd to find ao
alternate disposal
letnods.
4 73/12/10 Copies of lao analyses H.Jot Hoort-OKtA
01 veil saipJei collected
oa 10/31/11.
I 74/03/05 lotice tilt liquid tastes lict Irooltoart-Kiaii Co.
rill go Joajer 4e 5ao.*nj.
accepted
it tie liaii Cooatf
Incinerator.
Correspondence
Correspondence
Co.ffealtMept
Ozler-fiaii Correspondence
Co.ffeaitoDept
5ee serrice list Correspondence
lotice to recipient,
accoipanied of tie
latest landfill
inspection foris,
tnat Hiaii Co. tost
cease to accept tneir
liquid vaste laterial.
I.5rootnart-Xiaii
Co.5an.Jny.Dept.
Scnvabel-PalDecterf Correspondence
actinj
2 16/02/27 Listing of tie contents Coarles Craier-ffooart Bros. Xobert 8rota-OtP\ Correspondence
-------
Pigt Ho. 3
06/29/89
nus mi
I 76/03/12
I 76/93/29
2 76/05/2*
muismmt RSCOKB imi mm
mm comr mmum sm
TMJ, OJFIO
nrif
of tne autoors paint .Co.
for possible disposal
io toe ffiaii Co.
iaodfill.
/oiior-op to revest for ff.Joe Xoott-OSPH
assistance in locating an
acceptable land disposal
site for raste sludge
laterials collected
froi paint bootbs.
MCIFIMf
C.Craier-Sobart
Bros. Co.
Correspondence
Deteninatioo tfiat,
assaiia; toe
continuation of ;ood
operations and
taintenance practices,
tnat snoold prerent toe
recipient froi ftafiag
in coipliance ritn tneir
ItOtS fenit.
Letter confiiina lain
points as discussed orer
tie telephone on 5/21/76.
fnose points are;
1) foe (fiaii Coootj
landfill is not
approred for tne
disposal of liquid
indastrial rastes,
2) 1.1.0. iifoid taste,
Joe. is a coipaof
toat oandles
indastrial li?oids
aid slndjes and to
tic OIPI'i
tnoriedje it latin?
«f«rf effort to
nandle toese
laterials io toe
test practical
lanner,
j; Sfsteco faste
freatient Centers
tare experieoce io
treating toe vastes
in foestioo.
Iraiole-OJPA
K.t. Fanflorpe-S./.ffo Correspoodeoce
odricn
If. Joe Ktort-OIPk
H.fhillii-St.RtgiiP Correspondence
aperCo
-------
19. t
9/89
imm pms DJH
umismnn mono inn mm
mm conn ucummi sirt
oaio
rmi
mipinr
oocmnr nil
2 7S/09/H
3 17/12/23
totict that th< om,
sfttr a iorestigatioo,
dots att recoittad that
tie sice be used (or a
saoitarf landfill
purpose.
Doe to groundirater
pollution froi rastes
deposited in tie grarel
terrain, tie author
reeoneods:
I/ Oijcofltiaoe disposal
of tastes in tie
Jand/iJJ t Jasooas
2; Carer tie liaddll
tad incinerator asi
. disposal areas rito
tro feet of elij
3) Drain and fill the
lagooaj rith claf
soils.
Kbdul Sashidi-MtH
lick
Brookbtrt-Kitti Co.
Correspondence
Jaies Ptsoiao-OSPA
Hiati Co. Bout ot
Con.
Correspondence
78/03/29 Annual sorref of tie
ffiaii Coootr ffealto
District's solid raste
disposal prograi. It
is recoiieoded tbat
Jfiaii Coootf ffealth
District reiaio oo
toe lift of approred
solid raste disposal
f tog rni.
X. Jot Hoort-OStH
Correspondence
Co.ffealth
1 78/07/17 letter coifiriii? earlier Jai«a
coarersation roere Jfiaii
Co., apon closing toe
incinerator, voold also
abandon the landfill and
incinerator scruoher
lajooo. letter states
toe OlPh 't concerns 00
hoi the scrubber rater
lagoon and toe
incinerator residue
riJJ be oaodeled.
UrooWart-ffiaii
Co.fog.
Correspondence
-------
?age So. 5
06/23/89
ness/mm pasts am
umismrm RECORD imi mm
mm coairr ucmmox sm
not, onio
rmi
mmui
rm
DOCIIWHI
1 78/10/12 Jfiaii Coootr piaos to
Cite t4« tlr aso toat
retains io tht tlj asn
lagoons and spread it
oo top of the
incinerator residue
after toe residue oas
fteeo jraded.
1 79/04/30 letter orjiny recipient
got to use toe foner
Jfiaii Coootr tandfiJJ
5ite to dispose of
deiolitioo and nigfiraf
lateriaJs.
2 M/96/21 Resoits of iorestioatioo
of disposal of fooodrf
sand oo tie recipients
property.
licit Jrooioart-tfiaii Couotf Jaies Ptanioo-QHH Correspondence
Lovell
frisseJl-Sao.Joy.Hi Correspondence
aiiCo.
K. lot Koore-OSPA
Iloji
Serfices
Correspondence
1 J0/07/22
1 80/11/24
1 80/12/03
Petenioatioo tnat S.P.I. Joe JToore-OffA
Corp. fooodrf saod is not
i regulated solid raste
and is not required to
go to a licensed sanitarf
laodfiJI nor reciere
special state approraJ.
Rooert laol-^ref Correspoodeoce
Serrices
Revest for infonatioo
aooat proper disposal
letiods for taste ileoool
froi tro area hospitals.
Jtefoest for a letter
froi tie 0IM yiriaj
penlssioo to use
raste oil for dost
control and ao
explanation of
correot policies
regarding toil
practice.
Aooert fanl-Arer Serrices Joe Xoort-OiPk Correspondence
Jtooerc lahl-Artj Serrices Joe Hoott-QltA Correspoodeoce
1 80/12/1S Jfeplf to revest
regardiog
toe regalatorf status of
Joe Hooie-OtPk
Jiooert lanl-ilref Correspoodeoce
Serrices
-------
to. s
06/29/as
mas/mug PASSS DATS
1 81/OUOS
minsmrm mow mm mm
mm cowrrr IICJMJMW* sin
nor, OHO
rim
taste oil tod its use
si s dost coatrol aqtnt.
Request tot assistance
io finding disposal
options tor 300 gallons
taeb ot paint tad
rarnisn along titb
200 gallons tt rash
nter.
mm RKIPIIIT
Robert fabl-Krer Serrices QIH
rm
vocmm
Correspondence
I 81/02/05
Response to request to
tat QIH tor nelp in
detertiaiai possible
disposal options tor
faint tad tarnish
rnortr. OSM ciOMt
tdequttelf respond
to this reqnest
ontiJ additional
intonation is
prorided.
tbaias tiastoo-OSPh
Robert
Serrices
Correspondence
I Sl/05/09
I 81/05/15
Reconeadatioa tbat tht Jaies Peaaino-Otfk
air qualitf abort tells
at the Coootf fraater
Station aad tt tbt Coantj
Sarage bt satpled. letter
also traasiits i copj of
a cbetical analfiit trot
tht list tiu tht Kill
tere siipietf (aot
present).
ffiaii Co. Board of
Con.
Correspondence
lotice toat air saipJes
riil be ttktt at the
liaii Co. ffaraye and
tie ffiaii Co. Jraasttr
Station tor the porpose
of determining tne
degree ot air qualitj
contaiination caused
or veil rater soppiies.
Staoief rrissell-JTiaii Co.
San.Jny.
O.Cflristian-ffiaii
Co.tng.
Correspondence
1 32/01/30 Reriei ot raste streais
froi nospitais located
in Piqaa and Troj, Ohio.
Oarid Strarer-OEPA
/Jrerfjf-colo-5
Recjclia
Correspondence
-------
Page to. 7
«'••
ness/mm PMIS om
1 87/02/2<
I 88/97/29
2 88/OJ/2J
88/11/18
TITLI
Letter also states that
tbt recipient can
properlf
naodle tiese rastes.
Preliiinary Jfatttral
Resources Surrey.
Response to recent
BIEC correspondence
indicating recipient
lay be a PHP.
Response to Request
tor Intonation.
Laboratory results of
rater saiple obtained
froi recipients veil.
RSCORS imi mm
mm mmnm sm
, oaio
mumr rm
Stoe Lucero-QSlPK
Brvct
BliBCbird-H.S.Dtpt.ollnttrior
R.leiaiaqer-Iniliitrial faste G.
Ois. Praitt-BISC
floyd Arey-drey Serrices.Jnc.
Hicbael Sttrktr-om
Sorrells-ffSflM
Steve Depugb
Correspondence
Correspondence
Correspondence
Correspondence
IS 88/11/21
9 M/12/39
4 8J/02/17
Laboratorf results of
rater saiples obtained
troi veils of local
residents and oat local
business.
Response to £e?uest
for lofonatioo.
Jficiael Stirktj-OStH
Jobn Siiioos-Laidlar taste
See docuiegts
Firginia
Sunlit-ism
Response to Soppleieotal H.ieiflia^er-Iadustnal Faste f&oias
for lofoiatioo. Ois. Seisbecker-USEPA
Correspondence
Correspondence
Correspondence
2 89/92/24
2 89/92/21
I 89/93/22
Jam tire of actirities
of aotior coipanf's
soisidiaries riti
respect to tie site.
Iran Cairos-LaidJar
Traosportatioo
Additional inforiatioo on Sicnael Starkej-OSPK
state applicaole or
relevant and appropiate
re?oireieots (ARMls).
Harf lulgbat-VSSPh Correspondence
Correspondence
Potter-USm
Reason for lac* of
response to recent
SJfC correspondence.
flojd
Serricesjnc. Josinessilndastrffn Correspondence
r.Con
45 89/OJ/27 Special lotice Letter. JTonaa Kiederganq-UStPA
Set serrice list Correspondence
-------
Page to.
as/29/89
neat/mm fusts om
2 S9/93/2I
5 89/94/95
I 39/94/19
1 99/94/19
2 89/94/19
3 89/94/19
4 89/94/13
2 89/94/17
3 89/94/19
2 99/94/19
2 89/94/21
4 89/04/24
2 89/94/24
2 89/94/25
2 89/94/25
TITLS
uunsmtin mow mu mm
mm com? ucimATon sm
ttor, osio
norm
Response to Request
tor Intonation.
Response to Request
tor Intonation.
Response to Request
for Intonation.
Response to recent
VSSPA correspondence.
Reason tor not responding
to recent UStPA
correspondence.
Response to Request
tor Intonation bf
tbe counsel tor
Srissot's Super
FaJoe.
letter totalizing tbe
good-faith offer lade
or tie me.
Response to Request
tor Intonation.
Response to Request
tor Intonttion.
Response to Request
for Id/oriJtioa.
Response to Request
/or Id/oriatioa.
Seiponie to Se?oest
/or In/oration.
Response to Request
tor Intonation.
Response to Request
tor Intonation.
Response to Request
tor Intonation.
Laiar Delanej-Siipson &
Belanej Ser
RSCIPIHT
OS!?*
socnnr TIPS
Correspondence
Correspondence
Correspondence
Ratter-VSSPA Correspondence
flofd Aref-Aref 5emces fonf Rutter-USSPA Correspondence
Lotus Cruz-Roper Industries,
Inc.
0oo Babbari-Bobbtri Rooting,
Inc.
Hofd Aref-Arej t-colo-S
Recfdiag
Toaf Rotter-QSSPA
Toor
J.Ricbtrd 5aitr-J.Richard
Saier Co.
Tonj Rutter-VSSPA Correspondence
Kildred trigbt-BISC
Oititri licholas-Orr lelt Co.
Sarr Croutb-Alutinai Co. of
Aierica
Robert Boaigtord-Petersoa
Construct
C.lessler-Citf Transfer 4
Oil Hill
Toaj Rutter-HSfPA Correspondence
Hachinerf
Hai Scbaefer-Jbe Scbaefer Co,
lac.
Alan faiser-Ctrpeater
Coastructioa
Arthur Oisbror-Bartttll
Propeller
four Rutter-VSSPA
TOOT Rutter-OSlPA
TOOT Ritter-VSSPA
Tooj Rotter-ffSm
foof Katter-VSSPk
, farj tulgbai-VSSPK
TOOT Rutter-QStPA
Tonj Rutter-QSSPA
Correspondence
Correspondence
Correipoadtnce
Correspondence
Correspondence
Correspondence
Correspoadence
Correspondence
-------
Page Jo. 9
"ncas/mm HGSS om
nni
mmsmmi mm imi
HI MI coum mcmmroR sirs
mi, ofiio
MHHOR
tm
2
J
2
4
7
5
*
4
2
2
SS
6
4
3
8
89/04/2S
89/04/25
89/04/25
89/04/25
89/04/25
89/04/25
89/04/25
89/04/25
89/04/2J
89/04/2$
89/04/2J
89/04/2$
89/04/2f
89/04/27
89/04/27
Response to Request
tor lotonitioa,
Response to Request
tor latomtioa.
Response to Request
for Intonation.
Response to Request
lor Intonation.
Response to Request
tor Intonttion.
Response to Request
tor Intortttion bf
coua5
-------
Page to. 19
OS/29/M
ricnmua tuts am
rim
mmsmmt mono mil mm
mm conn minmm sirs
TROJ. OHIO
HTBOR
Docvmr rm
oocmmR
3 89/04/27
i 89/04/27
89/9'4/28
4 89/04/28
3 89/94/29
52 89/05/91
2 89/05/01
4 89/05/01
7 89/05/02
7 89/05/92
2 89/05/02
4 89/05/02
S 89/05/03
Response to Request
tor Intonation.
Rtspoast to Request
tor lotorutioo.
Response to Request
tor Intonation.
Response to Request
tor Intonation.
Rtspoase to Request
tor Intonation.
Rtsponie to Request
tor latortttioa.
Resfosae to Request
tor Intonation bf
toe counsel tor
Fergosoa Coastractioa
Co.
Rtspoase to Request
lor latortitiott bf
the couasel tor the
filiigt ot Pleasant
Bill, Ohio.
Sespoase to Request
(or Inforiatioo.
lespoaie to Request
tot Intonation.
Response to Request
tor Intonation.
M4itional response to
Request lor lalorntion.
Response to Request
lor Intonation bj
the counsel tor
Irentlo Jureaile
furniture Co.
Robert Roberts-Chetlma Jonj Rutter-VSlPA Carrespoadeoce
tilliai lukeas-Stillvater Toof Rutter.-ffSJM Corrtspoadtact
Tecbaolog
Heliaia Keip-Cbanpioa
Interactional
Joof Ratter-USEPA Correspoadeace
Tonj Rutter-VSSPH Correspondence
lillian Jaaaiaq-kRC Abrasives Tonj Rutter-OSttl Correspondence
Robert Tate-Cjclops
Industries,Inc.
B.LSttiatr-KRKCO Inc.
foaf Rutttr-VSSPl Correspondence
John fonj Ratttr-VSSPA Correspondeace
Ganbausea-Blake,Iaulkner,etal
Kichael Toaj Rutter-VSSPk Correspondence
6utiaaa-HcCulloch,Ielger,..
Jonf Rutttr-USSPk Correspondence
Sreqorj Bora-Tipp Citj, Ohio Jonf Rutter-VSftk Correspondence
Douqlas Kajoor-Goodson
toljttrs.Ioe
L.Sdtard Trf-frojan
»sphalt,Iac.
Tonj Rutter-VSSPt Correspondence
lilliat Jiaaicq-MC Abrasires foaf Rutter-VSSPH Correspondence
Andrea traas-Sutler t Butaette Harj lulgbat-VStPA Correspondence
8 89/05/04 Response to Request Aaron Parker-triendlY Ice foof Rutttr-VSSPA Correspondence
-------
n
nsts am
5 89/05/05
6 89/05/08
2 89/05/08
5 89/05/08
» U9/05/11
5 39/05/12
5 89/05/17
5 39/05/17
1 flJ/Jf/15
5 89/0J/1J
tint
for Info nation.
Response to flegoest
/or Infonation.
Response to Heftiest
for Iflforiitiofl.
Response to Request
tor Infonatioo Of
toe counsel for
Beatreie.
Response to Request
for Inforiatioo.
Response to Regoest
for Infonation bj
counsel for fnt«rprise
Jfoofiflfl. i Saeet Jfetal.
Response to Revest
for Inforiation.
Response to Reqoest
for Iflfonation.
Response to Revest
for Infonation.
Response to Revest
for loforiatioo.
moRD imi mm
mm coirm ucimum SUE
JROJ, osio
MTHOR
Creai
Paul
Stores
Oarrel
0eraftoffiXae^fejl-ffafer,5rorni
Hut
Berian fonf flntter-ffSfPJ
, Inc. foof Rotter-ffSfPJI
Juts R»rtzell-8»rtztll
Industries
Jaies
/acooson-Jacooson,Darst,et ai
SneJJ I Ifcfarland-fipp
Xacnineifool
Kaj
of
Bernard Burst-Ohio Dtpt. of
frans.
RaJpi
, Inc.
ictflfliledoeient of good- Ion
faiti offer reciered froi
toe Bosiness and Indastrf
Inrironiental Coiiittee
(UK).
Letter concerning toe
reiedf to tie site.
BItC contest that a
sinyJe Barrier cap
ratoer tnan a doooJe
carrier cap rill
satisff all reguireients
for protection of tie
aealto and earirooieot.
CnarJes risdale-JTioa, t
5palding
Rotter-l7SfPJI
Tonf flotter-OSfPil
fonf Jlotter-ffSfPi
oocowir
Correspondence
Correspondence
Correspondence
Correspondence
Correspondence
fonf flatter-ffSIP*
Tonf Ratter-ffSm
foof Rutter-USm
(Tildreif torjk-BIK
Correspondence
Correspondence
Correspondence
Correspondence
Correspondence
Correspondence
flatter-KIPA
16 S3/9S/21 Iflforiation relating to 0. lane-beating,Wuetiing i Ktrj /aignai-ffSJPJ Correspondence
-------
PUIS DM! TltLS
the tattrliae project
tad the regaireieat
that i aet transfer
station be bailt. Mao
included is a diagran
indicating there the
taterliae till be
located as tell as a
list people tho hare,
till or could be
connected to the
taterline.
tmuismrm mm inn mm
Him cowrr mnmm sirs
rw, OBIO
mm
flekatp
oocnsn TIPS
Docmm
4 54/09/00
Sapertaad Prograi tact
Sheet • Hiaii County
Incinerator Site rroj,
Ohio teiedial
Iniestiqation/
feasibility Stadj.
(/SIP/I
fact Sheet
S 09/04/00 fact Sbttt • 'Seiedial
larestigation and
feasibility Stady
Cotpleted at the Hiaii
County Incinerator
Sapertaad Site frof,
Ohio'.
2 16/09/20 Kiaii Countf laciaerator
Statrtl Intonation
lectio;.
1 81/10/08 teqaest tor an
iarestigation
at activities it avery
Serricet, troy, Ohio.
OSEP*
tact Sheet
Irookbart-Sanitary
Saqiattr
Joe Koore-OSPl
Hetorandat
Dare Strayer-Oin Htnoraadat
2 34/10/09
Trip Report for Kiaii
Co., Incinerator SI/IS
kick oil teeting
J/27/J4.
Kargaret HcCae-VSSPA
file
Seioraadat
1 84/09/19 'VSSPk To Briel Citizens VSSH
On Saperland Actions
Scheduled for toner
lets Release
-------
It to. 13
:BE/mnE PACK
2 89/03/24
I 99/99/90
umismnn WORD non
mm conn ucmum sin
OHIO
tmi
Tioj, OS, laodfill
lod locioeratioo Site*
lets Rtlease "ffSJPA, Ohio tJSSPA
SH Propose $21.9 Killioa
Cleao-ap for ffiaii Cooatf
locioerator; Searing
Stt tor April 1C.
Annual Total towage
for tie fears 1973
to 1919.
fotice of a poolk
letting to be be Id
oo 4/f/J9 to discuss
reiedial alteroatires
aod iorites vritteo
contott to bi
subiitted oo later
coaa t/2S/99.
Kiaii Co.
QSIPH
Mcmun mi
lers Release
Otbtr
Other
1 72/97/01 Jfer iocioerator rate ffiaii Co.
scoedole.
2 16/12/K Coiiereial Saoltr Periit
Applieatioo.
2 70/01/04 Coiiereial ffaolio? Periit
Applicatioo.
4 78/01/0$ Coiiereial ffaoler Periit
Jppikatioo.
2 78/02/03 Coiiereial ffaoler Periit
Jpplicatioo.
2 71/02/15 Coiiereiil holer Periit
Application.
1 79/01/10 Coiiereial Hauler Periit
Application.
4 78/12/0J 0ROM io toe latter of,
triaii Coootf loeioerator.
5 (7/11/01 'lotes 0o Inspection 0f
Solid faste Pro;rai lot
ffiaii Ccootf*
It. ttrqmoa • Sroro Bridie
Hills
C.f.fliiter-fiilters Beatiaq
Serrice
frof Iron 4 Hetal Co., Inc.
I.J.f., Inc.
R. fergosoo - Srovo Bridge
Hills
SCA ot Daftoo, Oaio.
fed rilliais-OfPA
Oscar Singer-Solid faste
Section
Hiati Co.
Coiiissiooers
ffiaii Co.
Conissioner
Hiati Co.
Coiiissiooers
Hiaii Co.
Coiiissiooers
Hiati Co.
Conissioners
Vlaii Co.
Coiiissiooers
ffiaii Coantf
0toer
Periit
Periit
Periit
Periit
Periit
Periit
Pleadinjs/Orders
Peports/Stadies
-------
Page to.
06/29/89
H
ness'/run fuss un
tint
mmismrm RICORO imi mm
mm conn mimum sirs
TROI, oaio
JfffTOJJ RSCIflSIT
Documr rm
oocnmti
9 70/04/02
1 '73/19/31
3 73/11/92
I 74/11/91
2 78/01/31
9 19/92/11
2 81/01/1S
21 83/95/25
3 37/92/13
28 S7/11/18
220 89/02/22
Sniiarf of coats
iacorretf /or operation
of tht iaciatrator
for tie f«ir 19S9.
Ulio taclostd i$ i
cut aaaljsis for tat
fear 1570.
Jaoiearf Landfill
laiftction fori.
Hick Brookbart-SaaitatY
fajiaeer
Hiati Co.Hunicipal Reports/Studies
League
Donald Histr
Hiaii County
ffrooad rater Evaluation Dart Johe-OSPK
lor Tae Hi an County
JaciaeratorMad Landfill.
Sanitary landfill
Inspection lorn.
Kiaii Count j, Ohio
Solid taste Disposal
facilitj Operational
Kepott.
Kick Brookart-tiiati
Co.Saaitarjlag.
Pollution Coatrol Science,Inc.
of Leacnate
troi Process laite
Solids - Sobart
Brothers Coipaof'
Report of Inrestigation Jaies Pennino-QSPA
Bobart Brothers laste
Disposal Site • tfiaii
Cooutf.
farard ftaaiia? Sfstei
Scoria? Package.
JeaJta Astessieat.
'ffoaicipal Solid faste
Laadfiils-fne Role of
ladustrial tastes la
rtose Landfills'
Retedial Inrestigation
Rtport - Volaie 1 of 2.
foi OntkoQOlPA
Hani
ffaocoi Corp.
CS2H Bill
usm
Reports/Studies
Jieports/Stodies
Aeports/Stodies
Reports/Studies
Reports/Studies
Reports/Studies
Reports/Studies
Ionise Jfeports/Stadies
labioski-QSEPH
Reports/Studies
Jteports/Stadies
Jl( 39/02/22 Poolic Couent
CI2/T Sill
vsm
Reports/Studies
-------
ftgt la. 15
OS/29/89
ncss/mns PMSS outs
M 99/92/22
19 S9/03/09
3 89/OS/19
317 39/0f/29
S3 89/04/OS
cm am
vssn
nrw
fttsibilitr
Stair Report.
Rneiial lartstigatioa
Report • foJoie 2 of 2.
Proposed, f Jan.
Obio SPA fteconeodatioos
/or Soil Jtstiag.
Respoasireaeti Sunarf. CBM Bill
Transcript of a Public
Bttriaq atli at tat
rrof ;onior Biqb School
oo
mmsmnn mono imt mm
KIMI coffirr mcimiTOR sirs
rsor, OHIO
norm
ucmm
vstn
3SSPK
fcports/Stodies
Acport5/Stodie>
frao5cript
-------
?« fo.
/29/li
asm utuimmn-ucom simiie/nm mm m m
mm mm mumm sirs. DOCHHSKTS ms for m*
copist w m miims m mm AT m
M6IOI F OfW'CfS; CHCJM, IIWWIS.
rs
rim
Bocmwir rm
'09/00 Rav data and data aontritt.
'HO/00 Cbiia-ot-Custodf Ions.
'00/00 Hiiti Cuootf laciatntor
Database Source ffoetiicots.
Fortj (oar rolls of
licrotili it all itigkt
tickets raortd trot
the site.
asm
tJSlPH
Ccaestoga-Korers
Saifliag/Data
Satpliaq/Oati
Saipliaq/Data
-------
cwwici Docmwirs imn-swumr TO m
koitmsmrm mm imi rot m mm count mcumm
sirs nor, OHO. DOCUHUTS ms for an COPISD m m
mums m mist nr m usspk RSG.V omcss, cameo, IL.
rrrw Jirraoi aocmn TTPS
To n« considered • OSPk I State of Onio Guidance
proposed legislation
in the State of Onio
7ifl,!l Closore Of
Saoitarf landfill
facilities • Draft'.
Delegation of fteiedr USSPk Guidance
Selection to flexions.
Superfond Coiitinitr USSPk Guidance
Relations
tens Sidelines and USSPHkHS-QOS/80 Guidance
^ecifications for
Preparing QkPP's.
Guidance Oocoieot: USSPk ffaidance
Oesijn Sfsteis
and J'inal Corer.
ffseo Guide to tne VSSPk Coidance
USSPll Contract
Laooratorf Projrai.
Interii Standard VSSPk ffoidance
Operating Safetf Guides.
Guidance leiorandni on USSPk Goidance
tne Ifse and Isiouce
of MiiniJtratire
Orders Under Section
19S (if CtHClk.
CSSClk Coipliaoce ritn USSPk Goidance
otner Jnrironiental
Statutes.
.tleient and Corer r.L.fforpflfSPJ.Gilfiert-USJPd Goidance
Subsidence of
ffamdoos taste
Project
-------
Page to.
OS/29/89
rim
emmet oocnmrs imi-sffwmir to m
unnsnuin RECORD imi mm mm coffirr
SIM ttor, oaio. oocnmrs am HOT am COPIED m m
miiuit m REVIEI Kr TBS ussn REG.? oincts, cameo, n.
unot
Mcmtt rm
85/96/00
BS/08/01
85/11/22
86/00/00
8S/09/2t
8S/10/91
87/00/00
87/06/01
87/06/30
Goidaact on Rettdial lortitigiticas/
rtttibilitr Staiiti Vadtr CIRCU.
Toiicologf Sittdbook.
todiogentot hitttstttt
Saidtact (Steoadtrj
Rt ft react I.
lattril CERCU Stttlettat
mn
Saidtliatt for Izpoiurt
Assessitat.
Saptrfaad Public Btiltb
Snloatioa Sanotl.
Srtlattiog fixed tooting
Igrttttott Vadtr CHCU.
Saidtliati aai
Speciticttloas tot
Prtoitiaq JoaJitf
isssonaee Project
PI is i.
lattril Gaidiact on
He Kiaiiai Stttltitati.
9850.2
9850.0-01
Goidaace
Guidance
Gaidaace
VStH - 50 fed Rtg 5034 (1986) Gaidaace
USm-ttd Rtq p.J«0<2 - Gaidaact
9/21/86
J2J5.4-J Gaidtoce
53 ted Rtg 8279 • L liattoa Gaidaace
ftrter
asm
52 ltd Reg 24333
Gaidaace
Gaidaace
88/05/06
88/06/91
88/10/01
88/11/17
Soperfood fipoiore
Assessueat Saaaal.
Regioa ? Groaadnter Strtttgj.
Conoflitf Rtlatioai la
Saaertaadi 4 Baadbook
(later it tersioa).
Gaidaace tor Coadactiag
Reiediai lartstigatioat
aad tttsibilitT Stadiet
Under CtSCll.
Gaidaace oa Preiiat
Pafieots Jo CIRCLE
Stttlttents.
J28S.S-J
Saiiuct
kdaikat S Coriagtoa-VStPA Gaidaace
9230.9-t3t Gaidaace
Gaidaace
05111 9J55J-0I
OSItR 9835.6 • Kdati/Porter Guidaace
vsm
-------
?aj« 10. J
JS/29/8S
Mfl
saima Docmnrs nm-snnmn TO rn
uummnn ucon IIDSI in m mm conn iicnmroi
5i» raor, OHIO, mamrs mi IOT MM COPISD BUT m
mumt m atmt AT m mn m.? QUICK, camso,n.
rim
tocnur rr?j
<2/07/OS Drift HUH Soidioce
Docoitott Ltodtill Dttiqa
Liotr Sfstns tod liail
Cortr,
USSPA
Guidaace
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