Superfund Record of Decision: Skinner Landfill, OH June 1993


           United States        Office of
           Environmental Protection   Emergency and
           Agency           Remedial Response
EPA/ROD/R05-93/225
June 1993

PB94-964113
&EPA   Superfund
          Record of Decision
          Skinner Landfill, OH

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50272.101
REPORT DOCUMENTATION 11. REPORT NO. 2. 3. Reclplenr. ACC88alon No.
PAGE EPA/ROD/R05-93/225
4. Title and Subtitle 5. Report Date
SUPERFUND RECORD OF DECISION 06/04/93
Skinner Landfill, OH 6.
Second Remedial Action - Final
7. Author(a) 8. Parformlng Organization Rept. No.
9. Performing Organization Name and Addr... 10 Project Ta8klWork Unit No.
11. Contract(C) or Grant(G) No.
(C)
(G)
12. Sponsoring Organization Name and Add,... 13. Type of Report & Period Covered
U.S. Environmental Protection Agency
401 M Street, s.w. 800/800
washington, D.C. 20460 14.
15. Supplementary Notas
PB94-964113
16. Abstract (Limit: 2OOworda)
The 78-acre Skinner Landfill site is a mixed waste landfill located in West Chester,
Butler County, Ohio. Land use in the area is predominantly commercial and residential
to the west, and agricultural to the north. The estimated 6,800 people who reside
within one mile of the site use several geologic units beneath the site as aquifers and
nearby wells drilled into the bedrock unit to obtain their drinking water supply. Prior
to 1934, the site was used to mine sand and gravel. Fr.om 1934 to 1990, the site was
used for the landfilling of a wide variety of materials, which include demolition
debris, household refuse, drums, and chemical wastes. The site consists of four
potential source areas including a former dump, a buried waste lagoon, an active metal
scrap yard, and several buried waste pits. The waste lagoon was used for disposal of
paint and ink wastes, creosote, pesticides, and other chemicals. In 1976, in response
to an onsite fire and reports of observations of a black, oily liquid in a waste
lagoon, the State investigated the landfill. The owner hindered this investigation by
covering the lagoon with a layer of demolition debris and asserting that nerve gas,
mustard gas, incendiary bombs, and other explosive devices were buried at the landfill
(See Attached Page)
17. Document Analysis a. Descriptors
Record of Decision - Skinner Landfill, OH
Second Remedial Action - Final
Contaminated Media: soil, sediment, debris, gw
Key Contaminants: VOCs (benzene, PCE, TCE, toluene, xylenes), other organics (dioxin,
PAHs, PCBs, pesticides, phenols), metals (arsenic, chromium, lead),
other inorganics
b. IdentifierslOpan-Ended Tarms
c. COSA TI FleldlGroup
18. Availability Statement 19. Security Class (This Report) 21. No.ofPag..
None 182
20. Security Class (This Page) 22. Price
None
(See ANSI-Z39.18)
SH Instructions on R.verse
OPTIONAL FORM 272 (4-77)
(Formarty NTJS.35)
Department of Commerce

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EPA/ROD/R05-93/225
Skinner Landfill, OH
Second Remedial Action - Final
Abstract (Continued)
lagoon area. After subsequent retraction of this claim, the U.S. Army and the State dug
several trenches into the buried waste lagoon and found black ooze and numerous barrels of
waste; however no munitions were found in the lagoon. In 1982, EPA conducted a limited
investigation of the site that identified VOCs in the ground water southeast of the
lagoon. Between 1986 and 1989, EPA continued investigations of onsite soil, sediment,
ground water, and surface water and determined that approximately 227,000 yd3 of waste had
been contaminated as a result of site operations. In 1990, the State closed the site. The
site has been divided into two OUs for remediation. A 1992 ROD addressed fencing of the
contaminated area(s) to limit site access and provision of an alternate water supply to
protect potentially affected users of ground water on and near the site, as OU1. This ROD
addresses a final remedy for contaminated soil, sediment, debris, and ground water, as
OU2. The primary contaminants of concern affecting the soil, sediment, debris, and ground
water are VOCs, including benzene, PCE, TCE, toluene, and xylenes; other organics,
including PAHs, PCBs, pesticides, and phenols; metals, including arsenic, chromium, and
lead; and other inorganics.
The selected remedial action for this site includes assessing the feasibility of
installing a soil vapor extraction system to treat contaminated soil and sediment
surrounding the lagoon wastes; capping approximately 227,000 yd3 of soil, sediment, debris
and waste lagoon using a multi-layer RCRA cap, with revegetation; excavating approximately
3,100 yd3 of contaminated soil and debris from areas outside of the burn area to be
capped, and consolidating it in the area to be capped; intercepting, capturing, and
treating contaminated ground water either onsite at a wastewater facility or offsite
depending on the volumes of wastewater involved, as determined during the design phase;
diverting the flow of uncontaminated ground water onto the site using a barrier wall such
as a slurry wall, vibrating beam, or grout curtain, and lowering the ground water level'
beneath the cap so that uncontaminated ground water does not come into contact with waste
materials beneath the cap; monitoring ground water and surface water; performing
additional investigation of two site areas to determine the type of wastes buried in those
areas; and implementing institutional controls. The estimated present worth cost for this
remedial action is $16,031,900, which includes an estimated annual O&M cost of $397,000.
PERFORMANCE STANDARDS OR GOALS:
Chemical-specific excavation goals for the soil outside of the former dump area and waste
lagoon are based on acceptable risk levels, and include PAHs 0.1 mg/kg to 0.33 mg/kg; PCBs
0.16 mg/kg; and lead 500 mg/kg. Chemical-specific ground water cleanup goals are based on
site-specific risk, and include arsenic 0.005 mg/l; benzene 0.005 mg/l; chromium 0.011
mg/l; cyanide 0.0052 mg/l; lead 0.0032 mg/l; PAHs 0.0001 mg/l to 0.52 mg/l; PCE 0.005
mg/l; phenols 0.15 mg/l to 2.12 mg/l; TCE 0.005 mg/l; toluene 1 mg/l; and xylenes 10 mg/l.

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DECLARATION FOR THE RECORD OF DECISION
SITE NAME AND LOCA TION
Skinner Landfill
West Chester, Butler County, Union Township, Ohio
STA TEMENT OF BASIS AND PURPOSE
This decision document presents the selected final remedial action for the Skinner
Landfill site in West Chester, Ohio, which was chosen in accordance with the
requirements of the Comprehensive Environmental Response, Compensation, and
Liability Act of 1980 (CERCLA), as amended by the Superfund Amendments and
Reauthorization Act of 1986 (SARA) and to the extent practicable, the National Oil
and Hazardous Substances Pollution Contingency Plan (NCP). This decision
document explains the factual and legal basis for selecting the final remedy for this
site. The information supporting this final remedial action decision is contained in
the administrative record for this site.
The State of Ohio concurs with the selected remedy.
ASSESSMENT OF THE SITE
Actual or threatened releases of hazardous substances from this site, if not
addressed by implementing the response action selected in this ROD, may present
an imminent and substantial endangerment to public health, welfare, or the
environment.
DESCRIPTION OF THE SELECTED REMEDY
This remedy is the second and final of two operable units for this site. The first
operable unit addressed immediate site concerns, through the construction of a
fence around the contaminated area, and by offering an alternate supply of
drinking water to the potentially affected users of groundwater. This final operable
unit addresses potential future migration of site contaminants into the groundwater
and will limit the potential for direct exposure of site contaminants to humans
through source control measures.
,

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The selected remedy includes the following:
.
.
.
.
.
.
construction of a RCRA cap over the waste materials;
interception, collection, and treatment of contaminated groundwater;
diversion of upgradient groundwater flow;
monitoring;
institutional controls; and
soil vapor extraction.
DECLARA TION
The selected remedy is protective of human health and the environment, complies
with Federal and State requirementS that are legally applicable or relevant and
appropriate to the remedial action, and is cost-effective. This remedy utilized
permanent solutions and alternative treatment (or resource recovery) technologies
to the maximum extent practicable.
Because this remedy will result in hazardous substances remaining on site above
health-based levels, a review will be conducted within five years after the
commencement of the remedial action to ensure that the remedy continues to
provide adequate protection of human health and the environment.
t
¥
~/o4/if6.

Date
Valdas V. Ada kus
Regional Adm" istrator
U.S. EPA, Region V

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o. _.0 -- - - _0 .
TABLE OF CONTENTS
SKINNER LANDFILL RECORD OF DECISION
SITE NAME, lOCATION, AND DESCRIPTION. . . . . . . . . . . . . . . . . .-. . . . .
SITE HISTORY AND ENFORCEMENT ACTIVITIES. . . . . . . . . . . . . . . . . . . .
1
2
COMMUNITY PARTICIPATION. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
3
SCOPE AND ROLE OF THE OPERABLE UNIT WITHIN THE OVERAll SITE

STRATEGY. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
5
SUMMARY OF SITE CHARACTERISTICS. . . . . . . . . . . . . . . . . . . . . . . . . .
5
SUMMARY OF SITE RISKS. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 12
EXPOSURE PATHWAYS. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 12
HUMAN HEALTH RISK. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 13
ENVIRONMENTAL RISK. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 14
DESCRIPTION OF ALTERNATIVES. . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 14
ALTERNATIVE 1 NO ACTION. . . . . . . . . . . . . . . . . . . . . . . . . . . .. 1 5

ALTERNATIVE 2 ...................................... 1 5

ALTERNATIVE 3 ...................................... 1 7
SOil VAPOR EXTRACTION. . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 18
ALTERNATIVE 4 ................................. . . . . .. 19

ALTERNATIVE 5 ...................................... 20


SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES. . . . . . . . .. 21
CRITERION 1: OVERALL PROTECTION OF HUMAN HEALTH AND THE

ENVIRONMENT. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 22
CRITERION 2: COMPLIANCE WITH APPLICABLE OR RELEVANT A~D
APPROPRIATE REQUIREMENTS. . . . . . . . . . . . . . . . . . . . . .. 22
CRITERION 3: LONG-TERM EFFECTIVENESS AND PERMANENCE. . .. 23
CRITERION 4: REDUCTION IN TOXICITY, MOBiliTY OR VOLUME. . .. 24
CRITERION 5: SHORT-TERM EFFECTIVENESS. . . . . . . . . . . . . . . . .. 25
CRITERION 6: IMPLEMENTABILITY ......................... 26
CRITERION 8: STATE ACCEPTANCE. . . . . . . . . . . . . . . . . . . . . . .. 27
CRITERION 9: COMMUNITY ACCEPTANCE. . . . . . . . . . . . . . . . . . .. 27

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2
-
SELECTED REMEDY: ALTERNATIVE 3 WITH THE INCLUSION OF SOIL .
VAPOR EXTRACTION. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 28

Capping. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 28

Downgradient groundwater control. . . . . . . . . . . . . . . . . . . . . . . .. 29
Upgradient groundwater control. . . . . . . . . . . . . . . . . . . . . . . . . . .. 30
Soil Vapor Extraction. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 30
Institutiona.1 Controls. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 30
STATUTORY DETERMINATIONS. . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 32
PROTECTION OF HUMAN HEALTH AND THE ENVIRONMENT. . . . . .. 32
COMPLIANCE WITH APPLICABLE OR RELEVANT AND APPROPRIATE
REQUIREMENTS (ARARs) ........................... 33
CQST-EFFECTIVENESS ................................. 35
UTILIZATION OF PERMANENT SOLUTIONS AND ALTERNATE
TREATMENT TECHNOLOGIES TO THE MAXIMUM EXTENT

PRACTICABLE. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 35
DOCUMENTATION OF SIGNIFICANT CHANGES. . . . . . . . . . . . . . . . . . . .. 36
RESPONSIVENESS SUMMARY. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 38

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FIGURE 1 -
FIGURE 2 -
FIGURE 3 -
FIGURE 4 -
TABLE 1 -
TABLE 2 -
TABLE 3 -
TABLE 2.6 -
TABLE 2-16 -
ATTACHMENT 1
A IT ACHMENT 2
A IT ACHMENT 3
,
FIGURES AND TABLES
SKINNER LANDFILL
RECORD OF DECISION
SITE MAP
MINIMUM AREA TO BE CAPPED
DELINEATION OF NORTHEAST CORNER OF SITE
LOCATION MAP
Site-specific Groundwater Trigger Levels
Remedial Response Levels for Contaminated Soils
Applicable or Relevant and Appropriate Requirements (ARARs),
Federal Requirements .
Federal Criteria, Advisories, and Guidance To Be Considered
(TBC)
Summary 01 Concentration Ranges 01 Chemicals 01 Concern
Administrative Record Index
State Criteria, Advisories, and Guidance To Be Considered
(TBC)
State Applicable or Relevant and Appropriate Requirements
(ARARs)

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DECISION SUMMARY
SKINNER LANDFILL
SITE NAME, LOCA TION, AND DESCRIPTION
The Skinner Landfill site is located in West Chester, an unincorporated area in
Section 22 of Union Township, Butler County, Ohio (see Figure 4).
The Skinner site is comprised of approximately 78 acres of hilly terrain. The site is
bordered on the east by Conrail railroad tracks. Land use in the immediate site
vicinity includes business and residential uses to the west and crop farming to the
north. Cjncinnati-Dayton Road borders the site to the west. The East Fork of Mill
Creek runs through the southern portion of the site. The Union Elementary school
is located h:nmediately across Cincinnati-Dayton road to the west of the site.
Approximately 6800 people live within 1 mile of the site.
The site was used in the past for the mining of sand and gravel, and was operated
for the landfilling of a wide variety of materials from approximately 1934 through
1990. Materials deposited at the site include demolition debris, household refuse,
and a wide variety of chemical wastes. A low area in the center of the site,
referred to as the waste lagoon, was used for the disposal of paint wastes, ink
wastes, creosote, pesticides, and other chemical wastes (see Figure 1).
Elevations at the site range from a high of nearly 800 feet above Mean Sea Level
to the northeast, sloping generally southwestward, to a low of 645 feet near the
confluence of Skinner Creek and the East Fork of Mill Creek. The natural
topography of the site is obscured by piles of solid waste materials.
Several geologic units which underlie the site are used locally as aquifers.
Groundwater at the site is contained in either the glacial drift aquifer or the bedrock
aquifer. The glacial drift ranges from zero to 40 feet thick on the site, and is
composed of layers of sand and gravel, and layers of silty to clayey materials. The
thickness, composition and permeability of these layers vary greatly over the site,
and this greatly complicates the flow of groundwater on the site. Groundwater
also flows through fractures in the bedrock at the site. Nearby wells drilled into
the bedrock are used for the supply of drinking water.
Both Skinner Creek and the East Fork of Mill Creek are small, shallow streams with
low flow water depths averaging less than 1 foot. Both of these streams flow to
the southwest from the Skinner Landfill site, toward Mill Creek, which in turn
flows into the Ohio River. A third on-site stream, Dump creek, borders the former
dump on the east. Dump Creek is intermittent, and flows south into the East Fork
of Mill Creek.

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SITE HISTORY AND ENFORCEMENT ACTIVITIES
In 1976, in response to a fire on the site and reports of observations of a black,
oily liquid in a waste lagoon on the site, the Ohio EPA began an investigation of
the Skinner Landfill. Before the Ohio EPA could complete this investigation, the
Skinners covered the waste lagoon with a layer of demolition debris, th~reby
hindering the investigation. Albert Skinner, the site owner at the time, dissuaded
the Ohio EP A from accessing the lagoon area by claiming that nerve gas, mustard
gas, incendiary bombs, phosphorus, flame throwers, cyanide ash, and other
explosive devices were buried at the landfill. This prompted the Ohio EPA to
request the assistance of the U.S. Army. Albert Skinner, in the presence of Ohio
EPA attQfneys and the U.S. Army investigators, subsequently retracted his claims
of the presence of ordnance. The U.S. Army and Ohio EPA then dug several
trenches into the buried waste lagoon, and found black and orange liquids and a
number of barrels of wastes. Subsequently, records searches have been
performed by the U.S. Army, and have indicated that there is no evidence of
munitions of any sort having been disposed of at the Skinner Landfill site.
In 1982, the U.S. EPA conducted a limited investigation of the site for the purpose
of scoring the Skinner Landfill site for inclusion on the National Priorities List (NPL).
This investigation showed that the groundwater southeast of the buried waste
lagoon was contaminated with volatile organic compounds. The Skinner Landfill
site was placed on the NPL in December, 1982.
In 1986, the U.S. EPA began a Phase I Remedial Investigation, with the sampling
of ground water, surface water, and soils. A biological survey of the East Fork of
Mill Creek and Skinner Creek was also performed.
In 1989, the U.S. EPA began its Phase II Remedial Investigation (8Phase II RI8); to
further investigate the site groundwater, surface water, soils, and sediments.
Overall, more than 400 samples from the site were analyzed in chemical
laboratories. The Remedial Investigation resulted in the installation of 33 soil
borings, and 39 groundwater monitoring wells.
In August 1990, through a legal proceeding, the Ohio EPA closed the site to all
further landfilling activities.
The Phase II Remedial Investigation was completed in May, 1991. The Feasibility
Study was completed in April, 1992.

The U.S. EPA completed a search for potentially responsible parties (PRPs) in April
1983. The results of that search were later supplemented by information requests

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under CERCLA ~ 1 04(e), and by administrative depositions held on June 17, 1991-
The present site owner, Mrs. Elsa Morgan-Skinner, produced a large quantity of
site records at her deposition. As a result of this information, U.S. EPA has
produced a list of PRPs for this site.
A unilateral administrative order (UAO) for the first operable unit at the site, which
encompasses site fencing, connections to the Butler County public water system
for potentially affected local users 01 groundwater, and groundwater monitoring,
was issued to the PRPs for the site on December 9, 1992. Several PRPs organized
as the Skinner Landfill PRP Group and expressed their intent to comply with the
UAO, and have now performed the majority of the work required under this UAO.
Several other PRPs stated that they would not comply with the UAO.
COMMUNITY PARTICIPA TION
During the course of the investigation, many meetings were held with the
community, with a local activist group, and with a coalition of community
representatives.
A fact sheet outlining U.S. EPA's plans for the investigation of the Skinner Landfill
site was distributed to the public in March of 1986.
A fact sheet describing the results 01 Phase I of the Remedial Investigation (RI) and
plans for the Phase II RI was distributed to the public in April of 1987.

A fact sheet describing the results of the Phase II RI and plans for the Baseline Risk
Assessment (RA) and Feasibility Study (FS) was distributed to the public in June of
1991. Representatives of the U.S. EPA and the Ohio EPA held a public meeting in
West Chester, Ohio on June 20, 1991 to discuss the results of the Phase II RI and
plans for future activities at the Skinner site.
A fact sheet describing the results of the Feasibility Study, presenting the U.S.
EPA's preferred alternative for a comprehensive cleanup of the entire Skinner
Landfill site, and commencing a public comment period was distributed to the
public in April, 1992. A component of this cleanup plan was on-site incineration of
approximately 17,000 cubic yards of lagoon wastes. A public meeting to discuss
the proposed plan and to gather public comments was held on May 20, 1992. A
second public meeting on this subject was held on July 29, 1992. An ancillary
purpose of this second public meeting was to present to the public the results of
an assessment of the risks posed by the on-site incineration option, which had
been requested at the May 20, 1992 public meeting. However, the July 29, 1992
public meeting was disrupted by a local activist group to the point that the risk

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assessment information could not be 'adequately conveyed to the public. The July
29, 1992 public meeting lasted from 7:00pm until 1 :45am.
Subsequent to the second public meeting, and due to concerns expressed by
members of the public and by elected officials, the U.S. EPA decided to alter its
decision-making approach for this site. On August 7, 1992, U.S. EPA mailed an
announcement to members of the public and issued a news release, indicating
that: .
1) U.S. EPA proposed to select an interim remedy for this site, including the
fencing of the contaminated portion of the site and the provision of
alternative potable water supply to potentially affected homes;
2)- The comment period for fencing and alternate water supply would end on
August 31, 1992;
3) The comment period for the remaining portions of the remedy would
remain open until further notice, in order to address community concerns.
The comment period for the remaining portions of the remedy did not close until
February 9, 1993; in total the public comment period was nearly ten months long.
A coalition of various West Chester community groups and residents was formed
after the July 29, 1992 public meeting in order to discuss the Skinner Landfill
cleanup and to meet with the U.S. EPA and Ohio EPA. This coalition includes
representatives from the Township Trustees, the Chamber of Commerce, Citizens
Lobby for Environmental Action Now (C.L.E.A.N), the Lakota School Board, the Old
West Chester Merchants Association, the Union School PTA, the Home Builders
Association, the Firefighters/Service Group, and a number of Township Residents.
The U.S. EPA and Ohio EPA met with this coalition approximately every other
week for a period of three months. Topics discussed before this coalition included:
- site history;
- description of Remedial Investigation results;
- applicability of RCRA regulations;
- applicable or relevant and appropriate requirements for the site remedy;
- viability of containment remedies;
- assessment of site risks;
- proposals for further studies;
- alternative remediation technologies for the lagoon wastes; and
- the remedy selection process.
The discussions held with the Coalition were highly productive and resulted in a
high degree of open communication and consensus-building. As a result of these
discussions, this Coalition issued a unanimous written recommendation that a

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5
containment remedy be implemented at the Skinner site. This recommendation is
available for public review in the Administrative Record.
On January 11, 1993, the U.S. EPA issued a Fact Sheet announcing that its
preferred alternative had changed from Alternative 5 (which included incineration),
to Alternative 3 (a containment remedy that does not include incineration), with
the possible inclusion of soil vapor extraction. This Fact Sheet, along with a press
release and newspaper advertisements, announced that the public comment period
would end on February 9, 1993.
On January 20, 1993, a legal representative of the Potentially Responsible Parties
(PRPs) requested an additional 30-day extension of the public comment period.
This request was denied, because the public comment period had already been
open for flearly ten months.
SCOPE AND ROLE OF THE OPERABLE UNIT WITHIN THE
OVERALL SITE STRA TEGY
The U.S. EPA has organized the remedial action at the Skinner site into two
phases, or "operable units." The first operable unit was an interim action to
protect human health from any potential immediate risks. This was achieved by
fencing the contaminated portions of the site to limit site access, to prevent
ingestion of or direct contact with contaminated soils. This Interim Action also
includes the provision of an alternate potable water supply to potentially affected
downgradient users of groundwater, and groundwater monitoring, to protect the
potentially affected users of groundwater on and near to the site. The Record of
Decision for the first Operable Unit Interim Action was signed by the U.S. EPA
Regional Administrator on September 30, 1992. A Unilateral Administrative Order
for the implementation of the first Operable Unit was issued to 20 Potentially
Responsible Parties (PRPs) on December 9, 1992.
This remedy is the second and final of two operable units for this site. This final
operable unit a"ddresses potential futUre migration of site contaminants into the
groundwater and will limit the potential for direct exposure of site contaminants to
humans through source control measures.
SUMMARY OF SITE CHARACTERISTICS
The site consists of the following contaminant source areas, as shown in Figure 1:
. a former dump, which was used for the disposal of a wide variety of
waste materials;

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. a buried waste lagoon, which was used for the disposal of a wide variety
of liquid wastes and sludges;
. an active metal scrap yard;
. several buried waste pits.
A considerable amount of scrap metal, auto bodies, railroad cars, and associated
junk is scattered over the site. Several residences are located on the site, including
one which is used for child care of several young children.
The site was studied in the course of a two-phased remedial investigation. The
results of these investigations are summarized below.
THE FORMER DUMP
The former dump area was used for the disposal of a variety of wastes, including
demolition debris, household refuse, and assorted scrap. Chemical wastes also
appear to have been disposed of in this area. Aerial photographs taken during the
operation of the dump show piles of drums in various areas of the dump. These
drums, if present, are now buried underneath other types of debris. A well (GW-
22) was installed near the center of the former dump during the Remedial
Investigation. Boring log information from this well indicates that the depth of fill
is approximately 15 feet in this location. Observations at the eastern edge of the
former dump indicated a fill thickness of over 30 feet. The total volume of wastes
within the former dump is estimated to be 120,000 cubic yards. Water samples
collected from GW-22 during the Phase I RI indicate that the most concentrated
groundwater contamination found on the site is in the area beneath the former
dump. This well is now buried under demplition debris deposited on the site by the
Skinners. Ground water contaminants detected in GW-22 include:
Contaminant
Concentration
Phenol
2-methyl phenol
4-methyl phenol
Acetone
1 ,2-dichloroethane
Benzene
Chlorobenzene
Ethylbenzene
2-hexanone
Methylene chloride
Toluene
Xylenes
670 parts per billion (ppb)
450 ppb
350 ppb
4800 ppb
4500 ppb
20,000 ppb
140 ppb
100 ppb
740 ppb
2200 ppb
530 ppb
300 ppb
,

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THE BURIED WASTE LAGOON "AREA
Prior to 1976, a low-lying area containing a pond was used for the disposal of
chemical wastes. Waste haulers were allowed to dump liquid wastes and drums of
solid or semi-solid wastes into the pond, and to stack the drums in an area near
the pond. Site records and deposition testimony of waste haulers indicate that
large quantities of chemical wastes were deposited in the waste lagoon. These
wastes include creosote, paint wastes, ink wastes, and pesticides. Nearby
residents at the time reported that the wastes in the lagoon were causing fires and
chemical odors. The Skinners eventually buried the waste lagoon under a layer of
demolition debris up to 40 feet thick, and the lagoon is now inaccessible to the
public. The debris which has been placed over and around the waste lagoon
consists of wood, plastic, metal, brick, wire, glass, paper and rubber. It is
estimated that 59,000 cubic yards of debris overlies the waste lagoon. The total
volume of materials which are contaminated due to the disposal of wastes in the
lagoon was estimated in the RI/FS to be 107,000 cubic yards.
The total volume of lagoon waste materials which exceed a 1 ()"4 risk level was
estimated in the FS to be 17,000 cubic yards. During the course of the Remedial
Investigation, 19 borings were installed in and around the buried waste lagoon in
order to determine its composition and extent. Those borings which penetrated
the waste lagoon itself encountered tarry materials, oily materials, and sticky,
raspberry and turquoise colored liquids. A ground penetrating radar (GPR) survey
of the lagoon area indicated the presence of a number of buried metallic objects
which may be drums. Chemical analyses of samples of solid and semi-solid
materials collected from borings drilled into the buried waste lagoon indicated the
presence of a wide variety of chemical constituents. Maximum concentrations of
some organic contaminants found in these samples follow:
Contaminant
Toluene
Xylene
Ethylberizene
1,1,2-trichloroethane
1,2-dichloropropane
Benzene
Naphthalene
2-methylnaphthalene
Phenanthrene
Bis(2-ethylhexyl)phthalate
Benzoic acid
Fluoranthene
Pyrene
Concentration
31,000 parts per million (ppm)
200 ppm
98 ppm
370 ppm
340 ppm
60 ppm
610 ppm
220 ppm
110 ppm
150 ppm
1100 ppm
110 ppm
48 ppm

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(continued)
Contaminant
Hexachlorobenzene
Flourene
Phenol
Butylbenzylphthalate
1,3-dichlorobenzene
1,4-dichlorobenzene
Hexachlorobutadiene
Acenaphthene
Benzo(a)anthracene
Chrysene
Hexachlorocyclopentadiene
8
Concentration
480 ppm
34 ppm
26 ppm
25 ppm
230 ppm
180 ppm
68 ppm
7.9 ppm
15 ppm
17 ppm
1100 ppm
Analysis of these same buried waste lagoon samples for pesticides indicated the
presence of the following:
Contaminant
Heptachlor
Endrin ketone
Gamma chlordane
Concentration
52 ppm
84 ppm
44 ppm
The following metals were detected at concentrations considerably above
background levels in the lagoon wastes:
Contaminant
Antimony
Cadmium
Lead
Silver
Thallium
Concentration
23 ppm
56.9 ppm
4360 ppm
13 ppm
1 ppm
Low levels of dioxins, furans, and PCBs were detected in some lagoon waste
samples. The concentrations od dioxins ranged up to approximately 29 parts per
trillion. PCB concentrations ranged up to 1.2 parts per million.

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. .'.'.. ... .~. . ..
9
Two groundwater monitoring wells located downgradient to the southwest of the
lagoon area (GW-20 and B-5) were found to be contaminated. The following are
the maximum concentrations of selected organic contaminants found in samples
collected from these wells:
Contaminant
1,1,2,2-tetrachloroethylene
1,1,2-trichloroethane
1 ,1-dichloroethane
1,2-dichloroethane
1,2-dichloroethene
, ,2-dichloropropane
Benzene
Chloroethane
Chloroform
Trichloroethene
Vinyl chloride
1,3-dichlorobenzene
1,4-dichlorobenzene
Benzoic acid
Bis(chloroethyl)ether
Naphthalene.
Concentration
6 ppb
56 ppb
73 ppb
180 ppb
35 ppb
370 ppb
410 ppb
50 ppb
85 ppb
71 ppb,
48 ppb
, 3 ppb
10 ppb
5 ppb
130 ppb
14 ppb
Many of the contaminants which were found in the groundwater in these wells,
which are located downgradient of the waste lagoon, were also found in the waste
lagoon materials. Furthermore, several of the contaminants found in these wells
were detected in the former dump area, which is upgradient of the buried waste
lagoon. By contrast, groundwater collected upgradient of the former dump did not
contain these contaminants. Therefore, it has been established that the
contamination present in groundwater beneath and downgradient of the former
dump and buried waste lagoon is attributable to the wastes present in the former
dump and waste lagoon.
BURIED PITS AND OTHER CONTAMINA TED SOILS
A low-lying area in the south-central portion of the site, to the east of the Skinner
residence, was used for waste disposal (see Figure 1). Three borings were drilled
in this area, and indicate that the fill materials are up to 18 feet thick. Analysis of
solid materials taken from these borings indicated the presence of relatively low
concentrations of acetone, methylene chloride, pyrene, fluoranthene, and
benzo(b)fIuoranthene (see Table 2-16). The volume of impacted soils in the buried
pit is estimated to be 500 cubic yards.
,

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10

Contaminated soils were also detected near wells GW-29 and GW-38. The
volumes of contaminated soils in these areas are estimated to be 1000 and 1600
cubic yards, respectively.
METAL STORAGE AREA
The area immediately to the west of the former dump is occupied by an active
scrap metal operation. A considerable volume of metal parts, motors, and
structures is present in this area. Soil samples taken from this area indicated the
presence of low levels of several organic contaminants, as would be expected in
any metal scrap yard. Groundwater monitoring wells installed around the metal
storage area indicate that this portion of the site is not a significant source of
groundwater contamination.
SURFACE WA TERS
There are three small ponds on or near the site. The Duck pond straddles the
northern site boundary. The Diving Pond and Trilobite Pond are located
immediately to the west of the metals storage area (see Figure 1).
The Skinner Landfill lies 1.5 miles east of the floodplain of Mill Creek, a major
south-flowing tributary of the Ohio River. Skinner Creek and the East Fork of Mill
Creek flow towards the southwest from the Skinner site into Mill Creek. Dump
Creek borders the former dump to the east, and is partially covered with fill
materials.
Samples of water and sediments taken from the ponds and creeks were collected
and analyzed in the course of the Remedial Investigation. Results of these
analyses indicate that contaminants are present in the creeks at insignificant levels,
and only very low levels i" the ponds. The creek and pond sediments are
contaminated at low concentrations with volatile and semivolatile organic
compounds (see Table 2-16).
Analysis of contaminated groundwater which is being discharged to the East fork
of Mill Creek via leachate seeps indicates the presence of low concentrations of
chloroform, trichloroethane, methylene chloride, benzene and acetone (see Table
2-16).
LEACHATE SEEPS
At several locations along the East Fork of Mill Creek to the south of the buried
waste lagoon and former dump, contaminated groundwater discharges to the
ground surface. These discharges are referred to as leachate seeps. Samples 01

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11
liquids from the leachate seeps were collected and analyzed by the U.S. EPA
during the RI, and subsequently by the Ohio EPA. The maximum concentrations of
these contaminants detected during these several rounds of sampling and analysis
are listed below.
CONTAMINANT
CONCENTRATION
Benzene.
Chloroethane
1 ,1-dichloroethane
Bis (2-chloroethyl)ether
Hexachlorobutadiene
26 parts per billion (ppb)
2 ppb
11 ppb
120 ppb
0.016 ppb
SITE GEOLOGY AND HYDROGEOLOGY
Subsurface materials at the Skinner Landfill are quite variable throughout the site.
This variability affects the manner in which chemicals move through the ground.
The unconsolidated glacial sediments that underlie the Skinner Landfill are a
mixture of soil types ranging from clay-rich to gravel-rich soils, and are from zero
to 40 feet thick. Soils under the northern and western parts of the buried waste
lagoon consist of low-permeability silty clays. The soils underlying the southern
and southeastern parts of the buried lagoon are more permeable silty sand and
gravel deposits. Soil boring samples collected from the buried lagoon area show
that the highest concentrations of organic chemicals underlie the southern part of
the lagoon. The more permeable soils underlying this part of the lagoon may
enable the chemicals to more readily migrate through the soil into the groundwater.
Those chemicals, such as volatile and some semi-volatile organic compounds, are
mobile and can be transported through permeable sand and gravel .soils underlying
parts of the buried lagoon. It is clear from the groundwater monitoring data that
chemicals from the buried waste lagoon and former dump are moving through the
soil and waste into the on-site groundwater.
Groundwater at the site is contained in either the glacial sediment aquifer or the
bedrock aquifer. Groundwater flow at the Skinner site is complicated by the site
geology, especially the extreme variability in the nature of the sediments that
comprise the unconsolidated glacial materials underlying most of the site. The
glacial deposits include a number of discontinuous zones of silty to clayey
materials, and layers of sand and gravel. Depth of the water table on site varies
from as shallow as 0-6 feet below the surface in the Skinner Creek valley to as
deep as 30-40 feet below the ground surface immediately to the south of the
buried lagoon. The porous and permeable sand and gravel deposits on site readily
store and transmit groundwater, which may contribute to the migration of site
contaminants. The low-permeability silty clays, as well as the underlying

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interbedded shale-limestone bedrock, are poor transmitters and producers of
groundwater, and thus limit the movement of groundwater and contaminants.
Groundwater movement is restricted by site geology and topography in all
directions except toward the southwest.
On-site aquifers discharge to the on-site streams, thereby providing a mechanism
for transport of .chemicals off-site. However, significant off-site migration of
contaminants appears !121 to have occurred to date. Monitoring data indicate the
presence of low concentrations of site-related chemicals in on-site ponds and very
low levels in on-site streams. .
SUMMARY OF SITE RISKS
Because the Skinner Landfill accepted a variety of wastes from 1934 until it was
closed in 1990, numerous chemicals are present at the site. Following the RI, U.S.
EP A conducted an evaluation to estimate the potential health or environmental
problems that could result if the site was not remediated. This analysis is referred
to as the Baseline Risk Assessment (RA). U.S EPA evaluated the health risks
associated with 114 different contaminants. A list of these chemicals is attached
as Table 2-16, and includes inorganic, volatile and semi-volatile organic chemicals,
pesticides, polychlorinated biphenyls (PCBs), polynuclear aromatic hydrocarbons
(PAHs), dioxins and furans. Those contaminants contributing the most
significantly to current and future site risks included: volatile organics, such as
carbon tetrachloride, vinyl chloride, benzene, chloroform, dichloroethene and bis (2-
chloroethyl) ether; pesticides, such as heptachlor, aldrin, dieldrin, chlordane,
chlordene, and hexachlorobenzene; PCBs, specifically Arochlor 1254; and
inorganics, such as arsenic and cobalt.
EXPOSURE PA THWA YS
The potential migration pathways for site contaminants include leaching from the
soils to the ground water, movement of contaminated ground water to surface
water and sediments, and volatilization of chemicals to air from water and soils.
The air pathway is not considered significant for this site under present conditions.
Sampling has Indicated that concentrations of volatile chemicals in surface soils
and water do not represent a significant source of concern for air. Additionally,
the depth of contaminated soils in the waste lagoon limits the emission of these
chemicals to air.
Currently, the only evidence of contaminants potentially leaving the site through
groundwater migration is the detection of 5 ppb of ethylbenzene in monitoring well
GW-24, which is located across the East Fork of Mill Creek from the buried lagoon
(see Figure 1). The only potential off-site routes of migration for surface water and

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13
surface water sediments are through the East Fork of Mill Creek and Skinner Creek.
The leachate seeps which discharge into the East Fork of Mill Creek appear to
originate from within the buried waste lagoon and the former dump and clearly
indicate a pathway for off-site migration of contaminants.
The Risk Assessment showed that the potential routes of current and future
exposure include: ingestion of and direct contact with contaminated soils; ingestion
of affected groundwater; dermal contact with groundwater; inhalation <.!f chemicals
that volatilize from groundwater to air during showering; and, ingestion of and
direct contact with surface water and sediments during recreational activities.
Inhalation of fugitive dust and volatile chemicals was also evaluated qualitatively as
a potential exposure route but did not warrant a quantitative assessment because
emissions from surface soil would likely be low. This is because the most
contaminated portion of the site, the buried waste lagoon, is covered by up to 40
feet of demolition debris and is not considered a source of air risk under the current
conditions.
HUMAN HEAL TH RISK
Human health risks at Superfund sites are typically assessed with respect to both
carcinogenic and noncarcinogenic adverse effects of a chemical, under current and
future exposure scenarios. The current and potentially exposed populations are
occupational workers at the site, residents living on and near the site, and persons
who may recreate in the area. Cancer risks from various exposure pathways are
assumed to be additive. . The Risk Assessment showed that currently none of the
residents living, working, recreating, or attending school Mi[ the site are exposed
to any site-related risks considered unacceptable by the U.S. EPA. Unacceptable
risks are those that may result in one additional cancer case in 10,000 to
1,000,000 people (10-4 to 10") exposed over a lifetime (70 years). However, the
risks to persons currently living, working or recreating gn the site are considered
unacceptable in that they exceed one additional cancer case in 100 persons
exposed over a lifetime.

The primary future potentially exposed populations are residential, recreational and
occupational. The risks for the future potentially exposed residential population
were assessed using both the assumptions that the waste lagoon was and was not
developed for residential use. The future risks calculated for persons living,
working, or recreating at the site were considered unacceptable in that they
exceeded U.S. EPA's acceptable risk range. The risks using the assumption that
the waste lagoon was not developed for future residential use were slightly lower,
but still exceeded one in 1,000.
Non-cancer risks are evaluated with respect to a hazard quotient, which is the ratio
of the level of exposure to an acceptable level. If the hazard quotient for an

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14
exposed individual or group exceeds 1.0 for a particular chemical, there may be
non-cancer health effects resulting from the exposure to that chemical. If the
hazard index, which is the sum of the hazard quotients for all chemicals in a
particular medium, exceeds 1.0 there may be a concern for potential health effects
from exposure to that medium. The RA showed that the hazard indices at the
Skinner site exceeded 1.0, suggesting that both current and future exposures to
chemicals of concern on the site may result in excess noncancer risks to all
populations.
ENVIRONMENTAL RISK
The potential future impacts of the site wastes on the East Fork of Mill Creek were
estimated in the Risk Assessment. It was projected that, under the -No Action-
scenario, surface water standards may be exceeded in the future in the East Fork
of Mill Creek for the following compounds: benzene, carbon tetrachloride,
chloroform, 1,1 ,2,2-tetrachloroethane, toluene, 1,1, 1-trichloroethane, 1,1,2-
trichloroethane, trichloroethene, bis(2-chloroethyl)ether, phenol, aldrin, dieldrin, and
Aroclor 1254.
The Ohio EPA Division of Water Quality, Planning, and Assessment (DWQPA)
recently completed a biological and water quality study of the Mill Creek Basin.
Sampling sites for the East Fork of Mill Creek included two areas which bracketed
the Skinner landfill site. Both sampling sites exhibited good habitat conditions. No
impairment of the fish community was observed at the sampling location
immediately downstream of the Skinner landfill site. No violations of water quality
standards were detected either upstream or downstream of the landfill.
Actual or threatened releases of hazardous substances from this site, if not
addressed by implementing the response action selected in this ROD, may present
an imminent and substantial endangerment to public health, welfare, and the
environment.
DESCRIPTION OF AL TERNA TIVES
The proposed plan for this site presented five alternatives. Remedial alternatives
were assembled from applicable remedial technology process options and were
initially evaluated for effectiveness, implementability, and cost. The alternatives
meeting these criteria were then evaluated and compared to the nine criteria as
required by the NCP. The first was a no action alternative, which is evaluated at
all Superfund sites in order to assess the potential risk to the public if no cleanup
was done. The no action alternative serves primarily as a point of comparison for
other alternatives. The other four alternatives evaluated a range of source control
,

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15
response options. Each of the options, excepting the wno actionw alternative,
included identical provisions for fencing and provision of an alternate potable water
supply. Since the fencing and provision of an alternate potable water supply were
addressed in the first operable unit interim action ROD, they are not included in the
following descriptions of alternatives.
AL TERNA TIVE 7 NO ACTION
The Superfund program requires that the wno actionw alternative be considered at
every site. Under this alternative, the U.S. EPA would take no action to control
the site or to limit the potential migration of the wastes. There are no costs
associated with the no action alternative.
AL TERNA TIVE 2
. EXCA VA TION AND ON-SITE INCINERA TION OF BURIED WASTE LAGOON
SOILS
. MUL TI-LA YERED CAPPING OF REMAINING WASTE MA TERIALS
. COLLECTION AND TREA TMENT OF CONTAMINA TED GROUNDWA TER
. DIVERSION OF UP-GRADIENT GROUNDWA TER FLOW
. DEED RESTRICTIONS
Under this option, the waste materials in the buried waste lagoon which exceed
the 10" risk level would be excavated and treated using an on-site incinerator. A
mobile incinerator would be brought onto the site, and operated for approximately
seven months in accordance with ARARs relating to RCRA Hazardous Waste
incinerators. An estimated 17,000 cubic yards of lagoon waste materials would be
incinerated. The resultant ash would be disposed of on-site in a lined cell and
stabilized, if necessary. Treatability testing would be required in order to
implement the design of the incinerator and for stabilization of the ash.
A multi-Iayere~ RCRA cap would be constructed over the area covered by the
former dump and the buried waste lagoon. The cap would consist of the following
layers, starting at the bottom:
. Immediately above the waste materials, a layer of permeable materials
such as sand would be installed, if necessary, for the purpose of venting the
gases which result from the decomposition of waste materials. It is possible
that the existing cover materials would adequately perform this function,
and that construction of a venting layer would not be necessary;
. A twenty-four inch thick layer of clay would be installed, and constructed
in a manner which would achieve a maximum permeability of 10.7 cm/sec;
. A thirty mil thick flexible membrane would be installed over the clay layer;

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- -_. .. - ...
~ - - .. .--- .. . .-
16
. A drainage layer would be installed over the membrane. This can be
achieved using six inches of sand with a geotextile fabric base, or by using
various commercially available synthetic products;
. An intrusion barrier would overlie the drainage layer. This is intended to
limit the possibility of intrusion into the waste materials by burrowing
animals. This would typically be composed of six inches of cobbles and six
inches of gravel;
. A twenty inch thick layer of soil would be installed on the top of the
intrusion barrier;
. Vegetatation would be planted and maintained on the cap, in a manner so
as to minimize the potential for erosion.
In order to prevent damage to the clay layer through frost penetration, the top of
the clay layer would be at least 30 inches below the top surface of the cap.
Any contaminated materials outside of the area to be capped, such as the waste
pit soils, would be dug up and moved onto the area to be covered by the cap. The
cap design would provide for the venting of gases from the waste materials.
Groundwater in the unconsolidated materials would be prevented from flowing
onto the site from the upgradient direction. This may be achieved by installing a
barrier wall, such as a slurry wall, vibrating beam, or grout curtain.
Contaminated groundwater which flows from the site toward the East Fork of Mill
Creek would be intercepted, collected, treated and then discharged. Discharge
options for the treated groundwater would be evaluated during the remedial
design. The treated water would be required to meet ARARs (see Attachment 3)
The site would be monitored for migration of contaminants to groundwater and
surface water. Site-specific groundwater trigger levels are given in Table 1
(attached).
Deed restrictions would be emplaced, which would limit the potential for activities
which would tend to interfere with the performance of the remedy.
Capital Costs: $22,810,000
Annual 0 & M Costs: $382,000
Net Present Value Cost: $28,700,000

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--" ..--......-.
17
AL TERNA T/VE 3
. CONSOLIDA TION AND MUL TI-LA YERED CAPPING OF WASTE
MA TERIALS
. COLLECTION AND TREA TMENT OF CONTAMINA TED GROUNDWA TER
. DIVERSION OF UP-GRADIENT GROUNDWA TER FLOW
. DEED RESTRICTIONS
A multi-layered RCRA cap would be constructed over the area covered by the
former dump and the buried waste lagoon. The cap would consist of the following
layers, starting at the bottom:
. Immediately above the waste materials, a layer of permeable materials
such as sand would be installed, if necessary, for the purpose of venting the
gases which result from the decomposition of waste materials. It is possible
that the existing cover materials would adequately perform this function,
and that construction of a venting layer would not be necessary;
. A twenty-four inch thick layer of clay would be installed, and constructed
in a manner which would achieve a maximum permeability of 10.7 em/see;
. A thirty mil thick flexible membrane would be installed over the clay layer;
. A drainage layer would be installed over the membrane. This may be
achieved using six inches of sand with a geotextile fabric base, or by using
various commercially available synthetic products;
. An intrusion barrier would overlie the drainage layer. This is intended to
limit the possibility of intrusion into the waste materials by burrowing
animals. This would typically be composed of six inches of cobbles and six
inches of gravel;
. A twenty inch thick layer of soil would be installed on the top of the
intrusion barrier;
. Vegetatation would be planted and maintained on the cap, in a manner so
as to minimize the potential for erosion.
In order to prevent damage to the clay layer through frost penetration, the top of
the clay layer would be at least 30 inches below the top surface of the cap.
Any contaminated materials outside of the area to be capped, such as the waste
pit soils, would be dug up and moved onto the area to be covered by the cap. The
cap design would provide for the venting of gases from the waste materials.
Groundwater in the unconsolidated materials would be prevented from flowing
onto the site from the upgradient direction. This may be achieved by installing a
barrier wall, such as a slurry wall, vibrating beam, or grout curtain.

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18
Contaminated groundwater which flows from the site toward the East Fork of Mill
Creek would be intercepted, collected, treated and then discharged. Discharge
options for the treated groundwater would be evaluated during the remedial
design. The treated water would be required to meet ARARs (see Attachment 3)
The site would be monitored for migration of contaminants to groundwater and
surface water. Site-specific groundwater trigger levels are given in Table 1
(attached).. .
Deed restrictions would be emplaced, which would limit the potential for activities
which would tend to interfere with the performance of the remedy.
The addition of soil vapor extraction in the area near to and underneath the buried
waste lagoon to alternative three was suggested during the public comment period.
This addition is discussed below.
Capital Costs: $9,619,000
Annual 0 & M Costs: $382,000
Net Present Value Cost: $15,500,000
SOIL VAPOR EXTRACTION
During the public comment period, it was suggested that extraction of the volatile
organic vapors from the permeable materials surrounding the lagoon wastes be
considered as an addition to alternative #3. Soil Vapor Extraction has previously
been a component of Alternative 5 only; these costs are already included in
Alternative 5. Soil vapor extraction is a technology whereby air containing organic
vapors is pumped out of the ground. The air is then treated to meet air emission
standards prior to release.
Capital Costs: $81,900
Annual 0 & M Costs: $15,000
Net Present Value Cost: $531,900
COSTS OF AL TERNA TlVE 3 WITH THE INCLUSION OF SOIL VAPOR
EXTRACTION
Capital Costs: $9,700,900
Annual 0 & M Costs: $397,000
Net Present Value Cost: $16,031,900

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- - ,.~ - - .. .
19
AL TERNA TlVE 4
. CONSOLIDA TlON AND SINGLE-LA YERED CAPPING OF WASTE
MA TERIALS
. COLLECTION AND TREA TMENT OF CONTAMINA TED GROUNDWA TER
. DIVERSION OF UP-GRADIENT GROUNDWA TER FLOW
. DEED RESTRICTIONS
A single-layered cap would be constructed over the area covered by the former
dump and the former waste lagoon. This would consist of the following layers,
starting from the bottom:
. twenty four inches of clay;
. a thirty mil polymeric membrane;
. six inches of sand with a geotextile fabric base;
. a biotic barrier consisting of six inches of, cobbles and six inches of gravel;
. a second geotextile layer;
. twenty inches of topsoil, and
. vegetation.
Any contaminated materials outside of the area to be capped, such as the waste
pit soils, would be dug up and moved onto the area to be covered by the cap.
Groundwater in the unconsolidated materials would be prevented from flowing
onto the site from the upgradient direction. This may be achieved by installing a
barrier wall, such as a slurry wall, vibrating beam, or grout curtain.
Contaminated groundwater which flows from the site toward the East Fork of Mill
Creek would be intercepted, collected, treated and then discharged. Discharge
options for the treated groundwater would be evaluated during the remedial
design. The treated water would be required to meet ARARs (see Attachment 3)
The site would be monitored for migration of contaminants to groundwater and
surface water. Site-specific groundwater trigger levels are given in Table 1
(attached).
Deed restrictions would be emplaced, which would limit the potential for activities
which would tend to interfere with the performance 01 the remedy.
Capital Costs: $8,914,000
Annual O&M Costs: $382,000
Net Present Value Cost: $14,800,000
,~-~ /

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20
AL TERNA TNE 5

. EXCA VA TION AND ON-SITE INCINERA TION OF BURIED WASTE LAGOON
SOILS
. MUL TI-LA YERED CAPPING OF REMAINING WASTE MA TERIALS
. COLLECTION AND TREA TMENT OF CONTAMINA TED GROUNDWA TER
. DNERSION OF UP-GRADIENT GROUNDWA TER FLOW
. SOIL VApOR EXTRACTION
. DEED RESTRICTIONS
Under this option, the waste materials in the buried waste lagoon which exceed
the 1 0" risk level would be excavated and treated using an on-site incinerator. A
mobile incinerator would be brought onto the site, and operated for approximately
seven menths in accordance with ARARs relating to RCRA Hazardous Waste
incinerators. An estimated 17,000 cubic yards of lagoon waste materials would be
incinerated. The resultant ash would be disposed of on-site in a lined cell and
stabilized, if necessary. Treatability testing would be required in order to
implement the design of the incinerator and for stabilization of the ash.
A multi-layered RCRA cap would be constructed over the area covered by the
former dump and the buried waste lagoon. The cap would consist of the following
layers, starting at the bottom: .
. Immediately above the waste materials, a layer of permeable materials
such as sand would be installed, if necessary, for the purpose of venting the
gases which result from the decomposition of waste materials. It is possible
that the existing cover materials would adequately perform this function,
and that construction of a venting layer would not be necessary;
. A twenty-four inch thick layer of clay would be installed, and constructed
in a manner which would achieve a maximum permeability of 10-7 cm/sec;
. A thirty mil thick flexible membrane would be installed over the clay layer;
. A drainage layer would be installed over the membrane. This may be
achieved using six inches of sand with a geotextile fabric base, or by using
various commercially available synthetic products;
. An intrusion barrier would overlie the drainage layer. This is intended to
limit the possibility of intrusion into the waste materials by burrowing
animals. This would typically be composed of six inches of cobbles and six
inches of gravel;
. A twenty inch thick layer of soil would be installed on the top of the
intrusion barrier;
. Vegetatation would be planted and maintained on the cap, in a manner so
as to minimize the potential for erosion.
In order to prevent damage to the clay layer through frost penetration, the top of

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21
the clay layer would be at least 30 inches below the top surface of the cap.
Any contaminated materials outside of the area to be capped, such as the waste
pit soils, would be dug up and moved onto the area to be covered by the cap. The
cap design would provide for the venting of gases from the waste materials.
Groundwater in the unconsolidated materials would be prevented from flowing
onto the site from the upgradient direction. This may be achieved by in~talling a
barrier wall, such as a slurry wall, vibrating beam, or grout curtain.
Contaminated groundwater which flows from the site toward the East Fork of Mill
Creek would be intercepted, collected, treated and then discharged. Discharge
options for the treated groundwater would be evaluated during the remedial
design. The treated water would be required to meet ARARs (see Attachment 3)
The site would be monitored for migration of contaminants to groundwater and
surface water. Site-specific groundwater trigger levels are given in Table 1
(attached).
Deed restrictions would be emplaced, which would limit the potential for activities
which would tend to interfere with the performance of the remedy.
Volatile organic vapors from the permeable soils in the area around the buried
waste lagoon would be treated using Soil Vapor Extraction. Volatiles would be
withdrawn from the ground and treated.
Capital Costs: $22,920,000
Annual 0 & M Costs: $397,000
Net Present Value Cost $29,000,000
SUMMARY OF COMPARA TIVE ANAL YSIS OF
AL TERNA TIVES
The remedial alternatives developed during the Feasibility Study were evaluated by
the U.S. EPA using the following nine criteria. The advantages and disadvantages
of each alternative were then compared to determine which alternative provided
the best balance among these nine criteria. These criteria are set forth in the
National Contingency Plan, 40 CFR Part 300.430.

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CRITERION 1: OVERALL PROTECTION OF HUMAN HEAL TH AND THE
ENVIRONMENT
Overall Protection of Human Health and the Environment addresses whether
a remedy provides adequate protection and describes how risks through
each pathway are eliminated, reduced or controlled through treatment,
engineering controls or institutional controls.
The cap and groundwater controls which are included in alternatives 2
through 5 provide protection of human health and the environment by
reducing the potential for migration of contaminants away from the site.
The m'ulti-Iayered cap (Alternatives 2, 3 and 5) will provide a greater
reduction of infiltration of water through the waste materials than would be
provided by the single layered cap (Alternative 4), and therefore will provide
a greater reduction in the potential for migration of contaminants away from
the site. The cap, in conjunction with the fencing and deed restrictions, will
effectively prevent people from physically contacting the wastes.
Incineration of the materials in the buried waste lagoon (Alternatives 2 and
5) would destroy the organic components of the lagoon wastes, and
therefore eliminate any potential for future off-site migration of these
materials. Additionally, the potential stabilization of the ash resulting from
the incineration process would provide effective immobilization of any
inorganic materials which remained.
However, it must be recognized that the lagoo,; wastes are only a portion of
the contaminated materials which are present at the site. Under any
alternative, all of the contaminated materials in the former dump will remain
on-site. While incineration of the waste lagoon materials would eliminate
the possibility of future migration of the organic lagoon wastes, it would not
affect the large amount of remaining contaminated materials.
CRITERION 2: COMPUANCE WITH APPUCABLE OR RELEVANT AND
APPROPRIA TE REQUIREMENTS
CompDance with AppHcable or Relevant and Appropriate Requirements
addresses whether or not a remedy will meet all of the applicable or relevant
and appropriate requirements (ARARsJ or other environmental statutes
and/or provide grounds for invoking a waiver.
..
Applicable requirements are those cleanup standards of control, and other
substantive requirements, criteria, or limitations promulgated under Federal

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or State environmental or facilitY siting law that specifically address a
hazardous substance, pollutant. .:ontaminant, remedial action, location, or
other circumstance at a CERCLA site. Relevant and appropriate
requirements are those cleanup standards, standards of control, and other
substantive requirements, criteria, or limitations promulgated under Federal
or State environmental siting law that, while not "applicable" to a hazardous
substance, pollutant, contaminant, remedial action, location, or other
circumstance at a CERCLA site, address problems or situations sufficiently
similar to those encountered at the CERCLA site that their use is well suited
to this particular site. ARARs are divided into chemical specific, action
specific, and location specific groups.
A State of Ohio facility siting law containing a facility-setback provision has
been identified as a potential ARAR for alternatives 2 and 5. This law,
found at Ohio Rev. Code Sec. 3734.05(D)(6)(g), has been referred to as the
"2000-foot rule". The law prohibits, with various exceptions, the location of
a new hazardous waste facility within 2000 feet of any residence, school,
hospital, jail, or prison.
A waiver of this provision may have been required for the implementation of
either of the alternatives which include incineration (alternatives 2 and 5),
due to the specific administrative requirements of this provision. A waiver is
not necessary for the location of a soil vapor extraction system within the
setback zone, because such system is not a 8hazardous waste facility"
within the meaning of Ohio law.
CRITERION 3: LONG- TERM EFFECTNENESS ~ND PERMANENCE
Long-term Effectiveness and Permanence refers to the ability of a remedy to
maintain reliable protection of human health and the environment over time.
This criterion includes the consideration of residual risk and the adequacy
and relitibility of controls.
All of the alternatives, with the exception of the No Action alternative, are
believed to result in minimal residual risk. All of the alternatives are
designed to limit the. potential for the future migration of contaminants off of
the site.
Alternat!ves 2 and 5 would achieve permanent destruction of the most toxic
and hazardous organic wastes within the buried waste la900n through
incineration.

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Alternative 5 and alternative 3, 'as modified, provide for permanent removal
and destruction of volatile organic compounds drawn from the permeable
materials which underlie portions of the buried waste lagoon through soil
vapor extraction.
The capping and groundwater controls which are components of alternatives
2 through 5 are considered to be effective over the long term for the
minimization of contaminant migration and the prevention of surf,!lce
exposure, but will require long-term maintenance and monitoring in order to
retain their effectiveness.
Under any alternative, all of the contaminated materials in the former dump
will remain on-site. While incineration of the waste lagoon materials would
achieve permanent destruction of the organic wastes in the buried waste
lagoon, it would not affect the large amount of remaining contaminated
materials.
CRITERION 4: REDUCTION IN TOXICITY, MOBIUTY OR VOLUME
Reduction 01 Toxicity, Mob/7ity 01 Volume is the anticipated performance of
the treatment technologies a remedy may employ.
Reductions in the Toxicity of wastes on the site would be achieved through
those alternatives which include incineration and/or treatment of materials
removed through soil vapor extraction (Alternatives 2 and 5). Toxicity
would be reduced by thermally destroying the organic waste materials.
All of the alternatives, with the exception of the No Action alternative, are
believed to provide reductions in the mobility of the waste materials, through
capping and control of contaminated groundwater. The options which
include a multi-layered cap (numbers 2, 3, and 5) have a slight advantage
over alternative 4, which relies on a single-layered cap. This is because the
infiltration of precipitation through the waste materials would be reduced to
a greater extent by a multi-layered cap than it would be by a single-layered
cap.
Reduction in the Toxicity, Mobility and Volume of contaminants found in the
groundwater will be achieved through treatment of contaminated
groundwater.
The incineration alternatives would eliminate any potential for future mobility
of the organic contaminants within the lagoon wastes, because these
materials would be destroyed. The incineration alternatives would also

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provide for reduction in the mobility of metals in the lagoon wastes, if the
incinerator ash was stabilized.
Soil Vapor Extraction would provide for the removal of volatile organic
contaminants from the area around the waste lagoon. These volatile
compounds will then be collected and treated. This would provide for
reduction in toxicity, mobility, and volume of volatile organic contaminants.
CRITERION 5: SHORT-TERM EFFECTNENESS
Shan-term Effectiveness relers to the period 01 time needed to complete the
remedy and any adverse impact on human health and the environment that
may be posed during the construction and implementation of the remedy.
Alternatives 2 and 5 involve excavation and incineration of the buried waste
lagoon materials. Short-term risks are associated with these portions of the
remedial action. This is largely because of the presence of a large variety of
contaminants within the waste lagoon, which could potentially be released
to the environment during excavation. These releases could be mitigated to
a large degree through engineering controls such as physical enclosures, or
through application of liquids or foam to cover the exposed areas. Short-
term risks associated with the incineration were projected to fall within the
acceptable risk range.
Alternatives 2 through 5 include the excavation and movement of
contaminated soils from outside of the area to be capped to the capped
area. This is expected to result in minimal short-term risks. Some
movement of materials within the area to be capped may also be required in
order to maintain acceptable slopes. This movement will be conducted in a
manner which will limit the disturbance of waste materials.
The remedial construction for the containment alternatives (Alternatives 3
and 4) is projected to last 1 to 2 years. The remedial construction for the
alternatives which include incineration (Alternatives 2 and 5) is projected to
last 3 to 4 years. Considerable administrative delays may have been
encountered during the implementation of incineration at this site, thereby
decreasing the short-term effectiveness.

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CRITERION 6: IMPLEMENT ABILITY
Implementabl7ity is the technical and administrative feasibility of a remedy,
including the availability of goods and services needed to implement the
chosen solution.
All of the alternatives (except the No Action alternative) are composed of
proven, off-the-shelf technologies, and are therefore considered technically
implementable.
Practically, the administrative implementability of an incineration remedy for
this site is poor. It appears likely that many years of administrative effort
could be required before incineration would be implemented at this site.
Intense community relations efforts would be required, and extensive legal
challenges could reasonably be anticipated.
CRITERION 7: COST
Cost includes capital and operation and maintenance costs.
The costs of the alternatives were calculated in the Feasibility Study, and
are listed below:
ALTERNATIVE 1
No Cost
ALTERNATIVE 2
Capital Costs: $22,810,000
Aflnual 0 & M Costs: $382,000
Net Present Value Cost: $28,700,000
ALTERNATIVE 3
Capital Costs: $9,619,000
Annual 0 & M Costs: $382,000
Net Present Value Cost: $15,500,000

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27
ALTERNATIVE 3 WITH SOIL VAPOR EXTRACTION
Capital Costs: $9,700,900
Annual 0 & M Costs: $397,000
Net Present Value Cost: $16,031,900
ALTERNATIVE 4
Capital Costs: $8,914,000
Annual O&M Costs: $382,000
Net Present Value Cost: $14,800,000
AL:rERNA TIVE 5
Capital Costs: $22,920,000
Annual 0 & M Costs: $397,000
Net Present Value Cost: $29,000,000
CRITERION 8: STA TE ACCEPTANCE
State Acceptance indicates whether, based on its review of the RifFS and
Proposed Plan, the State of Ohio concurs, opposes, or has no comment on
the preferred alternative.
The State of Ohio concurs with the selected remedy.
CRITERION 9: COMMUNITY ACCEPTANCE
Community Acceptance is assessed in the Record of Decision following a
review of the public comments received on the FS report and the Proposed
Plan. .
The Skinner Landfill Coalition, representing a cross-section of the
community, has recommended a containment remedy which closely parallels
the selected alternative.
Many comments were made during the public comment period in opposition
to incineration. Some commenters expressed support for incineration. The
U.S. EPA continues to believe that incineration is a viable and effective
technology which could be safely applied at the Skinner site. However, U.S.
EP A does not believe that community acceptance of incineration can be

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readily obtained at the Skinner site.
Public reaction to U.S. EPA's announcement of a shift in preference from
incineration to containment was generally favorable. Community acceptance
of the selected remedy appears to be strong.
SELECTED REMEDY: AL TERNA TIVE 3 WITH THE INCLUSION
OF SOIL VAPOR EXTRACTION
Capping
-
A multi-layered RCRA cap will be constructed over the area covered by the former
dump and the buried waste lagoon. The minimum extent of this cap is shown in
Figure 2. The purpose of this cap is to minimize the infiltration of water from
precipitation through the contaminated waste materials. The cap will consist of
the following layers, starting at the bottom:
. Immediately above the waste materials, a layer of permeable materials
such as sand will be installed, if necessary, for the purpose of venting the
gases which result from the decomposition of waste materials. It is possible
that the existing cover materials will adequately perform this function, and
that construction of a venting layer will not be necessary;
. A twenty-four inch thick layer of clay will be installed, and constructed in
a manner which will achieve a maximum permeability of 10.7 cm/sec;
. A thirty mil thick flexible membrane will be installed over the clay layer;
. A drainage layer will be installed over the membrane. This may be
achieved using six inches of sand with a geotextile fabric base, or by using
various commercially available synthetic products;
. An intrusion barrier will overlie the drainage layer. This is intended to limit
the possibility of intrusion into the waste materials by burrowing animals.
This wil~ typically be composed of six inches of cobbles and six inches of
gravel;
. A twenty inch thick layer of soil will be installed on the top of the
intrusion barrier;
. Vegetatation will be planted and maintained on the cap, in a manner so as
to minimize the potential for erosion.
In order to prevent damage to the clay layer through frost penetration, the cap
shall be constructed so that the top of the clay layer is at least 30 inches below
the top surface of the cap.
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Any contaminated materials outside 01 the area to be capped, such as the waste
pit soils, will be dug up and moved onto the area to be covered by the cap. The
cap design will provide for the venting of gases from the waste materials.
The cap will be constructed so that the slope will not exceed 5% to the maximum
extent practicable. However, this will not be possible in certain portions of the
site, such as the eastern edge of the former dump, where there is a precipitous
drop-off. In order to provide a structurally stable cap in these areas, it is
anticipated that concrete retaining walls or similar structures will need to be
constructed. It is possible that some waste materials will have to be moved in
order to facilitate the construction of the cap. The cap shall be designed in a
manner which will minimize the amount of contaminated waste materials to be
moved. Any such movement will be conducted in such as manner so as to
minimize-the release of contaminants to the environment.
Contaminated soils and waste materials from the buried pit area which exceed the
concentrations listed in Table 2 shall be excavated and placed under the cap. Soils
in the areas near wells GW-29 and GW-38 (see Figure 1) shall be evaluated for
potential consolidation under the cap. In the course of the remediation, it is
possible that other contaminated areas which lie outside of the capped area will be
encountered. Any such additional materials may be consolidated under the cap.
Downgradient groundwBter control
Contaminated groundwater downgradient of the area to be capped will be
intercepted, captured, and treated.
. Interception of contaminated groundwater: Contaminated groundwater is
present downgradient of the area to be capped. Contaminated groundwater
shall be defined as that which contains contaminant concentrations
exceeding the values listed in Table 1. This contaminated groundwater shall
be intercepted and captured. Conceptually, this may be achieved by
installing an underground barrier wall and collection trench downgradient of
the waste materials. Common barrier wall construction techniques include
slurry walls, vibrating beams, and grout curtains. This interception may also
be achieved through the pumping of groundwater extraction wells. The
system shall be designed to assure that no groundwater which contains
contaminants exceeding the site-specific groundwater trigger levels given in
Table 1 (attached) is allowed to pass into or underneath the East Fork of Mill
Creek.
. Treatment of contaminated groundwater: Contaminated groundwater
from the site must be removed from the ground and treated prior to
discharge. This may be achieved through the use of an on-site wastewater

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_.~_.., ~ - _. . -~ . . - ~- -
30
treatment plant. The discharge must meet ARARs (see attachment AI.
Depending on the volumes of wastewater involved, it may be economical to
transport the wastewater off-site for treatment in a permitted facility. In this
case, the discharge will have to meet the limits of the facility's permit.
In the course of the design, it may be determined by U.S.EPA that the capture of
contaminated groundwater from areas of the site other than immediately
downgradient of the area to be capped will be necessary.
Upgradient groundwater control
Currently, groundwater flows into the site from upgradient and becomes
contaminated as it flows through the site. Additionally, it appears that some
contaminated waste materials are in contact with the groundwater, and are
therefore causing contamination of the groundwater. Therefore, the flow of
groundwater onto the site shall be controlled, as will the level of groundwater
underneath the cap, so that contaminated materials are no longer in contact with
the groundwater. One method to achieve this is by installing a barrier wall
upgradient of the former dump and waste lagoon. There are several types of
barrier walls, including slurry walls, vibrating beams, and grout curtains. It may be
necessary to obtain an easement along the northern site boundary in order to
install the cap and to implement the upgradient groundwater control. Installation
of the cap may cause a sufficient depression of the water table beneath the cap,
thereby fulfilling the function of upgradient groundwater control.
Soil Vapor Extraction
Soil Vapor Extraction (SVE) is a technology by which volatile organic vapors and air
found in the pore spaces in the soil underground are extracted, and then treated
before discharge to the atmosphere. The waste lagoon is underlain in some areas
by a permeable, sandy material, from which it appears possible to extract volatile
organic vapors. If feasible, such extraction will help to control the potential for
migration of contaminants away from the waste lagoon.
As part of the design of this remedy, an investigation of the feasibility of
conducting SVE in the area surrounding the buried waste lagoon will be performed.
If U.S. EPA determines that this technology is implementable and effective based
upon the results of this investigation, then it will be implemented.
Institutional Controls
This remedy includes institutional controls to limit the future use of all areas of the
site where remedial construction has occurred. These areas will include the area
covered by the cap, any barrier walls, water treatment systems, extraction wells,

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31
etc. The restrictions must prevent the use of this portion of the site for any
activity which will interfere with the performance of the remedy, or which will
result in the exposure of contaminants to humans or the environment. Such
activities include residential or recreational use, excavation, or construction of
wells. U.S. EPA will seek to prevent all individuals from traversing the cap, once
completed, sot that the cap will not be damaged. The U.S. EPA will seek deed
restrictions from the site owner as a means to impose these limitations on the use
of the property..
In the event that institutional controls cannot be implemented effectively, the
U.S. EPA and Ohio EPA will consider additional actions as necessary to ensure that
the remedy remains effective on a long-term basis.
Monitoring
Since a large volume of potentially mobile contaminants will be left on this site,
routes by which contaminants will migrate through the ground must be monitored
following construction of this remedy. This shall include monitoring of
groundwater and surface waters, and monitoring for the potential migration of
Dense, Non-Aqueous Phase Liquid (DNAPL) contamination from the site. DNAPLs
are contaminants such as creosote which are denser than water and are not very
soluble in water, and therefore tend to sink through the aquifer.
The performance of this monitoring will require that additional monitoring wells and
other types of monitoring devices be installed as part of the remedial action. The
groundwater shall be monitored to assure that the site does not cause
exceedances of the Site-Specific Groundwater Trigger Levels given in Table 1.
These site-specific trigger levels are drawn from the Baseline Risk Assessment. In
addition, radiologic testing of groundwater and surface water and of any excavated
soils or subsurface samples shall be included in the monitoring program, as a
precaution. The surface waters shall be monitored to assure that ARARs are not
violated. 11 the Site-Specific Groundwater Trigger Levels are exceeded in
groundwater i~ down gradient monitoring wells, U.S. EPA and Ohio EPA will
consider whether additional remedial activities are necessary to address
groundwater conditions.
Extensive monitoring of all media will be required during the remedial design and
remedial construction.
Additional Investigation
Further investigation of two areas of the site will be required as part of the pre-
design investigations. The first is the northeast corner 01 the site, as shown in
Figure 3. The northeast corner 01 the site is to be capped. Prior to capping, a
.,

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limited investigation will be performed in order to identify the types of materials
which are buried in this area. It is possible that the extent of the cap will be
increased based upon the results of this investigation. The second portion to be
investigated is the area of the site which lies along Skinner Creek. Low-level
contamination has been detected in the Skinners' residential well, which is located
near to Skinner Creek. Sampling must be performed in order to determine the
sources of groundwater contamination within the Skinner Creek valley. It is
possible that this investigation may lead to the consolidation of additional
contaminated soil materials under the cap, and/or additional groundwater
monitoring, pumping and treatment.
Cost .of the Selected Remedy
Capital Costs: $9,700,900
Annual 0 & M Costs: $397,000
Net Present Value Cost: $16,031,900
STA TUTORY DETERMINA TIONS
U.S. EPA's primary responsibility at Superfund sites is to undertake remedial
actions that are protective of human health and the environment. In addition,
Section 1 21 of CERCLA establishes several other statutory requirements and
preferences. These specify that when complete, the selected remedial action must
comply with ARARs under Federal and State environmental laws, unless a
statutory waiver is justified. The selected remedy must also be cost effective and
utilize permanent solutions and alternative treatment or resource recovery
technologies to the maximum extent practicable. Finally, the statute includes a
preference for remedies that employ treatment that permanently and significantly
reduces the toxicity, mobility or volume of hazardous substances, pollutants and
contaminants. The following sections discuss how the selected remedy meets the
statutory requirements and preferences, where applicable.
A.
PROTECTION OF HUMAN HEAL TH AND THE ENVIRONMENT
The selected remedy provides for protection of human health and the environment
by limiting the potential for migration of contaminants off of the site. This is
achieved through capping, control of groundwater flow upgradient, soil vapor
extraction, and collection and treatment of contaminated groundwater
downgradient of the areas in which wastes were disposed.
The potential for direct exposure of the wastes to humans, or release into the
environment, will be limited by the physical barrier of the cap, and through the

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deed restrictions, which will limit inappropriate activities on the site.
The selected remedy is projected to reduce overall site risks to within the
acceptable risk range for carcinogens (i.e. less than 10.8 excess cancer risk), and
below the site-specific cleanup levels for non-carcinogens (i.e. a hazard index of
less than one). The selected remedy poses no unacceptable short-term risks or
cross-media impacts.
B.
COMPLIANCE WITH APPLICABLE OR RELEVANT AND APPROPRIA TE
REQUIREMENTS (ARARs)
Applicable requirements are those cleanup standards of control, and other
substantive requirements, criteria, or limitations promulgated under Federal or State
environmental or facility siting law that specifically address a hazardous substance,
pollutant, contaminant, remedial action, location, or other circumstance at a
CERCLA site. Relevant and appropriate requirements are those cleanup standards,
standards of control, and other substantive requirements, criteria, or limitations
promulgated under Federal or State environmental siting law that, while not
"applicable" to a hazardous substance, pollutant, contaminant, remedial action,
location, or other circumstance at a CERCLA site, address problems or situations
sufficiently similar to those encountered at the CERCLA site that their use is well
suited to this particular site. ARARs are divided into chemical specific, action
specific, and location specific groups.
All ARARs will be met for the selected remedy. The RCRA Land Disposal
Restrictions do not apply to this operable unit remedial action.
In implementing the selected remedy, the U.S. EPA and Ohio EPA have agreed to
consider a number of procedures that are not legally binding. These are listed in
Attachment 2 and Table 2.6.
ARARs for the. selected remedy are identified in Table 3 and Attachment 2.
CHEMICAL SPECIFIC ARARs
The selected remedy will achieve compliance with chemical specific ARARs relating
to the interception of contaminated groundwater downgradient of the buried waste
lagoon and former dump. ARARs include Maximum Concentration Limits (MCLs)
established pursuant to the Safe Drinking Water Act (SDWA), Ambient Water
Quality Criteria, and State standards which give concentration limits for drinking
water and surface waters. MCLs and State drinking water standards are applicable
based on the possibility that groundwater beneath the site might eventually be
used as a source of drinking water, and because the aquifers underlying the site

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are used as sources of drinking water in the site vicinity. The other water quality
standards and limits will be applicable in the event that treated groundwater will be
discharged to surface waters, and because site groundwater naturally discharges
into the on-site streams. These values are compiled for contaminants found at this
site, and are listed in Table 1 as Site-Specific Groundwater Trigger Levels.
Federal and State ARARs relating to air emissions and the quality of ambient air
will be met during and after construction of the remedy.
ACTION SPECIFIC ARARs
The systems for the treatment and discharge of groundwater and surface water
run-off from the site will be operated in a manner which will prevent any violation
of surface-water quality standards which apply to the East Fork of Mill Creek. Any
discharges from the treatment system will meet Federal and State ARARs relating
to discharges of contaminants to surface waters.
The cap shall be constructed in accordance with the requirements of RCRA Subtitle
C, and with the specific requirements of the Ohio Solid Waste Rules. RCRA
requirements will be met as appropriate for the treatment and storage of Hazardous
Wastes. Most RCRA requirements are administered under the State of Ohio's
implementing regulations. U.S. EPA does not have sufficient evidence to
demonstrate that listed RCRA wastes were disposed of at the site. RCRA
requirements therefore are not applicable to the site, except to the extent that new
hazardous wastes (such as treatment residuals) are generated during the
implementation of the remedy. However, the extensive chemical analysis which
was performed on the site wastes indicates that several RCRA regulations,
although not applicable, are relevant and appropriate to the selected remedy
because they address problems or circumstances very similar to those encountered
at this site. For instance, the cap which will be constructed on the site will
conform with the requirements of RCRA Subtitle C, which contains capping
requirements for a hazardous waste facility (as opposed to RCRA Subtitle D, which
contains cappi.ng requirements for a solid waste facility).
LOCATION SPECIFIC ARARs
The selected remedy will address and comply with all location specific ARARs.
Specifically, water use and quality limitations relating to the East Fork of Mill Creek
will be met in the event that treated groundwater is discharged to these waters.

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C.
COST-EFFECTIVENESS
The U.S. EPA believes that the selected remedy is cost-effective in mitigating the
risks posed by the site contaminants within a reasonable period of time. Section
300.430(fHiiHD) of the NCP requires U.S. EPA to evaluate cost-effectiveness by
comparing all the alternatives which meet the threshold criterion; protection of
human health and the environment, against three additional balancing criteria: long-
term effectiveness and permanence; reduction of toxicity, mobility or volume; and
short term effectiveness. The selected remedy provides the best overall balance of
these criteria and provides for overall effectiveness in proportion to the cost. The
incremental cost of incineration of the waste lagoon materials at this site is
approximately $13,000,000. Current information indicates that the overall site
risks wOt.lld not be enhanced by the incineration of the lagoon wastes to a degree
which would justify this large added cost, particularly given that the lagoon wastes
are only a portion of the contaminated materials at the site. The estimated cost of
the selected remedy is:
Capital Costs: $9,700,900
Annual 0 & M Costs: $397,000
Net Present Value Cost: $16,031,900
D.
UTILIZA TION OF PERMANENT SOLUTIONS AND AL TERNA TE TREA TMENT
TECHNOLOGIES TO THE MAXIMUM EXTENT PRACTICABLE
U.S.EPA believes that the selected remedy represents the maximum extent to
which permanent solutions can be utilized in a cost effective manner to address
potential migration of contaminants away from the Skinner Landfill site. The
selected remedy provides the best balance of tradeoffs in terms of long-term
effectiveness or permanence; reduction in toxicity, mobility or volume; short-term
effectiveness; implementability; cost; and State and community acceptance. The
criterion of long-term effectiveness and permanence is addressed by the installation
of a multi-layered cap, and groundwater collection trenches. Soil Vapor Extraction,
if feasible, will provide for permanent removal of organic vapors.
A detailed evaluation of the potential for application of alternate treatment
technologies to the lagoon wastes was performed. The buried waste lagoon
includes a wide variety 01 organic and inorganic waste materials, in a matrix that
includes soils, garbage, and demolition debris. It was determined that no currently
practicable alternate treatment technologies are applicable to these materials; the
only options for the buried waste lagoon materials are incineration and
containment. Soil Vapor Extraction (SVE) is an alternate treatment technology,
and is to be applied in the permeable materials which underlie part of the buried
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waste lagoon. This application of SVE is the maximum extent to which alternative
treatment technologies can be practicably applied at this site.
None of the alternatives evaluated for this site would provide a totally permanent
solution. Incineration would provide for permanent destruction of the organic
components of the lagoon waste materials to the maximum extent practicable.
However; inciner.ation of the lagoon waste materials would only address a portion
of the contaminated materials on the site. The most highly contaminated
groundwater at the site was detected during Phase 1 of the Remedial Investigation
upgradient of the lagoon. Incineration would not have addressed the source of
these contaminants. Therefore, even if we were to incinerate the lagoon wastes,
we would not be left with a wcleanw site, by any means. Identical provisions for
capping, groundwater control, collection, and treatment, soil vapor extraction, and
institutioAal controls would be required whether or not incineration was chosen.
Due to the large volume of contaminated materials which are present at this site,
and the fact that the chemical contaminants are mixed with and buried under a
wide variety of debris, the U.S. EPA believes that a no truly permanent solutions
are presently practicable for the majority of the waste materials at this site.
The selected remedy does not utilize resource recovery technologies.
E.
PREFERENCE FOR TREATMENT
The selected remedy satisfies, in part, the statutory preference for treatment as a
principal element. Contaminated groundwater will be collected and treated.
Vapors which are removed through soil vapor extraction will be treated prior to
discharge to the atmosphere. The majority of the waste materials on the site,
including the wastes in the buried waste lagoon and the former dump, will not be
treated, but will be contained.
DOCUMEN.TA TION OF SIGNIFICANT CHANGES
The Proposed Plan for this remedial action, as released to the public in April, 1992,
stated that the U.S. EPA's preferred remedy was Alternative #5, which included
on-site incineration of the contaminated materials from the waste lagoon using a
transportable incinerator. Two public meetings were held, on May 20 and July 29,
1992, to discuss the Proposed Plan. A number of local citizens were opposed to
incineration.
Subsequent to the second public meeting, and due to concerns expressed by
members of the public and by elected officials, the U.S. EPA decided to alter its
decision-making approach for this site. On August 7, 1992, U.S. EPA mailed an

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announcement to members of the pubRc and issued a news release, indicating
that:
1) U.S. EPA proposed to select an interim remedy for this site, including the
fencing of the contaminated portion of the site and the provision of
alternative potable water supply to potentially affected homes;
2) The comment period for fencing and alternate water supply would end on
August 31, 1992; -
3) The comment period for the remaining portions of the remedy would
remain open until further notice, in order to address community concerns.
The comment period for the remaining portions of the remedy did not close until
February 9, 1993; in total the public comment period was nearly ten months long.
A coalition of various West Chester community groups and residents was formed
after the July 29, 1992 public meeting in order to discuss the Skinner Landfill
cleanup and to meet with the U.S. EPA and Ohio EPA. This coalition includes
representatives from the Township Trustees, the Chamber of Commerce, Citizens
Lobby for Environmental Action Now (C.L.E.A.N), the Lakota School Board, the Old
West Chester Merchants Association, the Union School PT A, the Home Builders
Association, the Firefighters/Service Group, and a number of Township Residents.
The U.S. EPA and Ohio EPA met with this coalition approximately every other
week for a period of three months. Topics discussed before this coalition included:
- site history;
- description of Remedial Investigation results;
- applicability of RCRA regulations;
- applicable or relevant and appropriate'requirements for the site remedy;
- viability of containment remedies;
- assessment of site risks;
- proposals for further studies;
- alternative remediation technologies for the lagoon wastes; and
- the remedy selection process.
The discussions held with the Coalition were highly productive and resulted in a
high degree of open communication and consensus-building. As a result of these
discussions, this Coalition issued a unanimous written recommendation that a
containment remedy be implemented at the Skinner site. This recommendation is
available for public review in the Administrative Record.
On January 11, 1993, the U.S. EP A issued a Fact Sheet announcing that its
preferred alternative had changed from Alternative 5 (which included incineration),
to Alternative 3 (a containment remedy that does not include incineration), with

-------
38
the possible inclusion of soil vapor extraction. This Fact Sheet, along with a press
release and newspaper advertisements, announced that the public comment period
would end on February 9, 1993.
u.s. EPA has chosen not to incinerate the lagoon waste materials at this site. Part
of the reason for this is because incineration of the lagoon waste materials would
only address a portion 01 the contaminated materials on the site. The most highly
contaminated groundwater at the site was detected during Phase 1 of the
Remedial Investigation upgradient of the lagoon. Incineration would not have
addressed the source 01 these contaminants. Therefore, even if we were to
incinerate the lagoon wastes, we would not be left with a .clean. site, by any
means. Identical provisions for capping, groundwater control, collection, and
treatment, soil vapor extraction, and institutional controls would be required
whether..or not incineration was chosen. In the end, U.S. EPA judged that the
long-term environmental gains which would have been associated with incineration
were limited, and that the difficulties and costs associated with the implementation
of incineration would be disproportionately high.
Soil Vapor Extraction (SVE) was added as a component 01 Alternative 3 in
response to comments received from the Skinner landfill Coalition, and from the
PRPs.
u.S. EPA feels that the selected remedy will achieve the best balance in serving
the needs of the environment, the community, and the future residents of West
Chester.
RESPONSIVENESS SUMMARY
Appended to this ROD is the Responsiveness Summary which presents background
information, describes community involvement and categorizes the public
comments received during the public comment period and U.S. EPA's responses to
the comments..

-------
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LEGEND
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as referred to in text
FIGURE 1. SKINNER LANDFILL
WEST CHESTER, 01110

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FIGURE 2. MINIMUM AREA TO BE CAPPED
SKINNER LANDFILL
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FIGURE 3. NORTIlEAST CORNER OF SITE
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2000 3000
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FIGURE 4. LOCATION MAP
SKINNER LANDFUL
.
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-------
. .0....- ..----....
Table 1
Skinner Landfill
Site-Specific Groundwater Trigger Levels
CONTAMINANT
CONCENTRA TION (MG/L)

0.03
0.005
1.0
0.004
0.0011
0.011
0.012
0.0052
0.001
0.0032
0.000012
0.096
0.005
0.00012
0.04
0.086
Antimony
Arsenic
Barium
Beryllium
Cadmium
Chromium
Copper
Cyanide
Iron
Lead
Mercury
Nickel
Selenium
Silver
Thallium
Zinc
Benzene
2-Butanone
Carbon Tetrachloride
Chlorobenzene
Chloroform
1,2-Dichloroethane
1,2-Dichloroethane(cis)
1,2-Dichloroethane(trans)
1,2-Dichloropropane
Ethylbenzene
Styrene
1,1,2,2-Tetract\loroethane
T etrachloroethene
Toluene
1 ,1 ,1- Trichloroethane
1,1,2-Trichloroethene
Trichloroethene
Vinyl Chloride
Xylenes (total)
0.005
0.0071
0.005
0.026
0.079
0.005
0.07
0.1
0.005
0.062
0.056
0.107
0.005
1.0
0.088
0.418
0.005
0.002
10.0

-------
Skinner Landfill
Site-Specific Gro~ndwater Trigger Levels
(Continued)
CONTAMINANT
CONCENTRA TION (MGIL)
Acenaphthene
Benzo(a)anthracene
Benzo (b )fluoranthene
Benzo (j)fluoranthene
Benzo(g,h,i)perylene
Benzo(a)pyrene
Bis(2-Chloroethyl)ether
bis (2-Chloroisopropyl)ether
bis(ethylhexyl) phthalate
Butylbenzylphthalate
Chrysene
Dibenzo (a, h)anthracene
1,2-Dichlorobenzene
1,2-Dichlorobenzene
1,4-Dichlorobenzene
2,4-Dimethylphenol
Dimethyl phthalate
Di-n-butyl phthalate
Fluoranthene
Hexachloroethane
Indeno(1,2,3-cd)Pyrene
Isophorone
Naphthalene
Nitrobenzene
4-Nitrophenol
Phenol
1,2,4- Trichlorobenzene
Phenanthr.ene
0.52
0.0001
0.0002
0.0002
0.0031
0.0002
0.0136
4.36
0.049
0.0084
0.0031
0.0031
0.011
0.6
0.075
2.12
0.073
0.19
0.0089
0.00099
0.0031
0.9
0.044
27.0
0.15
0.37
0.077
0.0063

-------
CONTAMINANT
Polychlorinated Biphenyls
Benzo(a)anthracene
Benzo(a)pyrene
Benzo(b)fluoranthene
Benzo(k)fluoranthene
Chrysene
Lead
Table 2
Skinryer Landfill
Remedial Response Levels
for Contaminated Soils
CONCENTRA TION (MG/KGJ
0.160
0.330
0.100
0.330
0.330
0.330
500.0

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Applicable
Action
Discharge of Water Treatment
System Bffluent
TABLE 3
or Relevant and Appropriate Requirements
Skinner Landfill Site
Pederal Requirements
Requirement
Discharge of effluent may not
interfere with the attainment or
mainteinance of water quality

Discharge of effluent may not
cause violation of Federally
approved State water quality
standards. These standards
may be in addition to or more
stringent than other federal
standards under the CWA.
Use of best available technology
(BAT) economically achievable is
required to control toxic and non-
conventional pollutants. Use of
Page 1 of 4
(ARARs)
Citation
Clean Water Act (CWA)
Sec. 302, 33 U.S.C. Sec. 1312
40 CFR 122.44
40 CFR 122 (a)

-------
Applicable or
TABLB 3
Relevant and Appropriate Requirements
Skinner Landfill Site I
Pederal Requirements
Action
Requirement

the best conventional pollutant
control technology (BCT) is
required to control conventional
pollutants. Technology-based
limitations may be determined on
a case-by case basis.
Discharge of Water Treatment
System Bffluent (cont.)
Discharge limitations must be
established for all toxic
pollutants that are or may be dis-
charged at levels greater than
those that can be achieved by
technology-based standards.

Discharge must be monitored to
include:
.The mass of each pollutant
.The volume of effluent
Page :2 of 4
(ARARs)
~
I
Citation
40 CFR 112.44(e)
40 CFR 112.44(i)
I

-------
....
Applicable or
TABLE 3
Relevant and Appropriate Requirements
Skinner Landfill Site
Pederal Requirements
(ARARs)
Action
Discharge of Water Treatment
System Effluent (cont.)
Requirement

.prequency of discharge and other
measurements as appropriate.
Approved test methods for waste
constituents to be monitored must
be followed. Detailed require-
ments for analytical procedures
and quality controls are provided
Monitor and report results as
required (at least annually) .

Comply with additional conditions
such as:
.Duty to mitigate any adverse
effects of any discharge.
.Propf" operation and maintenance
of treatment systems.
Develop and implement a Best Man-
agement Practice (BMP) program
and incorporate measures that
prevent the release of toxic
constituents to surface waters.
Page 3 of 4
Citation
40 CFR 122.44(1)
40 CFR 122.41(1)
I
40 CFR 125.100 and 104

-------
Action
Applicable or
TABLE 3
I
Relevant and Appropriate Requirements
Skinner Landfill Site
Federal Requirements
Discharge of Water Treatment
System Effluent (cont.)
Requirement

The BMP Program MUS t :
.Establish specific procedures for
the control of toxic and hazardous
pollutant spills.
Storm Water Discharge
. Include a prediction of
direction, rate of flow, and total
quantity of toxi pollutants where
experience indicates a reasonable
potential for equipment failure.

. Assure proper managment of solid
and hazardous waste in accordance
with regulations promulgated under
RCRA.
Sample preservation procedures,
container materials, and maximum
allowable holding times are pre-
scribed.
Comply with substantive require-
ments of a NPDES permit for storm
water discharge
Page 4 of 4
(ARARs)
Citation
40 CPR 136.1-136.4
40 CPR Parts 122, 123, 124 and
Section 402(p) of the CWA.

-------
TABLE 2.6
OTHER PEDBRAL CRITERIA, ADVISORIBS, AND GUIDANCE TO BB CONSIDERED
1.
Federal Criteria. Advisories. and Procedures
Health Effects Assessments (HBAs) and Proposed HEAs,
Chemicals), "BCAO, U.S. EPA, 1984].
("Health Effects Assessment for (Specif:
Reference Doses (RFDs), ("Verified Reference Doses of U.S. EPA," ECAO-CIN-475, January 1986). St
also Drinking Water Bquivalent Levels (DWELs), a set of medium-specific drinking water leve:
derived from RFDs. (See U.S. EPA Health Advisories, Office of Drinking Water, March 31, 1987)

Carcinogen Potency Factors (CPFs) (e.g., Q1 Stars, Carcinogen Assessment Group [CAG] Values
(Table 11, "Health Assessment Document for Tetrachloroethylene (Perchloroethylene)" U.S. EPi
OHEA/6008-82/00SF, July 1985).
Pesticide and Food additive tolerances and action 1 evels. Note: Some tolerances and action leve:
may pertain and should therefore be considered in certain situations. .

Waste Load allocation proced~res, EPA Office of Water (40 CFR Part 125, 130).
Federal Sole Source Aquifer requirements (See 52 fR 6873, March 5, 1987).
Public health criteria on which the decision to list pollutants as hazardous under Section 112 (
the Clean Air Act was based.
Source: U.S. SPA, August 1988, CERCLA Compliance with Other Laws Manual: Draft Guidance.
Page 2.6-1

-------
TABLE 2. 6
OTBBR FBDERAL AND STATB CRITBRIA, ADVISORIES, AND GUIDANCE TO BE CONSIDERED (Cont.)
Guidelines for Ground-Water Classification Under the U.S. ,EPA Ground-Water Protection Strategy
Advisories issued by FWS and NWFS under the Fish and Wildlife Coordination Act.

TSCA Compliance Program Policy, (-TSCA Enforcement Guidance Manual - Policy Compendium, -U.S. EP1
OECM, OPTS, March, 1985). ,
OSHA health and safety standards that may be used to protect public health (non-workplace).
Health Advisories, SPA Office of Water.
EPA Water Quality Advisories, EPA Office of Water, Criteria and Standards Division.
2.
U.S. EPA RCRA Guidance Documents

Interim Final Alternate Concentration Limit Guidance Part I:
Requirements (July, 1987).
ACL Policy and Informati:
a.
U.S. SPA's RCRA Design Guidelines
(1)
(2)
Surface Impoundments, Liners Systems, Final Cover and Freeboard Control.
Waste Pile Design - Liner Systems.
(3)
(4)
Land Treatment Units.
Landfill Design - Liner Systems and Final cover.
I
Source: U.S. EPA, August 1988, CERCLA Comnliance with Other Laws Manual: Draft Guidance.
Page 2.6-2

-------
b.
OTHER PEDERAL AND STATB CRITERIA, ADVISORIES, AND GUIDANCE TO BB CONSIDERED (Cant.)
TABLE 2.6
Pe~itting Guidance Manuals
c.
(1)
Pe~it Writer's Guidance Manual for Hazardous Waste Land Treatment, Storage and Disposa
. Facilities, Phase Ii (February 15, 1985) EPA/530-SW-85-024.

Pe~it Writer's Guidance Manual for Subpart F. (October 1983)
(2)
(3)
Pe~it Applicant's Guidance Manual for the General Facility Standards.
1983) EPA " OSW 00-00-968. .
(October 15
(4 )
(5)
Waste Analysis Plan Guidance Manual.
(October 15, 1984) EPAj530-SW-84-012.
Permit Writer's Guidance Manual for Hazardous Waste Tanks.
(July 1983).
(6)
(7)
Model Permit Application for Existing Incinerators. (1985)

Guidance Manual for Evaluating Permit Applications for the Operation of Hazardous Wast.
Incinerator Units. (July 1983).
(8)
A Guide for Preparing RCRA Permit Applications for Existing Storage
(January 15, 1982).

Guidance Manual on closure and post-closure Interim Status Standards.
Facilities
(9)
Technical Resources Documents (TRDs)
(1)
Evaluating Cover Systems for Solid and Hazardous Waste.
867.
(September 1982) EPAOSW-OO-OO
(2 )
Hydrologic Simulation of Solid Waste Disposal Sites.
(November 1982) EPA OSW-00-OO-868
i
Source: U.S. EPA, August 1988, CERCLA Com~liance with Other Laws Manual: Draft Guidance.
Page 2.6-3

-------
TABLE 2.6
OTBBR PBDBRAL AND ~TATB CRITERIA, ADVISORIES, AND GUIDANCB TO BB CONSIDERED (Cont.)
d.
(3)
Landfill and Surface Impoundment Performance Evaluation.
869.
(April 1983) EPA osw-OO-OO
(4)
Draft Minimal Technology Gui.. J.ines on Double Liner Systems for Landfills and Surfac
Impoundments. (May 1985) PB 87151072-AS.

Draft Minimal Technology Guidelines on Single Liner System for Landfills and Surfac
Impoundments. (May 1985) PB 871173159. .
(5)
(6)
(7)
Management of Hazardous Waste Leachate.
(September 1982) OSW-OO-OO-871.
Guide to the Disposal of Chemically Stabilized and Solidified Waste.
872.
(1982) EPA/530-SW
(8)
Closure of Hazardous Waste Surface Impoundments. (September 1982) OSW-OO-OO-873.
,9)
Hazardous Waste Land Treatment.
(April 1983) OSW-00-OO-874.
(10) Soil Properties, Classification, and Hydraulic Conductivity Testing. (March 1984) Of,\1
00-00-925M OSWER directive 9480.00-70.
Test Methods for Evaluating Solid Waste
(1)
(2 )
Solid Waste Leaching Procedure Manual. (1984) OSW-OO-OO-924.
Methods for the Prediction of Leachate Plume Migration and Mixing.
(3)
Hydrologic Evaluation of Landfill Performance (HELP) Model, Volumes I and II (1984)
EPA/S30-SW-84-009 and EPA/S30-SW-84-010.
Source: u.S. BPA, August 1988, CERCLA Compliance with Other Laws Manual: Draft Guidance.
Page 2. 6 - 4

-------
TABLE 2.6
OTHER PBDERAL AND STATE CRITERIA, ADVISORIES, AND GUIDANCE TO BE CONSIDERED (Cont.)
(4)
(5)
Hydrologic Simulation of Solid Waste Disposal SitFs.
(November 1982) EPA OSW-OO-OO-861'
Procedures for Modelling Flow through Clay Liners to Determine Required Liner Thicknesl:
(1984) BP~/530-SW-P4-001 and OSWER directive 9480.00-9D.
(6)
(7)
Test Methods for Evaluating Solid Wastes, third edition.
(November 1986) SW-846.
(8)
A Method for Determining the Compatibility of Hazardous Wastes.
Guidance Manual on Hazardous Waste Compatibility.
EPA/600-02-800-076.
a.
U.S. EPA Office of Water Guidance Documents
3.
Pretreatment Guidance Documents:
(1)
(2)
304(g) Guidance Document Revised Pretreatment Guidelines (3 Volumes).
Guidance for POTW Pretreatment Program Manual (October 1983) .
(3)
Developing Requirements for Direct and Indirect Discharges of CERCLA Wastewater, Draft
(1987) .
(4)
(5)
Domestic Sewage Exemption Study.
Guidance for Implementing RCRA Permit by Rule Requirements at POTWs.
(6)
(7)
Application of Correction Action Requirements at Publicly Owned Treatment Works.
Draft Guidance Manual on the Development and Implementation of Local
Limitations Under the Pretreatment Program (1987).
Dischar~
Source: U.S. EPA, August 1988, CERCLA Compliance with Other Laws Manual: Draft Guidance.
Page 2.6-5

-------
OTBBR FEDBRAL AND STATE CRITBRIA, ADVISORIES, AND GUIDANCB TO BB CONSIDERED (Cont.)
TABLB 2. 6
b.
Water Quality Guidance Documents
(1)
Ecological Evaluation of Proposed Discharge of Dredged Material into Ocean Watel
(1977) . .
(2)
Technical Support Manual: Waterbody Surveys and Assessments for Conducting Us
Attainability Analyses (1983).
(3)
(4)
Water-Related Environmental Fate of 129 Priority Pollutants-(1979).
Water Quality Standards Handbook (December 1983).
(5)
Technical Support Document for Water Quality-based Toxic Control.
(1983).
c.
NPDES Guidance Documents
(1)
(2)
NPDES Best Management Practices Guidances Manual (June 1981).
Case studies on toxicity reduction evaluation (May 1983).
d.
Ground Water/UIC Guidance Documents
(1)
(2)
Designation of a USDW (No. 7.1, October 1979) .
Elements of aquifer identification (No. 7.2, October 1979).
(3 )
Interim Guidance Concerning Corrective Action for Primary and Continuous Release (,
Class I and IV Hazardous Waste Wells (No. 45, April 1986) requirements.

Requirements applicable to wells injected into, through, or'above an aquifer that ha
been exempted pursuant to Section 146.104(b) (4). (No. 27, July 1981).
(4 )
Source:
U.S. EPA, August 1988, CERCLA Comoliance with Other Laws Manual: Draft Guidance.
Page 2. 6 - 6

-------
TABLE 2.6
)THER FEDERAL AND STATE CRITERIA, ADVISORIES, AND GUIDANCE TO BE CONSIDERED (Cont.)
f.
Ground-Water Protection Strategy (August 1984).
Clean Water Act Guidance Documents.
e.
4.
U.S. EPA Manuals from the Office of Research and Development
State approval of water supply system additions or developments.
State ground water withdrawal approvals.
:ource: U.S. EPA, August 1988, CBRCLA Compliance with Other Laws Manual: Draft Guidance.
Page 2.6-7
~
~

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   Snils   Ciround Waler     Surface Waler     
brmical Waste Site-  Unconsolidated Mill Skinner Dump Diving Trilohite
 Logoon Wide and Bedrock Wells Creek Creek Creek Pond Pond
 (mllKl) (milK I)   (mall.) (mall.) (mall.) (mill.) (maIL) (mall.)
',JllIinum      0.011 H.6         1.02 4.61
~jrilnon,. U 23 4.9 14.9             
,...nic   I   0002 . 0.11612          
.:lIn      0.003 '.9' 0.0412 . 0.068)       0.0311 0.114)8
,Ilium               -  
.Jmlum 1.1 '6.9 0.54 II 0.001153 . 0.064      0.0031 . 0.0058  
:unmium   6.1 . 91  '0.004 . 0.1)1          
,:...      0003 .0.31 0.00'6 . 0.00'6        
'I~'   12 '14  0.002 . 0.163  ..      -  
.d 6.1 4360 ).1 1030 0.00282 . 0.'4          
anlanclc      0.0104 18   0.016) 0.0715      
lchlo.oe.hen.      0.00' ..,          
hlo...ronn 0.02 ))    O.rMlI - 0.085          
2.OIdlloroe.h.lI. 0.00) 210  ..  000' ,0.18     ..     
8ullllOn. 0.24 )9 0.0)1 ' 0.04'  0.006 .0.036     .     
.1,1. T lichlurodh..... 0026 . 6J    0.rM126 0012     ,-     
.!bon T....chloridc 0.041 160    000) . 0.0067          
.2-Dichloropropan. 0.14 340   I 0.021 ,0.31          
        . -   
ridlln""lhene 0.006 140    O.rMU - 0.011          
.ibromnchloromelhuae                 
.I,2.T./chlorodh....e 0.07) 310    00" .' O.OH      .    
cnune 0.001 .60 0.00049 . 0.0022  0.001 20          
TAl"..., 2-16
SUMMARY C)It' c.:ONCEN'fRATION MANtiES en; c.:1I~MICAI.S C)It' c.:ONC":RN
. -fl.' I 016
1 1
wd. - c"'.innetlri..\AI.I.-TAR2.)(I.S 04003.13
I'rin.ed: 4n4191

-------
TAli..,. 1-16
SUMMARY (w t.:ONCI!:NTRA TION RANmo:S OF CItEM It.:AI.S 0.' CONt.:I!:RN
. .<20"
Soils (~rnund Water Surface Water
'hemicul Wasle Sile- Unconsolidaled Mill Skinner Dump Diving Trilobile
lagoon Wide illIIl Bedrock Wells Creek Creek Creek Pond Pond
(milK.) (mIlK.) (n'III.) (mill.) (mill.) (mill.) (mlA-) (mill.)
t.klhyl. 2.I'cnlanonc
"nanonc -
I
...achloroelhcne 0.1149 44 0.0021 2.1 0.001 .0.02
1,2,2. TetnchlolOdhlnc 0.04 130 0.0116 .0.006 .
olueM 0.001 )1000 0.001 - 0.36 0.001) 3.1 -
hlo.obtnune 5 " 0.002 . 0.002 0001 . 0.021 -
Ihylbenune 0.0008 9. 0.001 0.002 '0.005 .0.0' .
ylme (loIal) 0.001 200 0.001 - 0.016 0.034 0." 0.003 - 0.003 .
,enol 0." 26 0.002 0.61 0.0006 . 0.0089 0.003 - 0.00) 0.0021 - 0.0021 0.001 0.001
.(2.Chlomethyl)Elhcr 0.21 21 0.001 . 0.24 - -
1.IJldliomhenune 0.043 no .
. . Dichlorobenune 0.1) 180 0.0035 - 0.011 .
,nql Alcohol 0.94 9.2 . 0.01'11 - 0.001 "
1.Dichlombenunc 0.43 94 0.006 - 0.006 " -
Melhylphenol 0.11 1.8 0.45 - 0.45 . - -
,(2.<1l1orollopmpyllF.lber - 0.003 .0.003
'.te'hylp.cnol 0.51 26 0.11 .0.14 0.14 o.n
u.hlomelbane 0.69 19 . .
Imhenune ( . - - .
."Dic Acid 1.6 1100 -
,"'Ihaltnc 0.11 . 610 0.22 . 0.21 O.OOOH 0.064 .
"tlhyl...""lbalenc 0.0)6 220 0.064 0.064 0.(0) - 0(0) -
melhyl ""thalale 0.12 - 61 . 0.001 - 0.001
'.naphlhylene I 41 . -
.nap.theM oon 1.9 -
h
-------
l'Alh.c.2-16
SUMMAR V 01' CUNO:NTRA'I'IUN RANC;a.:S CU' C....:I\-nc:AI.S CW CUNd:RN
I -~~ J of 6
Soils C.round Water Surface Waler
:1~miral Waste Site- Unconsolidated Mill Skinner Dump Diving Triluhile
Lagolln Wide ami Bedrock Wells Creek Creek Creek Pond Pond
(mllKl) (mllKl) (011/'1.) (01&11.) (mill.) (mill.) (mill.) (mill.)
.. . 6.11
, oI1o(h)l-luo'l/Ithtne 0..55 1 0.21
. ,,'o.k)J-1uo"I1t1~ne 0..29 5 0..05 . 0.16 ..
",,,.o(elf')olTne 0.31 10 0.1162 56 ..
I
o;'",o( 1,2,J.rd)l'ylTne 0.2 ).4 0.29 1.5 ..
iheolo(e.hIAnlh,acene ..
'J,.o(..h.i)l'erylene 0.16 4.1 0 JI 1.1
"eIlIlC 0..0011 0..0096
'111...1110, 0..0082 52 ..
.drin 0.64 II 0.IlOO5 . 0..IlOO5 ..
'ddrin 1.1 1.9 -. O.OOOIJ - 0.IlOO IJ ..
.. UP!: 0.044 .0.044 ..
.drill 0.61 . 0..65 ..
nmD 0.019 0.019 0..01 - 0..11 ..
".I)\H 0.055 . 0.055 O.OIJ .0.091 O.OOOCI6 . 0.l1OOO9
r,drin .donc 0.045 14 ..
."'e.( 'hlordane ..
IInme ntlordane 1.8 44 . -
mrlo,.I248 0.55 . 0."18 ..
01<10,.1254 0.14 . 980 0.01102 . 0.0002 ..
rnrlo,.I26o. 0.46 1.2 ..
eurhlo.ohtnlene o..OOO9J 1800 o..on 2J 0.0IlOO2 . 0.00024 .. o..OOOOH . o..OOOOJJ
e lerhlororyloprn..diene 0.11 4100 ..
1> 1.16F..05 - 0.00014
"""II'ENTI\ eDl) 8E.01 . 0.0II011J
,1IallIF-XA t'lm 1.96F..05 . 00lI0189
,1181 liE....... CDU 0.0lI0105 . O.OIIOJ09 0..011000 I . 0.000205
,.... OC'1'A 1:00 0.001165 . 0(1)]165 00lI0192 . 0.0lI0192
1,1,8-1'CUF 9.6E.06 .OOlM)022 0 000lI08 . 0..0l1OOO8
,...1 TETRA ('OF 1.4E.06 - 0.002)0.5 0.000008 . 0..000lI08
I
oIell'F-NT A cOt' 1.0.1E.0.5 . 0..002151
01" IIEXA t:lJF 1.111;.0.5 . 0..005469
oIelllFFfA CDf 0.0lI0104 .0..00]111 -.
alai Ol"T A CDF 0..000019 . 0..015109 .. -
. Noe U...rted
.15
\Od. . r:\skinneNi.k\AI.".TAII2.XI.S 04011J.1J
I'rinled: 4n41'JI
~
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l'AUI.r.1-16 .
SIIMMAHY (n; CUNn:NTHATIUN RAN(~ES ()Io' CIII<:MU: AI.S en; CUNC[RN
. '.II~ 4 on
Sediments
Chemical Mill Skinner Dump Dnck Diving Trilobile
Creek Creek Creek Pond Pond Pond
(m,IK.) (mglK,) (m,IK,) (m.lKg) (m.IK.) (m.IK.)
Aluminum 8860 15900 18600 24900 1)300 1S3UO ]2300 . 42700
AnlinlllllY
Anrnic I.
Rarium 136 20?
1I~l}'lIium 1.6 2.3
(~admium
Chromium 21.3 2'1.7 17.1 26.8 31.' 46.4
eohalr 15.7 18.7 19.4 21.6
COf1I'ichloroelhene 0.0299 0.0299
1.1. IJid,lo,oelhane
1,2. l>id1lorue.hene 11.0"1 II.CIU
('hlom'onn
1,2. Dichloroelhane .
1.8ulanone 0.005 0.011
1,1,1. Trichloroethane
eart.on Telrachloride
I
1.2.0ichloroprorane
lrichloroelhene 11.U1 0.02 0.0016 0.0016
IJibromochlon....e.halle
1,1,2. T richloroe.hane
Henzrne 0.0403 . 0.0403
.
INd. . c:\akinneM.k\AI.I..TAD2.XI.S O4ooJ.1)
I'rillled: 4n4191
-------
'I'AIII r.1.16 .
StlMMARY ()It' (:UNO:Nl'RATIUN RAN(:t:S n..' Cln:MICAI.S m. CUNO':RN
1.".50r6
Stdimtnts
Chtmicul Mill Skinner Dump Duck Diving Trilobile
Creek Creek Creek PUUlI I'ond Pund
(mslKsl (mglKgl (mglKsl (mglKsl (mslKsl (mllKsl
4. Melhyl. }.I'enlanone O.OOIJ .0.0016 0.0049 . 0.0049 ..
2.IIeaanone IW051 . 0.0051
'fellachloloclhene I ..
1,1,2,2. 1'ellachloloelhll1e 0.002 . 0.IN12 . -
Toluene ..
Chlorobenzcne ..
Elhylbenzene .. 0.014 .0.014
Xylme (104111 .. - - 0.008 .0.261
rhenol 0.055 . 0.1391 - -
bi.( Z -Chloroelhyl)Elbcr . -
I,). Uichlolobenzene ..
1,4.l)lchlorobenzene . -
Renzyl Alcohol .. ..
1,2.Oi"'''orohenre"e . -
2-Mclhyl""enol -.
bi.(2 .(l1loroi,orroloylmlbel ..
4.Melhyl""enol . 0.0165 1.5H2 001O~ . 0.0191 . -
llea.chloraelbane ..
Nitlobenzene O.OOH O.OOH . -
Denzoic Acid ..
Na""lbalene 0.022 . 0.38 001116 . 00648 0.18 . 0.18 0.1341 . 0.14
2. Melhylna,,'''halene 0.002 - 0.045 0.0215 - 0.1001 0.12 - 0.16 0.18 - 0.49
Dimelbyl r'hlbatlle ..
Accn""'lhylene 0.11184 . 0.12 . -
Acenll"'lhene 0.4 - 0.4 0.14 - 0.14 0.13 . 0.16
Uibenzor"ran 0 1142 - 0.28 O.lIlIlJ . 0.13 0.15 - 0.15
Uiclhylphlha'ale 0.0)]5 - 00511 0.1121 . O.02SJ .. ."
1~IIO"'no 0.0271 . 0.39 O.IN" . 0.22 0.22 . 0.22 0.1 . 0.14
renlaehlorol"enol
rIIenanlh",,,o 0.0'105 2.9 0.11151 1.8 0152 - 2 0.12 " 0.59
Anlhraeono o.un . 0.58 0.014 . 031 0.51 . 0.51 ," ".
Di.n. BUlyl""lhallle 0.073 . 0.16 0.011 - 0.071 ""
I-luoranlhene 0.11 3.) 0.031] 2.5 0.13 1.9 0.11 .0.14
Py"'1IC 0.089 3.2 0.0217 1.5 0.134 1.9 0.18 . 0.6901
BUly lbenzyl""'halale .. ."
Benzo(alAnlhraceno 011476 1.6 0.0876 . 0.68 0.124 .0.83 0.099 .0.1
Ony.eno 0.0602 1.9 0.056 .0.69 0.11 .0.88 0.11 .0.14
111.(2 -Ethylheayllrhlhlilio 0.043 .0.18 ; 0.033 .0.51 0.08 .0.08 0.1341 . 0.1341 0.26 .0.26
Oi.n-Odvl ."lhllalo ..
WI" - c:\sUnncNi,k\AI.I..'fAII2.XI.S 1l-l003.1J
rrineod: 4n4191
-------
TAlh..l-16
SUMMARY ()Io' (:ONCF.NTRATION RArmES OF cm.:MICAI.S OF CONCERN
.~ , 0(6
Sediments
Chemical Mill Skinner Dump Duck Diving Trilobile
Creek Creek Creek Pond Pond Pond
(malKa) (malKal (malK.1 (malKal (malKa) (malKal
B~n~o(bIRlIOrllllhen~ 0.OJ66 1.1 0.0116 - 0.51 O.IOJ 1.1 0.1J41 0.16 ,.
B~n~o(.)I'I\JOrllllhen. 0.011~ 1.2 00146 - 051 0.019 0.16
B~n~o(lll'yftn~ 0:069 1.4 0.0084 . O.H O.IH . 0.14
Indcno( 1.2,}.cdll'yftn~ 0.099 0.61 0.OJ9~ 0.26 0.0~9 0.0~9
Oiben~o(..hIAnlhllC~n~ O.O~~ O.IJ
B~n~ol8.h,i )I'~ryl.n~ 0.D18 0.51 0.0~8 0.21 O.O~~ - O.O~~
hell. BIIC 0.028 0.028
lI~plIchlor
Aldrin .
Di~ldrin
4,4'.Df>F.
Endrin .
4,4'.f>I)f> 0.0038 . 0.0038 .
4,4'.Of>T
Endrin tclon~ . .
Ilphl.(lIloldan~ 0.0042 . 0.0042 , -
aunma.(lIlordine .
Aroclor-l241 -
Aroclor.ln4 0.16 .0.16 0.2 0.29
A",clor-1260 o.lIIl~J - 00298~ O.H 0.44219
1I~..chlorobenun~ 0.0029 .0.016 O.OOJ - O.OO} 0.00)2 - 0.00)2 0.0019 0.0012
11~llchlolocylopenlldi~n~ 0.052 - 0061 -
1I~..chlorobu..di~n~ 0.0019 . 0.0019 0.0021 - 0.021 O.OOH .OOOH 0.002} - 0.00}4
(k"chlorocyclopcnl~ne 0.012 0.012 .
II~J1Ilchloronolboftn~ 0.111112 0.029 0.0011 - 0.002~ 0.0021 . 0.0031 0.0011 0.0011
Chlol.n~ 0.00 13 0.0034 O.(NII3 - 0.0049 0.00161 0.00161 .
2.3,1,8. TCm) .
ToIII1'E1RA COI) . .
'1'0111 I'ENT" <:I)J) .
TotllllEXA (:01) .
Totll llEPTA COO .' - .
'1'01" OCTA COI) .
2.3.1.1- TCI)f
ToIII1EDA ('IIF I
.
ToIIl PEN1'" COI'
TotllllEXA ('IIF
ToIIllIEPTA ('III'
Tot" OCT A CI>F -
- . - Nollkl~d.d
wds - c:".inMI\rh.\AI.I..TAII2.XI.S O4ooJ.13
I'rinl~d: 4n4191
-------
ATTACHMENT 1
ADMINISTRATIVE RECORD INDEX
-
-------
~
..
REMEDIAL ACTION
ADMINISTRATIVE RECORD
(Index and Documents)
tor the
SKINNER LANDFILL SITE
REMEDIAL ACTION
WEST CHESTER, omo
FEBRUARY 1992
Ua1ted Slates ~ Protecd- Ap8cJ
RIII- v
23G S08tIt DeuiIara SInIt
QIap, IL 6088
"11
-------
INTRODUCTION
These documentS comprise the Administrative Record for the Skinner Landfill Superfund
Site-Remedial Action. An index of the documentS in the Adminisuative Record is located
at the front of the first volume along with an acronym index and an index of guidance
documentS used by EP A Agency Staff in selecting a response action at the site.

The Adminisuative Record is also available for public review at United States
Environmental Protection Agency, 77 West Jackson Blvd. 7th F1oor, Clicago, Illinois, 60604.
QuestioDS concerning the Administrative Record should be addressed to the EP A
Administrative Record Coordinator.
The Administrative Record is required by tbe Comprehensive Environmental Response,
Compensation. and Liability Act (CERCLA),as amended by the Superfund AmendmentS
and Reauthorization Act (SARA).
~
-------
Skinner Landfill Superfund Site
West Chester, Ohio
Administrative Record
Iable of Contents
VOLUME I
(Document Nos. 1. 26)
VOLUME II
{Document Nos. 27. 53)
VOLUME III
(Document Nos. S4. 94)
VOLUME IV
(Document Nos. 95. 100 Pan 1)
VOLUME V
(Document Nos. 100 Pan 2 . 111)
VOLUME VI
(Docuinent No. 112)
VOLUME VII
(Document No. 113)
-------
P,,,'lo.
02/10/9Z
AIIIIIIIITUII. I!CIIID IIIIIX
_IAL ACTICII
" 11:1- UI8'ILL 11ft
"'" ~ITD. 0110
FICHE/FlAME 'AGEl DAII llTU AIIT.. IICI"m DClQM!IT IT" OOCIUIIE
00/00100 I~ Artlct. I~ Artlcte
ret D......", cl8L..,.
!pa pr- of tlnl:ffllt
00100100 0.... I.... In - I~ Artlcte 2
Stl,..,. LIIIIHIH
,,...
00100/00 ......... Artlct. .~ Article 3
rot Skinner LIIIIHI H
cautc8 be "....
2 00100100 lot.. ret Otller 4
St.- Llnl:ffftt
'0 00/00/00 5tl- Llnl:ffltt I.,orU/ltudl..
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rea .......' VI.
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Stl,..,. 0.- D...rt88tt
3 63/06/25 Llnlf' rot ltuf0rc8 ....., lutter Ccg,ty lI.et tll Corrnpondlft::l 9
I_tllltian of tile ""Ian 1--1, 0-
stl,..,. .... If Vlat I. ---4 ....11'lan
Clle8t81'
64/01/21 LIttW reI Ft.,.. ..... Laul8 C8t8r eorrl..,..-.&- 10
....., for 8 witt..
"II8Pt an tIa8 ...t tIa
188N'8 8Ctlan '18/64 In
........ to 1Ir. Stlnner'e
..... and refuu
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4 64/D1119 Liner res CorrespIII'dInce II
Skinner Llnl:fflta
Z 64/1Z1OO .~ artlct. TM ''''''1, 'UI"U" Verl- .~ artlct. 'Z
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" . Llnl:ffl It ~I",
-------
P.,a .0. Z
02/10/92
ADIIIIIITlATIVI IICIIID IIIDO
I_IAL ACfIC18
sel- UI8"U IITI
IIIIT ClEITD. 01110
FICHE/FlAME PAGEl DATE TlTU AllY.. IECIPIEIT DOCIIRT "" OC1C1U81
Z2 81/10/23 Flt.d Inwstl'ttl- E =, CItY .... USIPA I...,.UIINdI. 13
of UnclntroHed ElWlr--, Ire.
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20 83105/1' Eataftl". S-ry . l.,.nt/lNdI.. 15
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for It Inner Landfill
.Ita
117 83/05/18 F I.., .""Itl CII2IIIILL UIIJIA ....rUIINdI.. 16
Act I 11ft linter" 1ft
It.nner Lenaf'll
IItt
4 84/04/20 Lttter ra: 188ft ""', MtII.". IOIIllb, CO! n..,..."'a 17
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07/01J1S
Z 84/09/24 Latter ro: LlndI VI.., .... COI8unttl_. COfr~--"'- 18
Stltl C18Ir1~0UI8 ltett C'..,.'.... USlPA
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37 84/10100 ...1. V ~ Orte88r UIIN I..-rUIINdI.. 19
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-------
. 'qe .0. 1
02/10,92
ADIIIIIIWTlW IECIIIII 1811
I_1M. ACtll8
Sltl... LA8If1U IITI
IoWIT C81TU. 01110
FICHE/flAME 'AGES DATE finE AUnIII IECI'lm DOaIIEIT Tm DOCIU8I
1..,1.. . stt-
LIfIItf t"
12 54/12/07 11811'8rG8 1'01 laben lCarNl8ll8l. G88 ..... USDA Correspandlra zs
Interl. I~ Ve8tan
85103106 S"- Landfl" 118& vart- ....t' '" lot.. Z4
~ lito
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11611J
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21 85108100 fino. C~ltY C8IIt 0,.....,. & -....rot 1IcCUo. l.,.rulStudl.. 26
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$"...... LandfIll
129 85108100 IIIrt Plan RI- C8IIt 0'....,. & U8N l.,..calltud'. Z1
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ftl...... cap USDA
85/10108 Cam.rsltlan locord G- vone. Ilflro O'ComDr. clm Ot".,. 29
1'01 .-1,.,... LlI'IIHfll USDA '.t
85/10m tarMruttan lecord '- ...... IUb IWftI OttIer SO
1'0' Upl8t1 of IIrlrwwr UllPA
lInIHIU . aU
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PI..
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-------
.-.. ... ..--. - .
118'8 MO. 4
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4 86/03/00 S\4I8rhnt 'I'OIr- USIN feet lII..t. 31
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A..., ArnIIft8I
A Ntt Ie ""tl",
to CIII-- -
f41C8t". IlMItl..tlon
of panlbl. _I~al
cant_lnetl on at th.
Stl,.,... LlNHltt
~alt.
86103/1' Trip IIIIOI't for """""t 1IcCu8. Jolin 'err- ~J= .~. 42
Itlmer Landfill UIIPA
Illfl klck'off ...tl".
3/6186
-------
p... 10. 5
02110192
ADIIIII8TIATM IECICID IIIDO
I_IAL ACTIOII
Ir'- uenu I.ft
WElT CIIIITD, 01110
FICHE/FlAME PAGEl DATI TlTLI AUf.. IICIP.m DaaJIEIIT T'f1II DODUII
86/03/" CClrlftr8lt I an lecord G- 1IaniI. Clldly 0--" GUlar 4J
rll Itl,.,.,. I.8rlHlU USDA
SpaclflCl
] 86/04/08 "~rl: '- 1IaniI, ,UI 1It8Dr..s. 44
Ski,... I.8nHItt I'tl USDA
86/04/'6 CCII'Iftr88tlan lecord '- 1IaniI. "In .art, ,,"tan Otller 45
ral UpdIte an Rimer U.,A
Landfm I.
86/04/25 llUer ret St- 08t,..... G- Wont, USDA C:orres~ '6
5"'1", It SIt.,.,.,. USDA
Landfltt Iftd lftdU8trll'
EAC888 LandflU
86/04/29 CCIrIftr8ltlan lecord '- 1IaniI, .laIIn 1lant8l'888, OUter 47
rll UpdIt. of Sklmer USDA \DOoTV
LIfIIH Itt I.'" r.....,..
to Ut. Am IIOlbrook
litultian
86104/29 CCII'Iftr88t Ian lecord '- 1IaniI. T. Clntto, Cll2JltILL OUter 41
reI Am lotbrook'. USDA
datld
4 86105/02 L.ntl' ral II.., O-.r, CUrtII let... USEJIA Corrupo. 40.. -I '9
Spacl.. 'estlclde =-
AN'"I. for 8..ldlnttlt
...... to be coUeet..
f,.. tilt Sklmer LIlldfIH
lIte
86105/09 . CalMrlatian 8ecord ~ 1IaniI. "In .art, ,,"tan Otller 50
Nt UIIdIt. of Rimer USDA
Landfm lit.
5' 86lO6lOO """'-.el' ~ DI'IIMr & USDA l...ru/l..t.. 51
.Uty A--.a licit.., I...
'roJect "1ft for
Adl81tl_' Cr....ter
""1", stlmer
Landf Itt
86/06/03 CCII'Iftr88t I an IICOI'd .... VanI. .laIIn llaftttrtll, Otlltr 52
rei Itlmer LIlldfIH USDA \IICDo TV
.
-------
P1t8 10. 6
02110192
ADIIIIIITUTIVI IECIIID 180
I..IIL ACT".
18:1- U8'IU. 11ft
loUT CIIIITD, 0110
FICNE/FIAME 'AGEl DA'I flU AUfa UCIPIm DCXUDT "" DOaU8E
II'" \lpdltI
211 86/D6/10 O\aUty AI--. C8ID Dreaer & UllPA .""U/INSI. 53
Pre'ect PI.. 1IcI... Inc.
for th. Ikl-
L.-f'" lit.
86I071Z9 C.......tlon I.... ~ ..... 11. "_, 1.ldInt Otller 54
.... ",,*t. on Ktlvltl. USDA
It Itl- Llndtlll
86/D8106 C.......t'on lecord G8w ...., Ie I II. IUI'ftI OtIIer 55
"" UpdItl on Sk'- USDA
L.-f'H
6 86/08110 Spec'll Anllyticil UlEPA Dem'l 11180101111. ."""t/INS'. 56
'-'e. I188ton
2 861091115 Litter .... '1-- c..." Dwtd ...-*.1 torrl''''''''' 57
C8aI'N for",..,.ty UlEPA
8d 'KIM to th.
st,mII' LINHIII
In Woet CII.tlr. CIllo
6 861091ZJ IeI8lM InIUI I'll ~ ..... Fill 1e..,..11'411 58
''''P leport for thl UIIPA
9/16/16 I'tl vi,'t
to It.mII' LINH'II
86111105 C.......t'on lecord G- IIanI, I18rt NIltIOfl. Vllton Othlr 59
"I' Sk'nner Lendflll UlEPA
'''--'t8 ft. lor'",
4 871t1ZJQ6 0ZI06I87 II IIPIIrt ~ ...., V.,.t- ""t I '" lotll 60
","I,. . Skimii' \IaN
. L8Mf' n
87/GV1Z CGrMrutt.. IICOI'd '- YonI, Dft18 ,.,1.. VIIton ather 61
I'ft IIIrft8/*ffel_'. USDA
0' lot 1 G88 ...-11
4 87104/01 s~ '''''1'88 UIIPA l.,..t./lNSI.. 6Z
1...111 IftYllt'..tlon
St'mII' LINH I" II tl
4 87104"3 Litter 1'1' le'dIaIl Starter. G8w Wane, UIIPA c~ 63
Int-tlon on IIIIIt CIN
G!N f..11 II ftICOI..,..,
-------
p,.. 10. 7
02/10/92
ADII.IIIWflVI IECCIO 1811
1118IAL ACTIC8
SIt.... U8nu 11ft
YEIT ~ITD, 0110
FICNE/FIAM! 'AGEl DATI TIM AlITa UCI'IDT DOCII8T Tm DOC88I
II pert of I ...... II
II effort Ie t~1
Sltl..... LMIHIU
Ilel
871115118 CCllMt'Utian llCON G88 WonI, --. coa, USDA Ottler 64
rll Itl..... LMlHln USDA
Flet III8et ",*t.
87/05118 CaIwerIItIIl'l llCON G88 WonI, C8r0t 1_, lutter O~... 6S
rei lit...... Lindt. n U8A ...
F8Ct 1t18M
87/05/18 1iI---.. rll G- WonI, vlrf- M_--- 66
Flet III8itt dl8crlb.", USDA
tile ...." tl of tile
U.I. EPA'I f'ret
...... of 'IM8tltatfan
It tII. lit I..... LlIIHltt
87/05/" 111----. rei T. eon.,. I. Wont. ~. "", "---" 67
Sit I..... LIIIH Itt USDA U8A
f let S118M
871115/23 88M8p1p8r Artlcl. TIle Cfncf,..tf Er4air... G8W Wont, USDA 81M1p1p1r Artfct. 68
rll W'I -- de,..,.
It lit...... LMIH.n
3 871115/26 EPA I"" to ~Itt 1- coa, G- Wont. USDA 18W8PlPlr Art'ct. 6'
Sltl..... Ilt"1 '... l\8t'caet-
-1.1 Inc.
87106/1'. C8wwutlan IICOI'd G88 WonI. CaNt 1- 0tII8r 7'11
...1 'let _t (6I1Z) USDA
~t. for 1It1.....
LIIIHItt
] 871f»/17 ""1", lot. PII G8W WonI, ,..1- _tf"l lot. 71
Itl..... LMIH.U It U8N
"-tan C8Itl'8Ctor
office
87107106 "-r"" ...1 G8W WonI. 'Ue II........ n
Tr', report for tile U8N
6IMII7 Iltl ril't
It tile lit......
,
-------
PI'.' ~C:. a
OZl1019Z
-1.IITIATift IECIIIID IIDII
I-IAL ACTlC8
srl- U.FILL 11ft
WIT CIIIITD, C810
FICNE/FIAME PAGEl DATI TITU AUT- IICI'IDT DOCIIUT "" OOC8JIIEJ
Landfill lito
2 87/08105 "---' r.: G- .,.,., ,no .......... 71
Trtp report for tho USDA
7/S0117 lito Yilit
to' tho Itlnner Landfill
lito In CIllo
Z 8710811. "_,.... re: G88 .,.,.. ""'111- A~ _.48 74
ItlCUI "---' USDA
for tllo Itlnner
Landfill lito
In CIllo
87/09/09 C-.tlon lecord USDA .-V81- Otllor 75
r.: Skinner Landfl It
87/tllJnJ C-.tlon lecord G- .,.,., llIIIrt ,,- OtMr 76
ro. I'urdI88o of tIIo U8N
''''''1 property
IIItteit II norm of tile
Rimer Landfill
2 87"0'22 "-"" ro: G88 YonI, ,n. .......... 77
Trip IIt80rt for .Ito USDA
vl.tt to Itlmer
Landfill on 10n1187
Z 87'10129 "_~ re. G88 YonI. V..,- --... 71
UpdIto on ttIo U8N
1t8CU1 of tile I--Ia.
I_c'_,on at tile
Rimer LlIIHflt
3 87/10m R~ -48 ,.., GIno YonI, v..,- "_J_" 79
UpdIt. on tile USDA
It8tuI of tile I--Ia.
lftW88tl..tlon at
Rimer Landfill
87/10/SO EN I.... -- USDA ,...,Ic 'NI. 1.,.- 80
ordar for Stlnner
Landfill ~hnt
lit.
-------
. p"o MD. 9
OZI 1 OI9Z
ADII'I'ITUTIVI IECIDID IllIG
UJIED'AL AeTlIII
SlCI- U8nLL 11ft
. IIIIf CleITll. 0110
FICKE/FlAME PAGEl DATE TITU AUT" IECIPIm DOa.IIEIIT TTN 0GaU8E1
87'11'07 11_... ,.. c:- 1IarII. '''1 11_--- 81
Trtp report fOf' USDA
Sktl'Nr Llndft I I
at,o vtalt candu£ted
en 11'6117
Z 87""'0 Lotter ,.. ~- 1IoWI. EI.. ItII'Nr Corr*'_A.- a
Sktl'Nr L8ndftll USDA
open ct.IIJItlll
87111/10 C_netten lecord G8w 1IcnI. ~- 1IoWI. auA Otller a
,.. Solid v..to USU'A
vlolltlen at SkII'Nr
L8f'df "'
87",1ZS Lotter rot J- 1IoWI, EI.. Ikll'Nr eorres,.- .C8 54
"""17 rotNJIICIlen USU'A
of do8Dllttcn dl.,...1
IInIHIU It 8m
Clftetr..tl'O~cn reed
Z 871111ZS Litter rot GInI 1IcnI. !lIke Slut.,. OEPA corrosparGnce as
capl.. of "'.. I U8PI
1...111 I_tl..tlcn
IIpDI't
4 87,111ZS 11_... ,.. PM ...., I. !llcII8I1 Iort 11_--- 86
TlCtInlcal 1..,1.. If \I 1f1 .....CI.,..
tho Ikll'Nr L8f'dftll CGIWIA tIM8
...... , I' lopIIf't
Dot" ........ 1917
88104105 C8ww88tllft I""" ~. IIn. I..nl wen Otller 87
,.1 It II'Nr L8f'df II I USDA
'8tpn8t-
UIO'/U C8ww88tton I~ G8w 1IcnI. .I8IIft 18U., 0tIIII' .
,.1 ''''' of 1181
II. wUIt Itl.....
LII'IIIf I n II II
88104/29 CCllWlf'Ut 11ft lecord GInI 1IcnI. !lIke IIrnI Otller 89
"1 I....tod ItICUI USIJ'A
UtldlII for Ski.....
II fut1lr'O ....
-------
'1"..0. 10
02110/92
AllleI.ISTlATIVI IICIIID 1II1II
IIIIBIIAL ACTIC8
_1- W8F1U IITI
"IT C.ITD. 01110
FlCHE/FIME PAGEl DATI TlTU AUnICII IECI'IEIT DCIQIIEIT 'TPI DOCIII8f
88106/22 'ree. 1.1.... ,., uaN Pree. I.t.- 90
TII. ~
A8811i8o....t. ...
188ftIIorlut'", Act
of t911 .......tz..
tll. U.I. 1rwtrw8Mt.,
'rotectl.. A..., to
prowtcla '''leal
Aullt- "",t. to
qu8llflld cltlllnl
,,... ... .... .ffectad
or ~8ftCIII'y .ffaecad
by
. ''''''1 "'-"fInI
"""'" -t. .t..
13 88106122 L.n... ...1 .t cll881 'tartl8y. G..... IUt_. USDA Co~ 91
Stt"... L8ndfIU GIlt. EM
CIICU eo. r"~"'"
2 881"104 L.tt... ..., AU",lIftWW. Vlctort. Ditter CO! n&p-"'- 9Z
Stl"... ... CUlly 8f lilt,,,,
...... 8f "I tit
17 89101'" L8tt8r ...1 Fred -----, ltate Lrrw-. WEI Corn.,..."'" 9J
tile ""'..-nt of U8PA
'" ............. IW'II
,. --tory t. C881ct
. USDA II
450 89/OZ1OO ,...,--- 8f c:-. 0.... & U8PA 1"",.llItIICIl.. 94
1...1., ........ 1tc:I88, Inc.
ActIYltl.. It
Ul88ltNt lid IlUrdauI
tIIat.. lit.. (l1li IU
,... I I",.,..
1...1.1 1_.1...1...
I...... f... .t"...
L8IIIIfI U II te
89104107 Lett., ...1 n.. Itl..... CUlt..... COI'rft.p...... a "
Stt"... L8ndfIU
-"'"
2 89104125 L.tt... ..., 0",1., ~U, Et.. Itlmer-...,.", Corr "'PC- ...-, 96
101 lei tl88t. auti... GIlle-I"
COWIty ~Uc""
L8ndfIU Operallnl
-------
j
p. ilo.
02/'0/92
"
-1118mflVl .ECDID lIDO
'_IAL ACfllII
_1- ueflU. 81T1
loUT CIIUTII, CIllO
FICKE/FlAME 'ACEI DATI
,
TITU
AUT-
..caPaRT
DOCUUr ""
00CIU8f
89/OS/08
TI.dIy E-.
Ho\btect I ~onIOft
L- Ft,..
Leuer ret
U.. Iklmer-_",..
~"c"" Lendfltt
OpIr8tl-
D..lel C""U.
OIN
c.~
9T
2
89/OSIZZ
"-.... ret
s.-.-, of ..tl",
.1 tII w inti_I",
end Icl- ..
05"718t for
Stlmer elto
Fred 1art8n.
U8A
Flte
"-'...
98
209
89/07/00
lIort '1.. for tll.
.....1.1 Inveetl..tlon
end F_Utlllty ltudr
of tile ftlmer
LendfUI elto
EDI lilli_I",
81'11 Icl-
U8A
leportl/lt1llll..
99
'" 89/09/28 ,1,.1 CIoaUty al_- w Intl_'", & UllPA IlpM"tlllt1llll.. 100
'roJect PI.. Scl-
Add8ra8 fOf' tile
.....1.1 Inveetl..tlon
end F_lblllty ltudr
3 ""'130 L.tter ret Albert 1_. H--- II. Metl.... torr -..-""- 101
Stlmer L8nlH1l1 and \load & L-.t",
th. .ffortl of th.
St.t. and F8der81
Gow. ._.tl to "'t.
tile ""1--
""21'2 L.tter ret H-.b\. ~oIIn 118ft, VII- Ad8I*u8. COrr &.,..."'_6 '02
Itl.... L8nIIfIU ~tCed IC.t. "'t. U8A
2 90/01'" Letter ret V.I_""'. 1I....et. "olin Ilam Corn_...._.. '0]
CIIanII fop tile U8A
ltatw of tile Ikt....
L8nIIfIII lice In
IIItler c:..r.cy. 011 to
4 90I02I04 L.tter rot Albert I8:8rI. 11.....1. ~oIIn 118ft Cor. ,-...-.. '04
Sklmer L8nlHUI \load & L..I",
6 90102/07 "-'..... r.s Fred 181't8M. IUlianr, mc ~ '05
Updaced 1dI1GIt. fOf' \llDA
fl.l~ ocetvlel.. for
-------
PI" 10. ,z
OZl10192
AIIIIIIllTUfiVi UcmD IIIDII
I_IAL ACTI..
III- U8'ILL IITI
~" ':'ITII, 0110
FICHE/FlAME PAGEl DArt TlTU AUra IKlrlEIT DOQIIEIIT "" DOCIIMf
ItlftnIP Landfill
, 90/DJ/26 Litter .... '_11 ......, . r8III '8I"t8ft, USDA Cor.........- 106
I..,... to propoul QUIA
to COIp(lto I dr.fe
f...I.lllty',tudr
fOf' ello It IftnIP
LlnlHnl ,Ito
14 90105107 Lotter ro. Crel, V........,.., 'r8111 1Ir_, USDA Corresp..... - 107
MI .....,~ of W 1",I_t", &
rJl Ad crl tortl ScllnCl
fOf' ,.Ioctl", ~o
rllld8mtll IIIUI
_e ~11t0
fOf' 1..11", on ~o
stlftnIP LlnlHlll
PNJoce
2 90105/09 Lotter .... IleIIl'" ...., HonIIrIblo "olin Glem COrr~"'- 101
I..,... 10 l.tter of CIIlo-lJIA
,,,'" IIIIIleII requesel
I"'-elon .....",1",
tM ftl..... LInlHIII
s.,.fwId II eo
9010611' Llttlr r.. II8rt L""', . r8III 1Ir,-" USDA Corr~r a..8 109
I.. CIllo IJIA lito OIN
C-alnator fOf'
tM nl..... LlnlHt I I
" 91104/01 Letter .... '....e 'r8111 18rt8n, II8rt Liller, OIPA ~..._.. 110
fw Itleo AUlI fOf' UIIN
tM nt..... LInlHIII
. lite
1041 9'105100 ..... II 18Idfll W I118lnaerl", & UIIN 18IIOf't11ltudl- 1"
I.....cl..tlon fOf' sctence
ttI8 Itt..... LInlHI II
Itte
419 91105100 """Icee for tllo W 1",1"""'", & U8P. leporti/itudl.. 112
....... II 1...181 lei..
I.....tl..elon of tile
SIr I..... LInIH I It
lite
t.6I 91lO6lOO "'Una IIIk W I118lnaerl", & U8A leporCilltudl1l 11]
,
-------
P.~ 80.
OZ/10I9Z
1J
FlCIIE"ItAME 'AGII DATI
TlTU
.....-. for tll.
Ulmer UNflt\
SIt.
..IIIITIATlVI IECCIII 1I11III
I_IAI. ACTIGI
ft... U8'ILL 11ft
"IT caITU, 01110
AUf..
_I"IIT
Science
OOCUIEI' ,nor
00CIII8
-------
REMEDIAL ACTION
ADMINISTRATIVE RECORD
(Index and Documents)
tor the
SKINNER LANDFILL SITE
UPDATE NO. 1
WEST CHESTER, omo
JULy 1992
Uait.ed Statel EImro88atal Protecdoa AIfK'I
..... V
71 Wilt Jacboa 8oaJ,nanI
CIaIcIp, D. 60QM
-------
.. ..... ~. ... . . .~
~
INTRODUCTION
These documents comprise the Administrative Record for the Skinner Landfill Site .
Update No. LAn index of the documents in the Adminisuative Record is located at tbe
front of the first volume along with an aaonym index and an index of guidance documents
used by EP A Agency Staff in selecting a response action at the site.

The AdmiDisuative Record is also available for public review at United States
Environmental Protection Agency, 77 W. Jackson Blvd, C1icago, n. 60604. Questions
concerning the Admini!:uative Record should be addressed to the EP A Adminisuative
Record" Coordinator.
The Adminicttative Record is required by the Comprebensive Environmental Response.
Compensation. and liability Act (CERCL\). as amended by the Superfund Amendments
and ReauthorizatioD Act (SARA).
"I
-------
Volume (1)
Volume (2)
.. ..~.. ,..,"-..
Skinner LandtiU Site - Update No.1
Remedial Action
Administrative Record
Table o( Contents
(DocumeDt Nos. 1-15)
(DocumeDt Nos. 16-33)
-------
'.98 10.
o 7I29/'IZ
AD'IIIISTUTIYE IECCID lIDO
. IEMEDIAL ACTlG8
SCIIlEI LAMD'ILL SITE. UPDATE 10. 1
WEST CHESTEI, OHIO
FICHE/FlAME 'AGES DATE
TITLI
AUTJa
IECI"IIT
DOCUEIT TYPE
OOCII\JIIIE.
24
Int.rNti_l
T8Chnoiory Corpor.tlon
USEPA
leporta/Studi.
00/00/00
8.0 O"*-o
o IIpo88L 'Len,
S_it E~iP88ftl
Sito
10 00/00/00 01110 I....i.. Code USEPA leporta/StUIU. 2
15 00/00/00 '"' Th_L ,- Emir_uL, Inc. USE'A lIeporta/Studi. 3
l.-diltlon InO.stry
Contrector SlIney
2' 00/00/00 PI'eCIOMd "en few USE" IltIOrtl/SNdI- ,
tho Skinner LlftdflLl
Sito
28 00/00/00 l..aioCion (Cloen-",,) USEPAI USEPA lep»rta/Studi.. 5
of cont_inet8d ,- Emir_ul, Inc.
unconcroll8d S'-"8rfynd
O~it.. Iy Incinerotion
end 0t/I8r ,.,llr
TedlnDl08i..
12 76/04/21 Indwatriol Wl8to Indwatrtol LI~td ... IIIUI_. OEN leporta/Studl.. 6
I_tl..tlon IrOacrtol 1188t8 0 t Il1088'
U.,tclll88to ot...,
4 76/f15/2O .lfUt- of ..ti.. "ry C- USEPA ....ti.. lot- 7
""cI ot Sllert ff
laben I. IIoUon',
Office on 8I8y 20, 1976
,t 3:10 ,...
4 90/09/00 En8iftllrine IuILotin USE" leporta/Studi. 8
Mobi'o/Tronaportoblo
Inci..,..tion Tr..tMfIt
3 90/11 /01 lotico of Lien Under USEPA El.. It I....r CorrlSpondIf'cl 9
-------
P... 10. 2
07/29/92
ADIUIIITIlATlVE RECOIl IIDD
IEJUIAL ACTICII
SltIDU UlDFlLL lITE. UPDATE 10. I
"IT CIlEITIa. 01110
FICHE/FlAME PAGES DATE TITLE AUTIIOI IICI'IOIT DOa.IIEIT TT'I OOClU8£
tile ~rfWld A8nI8Inca
...., IlUtllori zation Act
of 1986
6 91/06/00 Fact SII..t re: USEPA Fact Slleeca 10
SIt I rwwr LII'Idf It l
"'... II l..aial
I_ti.ation
49 91/06/17 D8p118iUon of 'ritton & &alOCiat.. USDA I.,ca/Studi.. "
El.. Sk I rwwr
91/06/17 P\,Dll c Voueller USEPA Otll.,. 12
For Adverti.i",
31 91/06/1' 08p118ition of 'ritton & AIIOClat.. USDA IlpII'tllStudi.. 13
CJI8,l.. II"..l
43 91/06/1. O....ttton of .rttton & AIIOCtat.. USDA ....,.ta/Studl.. II.
.Icfteel CCU\tr-,88\
( 39 91/06/19 D8p118itlon of 'ritton & A.lOCilt.. USIN llpOf't.lStud I.. 15
lay Skirwwr
4 911061ZO UlU'A .. «IE'A USDAlOPA ,...,te ,,... IIl- 16
Inwite tile ..te
-to I tnf_ti_l
_te 8Ott,.
2 91/07/30 Litter reI L I.. WIlt tacre. _HI SUlU_. Cor. £...,..-""- 17
,...l ....-t fOt' CI.IAII USDA
I '.-tIt ut_t~
of t'" e-.c period
tllat t. 8dI-..l8d for tile
Skinner Landfill Sit.
2
911011(111
Skinner LlI'Idftll:
r.tl..t" ~tity of
01'\88
CIIrt.t.., .iron(
Crall v......,...
\AI E"II...,I", &
Scl_. Inc.
Shlill SUlll_.
USDA
Corrnpondlnc.
18
,
-------
p... 10.
07/29192
3
ADIII.ISTIATlVI 1IQ8D lax
I£JUIAL ACTIC8
SlCI..1 LAllDFiLL SIT! . ~T! MO. 1
~ST CNESTER. 01110
flCHE/flAME PAGES DATI
TITLE
AUTIIOI
IICI"IIT
DOCUIE.T TYPE
DOCIII.Mi£ .
12 91/09/1' LeUer re: H_.olo .IoIvI 1oeIINr. SMHo SUtllvon. Corrft4lOo dllleo 19
I....' for .&1_101' ..... of I.._«nl- USIN
an USlPA'. c-ca
pwlod for ~fund SI«o
8 91/10/00 E",lnterl", Iullo,ln USEPA Vwl- l.porU/StlolSl.. 20
CafI«rol of AII'
f EaI..I- ,,..
..terlol. Hendl", Ourl".
l-.ctlo,lan
91/10/24 Lener rea fred ler_. Iltay SctI8ffner Corrft.,AdII- 21
1....« of ""Ian USE'A
TCIIIIWIlp ...181--
In IftluU I", ~,flN
_ml", I I II1II
9
92/01/00
Eltl.,I",
Potentlol for
Occur..-o of DUll\.
at ~f1n8 lit.
USEPA
leporU/StlolSl..
zz
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"
_lllnUTlY! IECCID IIIDO
IfJEDIAL AeTlOl
SlCI.. LA8'ILL SITE' UPOATE 110. 1
WEST eKES TEl, OKlO
fICKE/f~ PAGES DATE
TITLE
AUT"
IECIPIEIT
Doa'.UT ""
DOCIII.IGE;
92/04/21
USE" ~..
A 3O.D8Y P\bL ie
eoil8lftt P.r I od III I ell
WHL c-h,* 01'1
- 21, 1992 for tile
(ClllPL.tlon of
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Sit. coordlnetor CEPA
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-------
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fICME/f~ 'AGES DATE
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Leuer re:
Stl,..,. LII'GfIU .
unian TOINIIip,
lut Ler c-ty
AD.UIISTUTIVI lEaJID lIDO
UMEDIAL ACTICII
SlCIIIIIEI LAlDFiLL SITE' UfIOATE 110. 1
WEST CMESTEI, 0110
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u.s. EPA ADMINISTRATIVE RECORD INDEX
:2::. C~
-.. ~"~"
:' :";:':!rS
~~::"~17
UPDATE .2
SKINNER LANDFILL SITE
WEST CHESTER, OHIO
10/13/92
=:::FiE!ii
.........------
---------
(iIlCr.,
::14
J., ~.S.
?:~"'!!"t ;.,
:::n;ressun
:~l;~nn, S. I
4::,n. C., ~.S. EPA
Allen, C., ~.S. EPA
.:iLE!jE:::::-::~
=:========:::::::
~e;:;as.tic~ w~ Jet::': C. :J:in:1l~ :~ CiS' ~c,
:v77-~3-~6~~. Sh~e of Cllio 'so ~! ~er~ Sti~n-
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-----
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.a
'C
2
l'
:i
-------
u.s. EPA ADMINISTRATIVE RECORD
SKINNER LANDF.ILL SITE
WEST CHESTER, OHIO
UPDA!E .3
05/04/93
.-If'
DOC' DtiTE ~ W THOR RECIPIENT TITLE/OESC~i?TION PAGES
---- ---- ------ --------- ----------------- ----
--------- -----------------
09130/92 Adilkus. V.. U.S. Record of DeciSion ind Re~00nS1y!neSS SUlury :1
EPA
, 1~/09/92 "uno. ~.. U.S. EPA PRP's Adlin1strative Order 'lith ~tticnl!ntsl 69
L
-------
u.s. EPA ADf1INISTRATIVE RECORD
SKINNER LANDFILL SITE
WEST CHESTER. OHIO ~
OPERAB~E UNIT .2
ORIGINAL
05/04/93
DOCI jj':'TE AUTHOR RECIPIENT TITLE/DESCRIPTIDN PAGES
..--- ---- ..----- --------- ----------------- -----
--------- -----------------
00/00/00 Resldents of Butler U.S. EPA Sign.tures of Butler County Resldents ~ho Are 2
Co un ty Agalnst the Burning of TOXIC ~.stes and NIII
Conslder Alternative Cle.nup "etnods
10/00/90 M.rt Engineers U.S. EPA COllunity Notific.tion PI.n, RI/FS, Appendix 64
~idwest, Inc. B for C.rdington Ro.d L.ndfill
01100/92 U.S. EPA U.S. EPA Fact Sheet: 'Estil.tlon of Air Iloacts for 4
SOli ~aPor Extr.ction (5VEI 5ystels'
C:l /i;'j;q2 '"err,;'.. '. - .C' u.5. EFA Refe.ence -act Shee,: 'Estl1it1ng rotentlal 9
u.~. t, II
fer 0:cure~ce 0; QN~-~ at S~oeriuno Sites'
,:,5/04/;2 C1 t1:er,s ~.5. EF~ Letters D.ted 5/4/;: to 2'.';3 FrOI ~arlOUS ii
C1:i:ens 'e: COllents on the Alternatlve
C~eanup ~!thods, the Incinerator .nd Other
iss"es Reg.rding the Cleanup of Skl~ner
~ar,ofi11
6 05/08/92 Whitacr., L.. CLEAN. Sullivan. 5.. U.S. Letter re: Forl.1 R!Quest for .n Extenslon to
inc. EPA the Public COllent reriod Ending on "a! 2;.
H92
:)oiOQ./,2 J~lon Township U.S. EFA COllents .nd Recoll.ndations 0" tne Prooosed 130
T "J stees rian for tr.e Cleanuc of the 5(lnner L.ndfili
\'S/OOi;: 5ilnner L.ndflll PRF U.S. EPA Cwllents :: the U.S. EPA's Interl. Re.eoy. 70 ,-
...
Group Be Incluoeo In the Adllnlstr.tlve ~ecord
q 09/24/92 Sulh. D.. Union Vander Kloot. J., Letter re: the TOlnship Adlinlstrative Office
T olllshiJi U.S. EPA Becol1n9 a Second Repository
:') 10/09/9: "attar, J., U.S. EfA Vander Kloot, J., Technlca: Support Branch's Evaluation of n
U.S. EPA "iternatl~e Treitlent Technolo~les
'0 llmm Hall, C., U.~. EPA V.nder KloDt. J.. "eiorindul re: Inhalation Rist C.lcaiations 131
..
U.S. EPA fer Prooosed ~oblie Inciner.tor .t S~lnner
Landfill
-------
DOCI DATE AUTHOR RECIPIEJlT TITLE/DESCRIPTION PAGES
===a ......-- ------ :':==8:::: ===..============ -----
12 11123m Lindensehlldt. D., V.nder ~loot, ~., Letter re: the Co.lihan's Reeouend.hons 2
~est Chester U.S. EPA for Cle.nuD
Co.l i hon
l:i 12100/92 U.S. ErA Public F.et Shret: 'U.S. EPA Re 10
Ev.lu.tes Cle.nuD ~ltern.tlve5 for the
Sklnner L.ndfill Site'
14 0::09/93 QinqenbiCh. Loo Allen. Coo U.S. EPA PRP GrOUD' s Pub Ii c ~o..",ts an the U. S. EPA' s 1380
Skinner L.nGtlll FKr Deeeiber 1~92 Fact Sheet far Sklnner L.ndflll
GrouD
15 C2i25/93 Dunn CorDon t1 on Skinner L.ndh 11 Intenl Reaedid "risures ~ort Phn 132
Teehnle.l Couittte
2
-------
u.s. EPA ADMINISTRATIVE RECORD
SKINNER LANDFILL SITE
WEST CHESTER~ OHIO
OPERABLE UN IT *2
UPDATE ~t1
OS/28/93
DOC' D~TE AUTHOR RECIPIENT
---- ---- ------ --------...
---------
v6 il7192 Citizens U.S. EPA
TITLE/DESCRIPTION
-----------------
-----------------
Letters Dated 6/17/92 to 1/19/93 FrOI-Various
Citizens re: COllents on the Alternative
Cleanup "ethods, the Incinerator and Other
Issues Regarding the Cleanup of Sklnner
Landfill
~I/m U.S. EPA Recipients
(1(,,00/1/3 U.S. EPA Recipients
Video!11 and Audio(4) Tapes FrOI 7/21//92
Public ",eting
Record of Decision iPendingl
PAGES
-----
2Q
v
v
-------
.,
- -.-. --"-, . -, .
ATTACHMENT 2
STATE POLICY/GUIDANCE DOCUMENTS FOR TBC TABLE
1.
ARARs, Final, Ohio EPA, Division of Emergency and Remedial
Response, DERR-OO-RR-OOl, July 12, 1991.
2.
Guidelines and Specifications for Preparing Quality Assurance
Project Plans, Final, Ohio EPA, Division of Emergency and
Remedial Respon~e, DERR-00-RR-008, March 5, 1990.
3.
How Clean is Clean, Final, Ohio EPA, Division of Emergency and
Remedial Response, Final, DERR-00-RR-009, July 26, 1991.

Background Guidance, Final, Attachment to DERR-00-RR-009, July
26,1.991.
4.
5.
Site Safety Plan Review Program, .Final, Ohio EPA, Division of
Emergency and Remedial Response, DERR-00-RR-015, May 1, 1990.

Best Available Treatment Technologies (BATT) for Remedial
Response Program Sites, Final, Ohio EPA, Division of Emergency
and Remedial Response, DERR-00-RR-016, October 23, 1992.
6.
7.
Procedures for Evaluation of Response Action Alternatives and
Remedy Selection for Remedial Response Program Sites, Final,
Ohio EPA, Division of Emergency and Remedial Response, DERR-
00-RR-019, October 23, 1992.
8.
Guidance on the Definition for Aquifer and Aquifer System,
Interim Final, Ohio EPA, Division of Drinking and Ground
Waters, DG0205.100, January 25, 1991.

Significant Zone of Saturation (OAC 3745-27-01(RR»), Final~
Ohio EPA, Division of Drinking and Ground Waters, GD0303.110,
August 5, 1991.
9.
10.
Review of Ground Water Sampling and Analysis Plans, Final,
Ohio EPA, Division of Drinking and Ground Waters, PP0303.200,
October. 3, 1990.
11.
Guidance on Solid Waste Siting Criteria: Sole Source Aquifer
[OAC 3745-27-07(B) (5»), Final, Ohio EPA, Division of Drinking
and Ground Waters, GD0202.101, May 6, 1991.

Guidance on Solid Waste Siting criteria: Minimum Distance
from a Public Water Supply Well [OAC 3745-27-07 (B) (4) ), Final,
ohio EPA, Division of Drinking and Ground Waters, GD0202.105,
August 5, 1991.
12.
1
-------
23.
24.
25.
26.
ATTACHMENT 2 (continued)
13.
Review of Ground Water Quality Assessment Plans, Final, Ohio
EPA, Division of Drinking and Ground Waters, PP0303.300,
October 3, 1990.

Guidance on Solid Waste Siting criteria: 100 gpm Aquifer [OAC
3745-27-07(B) (9), Final, Ohio EPA, Division of Drinking and
Ground Waters, GD0202.102, October 8, 1991.
14.
15.
Guidance on Solid Waste Siting Criteria: Minimum _Isolation
Distances to Wells and Developed Springs, Final, Ohio EPA,
Division of Drinking and Ground Waters, GD0202.103, October 8,
1991.
16.
Guidance on Solid Waste Siting criteria: Material Acceptable
to the Director [OAC 3745-27-07 (B) (15), Final, Ohio EPA,
Diyision of Drinking and Ground Waters, GD0202 .104, October 8,
1991.
17.
NPDES Existing Effluent Quality, Policy 1.02, Ohio
Division of Water Pollution Control, February 22, 1989.
EPA,
18.
NPDES Small Dischargers, Policy 1.03, Ohio EPA, Division of
Water Pollution Control, February 22, 1989.
19.
20.
NPDES Application Requirements, Policy 1.10, Ohio
Division of water Pollution Control, August 1, 1988.

NPDES Monitoring Frequency, Policy 1.12, Ohio EPA, Division of
water Pollution Control, January 20, 1989.
EPA,
21.
NPDES Wastewater Treatment Plant Operator Certification,
Policy 1.13, Ohio EPA, Division of Water Pollution Control,
August 1, 1988.

NPDES Upstream/Downstream Sampling, Policy 1.14, Ohio EPA,
Division of Water Pollution Control, August 1, 1988.
22.
NPDES Permit Limits When Calculated Limits Are Below
Detection, Policy 1.15, Ohio EPA, Division of Water Pollution
Control, Auqust 1, 1988.
NPDES Tiered Permits, POlicy 1.16, Ohio EPA, Division of Water
Pollution Control, August 1, 1988.
NPDES Permit Transfers, Policy 1.19, Ohio EPA, Division of
Water Pollution Control, August 1, 1988.
NPDES Sampling Frequencies for Industrial Dischargers, Policy
1.20, Ohio EPA, Division of water Pollution Control, August 1,
1988.
2
-------
37.
38.
39.
40.
.,
. - ,..-., -...
ATTACHMENT 2 (continued)
27.
NPDES Discharge of Petroleum Liquids Resulting from Corrective
Actions and Closure of Petroleum Underground storage Tanks,
Policy 1.21, Ohio EPA, Division of Water Pollution Control,
October 2, 1989.
28.
Permits to Install - Procedures for Submittal of Plans for
Pretreatment Facilities, Policy 2.02, Ohio EPA, Division of
Water Pollution .Control, August 1, 1988.
29.
Permits to Install - Holding Tank Installation, Policy 2.03,
Ohio EPA, Division of Water Pollution Control, August 1, 1988.

Permits to Install - Professional Engineer Requirement, Policy
2.04, Ohio EPA, Division of Water Pollution Control, October
7,_1988.
30.
31.
Permits to Install - Installation of Surge Tanks, Policy 2.06,
Ohio EPA, Division of Water Pollution Control, August 1, 1988.
32.
Enforcement Management System, Policy 3.01, Ohio EPA, Division
of Water Pollution Control, August 1, 1988.
33.
Verified Complaint Procedures, Policy 3.03, Ohio EPA, Divison
of Water Pollution Control, May 18, 1989.
34.
Quarterly Noncompliance Reports, Policy 3.04, Ohio
Division of Water Pollution Control, August 1, 1988.
EPA,
35.
Design Criteria: Sewage Collection, Treatment, and Disposal,
Policy 4.01, Ohio EPA, Division of Water Pollution Control,
August 1, 1988.
36.
Design Criteria: Isolation Requirements, Policy 4.02, Ohio
EPA, Division of Water Pollution Control, January 25, 1989.
Design Criteria: Experimental Systems, Policy 4.03, Ohio EPA,
Division of Water Pollution Control, August 1, 1988. .
.
Design Criteria: Small Diameter Gravity Sewers, Policy 4.06,
Ohio EPA, Division of Water Pollution Control, October 1,
1988.
Design Criteria: Non-toxic Fly Ash, Bottom Ash, and Foundary
Ash, Policy 4.07, Ohio EPA, Division of Water Pollution
Control, February 24, 1989.

Design criteria: Waste Pickle Liquor Disposal, Policy 4.08,
Ohio EPA, Division of Water Pollution Control, August 1, 1988.
3
-------
47.
48.
41.
ATTACHMENT 2 (continued)

Design Criteria: septage Disposal, Policy 4.11, Ohio EPA,
Division of Water Pollution control, August 1, 1988.
42.
Design Criteria: Filter Sand Testing and Approval, Policy
4.13, Ohio EPA, Division of Water Pollution Control, August 1,
1988.
43.
Design criteria:, Lift station Overflows, Policy 4.15, Ohio
EPA, Division of Water Pollution Control, August 1, -1988.
44.
Design criteria: Hydrogeologic Evaluations on Surface
Impoundment Sites, Policy 4.17, Ohio EPA, Division of Water
Pollution Control, August 1, 1988.

Pretreatment: Adding/Deleting Program, Policy 5.01, Ohio EPA,
Division of Water Pollution Control, August 1, 1988.
45.
46.
Pretreatment: Approved Program MOdification, Policy 5.02,
Ohio EPA, Division of Water Pollution Control, February 22,
1989.
Public Records Inspection POlicy, Policy 6.02, Ohio EPA,
Division of Water Pollution Control, August 1, 1988.
Fees, Policy 6.04, Ohio EPA,
Control, August 1, 1988.
Division of Water Pollution
4
-------
.... . - . .
"
,
ATTACHMENT 3
STATE APPLICABLE OR RELEVANT AND APPROPRIATE
REQUIREMENTS (ARARS)
-------
OS/28/93
OHIO REVISED CODE (ORC) ARARs FOR THE SELECTED REMEDY FOR OPERABLE UNIT 2
SKINNER LANDFILL
BUTLER COUNTY
Page
REVISED CODE
SECTION
ARAR
TYPE
PARAGRAPH
TITLE OR SUBJECT OF
REGULATION
DESCRIPTION OF
REGULATION
APPLICA TlON OF
REGULATION
3704.05
3714.13
3734.02
3734.02.7
3734.03
3734.04.1
3767.13
3767.14
A.I
(GI
A.B
A.c.o.a
PROHIBITS VIOLATION OF AIR
pOLLUTION CONTROL RULES
DEMOLITION DEBRIS FACILITIES.
VIOLATIONS PROHIBITED
EXEMPTIONS TO SOLID &.HAZ. WASTE
TISID REQUIREMENTS
HANDLING LOW.LEVEl RADIOACTIVE
WASTE PROHIBITED
PROHIBITS OPEN DUMPING OR
BURNING
EXPLOSIVE GAS MONITORING
PROHIBITION OF NUISANCES
PROHIBITION OF NUISANCES
PROHIBITS EMISSION OF AN AIR CONTAMINANT
IN VIOLATION SEC. 3704 OR ANY RULES.
PERMIT. ORDER OR VARIANCE ISSUED
PURSUANT TO THAT SECTION OF THE ORC.
PRatt/lilTS VIOl A liONS OF ANY SECTION OF
CI1APTER 3714 CONCERNING ONSTRUCliON
AND DEMOLITION DEBRIS DISPOSAL FACILITIES
OR ANY RULE OR ORDER ISSUED PURSUANT TO
IT. DISPOSAL OF ASBESTOS IS SPECIFICAll Y
PROHIBITED WITHOUT AUTHORIZA TlON.
PROVIDES AUTHORITY AND CONDITIONS BY
WHICH TIlE DIRECTOR MAY EXEMPT ANY
PERSON FROM PERMllTlNG OR OntER
REOUIREMENTS GOVERNING TItE GENERATION.
STORAGE. TREATMENT. TRANSPORT OR
DISPOSAL OF SOLID OR HAZARDOUS WASTE.
AI PROHIBITS COMMINGLING LOW LEVEl
RADIOACTIVE WASTE WITH ANY TYPE OF 50110
WASTE. ItAZARDOIiS WASTE. OR INfECTIOUS
WASIE.III NO OWNER OR OI'I.IIAIOI1 01 A
SOLID. INfECTIOUS OR HAZARDOUS WASIE
FACILITY SHALL ACCEPT fuR TRANSFER.
STORAGE. TREATMENT OR DISPOSAL Of ANY
RADIOACTIVE WASTE.
PROHIBITS OPEN BURNING OR OPEN DUMPING Of
SOLID WASTE OR TREATED OR UNTREA TED
INFECTIOUS WASTE.
REQUIRES EXPLOSIVE GAS MONITORING PLANS
FOR SANITARY LANDFilLS AND PROVIDES
AUTHORITY TO THE DIRECTOR OF OHIO EPA TO
ORDER AN OWNER OR OPERA TOR OF A FACILITY
TO IMPLEMENT AN EXPLOSIVE GAS
MONITORING AND REPORTING PLAN
PROHIBITS NOXIOUS EXHALATIONS OR SMEllS
AND THE OBSTRUCTION OF WATERWAYS.
PROHIBITION AGAINST THROWING REfUSE. OIL.
OR FILTH INTO LAKES. STREAMS. OR DRAINS.
MAY PERTAIN TO ANY SITE WHERE EMISSIONS CHEMICAL
OF AN AIR CONTAMINANT OCCUIIS EITItER AS A ACTION
rlAE.EXISTING CONDITION Of HIE SITE OR AS A
RESULT Of REMEDIAL AClIVITIES. SHOULD BE
CONSIDERED FOR VIRTUALLY AI.l SITES.
I'[RTAINS TO CONSlIlIIC1 IIJN AND DLMOll110N
DEBRIS fACilITIES WHERE I1AZAROOIiS WASTE
OR HAZARDOUS CONSTITUENTS IIAVE COME TO
BE LOCATED. CONSIDER FOR SITES WHERE
REMEDIAL ACTION WILLINCLUDEDEMOLITION Of
STRUCTURES OR ASIIESTOS HAS COME TO BE
LOCA TED.
PERTAINS TO ANY SITE AT WIIICII SOLID OR
HAZARDOUS WASTE HAS COME TO liE
LOCATED.
PERTAINS TO ALL SITES AT WHICH LOW lEVEl
RADIOACTIVE WASTE HAS COME TO BE
lOCATED.
ACTION
ACTIUN
CIIEMICAI
ACIION
PERTAINS TO ANY SITE AT Wlt/CH 50110 WASTl ACTION
HAS COME TO BE LOCATED OR WilL BE LOCA nuN
GENERATED DURING A REMEDIAL ACTIUN.
PERTAINS TO ALL SANITARY lANDfillS EXCEPT LOCATION
fOR THOSE THAT DISPOSED OF ACTION
NONPUTRESCIBlE WASTES.
PERTAINS TO ANY SITE THAT MAY ItAVE
NOXIOUS SMELLS OR MAY OBSTRUCT
WATERWAYS.
ACTION
CHEMICAL
PERTAINS TO ALL SITES LOCATED ADJACENT TO ACTION
LAKES. STREAMS. OR DRAINS. CHEMICAL
-------
OS/28/93
OHIO REVISED CODE (ORCI ARARs FOR THE SELECTED REMEDY FOR OPERA8LE UNIT 2
Pege
2
SKINNER LANDFILL
BUTLER COUNTY
REVISED CODE
SECTION
PARAGRAPH
TITLE OR SUBJECT OF
REGULATION
DESCRIPTION OF
REGULA TlON
APPLICA TION OF
REGULA TION
ARAR
TYPE
6111.04
ACTS OF POllUTION PROHIBITED
- POLLUTION OF WATERS OF THE STAle IS
PROHIBITEO.
PERTAINS TO ANY SITE WHICH HAS
ICONTAMINATED ON-SITE GROUND OR
SURFACE WATER OR WILL HAVE A DISCIIARGE
TO ON. SITE SURFACE OR GROUND WATER.
ACTION
6111.04.2
RULES REQUIRING COMPLIANCE WITH
NATIONAL EFFLUENT STOS
ESTABLISHES REGULA TIONS REQUIRING
COMPLIANCE WITH NA TlONAL EFflUENT
STANDARDS.
PERTAINS TO ANY SITE WltlCH Will HAVE A
PIONT SOURCE DISCltAHm
ACTION
6111.07
A,C
WATER POLLUTION CONTROL
REQUIREMENTS, DUTY TO COMPLY
PROHIIIITS FAILURE TO COMPL Y WITH
REQUIREMENTS OF SECTIONS 6111.01 10
6111.0B OR ANY RULES, PERMIT OR ORDEH
ISSUED UNDER THOSE SECTIONS.
PERTAINS TO ANY SITE WIIICII11AS
CONTAMINATED GROUND WATER OR SURFACE
WATER OR WILL HAVE A DISCHARGE TO ON-SITE
SUHFACE DR GROUND WATER.
ACTIUN
-------
OS/28/93
ADMINIS.
CODE
SECTION
PERTINENT
PARAGRAPH
OHIO AOMINISTRA TlVE CODE (OACI ARAR, FOR THE SelECTED REMEDY I UR Ol'mAbLE UNII 2
SKINNER LANDFill bUTlER COUNTY
TITlE OR
SUBJECT
OF
REGULATION
DESCRIPTION
OF REGULATION
....- -- -- ... -
AI'I'LICA TIUN
OF REGULATION
Peyo
ARAR
TYPE
3745+03
ACTION
3745.\.04
17~5.\.05
3745.\.06
3745+07
3745.\.\7
3745.\.30
3745.\5.06
A..B.C.D.E
A.B.C
A.B
C
A\.A2
ANALYTICAL AND
COLLECTION
PROCEDURES
THE "FIVE FREEDOMS"
FOR SURFACE WATER
ANTIDEGRADA TION
POLICY FOR SURFACE
WATER
MIXING ZONES FOR
SURFACE WATER
WATER QUALITY
CRITERIA
WA TER USE DES FOR SW
OHIO TRIB
WATER USE DES FOR
MILL CREEK
MALFUNCTION r.
MAINTENANCE OF AIR
POLL CONTROL
EQUIPMENT
SPECIFIES ANALYTICAL METHODS AND COllECTION PROCEDURES
FOR SURFACE WATER DISCHARGES.
ALL SURFACE WATERS OF THE STATE SHAll BE FREE FROM:
AI OBJECTIONAL SUSPENDED SOLIDS.
BIFLOA TING DEBRIS. OIL AND SCUM.
CI MATERIALS THAT CREATE A NUISANCE.
DI TOXIC. HARMFUL OR LETHAL SUBSTANCES.
EI NUTRIENTS THAT CREATE NUISANCE GROWTH
PREVENTS DEGRADATION OF SURFACE WATER QUALITY BelOW
OESIGNA TED
USE OR EXISTING WATER QUALITY. EXISTING INSTREAM USES
SHALL BE
MAINTAINED AND PROTECTED. TI1E MOST STRINGENT CONTROLS
FOR
TREATMENT SHAll BE REQUIRED BY THE DIRECTOR TO BE
EMPLOYED FOR
ALL NEW AND EXISTING POINT SOURCE DISCHARGES. PREVENTS
ANY
DEGRADATION OF "STATE RESOURCE WATERS".
IAI PRESENTS THE CRITERIA FOR ESTABLISHING NON. THERMAL
MIXING
ZONES FOR POINT SOURCE DISCHARGES
IBI PHI ;;ENTS THE CRITERIA FOR ESTABLISHING THERMAL
MIXING ZONES
FOR POINT SOURCE DISCHARGES
ESTABLISHES WATER QUALITY CRITERIA FOR POLLUTANTS WHICH
00 NOT HAVE SPECIFIC NUMERICAL OR NARRATIVE CRITERIA
IDENTIFIED IN TABLES 7.\ THROUGH 7-\5 OF THIS RULE.
ESTABLISHES WATER USE DESIGNATIONS FOR STREAM SLUMENTS
WITHIN THE
SOUTHWEST OHIO TRIBUTARIESR BASIN.
ESTABLISHES WA TER USE DESIGNATIONS FOR STREAM SEGMENTS
WITHIN THE
MILL CREEK BASIN.
ESTABLISHES SCHEDULED MAINTENANCE AND SPECIFIES WHEN
POLLUTION SOURCE MUST BE SHUT DOWN DURING MAINTENANCE.
PERTAINS TO BOTH DISCHARGES TO SURFACE WATERS AS
A RESUL T OF REMEDIATION AND ANY ON.SITE SURFACE
WATtRS AFFECTED BY SITE CONDITIONS.
PERTAINS TO BOTH DISCHARGES TO SURFACE WATERS AS
A RESUL T OF
REMEDIA TION AND ANY ON.SITE SURFACE WA TERS
AFFECTED BY SITE
CONDITIONS.
REOUIRES THAT BEST AVAILABLE TECHNOLOGY IBATI BE
USED TO TREA T
SURFACE WATER DISHARGES. DWQPA USES THIS RULE TO
SET STANDARDS
WilEN EXISTING WATER OUAIITY IS BETTER THAN UtE
DESIGNA TED USE.
APPLIED AS A TERM OF DISCHARGE PERMIT TO INSTAll
IPTII.
PERTAINS TO BOTH DISCHARGES TO SURFACE WATERS AS
A RESULT OF REMEDIAL ACTION AND ANY SURFACE
WATERS AFFECTED BY SITE CONDITIONS.
PERTINENT IF SIREAM UR STREAM SEGMENT IS ON.SIIE
AND IS EITHER AffECTED BY SITE CONDITIONS OF IF
REMEDY INCLUDES DIRECT DISCHARGE. USED BY DWOPA
TO ESTABLISH WASTE LOAD ALLOCATIONS.
PERTINENT IF STREAM OR STREAM SEGMENT IS ON.SITE
AND IS EITHER AFFECTED BY SITE CONDITIONS OF IF
REMEDY INCLUDES DIRECT DISCHARGE. USED BY DWQPA
TO ESTABLISH WASTE LOAD AllOCATIONS.
PERTAINS TO ANY SITE WHICH UTILIZES OR WILL
UTILIZE AIR POLLUTION CONTROL EOUIPMENT ON.SITE.
CIIEMICAL
CHEMICAL
CHEMICAL
CIIEMICAL
ACTION
A c: IIUN
LOCA TlON
ACTION
LOCA TlUN
ACTION
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OHIO ADMINISTRATIVE CODE 10ACI ARAR. fOR THE SHECTED REMEDY fOR OPERABLE UNIT 2
OS/28/93 SKINNER LANDfill BUTlER COUNTY Page 2
ADMIN IS. TITlE OR ARAR
CODE PERTINENT SUBJECT DESCRIPTION APPLICA TlON TYPE
SECTION PARAGRAPH Of Of REGULATION Of REGULATION
REGULATION
3746.11;.07 A . AIR POLLUTION DEfiNES AIR POLLUTION NUISANCE AS AS THE EMISSION OR PERTAINS TO ANY SITE WltlCH CAUSES. OR MAY ACTION
NUISANCES PROHIBITED ESCAPE INTO THE AIR fROM ANY SOURCE IS' OF SMOKE. ASHES. RE~SONABLY CAUSE. AIR POLLUTION NUISANCES.
OUST. DIRf. GRIME. ACIDS. fUMES. GASES. VAPORS. ODORS CO SIDER fOR SITES THAT WILL UNDERGO EXCAVA TlON.
AND COMBINA TlONS Of THE ABOVE THAT ENDANGER HEALTH. DEMOLISION. CAP INST ALLA TION. METHANE PRODUC liON.
SAfETY OR WelfARE OF THE PUBLIC OR CAUSE PERSONAL CLEARING AND GRUBBING. WA TER TREATMENT.
INJURY OR PROPERTY DAMAGE. SUCH NUISANCES ARE INCINERATION AND WASTE FUel RECOVERY.
PROHIBITED.
3745.16.02 B.C STACK HEIGHT ESTABLISHES ALLOWABLE STACK HEIGHT FOR AIR CONTAMINANT PEIITAINS TO ANY SIlE !lIAT liAS OR Will IIAVE AN AIR ACIION
REQUIREMENTS SOURCES BASED ON GOOD ENGINEERING PRACTICE. CONTAMINANT SOURel ON. SITE (pARTICULATE. DUST.
FUMES. GAS. MIST. SMOKE. VAPOR. ODORSI EMITTED
FROM A STACK. CONSIDER fOR REMEDIES
INCORPORATING INCINERATION. WASTE FUel RECOVERY
AND WASTEWATER TREATMENT.
3745.'7.02 A.B.C PARTICULATE AMBIENT ESTABLISHES SPECIFIC STANDARDS fOR TOTAL SUSPENDED PERTAINS TO ANY SITE lIlAT MAY EMil MEASURABLE CtiEMICAL
AIR QUALITY PARTICULA TES. UUANflTlES OF PARlICUIATE MATTER IBOTH STACK AND
STANDARDS FUGITIVE!. CONSIDEH FOR SITES TlfA T Will. UNDERGO
lXCAVA TION. DEMOlIllON. CAP INSTAllA TlON.
CLEAHING AND GRUBBING. INCINERATION AND WAS IE
FUEL RECOVERY.
1745.\7.05 PARTICULA TE DEGRADATION OF AIR QUALITY IN ANY AREA WtiERE AIR PERTAINS TO SIIES IN CERTAIN LOCATIONS THAT MAY CItE MICA L
NON.DEGRADA TION QUALITY IS BE TTER TtiAN REQUIRED BY 3746.17.02 IS EMIT OR ALLOW THE ESCAPE OF PARTICULA TES IBOlli tOCA TION
POLICY PROHIBITED. STACK AND FUGIlIVEI. CONSIDER FOR SITES THA T
WILL UNDERGO EXCAVATION. O£MOIIiION. CA"
INSTALLATION. CLEARING AND GRUBBING.
INCINERA TION.
3745 17.08 AI.A2.B.D EMISSION All EMISSIONS OF FUGITIVE DUST SllAll BE CONTROllED. I'LRlAINS TO SII[S WIIiCII MAY IIAVI. HJGIIIVI ACIION
RESTRICTIONS FOR EMISSIONS INON.STACKI OF DUST. CONSIDER Fon
FUGITIVE DUST SITES TtiAT Will UNDERGO GRADING. LOADING
OPERATIONS. OEMOLITION. CLEARING AND GRUBBING AND
CONS TRUCTION.
3745.20.06 A.B STANDARD FOR ACTIVE ESTABLISHES OPERATING STANDARDS FOR AN ACTIVE ASBESTOS PERTAINS TO SITES WIIERE ASBESTOS HAS COME TO BE CllfMICAI.
ASBESTOS WASTE WASTE DISPOSAL SITES LOCATED AND MUST BE CONSOLIDATED ON.SITE.' AC110N
DISPOSAL SITES CONSIDER fOR lANDfiLLS WHERE WASTES WILL BE
EXCAVATED AND RE.DEPOSITED ON. SITE.
3745.20.07 A.B.C STANDARD FOR ESTABLISHES EMISSIONS AND MAINTENANCE STANDARDS FOR PERTAINS TO SITES WHERE ASBESTOS HAS COME TO BE CltfMICAI
INACTIVE ASBESTOS INACTIVE ASBESTOS WASTE DISPOSAL SITES. LOCATED. CONSIDER FOR LANDfilLS WlTti INADEQUATE tOCA TION
WASTE DISPOSAL SITES COVER OR WHERE WASTES Will CONSOLIDA TED.
3746.21.02 A.B.C AMBIENT AIR QUALITY ESTABLISHES SPECIFIC AIR QUALITY STANDARDS FOR CARBON PERTAINS TO ANY SITE WHICH Will EMIT CARBON CltEMICAL
STANDARDS AND MONOXIDE. OZONE AND AND NON. METHANE HYDROCARBONS. OXIDES. OZONE OR NON. METHANE HYDROCARBONS. ACTION
GUIDEliNES CONSIDER fOR SITES THAT WilL UNDERGO WATER
TREATMENT. INCINERATION AND fUEL BURNING (WASTE
FUEl RECOVERYI.
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OHIO ADMINISTRATIVE CODE fOAC) ARAR. fOR TIlE SelECTED REMEDY fOR OPERABLE UNIl 2
OS/28/93 SKINNER LANDfiLL BUTLER COUNTY Page 3
ADMINIS. TITLE OR ARAR
CODE PERTINENT SUBJECT DESCRIPTION APPLICA TlON TYPE
SECTION PARAGRAPH Of Of REGULATION Of RWULA TION
REGULA TlON
3745.21.03 B.C.D METHODS Of AMBIENT SPECifiES MEASUREMENT METHODS TO DETERMINE AMBIENT AIR PERTAINS TO ANY SITE WHICIt WILL EMIT CARBON CHEMICAL
AIR QUALITY QUALITY fOR THE fOllOWING CONSTITUENTS: CARBON MONOXIDE. OZONE OR NON. METHANE HYDROCARIJONS. ACTION
MEASUREMENT MONOXIDE. OZONE AND NON.METHANE HYDROCARBONS. CONsiDER fOR fOR SITES WHERE TREATMENT SYSTEMS
Will RESULT IN AIR EMISSIONS.
., 14~.21.05 NON.DEGRADA TION PROHIBITS SlliNlflCANT AND AVOIDAlJlE DEJERIORATION OF 11B1AINS 10 ANY 5111. WIIICIt WllllMIT CAIIIJON IIClION
POLICY AIR QUALlIY. OXIDES. CARIJON oXlm.s. AND NON.ME ntANE
HYDROCARBONS. CONSIDER fOR 51 rES TItA TWill
UNDERGO WATER TREATMENT. INCINERATION AND FUll
BURNING IWASTE fUEl RECOVERYI.
3745,21.07 A.B.G.I.J ORGANIC MATERIALS REQUIRES CONTROL Of EMISSIONS Of ORGANIC MATERIALS fROM PERlA INS TO ANY SIlE WHICH IS EMITTING OR WILL ACTION
EMISSION CONTROL: STATIONARY SOURCES. REQUIRES BEST AVAILABLE TECHNOLOGY. EMIT ORGANIC MATERIAl. CONSIDER fOR SITES THAT CHEMICAL
STATIONARY SOURCES Will UNDERGO WATER TREATMENT (AIR STRIPPINGI.
INCINERA TlON AND fUEl BURNING (WASTE fUEL
RECOVERY'.
3745.21.06 A.E CARBON MONOXIDE REQUIRES ANY STATIONARY SOURCE Of CARBON MONOXIDE TO PI:RTAINS TO ANY SITE WHICH IS EMITTING OR WILL ACHON
EMISSION CONTROL: MINIMIZE EMISIONS BY THE USE Of BEST AVAILABLE CONTROL I Mil CARIION MONOXIDE. CONSIDER 1"011 :;ITES 111 A T CItEMICAl
STATIONARY SOURCES TECHNOLOGIES AND OPERATING PRACTICES IN ACCORDANCE WITH VVlll UNDERGO WATER TREATMENT. IrH:II",I.BATION AND
BEST CURRENT TECHNOLOGY. fUEL BURNING IWASTE fUEL RECOVlII> ,.
3745.21.09 VOC EMISSIONS ESTABLISHES LIMIT A TIONS fOR EMISSIONS Of VOLA TilE ACTION
CONTROL: STATIONARY ORGANIC COMPOUNDS FROM STATIONARY SOURCES.
SOURCES
! . ;c, 23.01 NITROGEN DIOXIDE ESTABLISHES A MAXIMUM AMBIENT AIR QUALITY STANDARD fOR PERTAINS TO ANY SITE WHICH IS EMITTING OR WILL CttEMICAL
AMBIENT AIR QUALITY NITROGEN DIOXIDE. EMil NITROGEN DIOXIDE. CONSIDER fOR SITES THAT ACTION
STANDARDS WII.L UNDERGO WATER TREATMENT. INCINERATION AND
FUEL BURNING IWASTE fUEL RECOVERY).
3745.23.02 A.B MEASUREMENT METHODS SPECifiES METHODS OF MEASUREMENT fOR NITROGEN DIOXIDE PERTAINS TO ANY SITE WHICH WILL EMIT NITRIGEN ACTION
FOR NITROGEN DIOXIDE TO DETERMINE AMBIENT AIR QUALITY. DIOXIDE. CONSIDER FOR SITES WItERE TREATMENT CHEMICAL
SYSTEMS MAY RESULT IN NITROGEN DIOXIDE EMISSIUNS.
ESP. THERMAL TREATMENT SYSTEMS.
'715.23.04 NITROGEN DIOXIDE PROHIBITS THE SIGNifICANT AND AVOIDABLE DETERIORATION PERTAINS TO ANY 51TE WHICH IS EMITTING OR WILL ACTION
NONDEGRADA TlON Of AIR QUALITY BY THE RElEASE Of NITROGEN DIOXIDE EMIT NITROGEN DIOXIDE. CONSIDER FOR SITES THA T CItEMICAL
POLICY EMISSIONS. Will UNDERGO WATER TREATMENT. INCINERATION AND
fUEL BURNING IWASTE fUEL RECOVERY).
3745.23.06 NITROGEN OXIDES REQUIRES THAT ALL STATIONARY SOURCES Of NITROGEN OXIDE PERTAINS TO ANY SITE WHICH WILL EMIT NITROGEN ACTION
EMISSION CONTROLS: MINIMIZE EMISSIONS BY THE USE OF THE lATEST AVAILABLE OXIDES. CONSIDER FOR SITES WHERE TREATMENT CHEMICAL
STATIONARY SOURCE CONTROL TECHNIQUES AND OPERATING PRACTICES IN SYSTEMS WILL RESULT IN NITROGEN OXIDE EMISSIONS.
ACCORDANCE WITH BEST CURRENT TECHNOLOGY. ESTABLISHES ESP. THERMAL TREATMENT.
LIMIT FOR NITROGEN OXIDE EMISSIONS FROM COMBUSTION.
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A
OHIO ADMINISTRATIVE CODE {OACI ARAR. FOR THE SElECTED REMEDY Fon OPERABLE UNIT 2
OS/26/93 SKINNER LANDFILL BUTlER COUNTY "aUt: 4
--- - - ----
ADMINIS. TITlE OR ARAI1
CODE PERTINENT SUBJECT DESCRIPTION APPLICA TlON TYPE
SECTION PARAGRAPH OF OF REGULATION OF REGULATION
REGULA TlON
3745.25.03 EMISSION CONTROL REQUIRES PRE PARA TION FOR AIR POLLUTION ALERTS. WARNINGS PERTAINS TO ANY SITE WHICH IS EMITTING 011 MAY ACTION
ACTION PROGRAMS AND EMERGENCIES. EMIT AIR CONTAMINANTS.
I
3745.27.03 B EXEMPTIONS TO SOLID DEFINES EXEMPTIONS TO SOLID WASTE REGULATIONS AND PERTAINS TO ANY SITE AT WHICH SOLID WASTE WILL BE ACTION
WASTE REGULATIONS ESTABLISHES LIMITATIONS ON TEMPORARY STORAGE OF MANAGED. CONSIDER [SPECIALLY FOR OLD LANDFILLS
PUTRESCIBLE WASTE OR ANY'SOLID WASTE WHICH CAUSES A WHERE SOLID WASTE MAY BE EXCAVATED AND/OR
NUISANCE OR HEALTH HAZARD. STORAGE OF PUTRESCIBLE WASTE CONSOllDA TED.
BEYOND SEVEN DAYS IS CONSIDERED OPEN DUMPING.
3745.27.06 B.C REQUIRED TECHNICAL SPECIFIES THE MINIMUM TECHNICAL INFORMATION REQUIRED OF THIS PARAGRAPH PRESENTS SUBSTANTIVE REQUIREMENTS ACTION
INFORMA TION FOR A SOLID WASTE PERMIT TO INSTALL. INCLUDED ARE A OF A SOLID WASTE PERMIT TO INSTALL. PERTAINS TO
SANITARY LANDFILLS HYDROGEOLOGIC INVESTIGATION REPORT. LEACHATE PRODUCTION ANY NEW SOLID WASTE DISPOSAL FACILITY CREATED
AND MIGRATION INFORMATION. SURFACE WATER DISCHARGE ON. SITE ANO EXPANSIONS OF EXISTING SOLID WASTE
INFORMATION. DESIGN CALCULATIONS. PLAN DRAWINGS. LANDFILLS. ALSO PERTAINS TO EXISTING AREAS OF
CONTAMINATION THAT ARE CAPPED PER SOLID WASTE
RULES. THIS RULE ESTABLISHES THE MINIMUM
INfORMATION REQUIRED DURING THE REMEDIAL DESIGN
STAGE.
3745.27.07 A.B LOCA TlON CRITERIA SPECIFIES LOCATIONS IN WHICH SOLID WASTE LANDFILLS ARE THIS RULE PREVENTS THE ESTABLISHMENT OF NEW 501.10 lOCATION
FOR SOLID WASTE NOT TO BE SITED. INCLUDES flOODPLAINS. SAND OR GRAVEl WASTE LANDFILLS AND EXPANSIONS OF EXISTING SOLID
DISPOSAL PERMIT PITS. LIMESTONE OR SANDSTONE OUARRIES. AREAS ABOVE SOLE WASTE LANDFILLS IN CERTAIN UNFAVORABLE LOCATIONS.
SOURCE AQUIFERS. WETlANDS. ETC. ALSO MAY PROHIBIT THE LEAVING OF WASTE IN.PLACE
IN CERTAIN UN FA VORABLE LOCA TIONS.
3745.27.06 C.D.H CONSTRUCTION SPECIFIES THE MINIMUM REQUIREMENTS FOR THE SOIL/CLAY PERTAINS TO ANY NEW SOLID WASTE DISPOSAL FACILIlY ACTION
SPECIFICA TIONS FOR LAYERS. GRANULAR DRAINAGE LAYER. GEOSYNTHETICS. CREAlED ON.SIlE AND ANY EXPANSIONS TO EXISTING
SANITARY LANDFILLS LEACHA TE MANAGEMENT SYSTEM. GAS MONITORING SYSlEM. ETC. SOLID WASTE LANDFILLS. POnTlONS AtSO PERTAIN TO
ALSO ESTABLISHES CONSTRUCTION REQUIREMENTS FOR AREAS OF CONTAMINATION THAT ARE CAPPED PER SOLIO
FACILITIES TO BE LOCATED IN GEOLOGICALLY UNFAVORABLE WASTE RULES. MAY SERVE AS SITING CRITERIA.
AREAS.
3745.27.09 F SANITARY LANDFILL INCLUDES REQUIREMENTS FOR DAILY COVER. INTERMEDIATE PERTAINS TO "NEW" SOLID WASTE DISPOSAL FACIlITIES ACTION
OPERATIONS. DAILY COVER FOR TEMPORARILY INACTIVE AREAS AND FINAL COVER TO BE CREATED ON. SITE AND EXISTING FACILITIES TO
COVER FOR AREAS AT FINAL ELEVATIONS. BE EXPANDED DURING REMEDIA TION
3745.27.09 N SANITARY LANDFILL SURFACE WATER MUST BE DIVERTED FROM AREAS WHERE SOLID ACTION
OPERA TIONS . WASTE IS BEING. OR HAS BEEN. DEPOSITED.
SURFACE WATER
3745.27.09 0 SANITARY LANDFILL REQUIRES REPAIR OF LEACHA TE OUTBREAKS; COLLECTION AND AC TlON
OPERA TIONS . TREA TMENT OF LEACHA TE ON THE SURFACE OF THE LANDFILL;
LEACHA TE AND ACTIONS TO MINIMIZE. CONTROL OR EliMINA TE
CONDITIONS CAUSING LEACHATE OUTBREAKS.
3745.27.10 B.C.D SANITARY LANDFILL. GROUND WATER MONITORING PROGRAM MUST 6E ESTABLISHED FOR PERTAINS 10 ANY NEW SOLID WASTE FACILITY AND ANY ACTION
GROUND WATER ALL SANITARY LANDFILL FACIlITIES. THE SYSTEM MUST EXPANSIONS OF EXISTING SOLID WASTE LANDfillS
MONITORING CONSIST OF A SUFFICIENT NUMBER OF WELLS THA TARE ON.SITE. ALSO MAY PERTAIN TO EXISTING AREAS OF
LOCATED SO THAT SAMPLES INDICATE BOTH UPGRADIENT CONTAMINATION THAT ARE CAPPED IN.PLACE PER TIlE
(BACKGROUNDI AND DOWNGRADIENT WATER SAMPLES. TlfE SOLID WASTE RULES.
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OS/28/93
ADMINIS.
CODE
SECTION
PERTINENT
PARAGRAPH
OHIO ADMINISTRA TlVE CODE 10ACI ARARa FOR TIlE SELECTED REMEDY FOR OI'toRAIiLE UNII 2
SKINNER lANDFilL BUTlER COUNTY
TITlE OR
SUBJECT
OF
REGULATION
DESCRIPTION
OF REGULATION
A PPLICA TlON
OF REOULATION
1'000
5
ARAR
TYPE
3746-27-11
3746.27-12
3746-27.12
3746'27-13
3746.27.14
3746-31-05
3746-32.06
A.B.G
A.B.D.E.MN
I. J
C
A
fiNAL CLOSURE Of
SANITARY LANDfiLL
fACILITIES
SANITARY LANDfiLL.
EXPLOSIVE GAS
MONITORING
EXPLOSIVE GAS
MONITORING fOR
SANITARY LANDfiLLS
DISTURBANCES WHERE
HAZ OR SOLID WASTE
fAC WAS OPERATED
POST.CLOSURE CARE OF
SANITARY LANDfiLL
fACILITIES
WA TER/AIR PERMIT
CRITERIA fOR
DECISION BY THE
DIRECTOR
WATER QUALITY
CRITERIA fOR
DECISION BY THE
DIRECTOR
SYSTEM MUST BE DESIGNED PER THE MINIMUM REOUIREMENTS
SPECIFIED IN THIS RULE. THE SAMPliNG AND ANALYSIS
PROCEDURES USED MUST COMPlY WITH THIS RULE.
SPECIFIES THE MINIMUM INFORMA TION NECESSARY FOR OHIO
EPA TO DETERMINE ADEQUACY Of CLOSURE METHODS FOR SOLID
WASTE LANDFillS. SPECIFIES ACCEPTABLE CAP DESIGN;
SOil BARRIER LAYER. GRANULAR DRAINAOE LAYER. SOil AND
VEGETATIVE LAYER.
ESTABLISHES WHEN AN EXPLOSIVE GAS MONITORING PLAN IS
REQUIRED fOR SOLID WASTE LANDFillS. SPECIFIES TIlE
MINIMUM INfORMA TION REQUIRED IN SUCH A PLAN. INCLUDING
DETAilED ENGINEERING PLANS. SPECIFICATIONS. INFORMATION
ON GAS GENERATION POTENTIAL. SAMPLING AND MONITORING
PROCEDURES. ETC. MANDATES WHEN REPAIRS MUST BE MADE TO
AN EXPLOSIVE GAS MONITORING SYSTEM. THIS RULE ONLY
APPLIES TO lADfillS WHICH RECEIVED 'PUTRESCIBLE" SOLID
WASTES.
IDENTIfiES PARAMETERS AND SCHEDULE FOR EXPLOSIVE GAS
MONITORING
REQUIRES THAT A DETAILED PlAN BE PROVIDED TO DESCRIBE
HOW ANY PROPOSED FILLING. GRADING. EXCAVATING.
BUILDING. DRILLING OR MINING ON LAND WHERE A HAZARDOUS
WASH FACILITY OR SOLID WASTE FACILITY WAS OPERATED
Will BE ACCOMPLISHED. THIS INFORMATION MUST
DEMONSTRATE THAT THE PROPOSED ACTIVITIES WILL NOT
CREATE A NUISANCE OR ADVERSElY AFfECT THE PUBLIC
HEAL TH OR THE ENVIRONMENT. SPECIAL TERMS TO CONDUCT
SUCH ACTIVITIES MAY BE IMPOSED BY THE DIRECTOR TO
PROTECT THE PUBLIC AND THE ENVIRONMENT.
SPECIFIES THE REQUIRED POST. CLOSURE CARE FOR SOLID
WASTE fACILITIES. INCLUDES CONTINUING OPERATION Of
LEACHATE AND SURFACE WATER MANAGEMENT SYSTEMS.
MAINTENANCE Of THE CAP SYSTEM AND GROUND WATER
MONITORING.
A PERMIT TO INSTALLIPTII OR PLANS MUST DEMONSTRATE
BEST AVAILABLE TECHNOLOGY (BATI AND SHAll NOT INTERFER
WITH OR PREVENT THE ATTAINMENT OR MAINTENANCE OF
APPliCABLE AMBIENT AIR QUALITY STANDARDS.
SPECIFIES SUBSTANTIVE CRITERIA fOR SECTION 401 WATER
QUALITY CRITERIA fOR DREDGING. FILLING. OBSTRUCTIONG OR
ALTERING WATERS OF THE STATE.
SUBSTANTIVE REQUIREMENTS PERTAIN TO ANY NEW SOLID
WASTE LANDFillS CREATED ON. SITE. ANY EXPANSIONS
OF EXISTING SOLID WASTE lANDfilLS ON. SITE AND ANY
EXISTING AREAS OF CONTAMINATION THAT ARE CAPPED
IN,PlACE PER THE SOLID WASTE RULES.
PERTAINS TO ANY SITE WHICH HAS HAD OR WilL HAVE
PUTRESCIBlE SOLID WASTES PLACED ON. SITE AND WHICH
HAS A RESIDENCE OR OTHER OCCUPIED STRUCTURE
lOCA TED WITHIN 1000 FEET OF THE EMPLACED SOLID
WASTE.
PERTAINS TO ANY DISPOSAL SITE WliERE EXPLOSIVE GAS
GENERATION AND MIGRATION MAY BE A THREAT.
PERTAINS TO ANY SITE AT WHICH HAZARDOUS OR SOLID
WASTE HAS BEEN MANAGED. EITHER INTENTIONAllY OR
OTHERWISE. DOES NOT PERTAIN TO AREAS THAT HAVE
HAD ONE. TIME tEAKS OR SPILLS.
SUBSTANTIVE REQUIREMENTS PERTAIN TO ANY NEWLY
CREATED SOLID WASTE LANDFillS ON.SITE. ANY
EXPANSIONS OF EXISTING SOLID WASTE lANDFillS
ON. SITE AND ANY EXISTING AREAS OF CONTAMINATlDN
THAT ARE CAPPED PER THE SOLID WASTE RULES.
PERTAINS 10 ANY SITE THAT Will DISHARGE 10
ON. SITE SURFACE WATER OR WILL EMIT CONTAMINANTS
INTO THE AIR.
PERTAINS TO ANY SITE THAT HAS OR Will AFFECT
WATERS Of THE STATE.
ACTION
ACTION
LOCA nON
ACTION
CHEMICAL
ACTION
LOCA TlON
ACTION
ACTION
ACTION
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......
~
OHIO ADMINISTRATIVE CODE tOACI ARAR. FOR THE SELECTED REMEDY FOR OPERABLE UNIT 2
05128/93 SKINNER LANDFILL BUTLER COUNTY PaUe 6
ADMINIS. TITLE OR ARAR
CODE PERTINENT SUBJECT DESCRIPTION APPLICA TION TYPE
SECTION PARAGRAPH OF OF REGULA TlON OF REGULATION
REGULA TlON
3745.50.44 A PERMIT INFO REOUIRED ESTABLISHES TltE SUBSTANTIVE HAZAROOUS WASTE PERMIT PEfcTAINS TO ANY SITE WHICH WILL IIAVE THEA TMENT. ACTION
FOR ALL HAZ WASTE REQUIREMENTS NECESSARY FOR OHIO EPA TO OETERMINE S ORAGE OR OISPOSAL OF HAZARDOUS WASTE OCCURHING
FACILITIES FACILITY COMPLIANCE. INCLUDES INFORMATION SUCH AS ON.SITE OR HAS EXISTING AREAS OF HAZARDOUS WASTE
FACILITY DESCRIPTION. WASTE CHARACTERISTICS. EOUIPMENT CONTAMINATION ON-SITE THAT WILL BE CAPPED
DESCRIPTIONS. CONTINGENCY PLAN, FACILITY LOCATION. IN.PLACE. THIS, ALONG WITH OTHER PARAGRAPHS OF
TOPOGRAPHIC MAP, ETC. TlUS RULE. ESTABLISHES TltE MINIMUM INFORMA TlON
1\1 0111111:0 IlIIIIING TltE RI MmlAI OI:SIGN STAGE
3745.50.44 B PERMIT INFO REQ FOR ESTABLISHES THE SUBSTANTIVE HAZAROOUS WASTE LAND PlRTAINS TO ANY FACILITY/SITE WHICH WILL HAVE ACTION
ALL HAZ WASTE LAND DISPOSAL PERMIT REQUIREMENTS NECESSARY FOR OHIO EPA TO HAZARDOUS WASTE DISPOSED OF ON.SITE OR HAS
DISP FACILITIES DETERMINE ADEQUATE PROTECTION OF THE GROUND WATER. EXISTING AREAS OF HAZARDOUS WASTE CONTAMINATION
INCLUDES INFORMATIQN SUCH AS GRQUND WATER MONITORING ON.SITE THAT WILL BE CAPPED IN,PLACE. THIS.
DATA, INFORMATION ON INTERCONNECTED AQUIFERS. PLUME IS I ALONG WITH OTHER PARAGRAPHS OF THIS RULE.
OF CONTAMINA TION. PLANS AND REPORTS ON GROUND WA TER ESTABLISHES THE MINIMUM INfORMATION REQUIRED
MONITORING PROGRAM, ETC. DURING THE REMEDIAL DESIGN STAGE.
3745-50.44 CI ADD'L PERMIT INFO: ESTABLISHES TIlE SUBSTANTIVE HAZARDOUS WASTE PERMIT PERTAINS TO ANY SITE AT WHICH STOHAGE OF ACTION
HAZ WASTE STORAGE IN REQUIREMENTS NECESSARY FOR OHIO EPA TO DETERMINE HAZARDOUS WASTE ON-SITE WILL OCCUR IN CONTAINEHS.
CONTAINERS ADEQUACY OF CONTAINER STORAGE. INCLUDES INFORMATION CONSIDER FOR WASTES AND CONTAMINATED SOILS THAT
SUCH AS DESCRIPTION OF CONTAINMENT SYSTEM, DETAILED ARE STORED PRIOR TO TREATMENT OR DISPOSAL. THI~,
DRAWINGS, ETC. SEE OAC 3745.55.70 TlIROUGH 3745.56.78 ALONG WITH OTHER PARAGRAPliS OF THIS RULE AND OAC
FOR ADDITIONAL CONTAINER REQUIREMENTS. 3745-55-70 THROUGH 3745.65.78, ESTABLISHES THE
MINIMUM INFORMATION REQUIRED DURING TIlE REMEDIAL
DESIGN STAGE.
3745.60.44 C4 ADD'L PERMIT INFO: ESTABLISHES SUBSTANTIVE HAZARDOUS WASTE PERMIT PERTAINS TO SIT[ AT WIIiCH HAZARIJOUS WASTE WIll. BE AC liON
HAZ WASTE STORITREAT REQUIREMENTS NECESSARY FOR OHIO EPA TO DETERMINE S10RED OR TREATED IN SURfACE IMPOUNDMENTS. 11115,
IN WASTE PILES ADEQUACY Of SURFACE IMPOUNDMENTS USED TO TREAT OR STORE ALONG WITH OTHER PARAGRAPHS OF THIS RUI E AND OAC
HAZARDOUS WASTE. INCLUDES INFORMATION SUCH AS WASTE 3746.56.20 THROUGH 3745-56-33, ESTABLlSltES TIlE
CHARACTERISTICS. DETAILED DESIGN PLANS AND REPORTS. MINIMUM INfORMATION REQUIRED DURING THE REMEDIAL
CONTROL OF RUN.ON AND RUN.OFF, CLOSURE INFORMATION, DESIGN STAGE.
ETC. SEE OAC 3746.66.20 THROUGIi 3746.66.33 FOR
ADDITIONAL SURFACE IMPOUNDMENT REQUIREMENTS.
3745.50.44 C6 ADD'L PERMIT INFO: ES1ABLISliES SUBSTANTIVE HAZARDOUS WASTE PERMIT PERTAINS TO SITE AT WlilCH HAZARDOUS WASTE WILL III ACTION
ENVIRONMENT AL REQUIREMENTS NECESSARY FOR OHIO EPA TO DETERMINE OR HAS BEEN STORED, TREATED OR DISPOSED Of IN
PERFORMANCE ADEQUACY OF SURFACE IMPOUNDMENTS. WASTE PILES. LAND SURFACE IMPOUNDMENTS, WASTE PILES. LAND TREA1MENT
STANDARDS TREA TMENT UNITS, LANDFilLS. AND UNDERGROUND INJECTION UNITS. LANDFILLS OR UNDERGROUND INJECTION WElLS.
WElLS USED TO TREAT, STORE OR DISPOSE OF HAZARDOUS THIS. ALONG WITH OTHER PARAGRAPliS OF THIS RULE
WASTE. INCLUDES INFORMATION SUCH AS WASTE AND OAC 3746.57.01 ESTABLISHES TliE MINIMUM
CHARACTERISTICS. DETAILED DESIGN PLANS AND REPORTS, INFORMATION REQUIRED DURING THE REMEDIAL DESIGN
CONTROL OF RUN. ON AND RUN.OFF. CLOSURE INFQRMATlON, STAGE.
ETC. SEE OAC 3745-57.01 ADDITIONAL REQUIREMENTS.
3746.50-44 C7 ADD'L PERMIT INFO: ESTABLISHES SUBSTANTIVE HAZARDOUS WASTE PERMIT PERTAINS TO SITE AT WHICH ItAZARDOUS WASTE WILL liE ACTION
HAZ WASTE DISPOSAL REQUIREMENTS NECESSARY FOR OHIO EPA TO DETERMINE OR HAVE BEEN DISPOSED OF IN LANDFILLS. THIS,
IN LANDFillS ADEQUACY OF LANDFILLS USED FOR DISPOSAL OF HAZARDOUS ALONG WITH OTHER PARAGRAPHS OF THIS RULE AND OAC
WASTE. INCLUDES INFORMATION SUCH AS WASTE 3745.57-021HROUGH 3746-67.1B, ESTABLISHES TIlE
CHARACTERISTICS, DETAILED DESIGN PLANS AND REPORTS. MINIMUM INFORMATION REQUIRED DURING THE REMEDIAL
CONTROL OF RUN.ON AND RUN.OFF, CLOSURE INFQRMATION. DESIGN STAGE.
ETC.. SEE OAC 3746.67.02 THROUGH 3745.57.18 FOR
ADDITIONAL LANDFILL REQUIREMENTS.
-------
OHIO ADMINIS TRA TlVE CODE 10AC' ARAR, FOR THE SElECTED REMEDY FOR OPERAIILE UNH 2
OS/26/93 SKINNER LANDFILL OUTlER COUNlY Poge
ADMINIS. TITlE OR ARAR
CODE PERTINENT SUOJECT DESCRIPTION APPLICA TION lYPE
SECTION PARAGRAPH OF OF REGULATION OF REGULA TION
REGULATION
3746-6' .05 A-J . REQ. FOR SPECIFIES REQUIREMENTS FOR CONOITIONALLY EXEMPT SMAll CONSIDER FOR SITES WIiERE THE QUANTIlY OF ACTION
CONOITIONAll Y EXEMPT QUANTIlY GENERATORS OF HAZAROOUS WASTE. PROVIDES REliEF HAZARDOUS WASTE GENERATED OY AN ON. SITE ACTION CHEMICAL
SMALL QUANTITY FROM MANY OF THE HAZARDOUS WASTE REGULATIONS. WILL OE LESS THAN 100 KG PER MONTH. MONTHLY LIMIT
GENERATORS FOR ACUTE HAZARDOUS WASTE IS ONE II' KG.
3745-61.06 A.a.CUI REQUIREMENTS FOR DEFINES RECYCLED HAZARDOUS WASTES AND ESTABLISHES PlRTAINS TO ANY SITE AT WHICII RECYCLING OF ACTION
RECYCLED MATERIALS SPECIFIC EXEMPTIONS FOR THESE WASTES FROM THE liAZARDOUS liAZAnDOUS WAS rES MAY TAKE PLACE. CONSIDEfI FOH CItlMICAI.
WASTE REGULATIONS. SHES AT WHICH THE FOLLOWING MATERIALS ARE
PRESENT:
INDUSTRIAL ETl1YL ALCOHOL
USED OA TTERIES
USED OIL
SCRAP METAL
PETROLEUM PRODUCTS
K067 COAL AND COKE TAR SLUDGE
3745.61-01 A.O RESIDUES OF HAZ EXEMPTS THE RESIDUES OF HAZARDOUS WASTES FROM EMPTY PERTAINS TO ANY AL TERNATIVE IIIAT INCORPORATES ACllON
WASTES IN EMPTY CONTAINERS FROM THE HAZARDOUS WASTE REGULATIONS. STORAGE OF HAZARDOUS WASTE ON. SITE IN CONTAINERS.
CONTAINERS PROVIDES SPECIFIC DEFINITIONS FOR THESE RESIDUES.
3745.52-11 A.D EVALUATION OF WASTES ANY PERSON GENERATING A WASTE MUSl DETERMINE IF THA T PERTAINS TO SITES AT WIIICt. WASTES OF ANY lYPE Ctll.MICAI
WASTE IS A HAZARDOUS WASTE IEITHER THROUGH LISTING OR (OOTH SOLID AND HAZARDOUS' ARE LOCATED- ACllON
BY CHARACTERISTIC'.
3746-52.30 HAZARDOUS WASTE REQUIRES A GENERA TOR TO PACKAGE IIAZARDOUS WAsn IN "r.nTAINS TO ANY SITf WllfRf IIA1AI100lIS WASH Will ClIIMICAI
PACKAGING ACCORDANCE WITt. U.S. Dor REGULA liONS FOR TRANSPOH1A1ION III (jEN[I1AllD BY ON.:;HL AC IIVII II'S ANI> SI 111'11 0 AClI:JN
OFF.SITE. DI'F.SUE FOR lREAMENl AND/OR DISPOSAL
3746.62-31 HAZAROOUS WASTE REOUIRES PACKAGES OF HAZARDOUS WASTE TO OE LAOEllED IN PERTAINS TO ANY SITE WHERE liAZAROOUS WASTE WILL CllEMICAl
LABELING ACCORDANCE WITH U.S.DOT REGULATIONS FOR OFF-SITE OE GENERA TED OY ON-SITE ACTIVITIES AND SHIPPED ACllON
TRANSPORTATION. OFF-SITE FOR TREATMENT AND/OR DISPOSAL.
3746-62-32 HAZARDOUS WASTE SPECIFIES LANGUAGE FOR MARKING PACKAGES OF HAZARDOUS PER1AINS TO ANY SITE WHERE IIAZAHDOUS WASTE Will CIfLMICAl
MARKING WASTE PRIOR TO OFF. SITE TRANSPORTATION OE GENERA TED OY ON-SITE ACTIVITIES ANO SHIP~ED ACllON
OFF-SITE FOR TREATMENT AND/OR DISPOSAL.
3745.52-33 HAZARDOUS WASTE GENERATOR SHAll PLACARD HAZARDOUS WASTE PRIOR TO PERTAINS TO ANY SITE WHERE HAZARDOUS WASTE WILL ClflMICAl
PLACARDING OFF-SITE TRANSPORT A TlON. OE GENERATED OY ON-SITE ACTIVITIES AND SHIPPED ACTION
OFF-SITE FOR TREATMENT AND/OR DISPOSAL.
3745-54-13 A GENERAL ANALYSIS OF PRIOR TO ANY TREATMENT. STORAGE OR DISPOSAL OF PERTAINS TO ANY SITE AT WHICH HAZAROOUS IS TO OE CHEMICAL
HAZARDOUS WASTE HAZARDOUS WASTES. A REPRESENTATIVE SAMPLE OF THE WASTE TREATED. STORED OR DISPOSED OF lOR HAS OEEN
MUST OE CHEMICALLY ANO PHYSICALLY ANA YZED. DISPOSED OFI.
-------
OHIO ADMINISTRATIVE CODE (OACI ARAR. FOR TIlE SHECTED REMEDY FOR OPERAlIlE UNn 2
OS/2B/93 SKINNER LANDFilL BUTlER COUNTY Paua II
ADMINIS. TITlE OR ARAR
CODE PERTINENT SUBJECT DESCRIPTION APPIICA TION TYPE
SE CTION PARAGRAPH OF OF REGULATION OF REGULATION
REGULA TlON
3746.64- 14 A.B.C SECURITY FOR HAZARDOUS WASTE FACILITIES MUST BE SECURED SO THAT PERTAINS TO ANY SITE AT WttlCH HAZARDOUS IS TO BE ACTION
HAZARDOUS WASTE UNAUTHORIZED AND UNKNOWING ENTRY ARE MINIMIZED OR TRJATED. STORED OR DISPOSED OF tOR HAS BEEN
FACILITIES PROHIBITED. 01 POSED OFI.
3745.54-16 A.C INSPECTION HAZARDOUS WASTE FACILITIES MUST BE INSPECTED REGULARLY PERTAINS TO ANY SITE AT WHICH HAZARDOUS IS TO BE ACtiON
ilEOUIREMENTS FOR TO DETECT MALFUNCTIONS. DETERIORATIONS. OPERATIONAL TREATED. STORED OR DISPOSED OF COR HAS BEEN
HAZARDOUS WASTE ERRORS AND DISCHARGES. ANY MALFUNCTIONS OR DISPOSED OFI.
FACILITIES DETERIORATIONS DETECTED SHAll BE REMEDIED
EXPEDITIOUSLY.
3746.54.17 A.B.C REQ FOR PRESENTS GENERAL PRECAUTIONS TO BE TAKEN TO PREVENT PERTAINS TO ANY SITE AT WHICH POTENtiAllY ACtiON
IGNITABlE.REACTIVE ACCIDENTAL IGNITION OR REACTION OF IGNITABLE. REACTIVE REACTIVE. IGNITABLE OR INCOMPATIBLE WASTES ARE LOCA TION
OR INCOMPATABlE HAZ OR INCOMPATIBLE WASTES. PRESENT.
WASTES
3745.54.31 DESIGN & OPERA TlON HAZARDOUS WASlE tACllIlIES MUSl BE OlSlliNED. l'lHIAINS 10 ANY Sill AT WllIClIlIAlAlllltllIS 15111111. ACIION
OF HAZARDOUS WASTE CONSTRUCTED. MAINTAINW AND OPioRATED TO MINIMIZE TilE TREATED. STunED OR UlSPOSlD UI. COR liAS IIlEN
FACILITIES POSSIBILITY OF FIRE. EXPLOSION OR UNPLANNED RElEASE OF DISPOSED OFI.
HAZARDOUS WASTE OR HAZARDOUS CONSTITUENTS TO THE AIR.
SOIL OR SURFACE WATER WHICH COULD THREATEN HUMAN HEAL TIi
OR THE ENVIRONMENT.
3745.54-32 A.B.C.D REQUIRED EQUIPMENT All HAZARDOUS WASTE FACILITIES MUST BE EQUIPPED WITH PERTAINS TO ANY SITE AT WHICH HAZARDOUS IS TO BE ACTION
FOR HAZARDOUS WASTE EMERGENCY EQUIPMENT. SUCH AS AN ALARM SYSTEM. FIRE TREATED. STURED OR DISPOSED OF COR HAS BEEN
FACILITIES CONTROL EQUIPMENT AND A TElEPHONE OR RADIO. DISPOSED OFI.
3746.54.33 TESTING & All HAZARDOUS WASTE FACILITIES MUST TEST AND MAINTAIN PIoRTAINS TO ANY SHE AT WHICH HAZARDOUS WASTE IS ACTION
MAINTENANCE OF EMERGENCY EQUIPMENT TO ASSURE PROPER OPioRA TION. TO BE TREATED. STORED OR DISPOSED OF COR HAS BEEN
EQUIPMENT; HAZ WASTE DISPOSED Of!.
FACll TIES
3746.64-34 ACCESS TO WHENEVER HAZARDOUS WASTE IS BEING /tANDlED. All PIoRTAINS TO ANY SITE AT WHICIi IIAZAIIDOUS WAS IE IS ACTION
COMMUNICA TlONS OR PERSONNEl INVOLVED SHAlLIiAVE IMMEDIATE ACCESS TO AN TO liE TREATED. STORED OR DISPOSED OF tOR /tAS IIHN
ALARM SYSTEM; HAZ INTERNAL ALARM OR EMERGENCY COMMUNICATION DEVICE. DISPOSED OFI.
WASTE FAC
3745-54-35 . REQUIRED AISLE SPACE ADEQUATE AISLE SPACE SHALL BE MAINTAINED TO AllOW PERTAINS TO ANY SITE AT WHICH IiAZARDOUS WASTE IS ACTION
AT HAZ WASTE UNOBSTRUCTED MOVEMENT OF PERSONNEl. FIRE EQUIPMENT. TO BE TREA TED. STORED OR DISPOSED OF COR liAS BEEN
FACILITIES SPilL CONTROL EQUIPMENT AND DECONTAMINATION EQUIPMENT DISPOSED OFt. CONSIDER FOR SITES WHERE WASTES
INTO ANY AREA OF THE FACILITY OPioRA TlON IN THE EVENT OF WILL BE STORED IN CONTAINERS.
AN EMERGENCY.
3745.64.37 A.B ARRANGEMENTS/ ARRANGEMENTS OR AGREEMENTS WITH lOCAL AUTHORITIES. SUCH PERTAINS TO ANY SHE AT WHICH HAZARDOUS WASTE IS ACTION
AGREEMENTS WITH AS POLICE. FIRE DEPARTMENT AND EMERGENCY RESPONSE TEAMS TO BE TREA TED. STORED OR DISPOSED OF COR HAS BEEN
LOCAL AUTHORITIES MUST BE MADE. IF LOCAL AUTHORITIES WILL NOT COOPERA TE. DISPOSED OFI.
DOCUMENTATION OF THAT NON. COOPERATION SHOULD BE
PROVIDED.
-------
OS/28/93
ADMINIS.
CODE
SECTION
PERTINENT
PARAGRAPH
OHIO ADMINISTRATIVE CODE 10ACI ARAR. fOR THE SELECTED REMEDY FOR OPERAblE UNIT 2
. SKINNER LANDfill BUTLER COUNTY
TITLE OR
SUBJECT
Of
REGULA TlON
DESCRIPTION
Of REGULA TION
APPllCA TlON
Of REGULA TION
PaUl:
9
ARAR
TYPE
3746-64-63
ACTION
3746-64.54
3745-64.56
3745.54.56
3745.54.92
3746.64-93
~745.54.95
3745.64.96
A.B
A
A-I
A.B
A.B
A.B.C
COPIES Of
CONTINGENCY PLAN;
HAZARDOUS WASTE
fACILITIES
AMENDMENT OF
CONTINGENCY PLAN;
HAZ WASTE FACILITIES
EMERGENCY
COORDINA TOR;
HAZARDOUS WASTE
FACILITIES
EMERGENCY
PROCEDURES;
HAZARDOUS WASTE
FACILITIES
GROUND WATER
PROTECTION STANDARD;
HAZ WASTE FACILITIES
HAZARDOUS
CONSTITUENTS IN
GROUND WATER; HAZ
WASTE fAC
POINT Of COMPLIANCE
fOR G~OUND WATER;
HAZ WASTE FACll
COMPLIANCE PERIOD
fOR GROUND WATER;
HAZ WASTE FACIL
COPIES Of THE CONTINGENCY PLAN REOUIRED BY 3745.54.50
MUST BE MAINTAINED AT THE fACILITY AND SUBMITTED TO ALL
LOCAL POLICE DEPARTMENTS. FIRE DEPARTMENTS. HOSPITALS
LOCAL EMERGENCY RESPONSE TEAMS AND THE OHIO EPA.
THE CONTINGENCY PI.AN MUST BE AMENDED If IT fAILS IN AN
EMERGENCY. TIlE fACILITY CHANGES (IN ITS DESIGN. .
CONSTRUCTION. MAINTENANCE OR OPERATIONI. THE LIST Of
EMERGENCY COORDINATORS CHANGE OR THE LIST Of EMERGENCY
EOUIPMENT.
AT ALL TIMES THERE SHOULD BE AT LEAST ONE EMPLOYEE
EITHER ON THE PREMISES OR ON CALL TO COORDINATE ALL
EMERGENCY REPSONSE MEASURES.
SPECifiES THE PROCEDURES TO BE fOLLOWED IN TIlE EVENT Of
AN EMERGENC'i'.
COMPLIANCE MUST BE ATTAINED WITH THE CONDITIONS
SPECifiED IN THE PERMIT TO ENSURE THAT HAZARDOUS
CONSTlUENTS eSEE 3746-64-931 00 NOT EXCEED THE
PROMULGA TED LIMITS ISEE 3745-64.941.
REOUIRES THAT PERMIT SPECifY HAZARDOUS CONSITIUENTS TO
WHICH THE GROUND WATER PROTECTION STANDARD OF
3745-64.92 APPLIES. HAZARDOUS CONSTITUENTS ARE
CONSTITUENTS IDENTifiED IN THE APPENDIX Of THIS RULE
THAT HAVE BEEN DETECTED IN GROUND WATER IN THE
UPPERMOST AQUifER UNDERLYING THE UNITCS, AND ARE
REASONABLY EXPECTED TO BE IN OR DERIVED fROM WASTE
CONTAINED IN THE UNlTeSI.
ESTABLISHES POINT Of COMPILANCE AT VERTICAL SURfACE
lOCATED AT THE HYDRAULICALLY DOWNGRAOIENT LIMIT Of THE
WASTE MANAGEMENT AREA THAT EXTENDS DOWN INTO THE
UPPERMOST AQUifER UNDERLYING THE UNITCSI.
A COMPLIANCE PERIOD DURING WHICH THE GROUND WA TER
PROTECTION STANDARDS APPLY WILL BE SPEC'flED IN THE
PERMIT. RULE REQUIRES THAT THE COMPliANCE PERIOD fOR A
FACILITY UNDERGOING A CORRECTIVE ACTION PROGRAM WILL
EXTEND UNTIL IT CAN BE DEMONSTRATED THAT THE GROUND
WATER PROTECTION STANDARD OF OAC 3745.64-92 HAS NOT
BEEN EXCEEDED fOR A PERIOD Of THREE CONSECUTIVE YEARS.
PERTAINS TO ANY SITE AT WHICH HAZARDOUS WASTE IS
TO BE TREATED. STORED OR DISPOSED Of COR HAS BEEN
DISPOI>ED Ofl
PERIAINS 10 ANY Sill AT WIUCI1 tiAZARDOUS WASTE IS
TO BE TREATED. STORED OR DISPOSED Of (OR HAS BEEN
DISPOSED Oft.
PERTAINS TO ANY SITE AT WHICH ItAZARDOUS WASTE IS
TO BE TREATED. STORED OR DISPOSED Of lOR HAS BEEN
DISPOSED Of I.
PERTAINS TO ANY SITE AT WHICH ItAZARDOUS WAStE IS
TO BE TREATED. STORED OR DISPOSED OF COR HAS BEEN
OISPOSED Of'.
PERTAINS TO ALL SITES WITH LAND.BASED HAZARDOUS
WASTE UNITS (SURfACE IMPOUNDMENTS. WASTE PILES.
LAND TREATMENT UNITS. LANDFILLS'. THIS INCLUDES
EXISTING LAND-BASED AREAS Of CONTAMINATION.
PERTAINS TO ALL SITES WITH lAND-BASED HAZARDOUS
WASTE UNITS ISURfACE IMPOUNDMENTS. WASTE PilES.
LAND TREATMENT UNITS. LANDFllLSI. THIS INCLUDES
EXISTING LAND-BASED AREAS OF CONTAMINATION.
PERTAINS TO ALL SITES WITH LAND.IIASED HAZARDOUS
WASTE UNITS (SURfACE IMPOUNDMENTS. WASTE PILES.
LAND TREATMENT UNITS. LANDfILLSI. THIS INCLUDES
EXISTING LAND-BASED AREAS OF CONTAMINATION.
PERTAINS TO ALL SITES WITH lAND-BASED HAZARDOUS
WASTE UNITS ISURfACE IMPOUNDMENTS. WASTE PILES.
LAND TREA rMENT UNITS. LANDFILLSI. THIS INCLUDES
EXISTING LAND.BASED AREAS Of CONTAMINATION.
ACIION
ACTION
ACTION
ACTION
CItEMICAl
CHEMICAL
ACIION
CHEMICAL
AC110N
CHEMICAl
-------
OHIO ADMINISTRATIVE CODE 10ACI ARAR. FOR THE SElECTED REMEDY FOR OI'EHAIILE UNIT 2
OS/28/93 SKINNER LANDFILL BUTlER COUNTY Page 10
ADMINIS. TITlE OR ARAR
CODE PERTINENT SUBJECT DESCRIPTION A PPLICA TlON TYPE
SECTION PARAGRAPH OF OF REGULATION OF REGULATION
REGULATION
3745.54.97 A.H GEN GROUND WA TER PRESENTS GENERAL GROUND WA TER MONITORING PROGRAM PERTAINS TO ALL SITES WITH LAND.IIASED IIAZARDOUS ACIION
MONITORING REQUIREMENTS. INCLUDES NUMBER. LOCATION AND DEPTH OF WASTE UNITS (SURFACE IMPOUNDMENTS. WASTE PILES. CHEMICAL
REQUIREMENTS; HAZ WElLS. CASING REQUIREMENTS, SAMPLING AND ANALYSIS LAND TREA TMENT UNITS. LANDFILLS) THIS INCLUDES
WASTE FAC PROCEDURES, ETC. EXISTING lAND.BASED AREAS OF CONTAMINATION.
3745.64.99 A.J GROUND WATER PRESENTS REOUIREMENTs OF GROUND WA TER COMPLIANCE PERTAINS TO ALL SITES WITH LAND IIASED IIAZARDOIIS ACTION
COMPLIANCE MONITORING PROGRAM. WASTE UNITS ISURFACE IMI'OIlNIlMENTS. WASTE PilES. CII"MICAI
MONITORING PRDG; HAZ lAND TREA TMENT UNITS. lANDFILlSI AT WHICII
WASTE FAC HAZARDOUS CONSTITUENTS HAVE BEEN DETECTED. TIllS
INCLUDES EXISTING LAND.BAsEO AREAS OF
CONTAMINATION.
3745.55.01 A.F GROUND WA TER PRESENTS THE REQUIREMENTS OF A GROUND WA TER CORRECTIVE PERTAINS TO ALL SITES WITH LAND.IIAsED HAZARDOUS AClION
CORRECTIVE ACTION ACTION PROGRAM THAT PREVENTS HAZARDOUS CONSTITUENTS WASTE UNITS ISURFACE IMPOUNDMENTS, WASTE PilES, CHEMICAl
PROGRAM; HAZ WASTE FROM EXCEEDING THEIR RESPECTIVE CONCENTRATION LIMITS AT LAND TREA TMENT UNITS. lANDFILLS) AT WHICH
FAC THE COMPLIANCE POINT BY EITHER REMOVAL OR TREATMENT OF HAZARDOUS CONSTITUENTS HAVE BEEN DETECTED. TIllS
THESE HAZARDOUS CONSTITUENTS. INCLUDES EXISTING lAND.BASED AREAS OF
CONTAMINATION.
3745.55." A.B.C GENERAL CLOSURE REQUIRES THAT ALL HAZARDOUS WASTE FACILITIES BE CLOSED l'fHlAINS TO ANY SITE AT WltlClIlIAZARDOUS WASH 15 ACIION
PERFORMANCE IN A MANNER THAT MINIMIZES THE NEED FOR FURTHEH TO BE THEATED. STOHED OR DlSPUSED OF lOA liAS IIUN
STANDARD; HAZ WASTE MAINTENANCE, CONTROLS, MINIMIZES, EliMINATES OR TREATED. STORED OR DISPOSED OFI.
FACIL PREVENTS POST. CLOSURE ESCAPE OF HAZARDOUS WASTE.
HAZARDOUS CONSTITUENTS. lEACHATE. CONTAMINATED RUN.OH
OR HAZARDOUS WASTE DECOMPOSITION PRODUCTS TO THE GROUND
OR SURFACE WATER OR THE ATMOSPHERE.
3746.56.12 B CONTENT OF CLOSURE SPECIFIES litE MINIMUM INFORMA TlON REQUIRED IN A CI USlltll SUIISIANIIVE REQUlRlMENlS I'IIIIAIN 10 ANY SilL AI AC liON
PLAN; HAZ WASTE PLAN FOR OHIO EPA TO DETERMINE THE ADEQUACY OF THE WIUCH HAZARDOUS WAS IE IS 10 liE Tl\EATUI. STOIILD on
FACILITIES PLAN. DISPOSED OF (OR HAS BEEN THEA TED. STORED OR
DISPOSED OFI.
3745.55.14 DISPOSAL/ DECON OF REQUIRES THAT ALL CONTAMINATED EQUIPMENT. STRUCTURES PERTAINS TO ANY SITE AT WHICH IIAZARDOU5 WASTE IS A C liON
EQUIPMENT. AND SOilS BE PROPERLY DISPOSED OF OR DECONT AMINA TED TO BE TREATED, STORED OR DISPOSED OF lOR liAS BEEN
STRUCTURES 110 SOilS REMOVAL OF HAZARDOUS WASTES OR CONSTITUENTS FROM A UNIT TREATED, SIORED OR DISPOSED OFt.
MAY CONSTITUTE GENERATION OF HAZARDOUS WASTES.
3745.65.\7 B POST. CLOSURE CARE SPECIFIES THE POST.CLOSURE CARE REQUIREMENTS, INCLUDING PERTAINS TO ALL SITES WITH LAND.BASED HAZARDOUS ACTION
AND USE OF PROPERTY MAINTENANCE, MONITORING AND POST.CLOSURE USE OF WASTE UNITS (lANDFILLS AND SURFACE IMPOUNDMENTS.
PROPERTY. WA{,TE PILES, lAND TREATMENT UNITS AND TANKS THAT
ME T REQUIREMENTS OF LANDFIllS AFTER CLOSURE..
THIS INCLUDES EXISTING LAND. BASED AREAS OF
CONTAMINATION.
3746.65.18 B POST. CLOSURE PLAN PRESENTS THE INFORMA TION NECESSARY FOR OHIO EPA TO PERTAINS TO ALL SITES WITH LAND.BASED HAZARDOUS AC nON
DETERMINE THE ADEQUACY OF A POST.CLOSURE PLAN. WASTE UNITS IlANDFILLS AND SURFACE IMPOUNDMENTS,
WASTE PILES, LAND TREATMENT UNITS AND TANKS THAT
MEET REQUIREMENTS OF LANDFILLS AFTER CLOSURE).
THIS INCLUDES EXISTING LAND.BASED AREAS OF
CONTAMINA TION.
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..
OHIO ADMINISTRATIVE CODE 10ACI ARAR. FOR THE SElECTEO REMEDY FOR OPERABLE UNIT 2
06/2B/93 SKINNER LANDFILL BUTlER COUNTY Paue 11
ADMINIS. TITLE OR ARAR
CODE PERTINENT SUBJECT DESCRIPTION APPLICA TION TYPE
SECTION PARAGRAPH OF OF REGULATION OF REGULATION
REGULA TlON
3746.56.\9 B NOTICE TO LOCAL LAND REQUIRES THAT A RECORD OF THE TYPE. LOCATION AND PERTAINS TO ALL SITES WITH LAND. BASED HAZARDOUS ACTION
AUTHORITY QUANTITY OF HAZARDOUS WASTES DISPOSED OF IN EACti UNIT WASlrE UNITS ILANDFILlS AND SURFACE IMPOUNDMENTS.
BE SUBMITTED TO THE LOCAL LAND AUTHORITY AND THE WASTE PILES. LAND TREATMENT UNITS AND TANKS THA T
DIRECTOR OF THE OHIO EPA. ALSO REQUIRES THAT A NOTATION MEET REQUIREMENTS OF LANDFILLS AFTER CLOSUREI.
TO THE DEED TO THE FACILITY PROPERTY BE MADE INDICATING TlUS INCLUDES EXISTING LAND. BASED AREAS OF
THAT THE LAND WAS USED TO MANAGE ItAZARDOUS WASTES AND CONTAMINA TlON.
HIAT CERTAIN USE RESTRICTIONS MAY APPLY TO THE
PROPERTY.
./V..56.71 CONDITION OF CONTAINERS tiOlDlNG HAZARDOUS WASTE MUST BE MAINTAINED PERTAINS TO ANY SITE AT WHICH HAZARDOUS WASlE ACTION
CONTAINERS IN GOOD CONDITION INO RUST OR STRUCTURAL DEFECTS). WILL BE STORED IN CONTAINERS.
3745.56.72 COMPA TlBILITY OF HAZARDOUS WASTES PLACED IN CONTAINER MUST NOT REACT PERTAINS TO ANY SITE AT WHICH HAZARDOUS WASTE ACTION
WASTE WITH WITH THE CONTAINER MATERIAL OR LINER MATERIAL. WILL BE STORED IN CONTAINERS.
CONTAINERS
3745.56.73 MANAGEMENT OF CONTAINERS HOLDING HAZARDOUS WASTE MUST BE CLOSED PERTAINS TO ANY sm AT WltlCH IIAZARDOUS WASTE ACTION
CONTAINERS IEXCEPT TO ADD OR REMOVE WASTEI AND MUST NOT BE HANDLED WILL BE STORED IN CONTAINERS.
IN A MANNER THAT MAY RUPTURE THE CONTAINER OR CAUSE IT
TO LEAK.
3746.56.74 CONTAINER REQUIRES AT LEAST WEEKLY INSPECTIONS OF CONTAINER PERTAINS TO ANY SITE AT WHICH HAZARDOUS WASTE ACTION
INSPECTIONS STORAGE AREAS. WILL BE STORED IN CONTAINERS.
3746.56.75 A.B.C.D CONTAINER STORAGE REQUIRES THAT CONTAINER STORAGE AREAS HAVE A PERTAINS TO ANY SITE AT WHICH IIAZARDOUS WASTE ACTION
AREA CONTAINMENT CONTAINMENT SYSTEM AND SPECIFIES THE MINIMUM WILL BE STORED IN CONTAINERS.
SYSTEM REQUIREMENTS OF SUCH A SYSTEM.
1745.55.76 CONTAINER PRESENTS GENERAL PRECAUTIONS TO BE TAKEN TO PREVENT PERTAINS TO ANY SITE AT WHICH POTENTIAllY ACTION
REQUIREMENTS FOR ACCIDENTAL IGNITION OR REACTION OF IGNITABLE OR REACTIVE OR IGNITABLE WASlES THAT ARE STORED. OR CHEMICAL
IGNIT ABLE/REACTIVE REACTIVE WASTES THAT WILL BE STORED IN CONTAINERS. ARE TO BE STORED. IN CONTAINERS.
WASTES
3746.55.77 A.B.C CONTAINER PRESENTS GENERAL PRECAUTIONS TO BE TAKEN WHEN DEALING PERTAINS TO ANY SITE AT WHICH POTENTIALLY ACTION
REQUIREMENTS FOR WITH INCOMPA TlBLE WASTES. INCOMPATIBLE WASTES ARE PRESENT. CHEMICAL
INCOMPATIBLE WASTES
3746.55. 7B CONTAINER CLOSURE SPECIFIES CLOSURE REQUIREMENTS FOR CONTAINERS AND PERTAINS TO ANY SITE AT WltlCH HAZARDOUS WASTE ACTION
REQUIREMENTS CONTAINMENT SYSTEM. WILL BE STORED IN CONTAINERS.
3745.66.92 A.G DESIGN 6 REQUIRES A SECONDARY CONTAINMENT SYSTEM FOR TANKS AND PERTAINS TO ANY SITE A T WHICH HAZARDOUS WASTE ACTION
INSTALLATION OF NEW ASSESSMENT TO DETERMINE TANK INTEGRITY. WILL8E EITHER STORED OR TREATED IN TANKS.
TANK SYSTEMS OR
COMPONENTS
-------
OS/26/93
ADMINIS.
CODE
SECTION
PERTINENT
PARAGRAPH
OHIO ADMINISTRATIVE CODE 10ACI ARARI FOR THE SELECTED REMEDY FOR OPERABLE UNIT 2
SKINNER LANDFILL BUTlER COUNTY
TITlE OR
SUBJECT
OF
REGULA TlON
DESCRIPTION
OF REGULATION
APPLICA TION
OF REGULA TION
Paga
12
ARAR
TYPE
3746.65.93
ACTION
3745.55.94
3745.55.95
3745.55.96
3745.55.97
3745.55.98
3746.65.99
3745.57.01
3745.57.03
3745.57.06
A.G.I
A.B,C
A.D
A.B.C.E
A,B
A.B
A.D
A.I
A,B
. CONTAINMENT AND
DETECTION OF
RElEASES FOR TANK
SYSTfMS
GENERAL OPERATING
REQUIREMENTS FOR
TANK SYSTEMS
INSPECTIONS OF TANK
SYSTEMS
RESPONSE TO LEAKS OR
SPILLS OF TANK
SYSTEMS
CLOSURE AND
POST.CLOSURE CARE
FOR TANK SYSTEMS
TANK REQUIREMENTS
FOR
IGNITABLE/REACTIVE
WASTES
TANK REQUIREMENTS
FOR INCOMPATIBLE
WASTES
ENVIRONMENTAL
PERFORMANCE
STANDARDS;
LAND. BASED UNITS
LANDFILL DESIGN AND
OPERA TING
REQUIREMENTS
MONITORING AND
INSPECTIONS OF
LANDFilLS
REQUIRES SECONDARY CONTAINMENT AND LEAK DETECTION
SYSTEMS FOR TANKS.
SPECIFIES GENERAL OPERATING REQUIREMENTS FOR TANK
SYSTEMS.
REQUIRES INSPECTIONS AT LEAST ONCE EACH OPERATING DAY.
REQUIRES THAT UNFIT TANKS BE REMOVED FROM USE AND
FURTHER RElEASES BE PREVENTED.
SPECIFIES CLOSURE AND POST.CLOSURE REQUIREMENTS FOR
TANK SYSTEMS.
PRESENTS GENERAL PRECAUTIONS TO BE TAKEN TO PREVENT
ACCIDENTAL IGNITION OR REACTION OF IGNITABLE OR
REACTIVE WASTES THAT ARE TREATED OR STORED IN TANKS.
PRESENTS GENERAL PRECAUTIONS TO BE TAKEN WHEN DEALING
WITH POTENTAlllY INCOMPATIBLE WASTES THAT ARE STORED OR
TREATED IN TANKS.
SPECIFIES LOCA TlON. DESIGN. CONSTRUCTION, OPERATION,
MAINTENANCE AND CLOSURE REQUIREMENTS FOR LANDFillS,
WASTE PILES. SURFACE IMPOUNDMENTS AND UNDERGROUND
INJECTION WElLS.
PRESENTS DESIGN AND OPERATING REQUIREMENTS FOR
LANDFilLS. INCLUDES LINER, LEACHATE COLLECTION AND
REMOVAL. RUN. ON/RUN. OFF CONTROL, ETC.
REQUIRES INSPECTION OF lANDFillS DURING CONSTRUCTION OR
INSTALLATION AND OPERATION.
PERTAINS TO ANY SITE A T WHICH HAZARDOUS WASTE
WILL BE EITHER STORED OR TREATED IN TANKS.
I
PERTAINS TO ANY SITE AT WHICH HAZARDOUS WASTE
WILL BE EITHER STORED OR. TREATEO IN TANKS.
PERTAINS TO ANY SITE AT WHICH HAZARDOUS WASTE
WILL BE EITHER STORED OR TREATED IN TANKS.
PERTAINS TO ANY SITE AT WHICH HAZARDOUS WASTE
WILL BE EITHER STORED OR TREATEO IN TANKS.
PERTAINS TO ANY SITE AT WHIC:H HAZARDOUS WASTE
Will BE EITHER STORED OR TREAlED IN TANKS.
PERTAINS TO ANY SITE AT WHICH POTENTIALLY
REACTIVE OR IGNITABLE WASTES ARE STOREO OR
TREATED lOR TO BE STORED OR TREATEDIIN EXISTING
TANKS.
PERT AINS TO ANY SITE AT WHICH POTENTlAlI.Y
INCOMPATIBLE WASTES ARE STORED OR TREATED lOR TO
BE STORED OR TREATEDIIN TANKS.
PERrAINS TO All SITES TltAT ElIIIER HAVE OR WILL
HAVE AT LEAST ONE OF THE FOLLOWING UNITS
ON. SITE:
LANDFllI.S. WASTE PliES. SURFACE IMPOlJNDMrNTS.
LAND TREATMENT FACILITIES AND UNDERGROUND
INJECTION WELLS lTIilS INCLUDES EXISTING
LAND.BASED AREAS OF CONTAMINATIONI.
PERTAINS TO ALL SITES AT WHICH A HAZARDOUS WASTE
LANDFILL Will EITHER BE LOCA TED OR AN EXISTING
LANDFill Will BE EXPANDED. THIS RULE ALSO
PERTAINS TO EXISTING LAND. BASED AREAS OF
CONTAMINATION.
PERTAINS TO All SITES AT WHICH A HAZARDOUS WASTE
LANDFILL WILL EITHER BE LOCATED OR AN EXISTING
LANDFILL WilL BE EXPANDED. THIS RULE PERTAINS TO
EXISTING LAND.BASED AREAS OF CONTAMINATION.
ACliON
ACTION
ACTION
ACliON
ACIION
ACliON
ACliON
ACTION
ACTION
-------
OHIO ADMINISTRATIVE CODE (OACI ARAR. FOR THE SELECTED REMEDY FOR OPERABLE UNIT 2
OS/20/93 SKINNER lANDFilL BUTlER COUNTY Paoa 13
ADMINIS. TITlE OR ARAR
CODE PERTINENT SUBJECT DESCRIPTION APPLICATION TYPE
SECTION PARAGRAPH OF OF REGULATION OF REGULATION
REGULATION
3745.57.\0 A.B LANDFILL CLOSURE AND SPECIFIES CLOSURE AND POST. CLOSURE REQUIREMENTS FOR PERTAINS TO ALL SITES AT WHICI1 A HAZARDOUS WASTE ACTION
POST.ClOSURE CARE HAZARDOUS WASTE LANDFILLS. INCLUDES FINAL COVER AND LANDFILL WILL EITHER BE LOCATED OR AN EXISTING
MAINTENANCE. LANDFILL WILL BE EXPANDED. THIS RULE PERTAINS TO
EXISTING LAND.BASED AREAS OF CONTAMINATION.
3745.57.\2 A.B LANDFill PROHIBITS THE DISPOSAL OF IGNITABLE OR REACTIVE WASTE PERTAINS TO ALL SITES AT WHICH POTENTIALLY ACTION
REQUIREMENTS FOR IN A LANDFILL. UNLESS THE WASTE IS TREATED. RENDERED OR IGNITABLE OR REACTIVE HAZARDOUS WASTE MAY BE CHEMICAL
IGNIT ABLEIAEACTIVE MIXED SO THAT THE RESULTANT MATERIAL NO LONGER MEETS LANDFILlED.
WASTES THE DEFINITION OF IGNITABLE OR REACTIVE WASTE.
3745.67.\3 LANDFILL PROHIBITS THE DISPOSAL OF INCOMPATIBLE WASTE IN THE PERTAINS TO ALL SITES AT WHICH POTENTIALLY ACTION
REQUIREMENTS FOR SAME CELL OF A LANDFILL. INCOMPATIBLE HAZARDOUS WASTE MAY BE LANDFill ED. CI1EMICAl
INCOMPATIBLE WASTES
3745.57.\4 A-D LANDFilL THE PLACEMENT OF BULK OR NON. CONTAINERIZED LIQUID PERT AINS TO ALL SITES AT WHICI1 A LIQUID ItAZARDOUS AClION
REQUIREMENTS FOR HAZARDOUS WASTE OR HAZARDOUS WASTES CONTAINING FREE WASTE OR HAZARDOUS WAStE CONTAINING FREE LIQUIDS
BULK. CONTAINERIZED LIQUIDS IWHETHER OR NOT ABSORBANTS HAVE BEEN ADDED) IN ARE CONSIDERED FOR LANDFILLING.
LIQUIDS ANY LANDFILL IS PROHIBITED.
3745.67.\6 A.B LANDFILL UNLESS THEY ARE VERY SMALL. CONTAINERS MUST EITHER BE PERTAINS TO ALL SITES AT WHICH A HAZARDOUS WASTE ACTION
REQUIREMENTS FOR AT LEAST 90°A, FULL WHEN PLACED IN THE LANDFILL OR LANDFILL WILL EITHER BE LOCATED OR AN EXISTING
CONTAINERS CRUSHED/SHREDDED PRIOR TO PLACEMENT IN THE LANDFILl. LANDFILL WILL BE EXPANDED AND CONTAINERS ARE TO
BE DISPOSED OF IN THE LANDFILl.
3145.5B.10 A.B REQUIREMENTS FOR SPECIFIES REOUIREMENTS FOR PERSONS WHO RECLAIM SPENT PERTAINS TO ANY SITE AT WHICI1 THERE ARE SPENT ACIION
RECLAIMING SPENT LEAD ACID BAnERIES AND FOR PERSONS WHO GENERATE. LEAD ACID BAnERIES WHICH MAY BE RECLAIMED
LEAD ACID BA nERIES STORE. TRANSPORT OR COLLECT THEM BUT DO NOT RECLAIM ON. SITE OR OFF.SITE.
THEM.
3145.81-1\ A.B MAXIMUM CONTAMINANT PRESENTS MAXIMUM CONTAMINANT lEVELS FOR INORGANICS. PERTAINS TO ANY SITE WHICH HAS CONT AMINA TED CI1EMICAL
LEVELS FOR INORGANIC GROUND OR SURFACE WATER THAT 15 EITHER BEING
CHEMICALS USED. OR liAS THE POTENTIAL FOR USE. AS A DRINKING
WATER SOURCE.
3146.8\-12 . A.B.C MAXIMUM CONTAMINANT PRESENTS MCLS FOR ORGANICS. PERTAINS TO ANY SITE wurCH HAS CONTAMINATED CHEMICAL
LEVELS FOR ORGANIC GROUND OR SURFACE WATER THAT IS EITHER BEING
CHEMICALS USED. OR HAS THE POTENTIAL FOR USE. AS A DRINKING
WATER SOURCE.
3145-81-13 A.B MAXIMUM CONTAMINANT PRESENTS MCLS FOR TURBIDITY. PERTAINS TO ANY SITE WHICH HAS CONTAMINATED CHEMICAL
LEVELS FOR TURBIDITY GROUND OR SURFACE WATER THAT IS EITHER BEING
USED. OR HAS THE POTENTIAL FOR USE. AS A DRINKING
WATER SOURCE.
-------
OHIO ADMINISTRATIVE CODE 10ACI ARAR, FOR THE SELECTED REMEDY FOR OPERABLE UNIT 2
OS/28/93 SKINNER LANDFILL BUTLER COUNTY Page 14
ADMINIS. TITLE OR ARAR
CODE PERTINENT SUBJECT DESCRIPTION APPLICA TlON TYPE
SECTION PARAGRAPH OF OF REGULATION OF REGULATION
REGULATION
3745.81-14 A.E MAXIMUM ffiESENTS MCLS FOR MICROBIOLOGICAL CONTAMINANTS. PERTAINS TO ANY SITE WHICH HAS CONTAMINA TEO CHEMICAL
MICROBIOLOGICAL GROUND OR SURFACE WA TER TtIA T IS EITtIER 8EING
CONTAMINANT LEVELS USfD. OR HAS THE POTENTIAL FOR USE. AS A DRINKING
WATER SOURCE.
3745.81-15 A.B MAX CONTAMINANT PRESENTS MCIS FOR RADIUM.226. RADIUM.228 AND GROSS PERTAINS TO ANY SIH WHICIIIIAS CONTAMINATED CII[MICAI
LEVELS FOR RADIUM ALPHA PARTICLE AClIVITY. liI!OUND 1111 SURfA!:I. WA lEA iliA 1 IS EITtIER 811NG
226. 228.GROSS ALPHAS USED. 011 liAS litE 1'0IlNIIAI':OIlUSl. AS A DIIINKINIj
WATER SOURCE.
3745-81'16 A.B MAX CONTAM LEVELS PRESENTS MClS FOR BETA PARTICLE AND PHOTON PERTAINS TO ANY SITE WHICIIIIAS CONTAMINATED CIIEMICAl
FOR BETA PARTICLE. RADIOACTIVITY FROM MAN. MADE RADIONUCLIDES. GROUND OR SURFACE WATER TtlAT IS EITHER BEING
PHOTON RADIOACTIV USED. OR HAS THE POTENTIAL FOR USE. AS A DRINKING
WATER SOURCE.
3745.81.21 A.B MICROBIOLOGICAL PRESENTS SAMPLING AND ANALYTICAL REQUIREMENTS FOR PERTAINS TO ANY SITE WHICH HAS CONTAMINATED CIIL MICAI
CONTAMINANT SAMPLING MICROBIOLOGICAL CONTAMINANTS. GROUND OR SURFACE WATER THAT IS EITHER BEING
. ANALYTICAL REQ USED. OR HAS THE POTENTIAL FOR USE. AS A DRINKING
WATER SOURCE.
3745-81.22 A.8 TU81DITY CONTAMINANT PRESENTS SAMPLING AND ANALYTICAL REQUIREM~NTS FOR PERTAINS TO ANY SITE WIHCII HAS CONTAMINATED CHEMICAL
SAMPLING. TURBIDITY. GROUND OR SURFACE WATER THAT IS EITHER BEING
ANALYTICAL USED. OR HAS THE POTENTIAL FOR USE. AS A DRINKING
REQUIREMENTS WATER SOURCE.
3745-81-23 A.E INORGANIC PRESENTS MONITORING REQUIREMENTS FOR INORGANIC PERTAINS TO ANY SITE WHICH HAS CONlAMINA TED CIlEMICAl
CONTAMINANT CONTAMINANTS. GROUND OR SURFACE WA TER THA TIS ElTtlER BEING
MONITORING USED. OR HAS THE POTENTIAL FOR USE. AS A DRINKING
REQUIREMNENTS WATER SOURCE.
3745.81.24 A.E ORGANIC CONTAMINANT PRESENTS MONITORING REQUIREMENTS FOR ORGANIC PERTAINS TO ANY SITE WHICH HAS CONTAMINATED CIIEMICAl
MONITORING CONTAMINANTS. GROUND OR SURFACE WATER THA T IS EITHER BEING
REQUIREMENTS USED. OR HAS THE POTENTIAL FOR USE. AS A DRINKING
WATER SOURCE.
3745.81-25 A-D ANALYTICAL METHODS PRESENTS ANALYTICAL METHODS FOR RADIOACnVITY. PERTAINS TO ANY SITE WHICH HAS COIHAMINATED CHEMICAL
FOR RADIOACTIVITY GROUND OR SURFACE WATER THAT IS EITHER BEING
USED. OR HAS THE POTENTIAL FOR USE. AS A DRINKING
WATER SOURCE.
3745-81.26 A.B.C MONITORING FREQUENCY ffiESENTS MONITORING REQIREMENTS FOR RADIOACTIVITY. PERTAINS TO ANY SITE WHICH HAS CONTAMINATED CHEMICAL
FOR RADIOACTIVITY GROUND OR SURFACE WATER THAT IS EITHER BEING
USED. OR HAS THE POTENTIAL FOR USE. AS A DRINKING
WATER SOURCE.
-------
OHIO ADMINIS TRA TIVE CODE 10ACI ARAR, FOR THE SElECTED REMEDY FOR OPERABLE UNIT 2
OS/28/93 SKINNER LANDFILL BUTlER COUNlY Page 15
ADMIN IS. TITlE OR ARAR
CODE PERTINENT SUBJECT DESCRIPTION APPLICA TION lYPE
SECTION PARAGRAPH OF OF REGULA nON OF REGULATION
REGULA TlON
3746.BI-27 A-E ANALYTICAL PRESENTS GENERAL ANALYTICAL TECHNIQUES FOR MCLS. PERTAINS TO ANY SITE WHICH HAS CONTAMINATED CI1EMICAL
TECHNIQUES GROUND OR SURFACE WATER THAT IS EITHER BEING
USE~. OR HAS THE POTENTIAL FOR USE. AS A DRINKING
WATER SOURCE.
3745.BI.40 A.B.C REQUIREMENTS FOR A PROVIDES CRITERIA BY WHICH DIRECTOR MAY GRANT VARIANCE P[IITAINS TO ANY SITE WllICtt ItAS CONTAMINATED CIILMICAI.
VARIANCE FROM MCLS FROM MCLS. GAOUND un SURf ACE WA rEA TIM T 15 EHHER B~ING
USED. OR HAS THE POTENlIAL FOR USE. AS A DR[NKINU
WATER SOURCE.
3745-81-46 AL TERNA TIVE ALLOWS FOR THE USE OF ALTERNATIVE TREATMENT TECHNIQUES PERTAINS TO ANY SITE WHICH HAS CONTAMINATED CHEMICAL
TREATMENT TECHNIQUE TO ATTAIN MCLS. GAOUND OR SURfACE WA TER THAT IS EITHER BEING
VARIANCE USED. OR HAS THE POTENTIAL FOR USE; AS A DRINKING
WATER SOURCE.
3746.9.04 A.B LOCA TION/SITING OF MANDATES THAT GROUND WATER WElLS BE: PERTAINS TO All GROUND WATER WElLS ON TltE SITE I OCA TlON
NEW GW WEllS AlLOCATED AND MAINTAINED SO AS TO PREVENT CONTAMINANTS THAT EITI1ER WILl8E INSTALLED OR HAVE BEEN ACTION
FROM ENTERING WElL. INSTAllED SINCE FEB. 16. 1976.
BI LOCATED SO AS TO BE ACCESSI8LE FOR CLEANING AND WOULD PEAT AIN DURING THE FS IF NfW WElLS ARE
MAINTENANCE. CONSTRUCT£O FOR TREATABILIlY STUDIES.
3746-9.05 A I.B.H CONSTRUCTION Of NEW SPECIFIES MINIMUM CONSTRUCTION REQUIREMENTS FOR NEW PEATAINS TO All GROUND WATER WElLS ON THE SITE ACTION
GW WELLS GROUND WATER WElLS IN REGARDS TO CASING MA TERIA\.. THAT EITHER Will BE INSTALLED OR HAVE BEEN
CASING DEPTH. POTABLE WATER. ANNULAR SPACES. USE OF INSTAllED SINCE FEB 15. 1975.
DRIVE SHOE. OPENINGS TO ALLOW WATER ENTRY. CONTAMINANT WOULD PERTAIN DURINU HIE FS IF NfW WEllS AR~
ENTRY. CONSTHUCHD FOR TRLA IABllHY SlUDIES.
,'.15.9.06 A.B.D.E CASING REQUIREMENTS ESTABLISHES SPECIFIC REQUIREMENTS FOR WElL CASINGS. PERTAINS 10 All GROUND WATER WElLS ON THE SHE ACTIUN
FOR NEW GW WELLS SUCH AS SUHABLE MATERIAL. DIAMETERS AND CONDITION. THAT EITHER WILL BE INSTALLED OR HAVE BEEN
INSTALLED SINCE FEB. 16. 1976.
WOULD PERTAIN DURING THE FS IF NEW WEllS ARE
CONS TRUCTED FOR TREAT ABILIlY STUDIES.
3746-9.07 A-F SURFACE DESIGN OF ESTABLISHES SPECIFIC SURFACE DESIGN REQUIREMENTS. SUCH PERTAINS TO All GROUND WATER WELLS ON HIE SHE ACTION
NEW GW WEllS AS HEIGHT ABOVE GROUND. WELL VENTS. WEll PUMPS. ETC. THAT EITHER WILL BE INSTAllED OR HAVE BEEN
INSTALLED SINCE FEB. 16. 1975-
WOULD PERTAIN DURING THE FS IF NEW WELLS ARE
CONSTRUCTED FOR TREATABILIlY STUDIES.
3746-9.08 A.C START-UP & OPERATION REQUIRE DISINFECION OF NEW WELLS AND USE OF POTABLE PERTAINS TO ALL GROUND WATER WElLS ON THE SITE ACTION
OF GW WELLS WATER FOR PRIMING PUMPS. THAT EITHER WILL BE INSTALLED OR HAVE BEEN
INSTALLED SINCE fEB. 16. 1975.
WOULD PERTAIN DURING THE FS IF NEW WEllS ARE
CONSTRUCTED FOR TREATABILIlY STUDIES.
3746-9-09 A-C.DI.E.G MAINTENANCE. ESTABLISHES SPECIFIC MAINTENANCE AND MODIFICATION PERTAINS TO ALL GROUND WATER WELLS ON THE SITE ACTION
OPERATION OF GW REQUIREMENTS FOR CASING. PUMP AND WELLS IN GENERAL. THAT EITHER WILL BE INSTALLED OR HAVE BEEN
WEllS INSTAllED SINCE FEB. 16. 1976.
WOULD PERTAIN DURING THE FS IF NEW WELLS ARE
CONSTRUCTED FOR TREATABILIlY STUDIES.
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OS/26/93
ADMINIS.
CODE
SECTION
PERTINENT
PARAGRAPH
OHIO ADMINISTRATIVE CODE 10ACI ARAR. FOR THE SElECTED REMEDY FOR OPERABLE UNIT 2
SKINNER lANDFilL BUTlER COUNTY
TITlE OR
SUBJECT
OF
REGULA TION
DESCRIPTION
OF REGULATION
APPLICA TION
OF REGULATION
P.ge
16
ARAR
TYPE
3746.9.10
3746.9.11
A.B,C
ABANDONMENT OF TEST
HOLES. GW WEllS
USE OF WELLS FOR
DISPOSAL
FOLLOWING COMPLETION OF USE. WElLS AND TEST HOLES SHALL
BE COMPlETElY FILLED WITH GROUT OR SIMILAR MA TERtAl OR
SHALL BE MAINTAINED IN COMPliANCE OF ALL REGULATIONS.
NO PERSON SHALL USE ANY WElL TO INJECT OR REINJECT ANY
SUBSTANCE INTO THE GROUND WITHOUT NECESSARY PERMITS.
I

PlRTAINS TO All GROUND WATER WElLS ON THE SITE
THAT EITHER WILL liE INSTALLED OR HAVE BEEN
INSTALLED SINCE FEB. 16. 1975.
MAY PERTAIN TO SYSTEMS THAT ENTAIL INJECTION OR
REINJECTION OF FLUID INTO THE GROUND. CONSIDER
FOR IN. SITU BIOREMEDIATION. SOIL flUSHING AND
GROUND WATER PlUME CONTAINMENT.
ACIION
ACTION
-------
Table of Contents
Skinner Landfill
Responsiveness Summary
OVERVIEW
. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
1
RUMORS OF ORDNANCE. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
5
RCRA WASTE CLASSIFICATION. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
6
COMMENTS FROM THE MAY 20, 1992 PUBLIC MEETING. . . . . . . . . . . . .
7
WRITTEN COMMENTS ON THE PROPOSED PLAN. . . . . . . . . . . . . . . . . .. 13
COMMENTS OF UNION TOWNSHIP. . . . . . . . . . . . . . . . . . . . . . . . . . . .. 25
PRP COMMENTS ON THE PROPOSED PLAN. . . . . . . . . . . . . . . . . . . . . .. 28
JULY 2~, 1992 PUBLIC MEETING. . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 40

PUBLIC COMMENTS ON THE u.S. EPA'S SHIFT IN PREFERENCE FROM
ALTERNATIVE 5 TO ALTERNATIVE 3 ....................... 49
PRP COMMENTS ON THE u.S. EPA'S SHIFT IN PREFERENCE FROM
ALTERNATIVE 5 TO ALTERNATIVE 3 ....................... 51
-------
SKINNER LANDFILL
RESPONSIVENESS SUMMARY FOR THE
RECORD OF DECISION
OVERVIEW
During the course of the investigation, many meetings were held with the
community, with a local activist group, and with a coalition of community
representatives.
A fact sheet outlining U.S. EPA's plans for the inv~'>tigation of the Skinner Landfill
site was distributed to the public in March of 198€
A fact sheet describing the results of Phase I of the Remedial Investigation (RI) and
plans for Phase II of the RI was distributed to the public in April of 1987.
A fact sheet describing the results of Phase II of the RI and plans for the Baseline
Risk Assessment (RA) and Feasibility Study (FS) was distributed to the public in
June of 1991. Representatives of the U.S. EPA and the Ohio EPA held a public
meeting in West Chester, Ohio on June 20, 1991 to discuss the results of the
Phase II RI and plans for future activities at the Skinner site.
A fact sheet describing the results of the Feasibility Study, and presenting the U.S.
EPA's preferred alternative for a comprehensive cleanup of the entire Skinner
Landfill site was distributed to the public in April, 1992. A component of this
cleanup plan was on-site incineration of approximately 17,000 cubic yards of
lagoon wastes. A public meeting to discuss the proposed plan and to gather public
comments was held on May 20, 1992. A second public meeting on this subject
was held on July 29, 1992. An ancillary purpose of this second public meeting
was to present to the public the results of an assessment of the risks posed by the
on-site incineration option, which had been requested at the May 20, 1992 public
meeting. However, this meeting was disrupted by a local activist group to the
point that the tisk assessment information was not adequately conveyed to the
public. The July 29, 1992 public meeting lasted from 7:00pm until 1 :45am.
Subsequent to the second public meeting, and due to concerns expressed by
members of the public and by elected officials, the U.S. EPA decided to alter its
decisionmaking approach for this site. On August 7, 1992, U.S. EPA mailed an
announcement to members of the public and issued a news release, which
indicated that:
1) U.S. EPA proposed to select an interim remedy for this site, which
included the fencing of the contaminated portion of the site and the
-------
. -...-.-- - ..
2
provision of an alternative water supply to potentially affected homes;
2) The comment period for fencing and alternate water supply would end on
August 31, 1992;
3) The comment period for the remaining portions of the remedy would
remain open until further notice, in order to address community concerns.
The comment period for the remaining portions of the remedy did not close until
February 9, 1993, a period of almost ten months.
A coalition of various West Chester community groups and residents was formed
after the July 29, 1992 public meeting in order to discuss the Skinner Landfill
cleanup ~nd to meet with the U.S. EPA and Ohio EPA. This coalition includes
representatives from the Township Trustees, the Chamber of Commerce, Citizens'
Lobby for Environmental Action Now (CLEAN), the School Board, the Old West
Chester Merchants Association, the Union School PT A, the Home Builders
Association, and a number of Township Residents. The U.S. EPA and Ohio EPA
met with this coalition every other week for a period of three months. Topics
discussed before this coalition include:
- site history;
- description of Remedial Investigation results;
- applicability of RCRA regulations;
- the w2000-foot rulew;
- viability of containment remedies;
- assessment of site risks;
- proposals for further studies;
- alternative remediation technologies for the lagoon wastes; and
- the remedy selection process.
The discussions held with the Coalition were highly productive, and resulted in a
high degree of open communication and consensus-building. As a result of these
discussions, this Coalition issued a written unanimous recommendation that a
containment remedy be implemented at the Skinner site. This recommendation is
available for public review in the Administrative Record.
On January 11, 1993, the U.S. EP A issued a Fact Sheet announcing that the
preferred alternative had changed from Alternative 5 (which included incineration),
to Alternative 3 (a containment remedy that does not include incineration), with
the possible inclusion of soil vapor extraction. This Fact Sheet, along with a press
release and newspaper advertisements, announced that the public comment period
would end on February 9, 1993.
On January 20, 1992, a legal representative of the Potentially Responsible Parties
-------
.. .," .".'-- ... "'..
. . . ....- ,'....
3
(PRPs) requested an additional 30-day extension of the public comment period.
This request was denied.
RESPONSES TO COMMENTS
A large number of comments were received after release of the proposed plan, and
during the public comment period, which lasted almost ten months. These
comments are responded to below. Some of the comments are quoted directly,
and others are paraphrased for clarity and brevity.
Several general subjects were raised repeatedly in public comments, and are
addressed below as general responses, rather than repeating the response for each
comment.
THE "2000-FOOT- RULE
A number of commenters expressed opposition to incineration based upon
the fact that construction of an incinerator would require the waiver of Ohio
Administrative Code 3734.05(d)(6)(g). In the comments, this rule was
described as a rule "forbidding incineration within 2000 feet of a school".
RESPONSE
The U.S. EPA and Ohio EPA have stated that, in order to operate an
incinerator at this site, a waiver of OAC 3734.05(d)(6)(g) could be required.
The reason that a waiver might be required is legal, not technical. The
U.S. EPA believes that the incinerator would have been able to meet the
technical requirements of this rule by demonstrating that this incinerator
would not pose a substantial danger to the local residents and school
children. However, the U.S. EPA would not meet the specific administrative
requirement that applications be reviewed by the Ohio Hazardous Waste
Facility Board; such review is not required for Superfund sites.
An incomplete and inaccurate description of this rule has been presented to
the public through several routes. This rule has been repeatedly described
as "forbidding incineration within 2000 feet of a school". This is incorrect.
The law does not mention incineration, nor does it forbid incineration within
2000 feet of a school. The pertinent portion of the rule is quoted below:
(6J The board shall not approve an application for a hazardous waste
facility installation and operation permit unless it finds and determines
as follows:
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4
(g) That the active areas within a new hazardous waste facility
where acute hazardous waste as listed in 40 C.F. R. 261.33
(e), as amended, or organic waste that is toxic and is listed
under 40 C.F.R. 261, as emended, is being stored, treated, 0'
disposed of and where the aggregate of the storage design
capacity and the disposal design capacity of all hazardous
waste in those areas is greater than two hundred and fifty
thousand gallons, are not located or operated within any of the
fol/owing:
(i) Two thousand feet of any residence, school, hospital, jail, or
prison;
(ii) any naturally occurring wetland;
(iii) Any flood hazard area if the applicant cannot show that the
facility will be designated, constructed, operated, and
maintained to prevent washout by a one hundred-year flood or
that procedures will be in effect to remove the waste before
flood waters can reach it.
Division (D)(6)(g) of this section does not apply to the facility of
any applicant who demonstrates to the board that the
limitations specified in that division are not necessary because
0' the nature or volume 0' the waste and the manner of
management applied, the facility will impose no substantial
danger to the health and safety of persons occupying the
structures listed in division (D)(6)(g)(iJ of this section, and the
facility is to be located or operated in an area where the
proposed hazardous waste activities will not be incompatible
with existing land uses in the area.
Significantly, the second paragraph of the rule above provides for the
opportunity for the applicant to make a demonstration that the activity will
not pose a substantial danger to the occupants of the residence, school,
hospital, etc. If the applicant can make this demonstration, it may be
allowed "to site a facility (such as an incinerator), within 2000 feet of a
school, residence, etc. No law which provides for such a demonstration
could accurately be described as wforbidding incineration within 2000 feet of
a schoolw. If incineration had been selected, U.S. EPA would have had to
make the demonstration described in the second paragraph of the rule, as
stated above. A similar demonstration would been required under the RCRA
Hazardous Waste Incineration regulations, and also under Section 121 (d)(4)
of CERCLA. Incineration would not have proceeded without such a
demonstration.
The effects of this rule are not limited to incinerators. Rather, it would apply
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5
to any cleanup alternative which involves the on-site treatment, storage, or
disposal of hazardous wastes. If alternative treatment technologies had
been applicable to this site, U.S. EPA would have had to waive this rule in
order to apply these technologies. Therefore, if this law was interpreted as
has been proposed by some commenters, EP A would be prevented from
cleaning up those Superfund sites which most require cleanup, i.e. those
which are located within 2000 feet of a residence, school, hospital, etc.
RUMORS OF ORDNANCE
A number of commenters expressed the concern that there might be military
ordnance buried at the site, and that these could explode during the site
cleanup.
RESPONSE
The issue of the rumored munitions at the Skinner site was the subject of an
intense investigation on the part of the U.S. EPA. U.S. EPA assigned a civil
investigator to this investigation and followed up on many rumors. .
Additionally, U.S. EPA requested that the U.S. Army perform records
searches to determine whether ordnance was ever brought to the Skinner
site. Similar requests were made to the U.S. Army by David Gully, Union
Township Administrator, and U.S. Representative John Boehner. U.S. EPA
presented the results of these investigations to the public at length at the
July 29, 1992 public meeting, and to the Skinner Landfill Coalition.
The local rumors all seem to lead back to someone who had spoken to John
or AI Skinner. None of the reports involved first-hand knowledge or
observations. John and AI Skinner appear to have used the claim of the
presence of ordnance on the site as a means of keeping investigators from
going on to the site. In 1976, AI Skinner told Ohio EPA investigators that
nerve gas, mustard gas, bombs, and other explosives were buried at the
site. This caused Ohio EPA to withdraw from the site and to seek the help
of the U.S. Army. AI Skinner later retracted this claim before Ohio EPA
lawyers and U.S. Army investigators. During depositions, both AI and John
Skinner testified under oath that there is no ordnance buried at the site.
A search of Army records has turned up no indication of the transport or
disposal of ordnance at the Skinner site. Furthermore, searches of records
relating to the nearby Sharonville and Kings Mill arsenals has indicated that
no chemical ordnance was ever brought to, or stored at, these facilities.
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U.S. EPA has followed up on all of the rumors that we have been told of
involving munitions. All have been baseless; none have involved useful,
first-hand information. U.S. EPA believes that it has adequately addressed
this issue and does not plan to conduct any further investigation of rumors
involving munitions at this site.
However, while the rumors have not produced any evidence, U.S.- EPA feels
that it is prudent to exercise caution during any excavation on the site. The
U.S. Army Corps of Engineers will have control over any excavation
activities which are conducted at the site. Army Ordnance Specialists, or
ordnance contractors, will be available as needed to supervise any
excavation.
RCRA WASTE CLASSIFICA TION
Several commenters asked whether the lagoon wastes are RCRA Hazardous
Wastes, and whether the incineration and handling of the lagoon wastes
would be performed in compliance with RCRA Hazardous Waste regulations.
RESPONSE
The U.S. EPA determined that the RCRA Hazardous Waste regulations are
relevant and appropriate requirements for the incineration and handling of
the lagoon wastes. This means that the extremely stringent RCRA
incineration regulations would have been followed in the construction,
operation, and monitoring of the incinerator, and in the handling of the
associated feed and waste materials.
The lagoon wastes were tested for a wide range of chemical constituents
during the performance of the Remedial Investigation. The results of this
testing show that a wide range of organic and inorganic constituents are
present in the waste at very high concentrations. It is upon this information,
that the U.S. EPA based its determination that the RCRA regulations are
relevant and appropriate to the lagoon wastes.
Several specific, but limited, tests are available which would
definitively classify the lagoon wastes as RCRA Hazardous Wastes. These
tests were not performed during the investigation. Such testing is not
necessary in order for the U.S. EPA to make a determination that the RCRA
Regulations are Relevant and Appropriate to a particular action. Rather,
much broader, more informative tests were performed, in order to fulfill the
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purposes of the RifFS, i.e. the characterization of the site and evaluation of
cleanup methods.
COMMENTS FROM THE MA Y 20, 7992 PUBLIC MEETING
COMMENT
You don't really know what is in the waste fill, but you are proposing to
burn it.
RESPONSE'
A considerable amount of testing of the lagoon materials was performed
during the Remedial Investigation. 18 borings were drilled into and through
the waste lagoon area. Samples of waste from these borings were analyzed
for a wide range of chemical parameters. These results are given in the
Remedial Investigation. The analyses indicate that there are a wide variety
of contaminants in the waste lagoon which can be destroyed through
incineration.
COMMENT
Are you going to test the waste before you burn it?
RESPONSE
Yes, if incineration had been chosen, we would have performed additional
tests on the materials prior to incineration.
COMMENT
A lot of these things become more toxic after you burn them. You are going
to take ash that is more toxic than what you put in to the incinerator, and
you are going to bury it.
RESPONSE
This is incorrect. At this site, the feed materials, or the materials which
would have been burned in the incinerator, included a wide range of organic
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8
contaminants. Some 01 these materials have been described as black,
raspberry, and turquoise colored ooze. Many 01 these materials are quite
toxic.
What is emitted from the stack 01 an incinerator is a very, very small fraction
of what goes in. During incineration. organic contaminants are destroyed.
The result is ash, which contains non-combustible residues. The ash was to
have been buried on-site. This ash would have been stabilized, it it had been
determined that metals could have been solubilized out 01 the ash at above a
threshold concentration.
The toxicity 01 the by-products 01 incineration (the ash and the stack
emissions) would be minuscule in comparison to the toxicity of the feed
materials.
COMMENT
The excavation could pose a hazard to school children.
RESPONSE
The risks during excavation could have been effectively managed through
engineering controls, such as the construction 01 a temporary building over
the open excavation, with provision 10r treatment 01 any emissions.
COMMENT
What happens i1 you hit something that might explode during the
excavation?
RESPONSE
The lagoon will not be excavated, under the selected remedy. However, any
excavation which will occur on the site will be performed under the
supervision 01 the Army Corps 01 Engineers, who will provide ordnance
expertise. A contingency plan 10r emergency responders will be
incorporated as part 01 the design.
COMMENT
The site is not much 01 a hazard to the residents at present, according to the
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Endangerment Assessment. It should be left in place. This highest priority
should be the health and safety of the current residents of this community.
RESPONSE
The health and safety of current residents, and the level of present hazards,
are extremely important considerations. But the short term effectiveness of
the remedy is not the only valid concern. This site contains contaminants
which will still be a problem for our great grandchildren. We have to be
concerned about the long-term effects of our actions and not only about our
current level of comfort.
COMMENT
There are differences in the remedies, but not enough to justify incineration.
RESPONSE
In selecting a containment remedy, U.S. EPA has concurred with this
comment.
COMMENT
Who is going to be doing this work? We have several contractors that we
don't trust.
, RESPONSE
All contractors will be carefully screened by U.S. EPA and Ohio EPA. No
remedial action contractors have been selected. This will be done after
complet!0n of the Remedial Design.
COMMENT
An early draft of the risk assessment for excavation should be released to
the public.
RESPONSE
Normally, only final documents which are deemed to be accurate
representations of the situation are released to the public.
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COMMENT
Ohio imports hazardous waste. Waste from Ohio should have priority at in-
state hazardous waste facilities.
RESPONSE
Unfortunately, the U.S. EPA would have to obtain off-site incineration
capacity on the open market, just like a private company. U.S. EPA cannot
force in-state facilities to accept this waste in preference to out-of-state
wastes.
COMMENT.
The incinerator should have at least two scrubbing devices.
RESPONSE
There would probably have been at least two types of emission control
devices on the incinerator.
COMMENT
If we incinerate, we will have airborne particles in the air. Where is this
stuff going to go?
RESPONSE
Please refer to the draft risk assessment for incineration, which is contained
in the Administrative Record. Airborne particles resulting from incineration
do not present a significant risk.
COMMENT
There aren't enough inspectors.
RESPONSE
Those who oversee the remedial action at this site will be assigned
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specifically to this project. U.S. EPA anticipates no shortage in personnel for
oversight of this project.
COMMENT
The kids at the Union School should be moved.
RESPONSE
Current information indicates that this action is not necessary. The
remediation will be monitored carefully, to assure that the school children
are not impacted.
COMMENT
Short-term heavy doses from an accidental fire or explosions should be the
concern, more so than long-term impacts. Option 3 should be selected.
RESPONSE
Alternative 3 was selected.
COMMENT
When will city water be provided?
RESPONSE
During April and May, 1993.
COMMENT
All of the decisions are made beforehand. You don't listen to us. The
purpose of a public meeting is merely to make us feel like you are listening
to us. We don't trust you.
RESPONSE
The actions of the U.S. EPA subsequent to these public meetings should
nullify this concern. We have gone to extraordinary lengths to respond to
,
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community concerns relating to this site.
COMMENT
If you incinerate the lagoon waste, it's going to be better because you're
going to be removing a major source of the problem: and instead of your
childrens' children having to worry about some ground water getting out of
the landfill. Incineration is the best alternative.
RESPONSE
This is the major justification for incineration.
COMMENT
Please give us more opportunity to comment.
RESPONSE
The decision for this site was delayed for nearly ten months so that
community concerns could be addressed. U.S. EPA feels that this was a
constructive, open, and successful process.
COMMENT
The potential dangers to those who respond to potential emergencies at the
site need to be considered and evaluated.
RESPONSE
-
A contingency plan will be developed as part of the remedial design. The
pertinent local responders will be included in the planning process.
COMMENT
Action should be taken quickly at this site. No matter how much study is
done, they won't have all the answers at this site. The contaminants could
move into the groundwater while we are trying to get ironclad answers to all
of the questions. There are some people here who will not trust EP A in any
case. There is no way to guarantee to the people in this room that there is
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100 percent safety. The waste' ought to be gotten out of there for the good
of the community.
RESPONSE
The U.S. EPA agrees with this rationale. We believe that the selected
remedy will satisfy this concern. The individual who made this comment
became a member of the West Chester Coalition for the Skinner -Landfill
Cleanup, and took part in a lengthy, constructive dialogue which resulted in
a consensus that a containment remedy would be recommended for this
site.
WRITTEN COMMENTS ON THE PROPOSED PLAN
COMMENT
One commenter from the vicinity of the WTI incinerator in East Liverpool,
Ohio wrote to express opposition to off-site incineration of Skinner Landfill
wastes at the WTI incinerator.
RESPONSE
Off-site incineration has not been an option at this site. Incineration of the
Skinner wastes at the WTI incinerator was never considered.
COMMENT
I believe- it is an absolute requirement to proceed with alternative 5. With
the current growth of the area and the future potential, we must take all
available precautions to protect the people, especially the children who will
prosper here. The price is cheap when compared to the consequences.
RESPONSE
This is a valid position. Unfortunately, there are no clear-cut right and
wrong answers on this site. It would be possible for a hazardous waste
professional to evaluate the information at this site and to arrive at a
preference for incineration. It would be equally possible for this person to
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arrive at a preference for containment.
In selecting containment, U.S. EPA is expressing the opinion that
containment is very likely to work. If it is found not to work in the future,
we will take appropriate action.
COMMENT
We moved to West Chester in 1978 and have watched the population grow
from 10,000 to 40,000. This, in itself, has placed tremendous pressure on
water conservation. Despite the new construction of at least three nearby
county water tanks, we have been under restricted water use for about five
ye.ars.
Any option that allows for the future possibility of contamination getting into
the ground water is very short term thinking. Even at added cost, this
leaching must be minimized.
RESPONSE
The selected remedy is designed to protect the groundwater, through
capping, collection and treatment of contaminated groundwater, and control
of groundwater flow. In addition, extensive monitoring will be performed to
assure that contaminants are not escaping from the site.
COMMENT
One commenter supported alternative #3, and asked what action will be
taken against the Skinners and the other PRPs.
RESPONSE
Alternative 3 was selected, as modified with the addition of soil vapor
extraction. The Skinners and a list of 20 PRPs have been notified of their
liability. The PRPs have formed a coalition to respond to the EP A on this
site, and have agreed to perform the Operable Unit 1, Interim Action
remedy.
COMMENT
Do whatever it takes to eliminate this terrible Skinner Landfill.
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RESPONSE
Action is to be taken per the requirements of this Record of Decision.
COMMENT
I do not agree with CLEAN, which wants to permanently leave dangerous
substances in the ground at this site and hope that they can't migrate in the
future. I support incineration and/or permanent removal of wastes.
RESPONSE
This is a valid position. Unfortunately, there are no clear-cut right and
wrong answers on this site. It would be possible for a hazardous waste
professional to evaluate the information at this site and to arrive at a
preference for incineration. It would be equally possible for this person to
arrive at a preference for containment.
In selecting containment, U.S. EPA is expressing the opinion that
containment is very likely to work. If it is found not to work in the future,
we will take appropriate action.
COMMENT
One commenter asked that U.S. EPA list out the Applicable or Relevant and
Appropriate Requirements that will be met by the selected remedy.
RESPONSE
The ARARs for the selected remedy are included as an attachment to the
Record Of Decision.
COMMENT
I support Alternative 3, because it does not involve major excavation or
incineration, due to the potential for exposure to children.
RESPONSE
Alternative 3 was selected, as modified with the addition of soil vapor
extraction.
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COMMENT
The dump isn't hurting anyone now. Use the money to educate our children
or to help the hungry and homeless.
RESPONSE
This is not feasible. The Superfund monies are designated by Congress
specifically for the cleanup of waste sites. Action must be taken at this site
to address potential future migration of contaminants away from the site.
Given what is known about the site and the contaminants which are
present, the selected remedy is a necessary and appropriate action.
COMMENT
Any school or classroom should not be located anywhere near a Superfund
cleanup site, regardless 01 the method 01 cleanup chosen. The school
should be moved. I am opposed to incineration. A comprehensive health
study of the area needs to be done.
RESPONSE
A health assessment was conducted by the Ohio Department of Health, and
a draft of this document was released to the public for review on February
8, 1993.
Current information does not indicate that the School needs to be moved.
The remediation will be monitored carefully, to assure that the school
children are not impacted.
COMMENT
The Skinner landfill should have been regulated better in the first place. EPA
should contain the waste somewhere off-site until commercial incinerator
capacity is available. The w2000-foot rulew should be followed.
RESPONSE
Ohio EPA and the Ohio Attorney General, and local citizens of West Chester,
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have tried a number of times over the last 20 years to get this site cleaned
up through legal proceedings. These were eventually successful in having
the dump shut down.
Off-site storage of the wastes was not considered as a viable alternative.
This would necessarily involve excavating the waste materials twice. Siting
of the waste storage area would undoubtedly prove to be difficult. All of
the trucks would have to be loaded and unloaded twice. All of these factors
conspire to make this an unappealing alternative.
COMMENT
I a.!TI opposed to incineration. Incineration is burning 10% of the lagoon
wastes and leaving the other 90%. I am concerned about lead dust. No
real thought went into the incineration risk assessment.
RESPONSE
U.S. EPA spent a considerable amount of time trying to determine the
derivation of this number. It appears that the problem is as follows:
The Remedial Investigation estimated that the total volume of lagoon wastes
is 107,000 cubic yards (cy). The volume proposed to be incinerated was
17,000 cy. This is because it was decided that only those materials which
pose a risk above 10-4 would be incinerated. This means that only the most
concentrated materials (the ooze) would be dug up and incinerated. While
the materials to be incinerated would be only a portion of the total volume of
lagoon wastes, it would contain the greatest amount of the hazardous
substances.
u.S. EPA devoted a considerable amount of time and resources to the
evaluation of the prospective risks posed by the incinerator. Unfortunately,
disruptive participants at the July 29th public meeting did not allow U.S.
EP A to completely explain the incinerator risk assessment.
The draft incinerator risk assessment indicates that projected lead dust
emission levels would not have caused health concerns.
COMMENT
One resident wrote expressing concern about the quality of her well water.
The analysis of samples taken July 7, 1992 had been ruined by the
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laboratory. She wants resident's to be hooked up to the public water supply.
She was upset that CLEAN had been allowed to bring in a speaker who was
allowed to speak before the general public had a chance to ask their
questions.
RESPONSE
This resident's well water was resampled and no contaminants w~re
detected. The hook-up of residents (including this individual's house) within
the potentially affected area to the County water supply, per the Interim
Action Record of Decision, will occur during April and May, 1993.
COMMENT
Please reconsider the choice of incineration. I am concerned about Dioxins
and Furans. I recommended that EP A: 1) identify all contents of the dump;
2) fence and patrol the dump area, and 3) delay all other action until you
have done this.
RESPONSE
Extensive testing of the materials within the buried waste lagoon was
performed during the Remedial Investigation. U.S. EPA conducted numerous
test borings and excavated trenches to characterize the wastes.
Additionally, sampling of water from below the dump was performed.
Enough information has been collected on the site to make a remedy
decision.
Fencing of the former dump is part of the Interim Action Record of Decision.
The fence has been installed. No on-site security will be provided, however.
The decJsion for this site was delayed for nearly ten months so that
community concerns could be addressed. U.S. EPA feels that this was a
constructive, open, and successful process.
COMMENT
I oppose incineration. I am concerned about malfunctions or accidents.
Please consider an alternative other than the five which were presented.
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RESPONSE
The design of a hazardous waste incinerator such as the one which was
proposed for this site includes waste feed cut-offs and air pollution control
devices which are designed to protect the community from the potential for
malfunctions or accidents. In any case, incineration was not selected.
The U.S. EPA went to considerable effort in an attempt to develop an
alternative to the basic options which were considered: incineration and
containment. Unfortunately, the heterogeneous nature of the lagoon wastes
at this site render any alternative treatment technologies inapplicable at this
site. The only viable remedies for this site are incineration and containment.
COMMENT
I support incineration. Incineration is the best long-term solution to the
problem. EPA has an obligation to pursue a remediation plan that is best for
the environment even if it isn't the most popular plan. Destroying the toxics
makes more sense than just covering them with a cap.
RESPONSE
U.S. EPA has chosen not to incinerate the lagoon waste materials at this
site. Part of the reason for this is because incineration of the lagoon waste
materials would only address a portion of the contaminated materials on the
site. The most highly contaminated groundwater at the site was detected
during Phase 1 of the Remedial Investigation upgradient of the lagoon.
Incineration would not have addressed the source of these contaminants.
COMMENT
The Skinner dump should be left alone. It is not hurting anyone. Digging it
up will just make it worse.
RESPONSE
The Skinner dump may not be hurting anyone now, but potential future
migration of contaminants is a concern. Therefore the selected remedy is a
necessary action.
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COMMENT
More investigation of munitions and radioactive waste should be performed.
The incinerator could cause the withholding of Federal highway funds. Has
EPA considered the impact the scrubber waters would have on the local
sewage treatment plant? EPA has not presented enough information to
justify the waiver of the 82000-foot rule8. Has EPA considered in.gestion in
its risk assessment?
Incineration is unacceptable.
RESPONSE
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See general response regarding ordnance, above.
There is no indication that radioactive materials were brought to this site.
During the drilling of the wells and test borings, radioactivity was monitored
as a safety precaution. No readings above background were detected. The
Ohio EPA walked over the site with a geiger counter, and did not detect
anything.
The disposition of scrubber waters could have been addressed in a number
of ways, including on-site treatment or transportation to the local sewage
treatment plant. As it is now, there will be no incinerator, and therefore no
scrubber.
See general response regarding 82000-foot rule8 above.
Yes, ingestion was evaluated in the Baseline Risk Assessment.
COMMENT
Although Ohio Law prohibits siting a commercial hazardous waste
incinerator within 2000 feet of homes and schools, U.S. EPA stated that
they can ignore this law and do as they please.
RESPONSE
This comment misstates both the prohibition contained in the 82000-foot
rule8 and the U.S. EPA's intent regarding the proposed waiver of this law.
Please see 82000-foot rule8 discussion above.
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COMMENT
Incineration expert Dr. Paul Connett showed us that EPA had mislead us as
to the toxicity of dioxin to humans.
RESPONSE
The U.S. EPA has not misled the public as to the toxicity of dioxins to
humans; it has released the most up-to-date information as it is developed.
The scientific community very rarely is in uniform agreement on any subject.
Paul Connett used this tendency, along with the fact that the state of
knowledge is advancing, to claim that the U.S. EPA is misleading the public.
This is unfair and incorrect.
COMMENT
There has been no assessment made of the current health of the
community. .
RESPONSE
This assessment has been performed by the Ohio Department of Public
Health. A draft of this Public Health Assessment was released for public
comment on February 8, 1993. U.S. EPA's role is to assess the potential
impacts which would result if the site were not cleaned up, and to develop
appropriate cleanup methods based upon this evaluation.
COMMENT
EPA has not characterized the waste at Skinner as .hazardous.. This
characterization must be made if we are to have the protection afforded by
the ResCSurce Conservation and Recovery Act (RCRA), which has stringent
requirements about what must and what must not be done in dealing with
the contamination. Usa Whitacre and many other residents demanded to
know why the designation has not been made, and EPA repeatedly refused
to answer the question. .
It appears that EP A does not want to designate the waste as hazardous
because they intend to incinerate the waste and then return the undestroyed
heavy metals and incinerator ash to the landfill, which would not be
consistent with the RCRA requirements.
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RESPONSE
The U.S. EPA responded to this question at the July 29th meeting, and at a
meeting with the Skinner Landfill Coalition. U.S. EPA indicated that the
lagoon wastes will be treated as RCRA Hazardous wastes, and that the
RCRA requirements are relevant and appropriate to incineration at this site.
Incineration would have been conducted in compliance with the stringent
RCRA incinerator standards, as U.S. EPA stated at the July 29th meeting.
Please refer to the 8RCRA Hazardous Waste8 discussion above.
COMMENT.
EPA intends to incinerate just 10% of the waste on site.
RESPONSE
U.S. EPA spent a considerable amount of time trying to determine how this
number was derived. It appears that the problem is as follows:
The Remedial Investigation estimated that the total volume of lagoon wastes
is 107,000 cubic yards (cy). The volume proposed to be incinerated was
17,000 cy. This is because it was decided that only those materials which
pose a risk above 1 O~ would be incinerated. This means that only the most
concentrated materials (the ooze) would be dug up and incinerated. While
the materials to be incinerated would be only a portion of the total volume of
lagoon wastes, it would contain the greatest amount of the hazardous
substances.
It is true, however that incineration would address only a portion of the site
wastes. This, among other factors, has led to the selection of the
containment remedy set forth in this Record of Decision.
COMMENT
We are afraid that EPA will decide to incinerate the whole site, after the
incinerator is built.
RESPONSE
This was never EPA's intention. In addition, incineration was not selected
as a remedy at this site.
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COMMENT
There has been no assessment of the risks in the event that the hazardous
waste incinerator at Skinner does not work perfectly.
RESPONSE
An assessment of the risks in the event of incinerator failure was -not
completed since incineration was not selected as a remedy.
COMMENT
We want you to go back and come up with some other alternative.
RESPONSE
In the course of the meetings with the Skinner Landfill Coalition, the U.S.
EP A presented an evaluation of alternative treatment technologies which
may be applicable to the Skinner Landfill lagoon wastes. The conclusion
was that there are really only two options for this site: incineration and
containment. There are no other viable technologies for destruction of the
lagoon wastes.
COMMENT
One commenter expressed embarrassment at the behavior of .a certain
specific group. at the July 29, 1992 pUblic meeting, and stated that some
people who came to receive information were unable to obtain that
information because of the rudeness of others. He expressed support for
what was to become the Skinner Landfill Coalition, and for the attainment of
a resolution that is acceptable to all.
Response
The U.S. EPA worked extensively with the Skinner Landfill Coalition, and
believes that the selected remedy is acceptable to a broad section of the
community .
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COMMENT
Once this incinerator begins operating, it will become a permanent facility.
RESPONSE
This would not have happened. Mobile incinerators such as the one which
was proposed for this site are not permitted for permanent use. In addition,
incineration was not selected as a remedy.
COMMENT
In addition to those comments responded to individually above, 13
commenters wrote brief comments which expressed opposition to on-site
incineration. Many of these comments cited the proximity of the Union
Elementary School and the 82000-foot rule8 as part of the reason for their
opposition.
RESPONSE
The U.S. EPA continues to believe that incineration is a viable technology
which could be applied safely at the Skinner site. Incineration has been
successfully implemented at a number of sites nationwide. However, U.S.
EP A has taken the public opposition to incineration at the Skinner site into
consideration, along with other factors, in its selection of a remedy which
does not include incineration.
COMMENT
-
A petition in opposition to incineration, containing 48 signatures, was
submitted.
RESPONSE
The EPA has taken the opposition to incineration into account, along with
other factors, in its decision not to pursue incineration at this site.
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COMMENT
The City of Mason encourages U.S. EPA to comply with all ARARs. Please
be thorough in your research and evaluate the outcomes of all the
alternatives before selecting one.
RESPONSE
All ARARs are to be complied with in this selected remedy. U.S. EPA
believes that it has been diligent in pursuing and evaluating the outcomes of
all alternatives.
COMMENT
The OSU Student Environmental Action Coalition expressed the following
concerns:
1) Incineration would violate the .2000 foot rule.;
2) The Ohio Department of Health is performing a study determining
the effects that incineration will have on the public. The results of
this should be included in the Feasibility Study; and
3) An in-depth munitions study should be completed and included in
the FS.
RESPONSE
See the general responses regarding the .2000-foot rule. and the ordnance
concerns. The study performed by the Ohio Department of Health has been
completed and was released for public comment on February 8, 1993. The
conclusions of this report do not change the Feasibility Study or the remedy.
.
COMMENTS OF UNION TOWNSHIP
COMMENT
U.S. EPA should provide answers to the questions which were raised in the
May 20, 1992 meeting in the form of a supplemental report to be
disseminated to the public, and then hold another community meeting.
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RESPONSE
A second public meeting was held on July 29, 1992 to address the
concerns raised in the May 20, 1992 meeting.
COMMENT
The Proposed Plan contained a detailed analysis only of Alternative 5. A
detailed analysis of the other alternatives should be made available to the
public.
RESPON~E
A detailed analysis of each alternative was presented to the public as part of
the Feasibility Study.
COMMENT
The U.S. EPA should publish a gantt chart of the project schedule.
RESPONSE
A schedule will be developed as part of the design.
COMMENT
U.S. EPA and the Agency for Toxic Substances and Disease Registry
(ATSDR) should work together. U.S. EPA should delay its decision until the
A TSDR has completed its health assessment.
RESPONSE
The A TSDR health assessment, performed by the Ohio Department of
Health, was released to the public in draft form on February 8, 1993. The
conclusions of this study recommend actions which are consistent with
those to be taken in the Operable Unit 1 and Operable Unit 2 Records of
Decision f(lr this site.
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COMMENT
Regulations should be followed without waiver.
RESPONSE
See general response regarding "2000-foot rule", above.
COMMENT
What will be required form the local government regarding safety, security,
and emergency services? Which of these services will be provided by
USEP A? What is expected of the local fire and EMS? Will the clean-up
contractor have a response team on site? If our personnel are exposed, who
will pay for blood work-ups and long term monitoring, if necessary? If
material is removed from the site, who will handle a leak or spill off-site?
How will notification proceed in the case of an incident? If a cave-in occurs
on-site, who will perform personnel extrication? Who will provide protective
equipment and training for local authorities who require access to the site?
RESPONSE
As part of the remedial planning for this site. the U.S. EPA will develop, in
coordination with the pertinent local government entities, a detailed
emergency planning and contingency plan which will outline the duties,
responsibilities. contingencies, and planned responses relating to emergency
situations. The above mentioned issues will be addressed as part of this
emergency planning and contingency plan.
COMMENT
What has been done to investigate the possible presence of ordnance'1
Whilt contingencies exist to deal with ordnance if it exists?
RESPONSE
See general response regarding ordnance, above.
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COMMENT
Will U.S. EPA meet at some point with local officials to discuss these
concerns and to develop training routines and contingency and response
plans that address these issues?
RESPONSE
Yes. Development of safety and contingency plans will be conducted in
cooperation with local officials.
COMMENT
The site should be fenced and posted.
RESPONSE
The site has been fenced and posted as part of the Interim Action operable
unit.
COMMENT
Alternate water supply should be provided to those in proximity to the site
RESPONSE
This has been performed as part of the Interim Action operable unit.
PRP COMMENTS ON THE PROPOSED PLAN
A coalition of Potentially Responsible Parties submitted lengthy combined
technicaillegal comments on September 21, 1992. These are addressed
below. .
COMMENT
Incineration is no more permanent than containment.
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RESPONSE
This is incorrect. Incineration would provide for permanent destruction of
organic lagoon waste materials. Containment provides only for a reduction
in the potential for migration of these materials. Therefore incineration
provides for a more permanent solution than containment.
COMMENT
On-site incineration can not meet the location-specific ARAR of the State of
Ohio's hazardous waste facility siting requirements. Section
3734.05(D)(6)(g»)i) of the Ohio Solid and Hazardous Waste Disposal Law
states that" (t)he [hazardous waste facility] board shall not approve an
application for a hazardous waste facility installation and operation permit
unless it finds and determines the : .. the active areas within the new
hazardous waste facility ... are not located or operated within ... (t)wo
thousand feet of any residence, school, hospital, jail or prison".
RESPONSE
The PRP Group has omitted significant portions of the pertinent regulation.
The full pertinent portion of the regulation states:
(6) The board shall not approve an application for a hazardous waste facility
installation and operation permit unless it finds and determines as follows:
(g) That the active areas '*Yithin a new hazardous waste facility
where acute hazardous waste as listed in 40 C.F. R. 261.33
(e), as amended, or organic waste that is toxic and is listed
under 40 C.F.R. 261, as emended, is being stored, treated, or
disposed of and where the aggregate of the storage design
capacity and the disposal design capacity of all hazardous
waste in those areas is greater than two hundred and fifty
thousand gallons, are not located or operated within any of the
following: .
(i) Two thousand feet of any residence, school, hospital, jail, or
prison;
(ii) any naturally occurring wetland;
(iii) Any flood hazard area if the applicant cannot show that the
facility will be designated, constructed, operated, and
maintained to prevent washout by a one hundred-year flood or
that procedures will be in effect to remove the waste before
flood waters can reach it.
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Division (DJ(6J(gJ of this section does not apply to the facility of
any applicant who demonstrates to the board that the
limitations specified in that division are not necessary because
of the nature or volume of the waste and the manner of
management applied, the facility will impose no substantial
danger to the health and safety of persons occupying the
structures listed in division (DJ(6J(gJ(iJ 01 this section, and the
facility is to be located or operated in an area where the
proposed hazardous waste activities will not be incompatible
with existing land uses in the area.
The second paragraph above provides for the opportunity to demonstrate
that the facility will pose no substantial danger to the health and safety of
persons occupying those structures.
See the w2000-foot rulew discussion, above.
COMMENT
The magnitude of the short-term risks involved in incineration were not fully
addressed. .
RESPONSE
A draft assessment of the risks associated with incineration has been
written, and has been placed in the Administrative Record. This risk
assessment has not been finalized, due to U.S. EPA's shift in preference
from incineration to containment.
COMMENT
Cost-effectiveness should have been considered in selection of a preferred
alternative. If U.S. EPA's containment alternatives did not sufficiently meet
the objective of treating on-site soils, a less costly alternative that combined
containment with limited treatment of impacted soils should have been
developed as part of the Feasibility Study.
RESPONSE
Cost-effectiveness is considered as part of the remedy selection process.
However, the U.S. EPA must give highest priority to the effectiveness of the
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remedy, before considering the trade-ofts in terms of cost.
The U.S. EPA has performed a detailed screening of remedial alternatives
~ for this site, once during the performance of the Feasibility Study, and
again during the Public comment period, for the benefit of the Skinner
Landfill Coalition. Both screenings brought U.S. EPA to the same
conclusion: we can either contain the lagoon wastes, or incinerate them.
There are no other viable technologies for clean-up of the lagoon wastes at
this site.
COMMENT
In addition to organic and inorganic chemicals, nerve gas, mustard gas,
incendiary bombs, phosphorus, flame throwers, cyanide ash, and explosive
gases were reportedly buried at the site, and there may be methane gas and
biohazards (i.e., pathogenic microbial agents) present at the landfill.
RESPONSE
See general discussion of ordnance issues, above.
While methane gas is likely to be present at the site, this possibility was
discussed and evaluated in the RifFS, and a gas collection system is included
in the cap specifications. There has been no indication of the presence of
pathogenic microbial agents at this site, and there is no reason to believe
that such agents would be alive at present, after over 15 years of burial.
The PRPs raised this concern with no supporting documentation.
COMMENT
The proposed plan does not fully address the impacts associated with
excavation of the buried waste lagoon.
RESPONSE
The Feasibility Study includes an evaluation of the public health risks
associated with the excavation of the buried waste lagoon. This evaluation
was performed assuming that no engineering controls would be used to limit
the potential releases. In reality, however, it would be possible to control
emissions during excavation by constructing a building over the open
excavation, and treating the emissions. This is a viable technology which
has been performed at a number of other sites nationwide.
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COMMENT
An appropriate remedy (which combines features of sev"ral U.S. EPA
alternatives) would consist of the following elements: 1) a cap over the
buried lagoon and active landfill areas; 2) soil vapor extraction in the soils
beneath the buried lagoon, if feasible; 3) groundwater collection and
treatment at the downgradient side of the potential source areas, if
necessary; and 4) institutional controls (fencing, deed restrictions~ and
extension of public water supply).
RESPONSE
What the PRPs have proposed is very similar to alternative 3, with the
addition of several qualifications and soil vapor extraction. The selected
remedy includes some aspects of the PRPs' proposal. Alternative 3 was
selected, with the inclusion of Soil Vapor Extraction.
COMMENT
The groundwater data for the site simply do not show the presence of
contamination attributable to the buried lagoon material or the landfill area.
No consistent contamination was found in the groundwater.
RESPONSE
The U.S. EPA strongly disagrees. The pattern of contamination that has
been observed at the Skinner site is consistent with U.S. EPA's knowledge
of the site history. Historical evidence indicates that chemical wastes were
stored or disposed of in a haphazard manner at the site, and that many,
many different chemicals were disposed of at the site. Therefore it is not
surprising that different contaminants are being detected from one
monitorfng well to the next.
The fact that there were a wide variety of contaminants detected in
monitoring wells at the site indicates that the site, i.e. the former dump and
the buried lagoon area, is causing groundwater contamination. The fact that
many of the contaminants which were found in the lagoon wastes were also
found in the groundwater also strongly indicates that the contaminants in
the groundwater originate within the site wastes.
The buried lagoon and the former dump contain a wide variety of potentially
mobile chemical contaminants. Groundwater contaminated with a number
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of these same chemical constituents was found downgradient of the lagoon,
and underneath the former dump. There are no other sources of
groundwater contamination in the site vicinity. The upgradient groundwater
wells were uncontaminated. Therefore, these groundwater contaminants
must originate from the site.
COMMENT
Given the setting of the buried lagoon materials at the site (above the water
table and below 20 feet of demolition debris), this lack of mobility means
that there is no mechanism for exposing individuals or organisms to these
materials, and the lack of exposure means that there is no risk to human
health and the environment.
RESPONSE
The U.S. EPA disagrees. Site related contaminants have migrated into the
groundwater, and are presently being discharged at low concentrations into
the East Fork of Mill Creek. This constitutes a mechanism for exposure of
these materials to humans and the environment. Given the demonstrated
migration of these materials into the groundwater and streams, there is a
potential for future exposure to humans and the environment.
COMMENT
Analytical data for groundwater samples also show that even the more
volatile organic compounds (VOCs) are not migrating away from the buried
lagoon.
RESPONSE
On the contrary, numerous volatile organic compounds were found in the
monitoring wells. These contaminants must have migrated. Otherwise,
their presence could not have been detected in the downgradient monitoring
wells.
COMMENT
During the drilling of the waste lagoon borings, materials may have been
carried down along with the augers, causing the samples taken from below
the waste lagoon to be contaminated.
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RESPONSE
The samples were taken using a split-spoon sampler. Before the auger is
advanced in the soil, a split-spoon sample is collected. Consequently, the
split-spoon obtains a soil sample which has not been disturbed by the auger.
Collecting soil samples in this manner ensures that the augering process
does not contaminate the soil samples.
COMMENT
Soil Vapor measurements were made using three different instruments.
RESPONSE
While it is true that the various types of field soil vapor testing instruments
are sensitive to different types of contaminants, each will give a general
indication of the level of organic contamination which is present. These
instruments were not intended to perform the same function as the
laboratory analysis which was performed on over 400 samples from this
site. They are intended as field screening tools, and provide information
which is useful in the overall characterization of the site.
The PRPs have proposed to use either of two different instruments for
analyzing vapors during the interim action at this site.
COMMENT
A sample from location SS-07, which contained 980 ppm of PCBs, should
not have been included in the evaluation of direct contact risk, because it
appears to have been buried since the sample was taken.
RESPONSE
The risks associated with the site still warrant a remedial action regardless
of whether or not sample location SS-07 is included in the risk assessment.
COMMENT
The residdntial exposure scenario for direct contact with surface soils is
improper methodology, and is incorrect for this site.
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RESPONSE
The residential exposure scenario results in the highest risk numbers. In this
case, the baseline risk assessment assumed that no action was taken on the
site, and that the site was used for residential purposes in the future. This
evaluation js performed in order to determine what could happen in the
future if the site were uncontrolled. This is a standard procedure which has
been performed at many Superfund sites, and is considered a proper
methodology.
COMMENT
The PRPs referred to an internal EPA Memorandum dated February 26, 1992
regarding assessment of risks.
RESPONSE
The Baseline Risk Assessment was finalized in 1990. This memo applies to
risk assessment performed after the date of the memo.
COMMENT
If there are up to 7000 drums in the lagoon area, at least one of the waste
borings drilled through this part of the lagoon should have encountered
drums.
RESPONSE
A geophysical survey of the lagoon area was conducted prior to the
installati'on of the lagoon borings. This information was utilized in the
selection of waste lagoon boring locations. Boring location were chosen so
as not to encounter buried drums.
COMMENT
The waste materials within the waste lagoon are not accessible.
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RESPONSE
The materials in the waste lagoon are definitely accessible. This was
demonstrated in 1976 when the U.S. Army and the Ohio EPA used a
backhoe to dig a trench into the waste lagoon materials.
COMMENT
The waste lagoon does not constitute a principle threat. The wastes are not
highly mobile because they have not moved significantly in the last 1 5
years.
RESPONSE
The wastes in the lagoon are highly toxic and have the potential for high
mobility. Past behavior of the contaminants can give us some indication as
to the likelihood of future migration. However, there is always an element
of uncertainty in making such predictions. The presence of a considerable
volume of highly toxic materials which have the potential for high mobility
continues to constitute a principal threat.
COMMENT
Incineration will not meet the objective of reducing contaminant mobility,
toxicity, and volume, because incineration would actually increase the
volume of waste materials due to the need for stabilization.
RESPONSE
The criterion (one of the nine criteria which are used for evaluating
alternatives) is actually Reduction of Toxicity, Mobility m: Volume. While it
is possible that the volume of materials would be increased, incineration
would achieve significant reductions in toxicity and mobility of
contaminants, thereby satisfying this criterion.
COMMENT
The incineration alternatives involve landfilling of the residual ash which
means that re-evaluation of the site will still be required every five years.
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RESPONSE
Under any of the alternatives, hazardous substances will remain on site, and
a re-evaluation of the remedy's protectiveness will be required by law at
least every five years.
COMMENT
Risks from the excavation of the waste lagoon could proceed through a
number of pathways other than through volatilization.
RESPONSE.
Excavation of lagoon wastes is not part of the selected remedy for the site,
but was a component of alternatives 2 and 5. All of these pathways could
be addressed through engineered controls, such as constructing a building
over the excavation area, and treating the emissions.
COMMENT
Excavation of the waste lagoon could take longer then projected due to
unexpected conditions.
RESPONSE
This is true.
COMMENT
U.s. EP~ has assumed that the bulk of the excavation work will be
performed with minimal health and safety protection using conventional
excavation techniques. However, due to the diverse and heterogeneous
nature of the waste, this assumption could be unrealistic.
RESPONSE
These assumptions were part of a .conservative. assessment of risks. If a
conservative assessment of risks shows that there is a risk to workers, then
the workers will wear protective equipment. The U.S. EPA would not
suggest that the lagoon be excavated by workers without the proper level of
personal protection.
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COMMENT
The RifFS did not provide the data needed to identify the most appropriate
incineration technology, if any, and its associated operational constraints.
These include the anticipated ash characteristics, cohesiveness, stickiness,
and liquid content.
RESPONSE
The purpose of a Feasibility Study is to determine the feasibilitv of cleaning
of the site using a range of technologies. The operational parameters are
determined during design.
COMMENT
On site incineration of hazardous waste sites has not gained wide
acceptance due to the inherent problems in siting, permitting, constructing,
and operating incineration systems.
RESPONSE
This is incorrect. Incineration of hazardous wastes has been applied
successfully at a number of Superfund sites.
COMMENT
Limiting incineration to the summer months would not be practical.
RESPONSE
This is probably true, when the cost of the project is taken into account.
COMMENT
There is a general shortage of off-site incinerator capacity. It would be
difficult to secure adequate off-site capacity of the Skinner wastes and to
schedule for the timely removal, transportation, and disposal of waste and
soil. In addition, off-site incineration is expensive.
1
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RESPONSE
U.S. EPA agrees.
COMMENT
The PRPs submitted a number of comments relating to the difficulty of
obtaining permits.
RESPONSE
Permits are not required for on-site work pertaining to the cleanup of a
Superfund site. Instead, the substantive requirements of the permit must be
met. This results in a substantial reduction in delays.
COMMENT
Stockpiling of soils prior to incineration could increase the risks.
RESPONSE
Stockpiling of wastes prior to incineration at Superfund sites is often
conducted inside a specially constructed containment building, which
provides for treatment of emissions. This would help to mitigate these risks.
COMMENT
Odorous substances can produce psychological responses which were not
consider:ed during the selection of the remedial alternatives.
RESPONSE
U.S. EPA agrees that odorous substances can produce psychological
responses. However, the potential for the production of odorous substances
is inherent in each of the remedial alternatives for this site; in each case,
U.S. EPA would have to address the potential impacts of implementing the
remedy on the local community.
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COMMENT
The PRPs provided a brief cost analysis of incineration, which projected a
cost of $88.5 million dollars, vs. the $29 million of EPA's cost estimate.
RESPONSE
The PRPs did not provide the documentation which would be nece-ssary in
order to evaluate their cost figures.
COMMENT
The PRPs stated that the remedy should be implemented using performance
standards.
RESPONSE
A performance-based remedy which identifies specific performance
standards has been delineated in this record of decision, as much as is
possible.
COMMENT
The PRPs oppose the blanket requirement for interception of groundwater
downgradient of the site, citing a lack of need for -multiple remedial
components that are redundant-. They suggested interception of
contaminated groundwater only -if contaminants are located in the
groundwater. .
RESPONSE
The selected remedy requires the interception, collection and treatment
contaminated groundwater downgradient of the site. There is not a blanket
requirement for collection of all groundwater downgradient of the site.
JUL Y 29, 1992 PUBUC MEETING
A second public meeting regarding the proposed plan was held on July 29, 1992.
A number of comments and issues were raised at this meeting, which lasted from
7:00pm to 1 :45am. During the course of the evening, many of the comments and
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issues which were raised by the public were answered. Additionally, many of the
concerns and questions raised at the July 29th Public Meeting are addressed
elsewhere in this responsiveness summary. However, due to the tempestuous
nature of this particular meeting, U.S. EPA did not have the opportunity to answer
a number of questions which were raised about the proposed incineration process.
These are addressed below.
COMMENT
The calculation of Destruction Removal Efficiency (DRE) is misleading
because it does not include Products of Incomplete Combustion (PICs) or
metals.
RESPONSE
While it is true that products of incomplete combustion (PICs) do not enter
into the calculation of the Destruction and Removal Efficiency (DRE) for an
incinerator, U.S. EPA disagrees with the statement that the DRE is
"misleading", because the PICs and metals are items which are measured
separately from the DRE.
U.S. EPA's hazardous waste incineration regulations define DRE as a net
waste-input mass rate versus stack-output mass rate comparison which U.S.
EPA and virtually all of the technical community feel best defines how well
certain toxic organics called "POHCs" (Principal Organic Hazardous
Constituents), in the feed material are destroyed and/or removed by the
incineration system.
Those toxic compounds or fractions thereof that are not destroyed, but are
removed and become part of the ash and/or residue streams exiting the
incinerator. These compounds must still be safely dealt with in some
manner,- such as stabilization.
Over the past 15 or 20 years during EP A's extensive involvement in the field
of incineration, the CRE parameter has served as a very useful measure of
how well incinerators perform, as well as being an equitable and reliable
regulatory enforcement tool.
Products of Incomplete Combustion (PICs) are complex organic compounds
which can be generated under certain unfavorable combustion conditions.
Should the types and amounts of PICs in the stack gas from a particular
incinerator be deemed of interest from a health risk or standpoint, a properly
designed sampling and analysis effort would be necessary to identify and
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quantify the PICs. PICs are typically of low-concentration, are usually
present as multiple and unusual compounds. Therefore, the work of
sampling and analyzing PICs becomes an expensive and time-consuming
endeavor that can exceed the cost of a DRE assessment.
Measurement of PICs is in fact frequently required and included during trial
burn operations when ORE and other performance parameters including
particulate and acid gas emission control are being determined. More often
than not, a complete incineration performance evaluation includes both DRE
and PIC analyses.
In addition. other measurement data from what are know as continuous
emission monitors or .CEMs. are also recorded. These parameters include:
ox.ygen, carbon monoxide, carbon dioxide, and total hydrocarbons, etc.
Such CEM data readings and records are made during a trial burn as well as
routinely thereafter during routine. day-to-day operation.
COMMENT
One comment was received alleging that the .EI Dorado. incinerator stack
emission .must be very toxic. based on the commenter's .speaking with
citizens. .
RESPONSE
By the .EI Dorado. incinerator. it is assumed that the commenter probably
refers to the large .ENSCO. commercial, PCB-permitted, stationary
incinerator located in EI Dorado, Arkansas. It is one of several PCB
treatment and disposal facilities in the Southwestern U.S. area under the
strict regulatory control and permitting responsibility of EPA's Region VI
office located in Dallas, Texas. While it is true that one segment of the
population in that area is, or at least was very concerned about the
environmental and health risk issues about that facility in earlier years, U.S.
EPA is not aware of any case where the concerns proved true or valid in the
ten or more years that the plant has been in operation.
COMMENT
If you mix polyethylene and PVC together and burn them in the laboratory.
they will use up all of the oxygen, and then products of incomplete
combustion (PICs) will result.
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RESPONSE
Burning in an incinerator such as the one which was proposed for the
Skinner site is very different from the laboratory experiment described by
this commenter. Incinerators are operated with an excess of oxygen, so
that the gases which are generated are able to burn. Incinerator operating
parameters are monitored to assure that the proper oxygen levels- are
maintained. Whatever gases do not burn in the primary combustion
chamber are passed on to the afterburner, where they are destroyed at high
temperature. The experiment described by the commenter included neither
an excess of oxygen nor an afterburner.
COMMENT
Before incinerating, you must have baseline health data. Otherwise, when
you are sick afterward, the EPA will tell you that your health effects are due
to the landfill, and not from the incinerator.
RESPONSE
Baseline health data has been gathered and published for this site by the
Ohio Department of Health. This was released to the public in draft form on
February 8, 1993.
COMMENT
The EP A has not gone out to gather the opinions of the people who live
around these incinerators.
RESPONSE
The U.S'. EPA has been conducting a study of the opinions and attitudes of
the people who live in the vicinity of several Illinois Superfund sites where
incineration has been completed, The studies are not yet complete, but the
public reactions were generally quite positive.
COMMENT
One commenter stated that .when the dump stack is open, metals can go
right out into the air.,
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RESPONSE
Many incinerator designs include an emergency vent opening, commonly
referred to as a "dump stack". Short-term, higher emissions of toxic metals
can occur during an emergency vent opening event because the vent
designs typically bypass the pollution control system (wet scrubber, etc.).
One vent design [the I.T. Corporation's design] exhausts from a point
beyond the" primary chamber, though that unit employs an extra b,:!rner at
the base of the vent stack.
It is U.S. EPA's goal to try to allow emergency vent operations only on a
very infrequent basis, e.g., once a month or less. Generally, the "events ..
as they are called, are quite short in duration (typically 15 to 30 minutes),
and hazardous waste feed is always stopped immediately (waste feed cut-
off). Using an emergency vent system to handle an unforseen major upset,
such as the failure of a scrubber cooling water pump, prevents incidents
such as fires or ruptures of the pollution control system.
U.s. EPA has begun to study and try to determine the emissions and health
risk issues surrounding the issue of emergency vent stacks by conducting
tests in pilot-scale incinerators. The pilot work thus far has indicated that
the net volume or mass increase in emissions is quite small.
COMMENT
Drum shredding operations can result in explosions.
RESPONSE
Drum shredding operations are typically run under an inert atmosphere, to
minimize the potential for fires and explosions.
COMMENT
Solidification is not dependable. There is a site in Warsaw, England, where
supposedly solidified materials had the consistency of pudding. Rocks
thrown out onto the solidified materials would slowly sink.
RESPONSE
Solidification of incinerator ash has been performed successfully at a large
number of sites nationwide, resulting in an inert mass.
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Stabilization at this site would. have been performed only after the
performance of pilot-scale tests, in which the formulation of the stabilization
materials would have been adjusted until a solid, stable result was obtained,
and it was demonstrated that the mobility of the remaining contaminants,
such as metals. was reduced to negligible levels.
Confirmation tests would have been performed on the materials which were
stabilized during the actual implementation of the remedy, to aS$ure that the
stabilization was minimizing the mobility of the various remaining metals.
COMMENT
Stabilization is ineffectual, because lime increases the solubility of lead.
RESPONSE
The solubility (and therefore the mobility), of lead compounds can be higher
at excessively high and excessively low pH levels (i.e. in acidic or basic
conditions). Lime can increase the pH of a solution. Therefore if
stabilization were performed with the addition of an extreme excess of lime,
the mobility of lead could potentially be increased. However, this concern is
easily addressed by stabilizing the materials at a relatively neutral pH. By
maintaining a relatively neutral pH, incinerator ash materials containing lead
can be, and have been, stabilized with great success.
COMMENT
The by-products of incineration are more toxic that what goes into the
incinerator.
RESPONSE
This is incorrect. At this site, the feed materials, or the materials which
would be burned in the incinerator, included a wide range of organic
contaminants, including materials described as black, raspberry, and
turquoise colored ooze. Many of these materials are quite toxic.
What is emitted from the stack of an incinerator is a very small fraction of
what goes in. During incineration, the majority of organic contaminants are
destroyed. The result is ash, which contains non-combustible residues.
These residues would have been stabilized, if it had been determined that
metals could have been solubilized out of the ash at a level above a
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threshold concentration.
The toxicity of the by-products of incineration (the ash and the stack
emissions) would be minuscule in comparison to the toxicity of the feed
materials.
COMMENT
EPA should evacuate the people who live around this site, and shut down
the school.
RESPONSE
Current information evaluated by U.S. EPA in the Baseline Risk Assessment
indicates that the Skinner Landfill presently poses no significant hazard to
the people who live around the site, or to the students in the school. This
conclusion has been borne out by the Draft Health Assessment produced by
the Ohio Department of Health. There is therefore no plan to evacuate the
local residents, or to shut down the school. U.S. EPA will monitor
conditions during the site cleanup to assure that the local residents and
school children aren't impacted.
COMMENT
EP A should put the materials in a concrete bunker, and wait until another
technology is available.
RESPONSE
The major portion of the hazards to the public which would be incurred
through remediation of this site, if Alternative 5 had been chosen, would
have resulted from the excavation of the buried waste lagoon. Particularly,
emissions of volatile organic compounds to the atmosphere would have
tended to increase.
In order to emplace the materials in a concrete bunker, it would be
necessary to excavate the lagoon waste materials. Then, if another
technology became available in the future, it would be necessary to
excavate and handle the materials a second time, thus doubling the resultant
emissions.
Additionally, U.S. EPA feels that it would not be responsible to set up a
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long-term storage facility at this site based upon the assumption that some
unknown remediation method would be found at an unspecified date in the
future. A viable technology for the remediation of the lagoon wastes
(incineration) is presently available.
For these reasons, the U.S. EPA does not feel that storage of the waste in a
bunker is a viable solution to the problems at this site.
COMMENT
What if a bomb goes off in the incinerator?
RESPONSE
Incineration and excavation are not components of the selected remedy.
However, a bomb would have been detected during excavation, and would
not have been fed into the incinerator. No object as large as a bomb would
be placed into a hazardous waste incinerator such as was proposed for this
site. Before being fed into the incinerator, materials are first treated or
broken up until they meet a specified particle size. Materials to be fed into
the incinerator which was proposed for this site would have first been
broken up to a size of less than 1 inch.
COMMENT
The Risk Assessment should evaluate the exposure of people to Dioxins
through the milk from dairy cows.
RESPONSE
This concern is inapplicable to the situation in West Chester, due to the lack
of dairy 'herds in the site vicinity.
COMMENT
There is no allowance for upsets in the design of the incinerator.
RESPONSE
Incineration was not chosen. However, any incineration system which
meets U.S. EPA's requirements incorporates quite an elaborate level of
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operational monitoring systems: These systems sense upsets and facilitate
taking quick, corrective actions by sensing that some pC!rameter is changing
and approaching the end of its prescribed range or limit. Most times, the
operators are alerted and can correct typical deviations from the norm.
An equipment redundance design philosophy, which is part of any well-
designed incinerator, often helps to avoid major upsets or shutdowns by
having standby equipment in the event of failure of equipment su~h as a
pump or valve, etc. Many have stand-by diesel generators to supply electric
power as well in the event of a power failure.
Also, keep in mind that an upset is allowed to go only just so far, into or just
beyond some permit limit; then the incinerator shuts down automatically and
the waste feed is cut off.
COMMENT
Does EPA know of a well-designed, well operated incinerator?
RESPONSE
Yes, there are over 150 stationary hazardous waste incinerators in the U.S.,
and 40 or more mobile or transportable incinerators; all are as carefully
designed, permitted, operated, and monitored as is humanly and reasonably
possible. EPA's regulatory and research programs and industry's experience
have made possible tremendous increases in reliability and reductions in
emissions and increases in safety and control over the past 15 to 20 years.
COMMENT
There is no instrument for constant monitoring of metals in the stack
emissions, only during the test burn.
RESPONSE
It is true that no continuous, wreal-timew stack monitor has yet been
developed to monitor metals emissions. Several researchers are currently
working on developing a laser device for this purpose. It is hoped that
results may be forthcoming in a few years, perhaps within 5 or 10 years.
Meanwhile, sampling, measuring, and monitoring the metals in the wastes
being incinerated, and limiting the metals input based upon what the trial
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burn data for metals must be re"lied upon.
COMMENT
The EPA should have evaluated using the plasma arc to clean up these
materials. .
RESPONSE
The plasma arc is a form of incineration.
Plasma Arc incineration was evaluated and determined to be inappropriate
for-the wastes at this site. The primary combustion chamber in a rotary kiln
incinerator, such as was proposed for this site, operates at approximately
1200oF. This results is a relatively low amount of volatilization of metals.
The plasma arc, however, operates at up to 3000oF. This high temperature
would result in volatilization of almost all of the metals in the waste.
Therefore, the designers of the incineration system would need to design a
system which would remove most of the metals present in the waste from
the stack emissions.
PUBLIC COMMENTS ON THE U.S. EPA'S SHIFT IN PREFERENCE
FROM At TERNA TIVE 5 TO At TERNA TIVE 3
COMMENT
I can't see that capping will do much good since the lagoon will still be left
in the ground. The groundwater must be contaminated. What about the
health of the children at Union School?
RESPONSE
The containment remedy is designed to limit the potential for migration of
contaminants to the groundwater by reducing the infiltration of water
through the wastes, through soil vapor extraction, by capturing and treating
contaminated groundwater, and through extensive monitoring. It is not
anticipated that the selected remedy will pose a hazard to the children at
Union School. Extensive monitoring will take place during any site activities
to assure that the health of on-site workers and nearby residents and school
children is not jeopardized.
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COMMENT
Soil Vapor Extraction should be part of the selected remedy. Dual extraction
and/or horizontal extraction wells should be investigated during the design
phase. Options to slurry walls should be evaluated. In-situ stabilization of
the lagoon was not evaluated.
RESPONSE
Soil Vapor extraction is part of the selected remedy. The methods
mentioned in this comment will be evaluated during the design phase. In-
situ stabilization of the lagoon was evaluated in the Feasibility study during
the screening of remedial technologies, and during a thorough investigation
of -remedial technologies which was performed by U.S. EPA for the Skinner
Landfill Coalition. These evaluations indicated that stabilization of the
lagoon wastes is not practical. This is due to the extremely difficult waste
matrix, which includes demolition debris and assorted metallic objects, and
due to the broad mix of chemicals which are present within the wastes.
COMMENT
I support alternative #3.
RESPONSE
Alternative 3 was selected, with the inclusion of soil vapor extraction (SVE).
COMMENT
I support the decision not to incinerate. We must be sure that continued
monitoring takes place at regular intervals and that the data is recorded and
published for the community to examine.
RESPONSE
Continued monitoring, and provision of the monitoring results to the public,
will be a part of the remedy.
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COMMENT
I support Alternative #3. Please include SVE. An evacuation plan for Union
Elementary School should be prepared.
RESPONSE
Alternative 3 was selected, with the inclusion of SVE. Emergency
procedures will be evaluated and developed in cooperation with the pertinent
local entities.
PRP COMMENTS ON THE U.S. EPA'S SHIFT IN PREFERENCE FROM
AL TERNA TIVE 5 TO AL TERNA TIVE 3
On February 9, 1993, the PRPs submitted 93 pages of comments on the U.S.
EPA's 6-page December, 1992 Fact Sheet. Many of these comments reiterate
issues which have been responded to above.
The PRPs interpreted the Fact Sheet as describing a .contingent. remedy, in which
incineration would be included as a fallback position in the Record of Decision.
This was an incorrect interpretation; it was never U.S. EPA's intention to include a
contingency for incineration in this Record of Decision. Whenever Hazardous
Substances are left on a Superfund site, U.S. EPA is required to conduct a review
of the site at ,least once every five years in order to determine whether the remedy
continues to be protective of human health and the environment. If, in the future,
the site remedy was determined to be not protective of human health and the
environment, the Five-Year Review of the performance of this remedy would have
the potential to result in a re-evaluation of the remedy, and potentially for the
implementation of additional remedial measures.
Based upon the assumption that a contingency remedy was being contemplated,
the PRPs submitted many comments in opposition to Alternative 5, in addition to
the approximately 50 pages of comments which they had submitted in opposition
to Alternative 5 on September 21, 1992. Alternative 5 was not selected, nor was
a contingency for incineration included in the ROD.
The PRPs carried their opposition to incineration to the point of demanding that
U.S. EPA rule out any possibility of incineration at this site in the future. In
suggesting that the U.S. EPA rule out any future consideration of incineration, even
if the containment rerr.edy is found to be ineffective in the future, the PRPs are
suggesting that U.S. EPA should abandon the only technology which is presently
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available which can effectively treat the lagoon wastes. The U.S. EPA will not rule
out the potential for incineration in the future. To do so would be to rule out the
only known viable technology for the cleanup of the lagoon wastes.
COMMENT
The PRPs attorneys submitted a large number of comments expressing
opposition to Alternative 5, to incineration, and to a .contingent remedy".
RESPONSE
The U.S. EPA did not select Alternative 5 or incineration for this site.
The U.S. EPA has not selected a contingent remedy for this site. The U.S.
EPA never proposed a contingent remedy for this site. However, U.S. EPA
stated that the ongoing review of the effectiveness of the remedy, through
five-year reviews, could result in a re-evaluation of the need for excavation
and incineration. Such review is required at every Superfund site where
Hazardous Substances remain on-site.
COMMENT
After fifteen years of uncontrolled infiltration of precipitation through the
clayey soils, the studies indicate that no or little migration has occurred.
RESPONSE
A wide range of contaminants were detected in the site monitoring wells.
Many of these same contaminants were detected in the site wastes, and
were not detected in the upgradient groundwater. Therefore migration of
contami!'ants from the site wastes to the groundwater has occurred.
COMMENT
The Group strongly supports U.S. EPA's thoughtful decision to select a
capping remedy rather than excavation and incineration.
RESPONSE
The U.S. EPA appreciates the PRPs' support of this decision.
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COMMENT
The PRPs proposed a phased approach, starting with installation of the cap
and monitoring of the groundwater. Then, an "engineering evaluation"
would be performed to determine whether the other aspects of the remedy
are necessary.
RESPONSE
The U.S. EPA will consider a phased approach to implementation. This may
allow the design and construction of the cap to proceed while the additional
site studies related to characterization of groundwater and soil gas
conditions are being conducted. The "engineering evaluation" will relate to
h2:t! the various aspects of the remedy will be implemented, not whether
they will be implemented.
COMMENT
The Soil Vapor Extraction, if feasible, would permanently remove
contaminants that have the potential for migrating to the groundwater, thus
eliminating or greatly minimizing the need for groundwater treatment.
RESPONSE
The U.S.EPA believes that it is highly unlikely that the operation of soil vapor
extraction at this site would eliminate the need for groundwater treatment.
Soil Vapor Extraction is only proposed for the permeable materials which
surround the buried waste lagoon. There are contaminated materials
elsewhere on the site, within the former dump, which will continue to pose a
hazard to the groundwater. It is also possible that contaminants will
continue to leach from the buried waste lagoon to some degree after
installation of the cap. Some of these contaminants may not be captured by
a soil vapor extraction system.
COMMENT
The PRPs expressed opposition to the capping of the former dump area,
stating that no samples have been taken of the material in the "active
landfill", and concluding that a requirement for capping of this area would be
arbitrary and capricious (pages 22-23).
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RESPONSE
Groundwater samples collected from within the former dump (GW-22) were
found to be the most contaminated water samples which were analyzed in
the course of the site investigations. The former dump is believed to be
hydrologically upgradient of the buried waste lagoon, so it appears that
these contaminants originate from within the former dump, and not from the
buried waste lagoon. Given what is known about the former dump and the
site operations, the remedy must address the former dump area as a part of
this site cleanup. The containment remedy, as selected in the Record of
Decision, includes capping of the former dump area.
COMMENT
"In selecting Alternative 5 as the Contingent Remedy, the Agency seriously
misapplied the statutory preference for reduction in Volume, Toxicity or
Mobility of Hazardous Substances. Although lip service is paid to the
unambiguous language preferring a reduction in toxicity, mobility 2!: volume,
in actuality the FS and Propose Plan impermissibly seek a reduction of all
three criteria to justify the remedy selection."
RESPONSE
This comment contradicts the PRPs' comments of September 21, 1992, in
which they demanded that our remedy meet all three of these criteria. To
quote their previous comment: "Incineration will not meet the objective of
reducing contaminant mobility, toxicity, i!lli volume, because incineration
would actually increase the volume of waste materials due to the need for
stabilization" (emphasis added).
The FS and Proposed Plan do not seek a reduction in all three criteria, as a
careful reading 01 the text of each will indicate. Please also refer to the
discussion of this criterion in the Feasibility Study.
COMMENT
The PRPs stated that the boundaries of the site have not been sufficiently
defined, 8ild that the area to be capped should be limited to areas of known
contamination.
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RESPONSE
The boundaries of the site, and the minimum area to be capped, are
indicated clearly in the Record of Decision. In order to maintain proper
slopes, it may be necessary to extend the cap beyond these boundaries.
This comment may relate to Figure 5.3 of the Feasibility Study, which
indicates the potential extent of a cap designed to cover the areas of known
contamination and to maintain maximum slope requirements.
COMMENT
The PRPs submitted their own lengthy discussion of the alternatives as they
relate to the nine criteria.
RESPONSE
For the U.S. EPA positions regarding each of the nine criteria, please refer to
the nine criteria discussion in the Record of Decision.
COMMENT
The lagoon waste materials are not .wastes.; they were referred to as
.soils. in the FS. .
RESPONSE
Subsurface materials are commonly referred to as .soils.. However, during
the waste lagoon investigation, borings encountered highly contaminated
solids, and what was described as sticky, black, raspberry and turquoise
colored liquids. These are clearly wastes.
COMMENT
During the July 29, 1992 public meeting, the U.S. EPA did not dispute the
community's observation that incineration would treat only 10-20% of all
the waste at the Skinner Landfill
RESPONSE
The PRPs have inaccurately described the community concern. The concern
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which was expressed was that'incineration would only treat 10% of the
lagoon wastes. U.S. EPA did dispute this observation at the public meeting.
Please see response on page 17 for a full discussion of this issue.
COMMENT
U.S. EPA failed to include a comparative assessment of the risks of the
alternatives.
, RESPONSE
A qualitative assessment of the risks of the alternatives was included in the
Fe_asibility Study, Section 5.0.
COMMENT
"It is ironic that U.S.EPA proposes a Contingent Remedy that will open a
currently closed pathway of exposure by excavating the buried lagoon and
thereby dramatically increase (according to U.S. EPA's own calculations) the
carcinogenic and non-carcinogenic risks. .
RESPONSE
U.S. EPA has not proposed a Contingent Remedy that includes excavation of
the buried lagoon.
U.S. EPA calculations do not show a .dramatic. increase in carcinogenic and
non-carcinogenic risks to the nearby residents. The risks were projected to
be within the acceptable range.
COMMENT
To the extent excavation and incineration are contemplated as the
contingent Remedy, they are not acceptable to the community, ... and
should be disregarded as options.
RESPONSE
The U.S. EPA never proposed a contingent remedy. However, we did state
that the ongoing review of the effectiveness of the remedy, through five-
year reviews, could result in a re-evaluation of the need for excavation and
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incineration.
The community has, in the written statement of the West Chester Coalition
for the Skinner Landfill Cleanup, expressed their support for something
closely resembling a contingent remedy: -Emergency plans shall be prepared
for the treatment of on-site wastes in the event of failure of the proposed
containment system- (letter, Nov.23, 1992). However, U.S. EPA feels that
the five-year review process will provide sufficient safeguards to' the public
and the environment over the long term; a contingent remedy was not
selected for this site.
COMMENT'
No record of the Jul, 29, 1992 Public Meeting has been placed in the
Administrative Recora.
RESPONSE
The video and audio tapes recorded during the July 29, 1992 public meeting
were placed in the Information Repository during August, 1992. It has
come to our attention that the U.S. EPA video and audio tapes were
removed from the information repository by unknown parties and were
replaced by a copy of the videotape generated by CLEAN. This problem has
been corrected.
COMMENT
-In view 01 the fierce--and legitimate-opposition 01 the local community to
the unacceptable risks and exposures posed by excavation and incineration
at this Site, as well as the threat of citizen suits and legal challenges
throughout the remedial design and implementation phase if U.S. EPA were
to revert to incineration as a remedial option, a responsible and meaningful
incorporation of citizen concerns into the decision-making process required
EPA to permanently and unconditionally abandon excavation and incineration
in favor of the simpler, safer, and technically appropriate containment and
capping remedy..
RESPONSE
In suggesting that the U.S. EPA rule out any future consideration of
incineration, even if the containment remedy is found to be ineffective in the
future, the PRPs are suggesting that we abandon the only technology which
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58
is presently available which can effectively treat the lagoon wastes. The
U.S. EPA will not rule out the potential for incineration in the future. To do
so would be to rule out the only known viable technology for the cleanup of
the lagoon wastes.
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