United States
Environmental Protection
Agency
Office of
Emergency and
Remedial Response
EPA/ROD/R05-89/098
July 1989
SEPA
Superfund
Record of Decision
Industrial Excess Landfill, OH
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50272-101
REPORT DOCUMENTATION
PAGE
1. REPORT Htt
EPA/ROD/R05-89/098
X RedptanT* AccMclon No.
4. Titt« and SUbtfO*
SUPERFUND RECORD OF DECISION
Industrial Excess Landfill, OH
Second Remedial Action - Final
5. Report Oat*
07/17/89
7. Autrior(a)
8. Performing Organization Rept No.
9. Performing Organization Nun* end Addrea*
ia ProiecVTaak/Work UnH No.
11. CorrtracXC) or Grant(G) No.
(C)
(0)
12. Sponsoring Organization Nam* and Addreea
U.S. Environmental Protection Agency
401 M Street, S.W.
Washington, D.C. 20460
IX Typ* of Report ft Period Covered
800/000
14.
15. Supplementary Not**
18. Atwtrict (Limit: 200 word*)
The 300-acre Industrial Excess Landfill site is in Uniontown, Stark County, Ohio.
Several hundred residences are within a half mile of the site, and all residences and
businesses in the Uniontown area rely on ground water from private well supplies.
Surface water at the site flows to Metzger Ditch which is located along the eastern
border of the site. The site was operated as a mixed industrial and refuse landfill from
1966 until 1980. Large amounts of fly ash and liquid wastes including latex and spent
organic solvents were disposed of in the landfill between 1968 and 1972. To prevent the
spread of contaminants associated with these wastes, several emergency actions have been
undertaken. In 1986 an active methane extra^ion system was installed to prevent the
offsite migration of explosive levels of methane gas. In April 1987 EPA installed air
strippers in eight residences and two businesses due to the presence of low levels of
volatile organic compounds. In September 1987 EPA signed a Record of Decision (ROD) to
provide an alternate water supply to 100 homes west of the site to ensure that the
community received safe drinking water while the final remedial action for the site was
implemented. This ROD represents the final remedial action for the site and addresses
the source area, gases generated within the source area, and contaminated ground water.
The primary contaminants of concern affecting the soil, sediments, and ground water are
VOCs including benzene, vinyl chloride, and PCE; other organics including carcinogenic
PAHs; and metals. Air contamination bv methane eras is (Continued on next page)
OH
17. Document Analyaia a. Deecripfcu*
Record of Decision - Industrial Excess Landfill,
Second Remedial Action - Final
Contaminated Media: soil, sediment, gw, air
Key Contaminants: VOCs (benzene, PCE), other organics (methane gas, PAHs), metals
b. ldentifl*r»/Open-end*dT*fin*
e. COSAT1 Reid/Group
18. AvailataUty 9ta*arnem
1m. 3ecwttyCUaa(TN* Report)
None
20. Security Cteea (Tree Pege)
None
21. No. of Page*
58
22. Price
(See ANSI-Z39.K)
9*9 Mtfeucvofte' on Npwe/ve
OPTIONAL FORM 272 (4-77)
(Formerly NT13-35) '
Deparvnent of Commerce
-------
EPA/ROD/R05-89/098
Industrial Excess Landfill, OH
16. Abstract (Continued)
also present at the site.
The selected remedial action for this site includes installing a multilayer RCRA cap
over the site to prevent surface water infiltration; expanding the existing methane
venting system to accommodate the potential increase of landfill gas due to the cap;
extracting and treating approximately 256 million gallons of contaminated ground water by
air stripping, carbon adsorption, and flocculation/sedimentation/filtration to achieve
compliance with Clean Water Act NPDES discharge criteria for surface water discharge;
continuing the pumping of ground water to maintain a lowered water table and protect
ground water from additional contamination by the landfill; treating surface water from
ponds at the site, if necessary; and dredging sediment from the ponds and ditch and
incorporating them under the cap; multimedia monitoring; and institutional controls
restricting future use of the site. The estimated present worth cost for this selected
remedial action is $18,548,000, which includes an estimated annual O&M cost of $440,000.
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EBCTARATICN FOR THE REOCRD OF EBdSICN
Site Name and
Industrial Excess land fill, Inc.
Uniontown, Ohio
Statement of Basis and Purpose
This decision document presents the selected final remedial action for the
Industrial Excess Landfill, Inc. site, in Uniontown, Ohio, developed in
accordance with CERdA, as amended by SARA, and, to the extent practicable,
the National Contingency Plan. Tnis decision is based on the administrative
record for this site. The attached index identifies the items that conprise
the administrative record upon which the selection of the final remedial
action is based.
The State of Ohio has concurred on the selected remedy.
Description of the Selected Remedy
Ihis remedial action is the final action for the Industrial Excess Landfill,
Inc. (TKT.) site. In September 1987, U.S. EPA signed a Record of Decision for
provision of an alternate water supply to approximately 100 homes near IEL
whose drinking water is affected or threatened by contaminants from EEL.
This final remedial action addresses the waste disposal area and the landfill
gas generation and groundwater contamination associated with the waste
disposal area. The remedy addresses the principal threats posed by TFT, by
isolating and containing wastes within the landfill, expanding the existing
methane venting system for the collection and flaring of landfill gas, and by
extracting and treating contaminated ground water beneath and near the
landfill. Additional studies of landfill gas generation and potential
migration, surface stability and hydrology, and hydrogeologic characteristics
and contaminant fate and transport must be conducted during the design phase
of the remedy to collect appropriate information for design of the various
treatment and containment systems.
The major components of the TFT, remedy include:
* Installation of a RCRA Subtitle C compliant cap over the entire surface
of the landfill with surface water drainage control and discharge;
* Expansion of the existing methane venting system;
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-2-
* Extraction and treatment of contaminated groundwater beneath and near
the landfill until cleanup levels are achieved;
* Pumping of groundwater to maintain the water table level beneath the
bottom of the wastes in TFT, in order to protect groundwater from
additional contamination by the landfill;
* Installation of fencing around the perimeter of the site;
* Use restrictions on future use of the site property; and
* Monitoring of the cap, ground water extraction and treatment system, and
methane venting system to ensure the remedy is effective.
Declaration
The selected final remedy is protective of human health and the environment;
attains Federal and State requirements that are applicable or relevant and
appropriate to the remedial action; and is cost effective. This remedy
utilizes permanent solutions and alternative treatment (or resource recovery)
technologies to the maximum extent practicable. A principal threat at the
site, the disposal area itself, will be addressed through containment rather
than treatment, and therefore, this portion of the remedy does not meet the
statutory preference for treatment as a principal element of the remedy.
Because of the disposal area size; the fact that there are no on-site hot
spots representing major sources of contamination; and the difficulties, risk
and cost involved with implementing a source treatanent technology, it is not
practicable to treat the source area. However, another principal threat, the
groundwater contamination, will be addressed through treatment which
permanently and significantly reduces the toxicity, mobility or volume of the
existing groundwater contamination. In addition, landfill gas generated by
the site will be collected and flared, providing additional reductions in
contaminant toxicity, mobility/ cr volume.
Because this remedy will result in hazardous substances remaining on-site
above health-based levels, a review will be conducted no less than once every
five years after commencement of remedial action to ensure that the remedy
continues to provide adequate protection of human health and the environment.
JUL 1 7 198S
Date f=?2- Valdas V.
Regional Administrator
U.S. EPA, Region V
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rfTTSION SUMMARY
1. Site Name, location, and
The Industrial Excess landfill (TFT.) site is located in the
unincorporated community of Uniontown, Ohio. Uniontown is located in
lake Township of Stark County, approximately 10 miles southeast of
Akron. The site is about four-tenths of a mile south of the
intersection of Cleveland Avenue and State Route 619, at 12646 Cleveland
Avenue (See Figure 1).
Located on a 30 acre tract of land east of Cleveland Avenue, the site is
set back from the road by a strip of land approximately 250 feet wide.
This strip is occupied by 2 businesses and 6 single-family homes, one of
which had been converted into a real estate office. Presently, five of
the homes are occupied; the real estate office is vacant.
An additional 6 homes are located at the northern edge of the site along
Hilltop Avenue and the southern curve of Amber Circle. The eastern
border of the site is formed by Metzger Ditch, which drains the peat
soils east and southeast of the site. A sod farm is located on the east
side of Metzger Ditch. The tract of land south of the site is occupied
by a seldom used sand-blasting and paint shop.
Several hundred residences are located within a half mile of the site,
mainly to the north, west and southwest. All residences and businesses
in the Uniontown area rely on groundwater obtained from individual or
private well supplies.
Covered with grasses, small trees and shrubs, the site itself is gently
rolling, with the highest elevation located at the northwest corner.
The property slopes to the east and south, directing surface run-off to
Metzger Ditch. The difference in elevation between the highest point
and the lowest point, located at the southeast corner, is approximately
60 feet (Figure 2). There are four small ponds on the site located
adjacent to Metzger Ditch.
H. Site History and Enforcpfr^nt Activities
A. Operational History:
Formerly the site of a sand and gravel mining operation, TFT, was
operated as a mixed industrial and refuse landfill from 1966 to 1980,
when it was ordered closed. During operation, the landfill accepted an
assortment of household, commercial, industrial (sludges, liquids, and
solids) and chemical wastes. Large amounts of flyash were accepted at
IEL from 1966 until at least 1972. Most of the liquid industrial
wastes, including latex, spent organic solvents, and off-spec product
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INDUSTRIAL
EXCESS
LANDFILL
scale appVoximate
1' : 1,550'
C *"
INDUSTRIAL EXCESS LANDF.LL
STARK COUNTY.OHIO
.FIGURE I
LOCATION FLAN
JCMNSPN ft Mi! WOTS." or
-------
o
•ai-
nxcnss
STAHK COUHTY. OHIO
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-2-
from the rubber industry, were dumped between 1968 and 1972. Based on
interviews with the former owner and depositions of various operators,
it appears as if most of the liquid waste disposal occurred on the
northern one-third of the landfill. The method of disposing of these
liquids was direct dumping on the ground, either in a lagoon or mixed
with other waste. In 1972, the Stark County Board of Health ordered the
cessation of liquids disposal. However, community residents indicate
that some liquids were disposed of after that date. General organic
material, inclining waste from the general public, was disposed of at
TTT. throughout its operation.
Due to public concern, and because the site was approaching its
volumetric limit, the landfill was ordered closed in 1980.
Approximately 80 to 85 percent of the site is underlain with waste.
Depths of landfill ing ranged from 60 feet at the northwest corner, to
only several feet along the east ad south portions of the site.
Subsequent to closure, the site was covered with a sandy, gravelly soil
and seeded. The site does not have an impermeable cap or liner.
B. CERdA Removal Activities:
In October 1984, the TKT. site was proposed for inclusion on U.S. EPA's
National Priorities List (NFL) of abandoned or uncontrolled hazardous
waste sites eligible for investigation and cleanup under the Superfund
Program. A Work Assignment was issued on December 26, 1984, for a
comprehensive remedial investigation/feasibility study at the site.
A Remedial Investigation, comprised of several phases of field work was
conducted between 1985 and 1988. During the Remedial Investigation,
surface soils, subsurface soils, and sediments, soil gas, and ground
water samples were collected and analyzed. The Remedial Investigation
Report, detailing the results of the investigation, was published in
July 1988. A Feasibility Study, which examined and evaluated remedial
alternatives for TFT., was released for public comment on December 21,
1988. The public comment period ended June 1, 1989.
While the RI/FS was conducted, several actions were taken at IEL by U.S.
EPA. In early 1986, an active methane extraction system was installed
on the site by U.S. EPA's Emergency Response Team, in order to prevent
the off-site migration of explosive levels of methane gas to adjacent
homes. The methane venting system (MVS) consists of a series of
extraction wells which collect landfill gas from depths of about 40
feet, and direct it toward a central point where the gas is then flared.
For the most part, the MVS has effectively prevented off-site migration
of landfill gases since its installation. Off-site soil gas samples
taken in late June and early July 1989 indicated off-site migration of
methane. Adjustments in the operation of the MVS quickly corrected the
problem.
During April 1987, U.S. EPA's Emergency Response Team also installed
air-strippers in 8 residences and 2 businesses, in response to the
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-3-
presence of low levels of vinyl chloride and other volatile organics in
several drinking water wells. The levels of vinyl chloride observed in
3 wells equal or exceed the Maximum Contaminant Level (MCL) for vinyl
chloride of 2 parts per billion (ppb) .
On September 30, 1987, U.S. EPA signed a Record of Decision to provide
alternate water to 100 homes located west (downgradient) of the TKT.
site. This area includes those homes and businesses whose groundwater
is currently contaminated by the site, and those who may be affected
prior to the implementation of the final site remedy. The decision is
considered to be one part, or an operable unit, of the overall site
remedy. The Potentially Responsible Parties (PRPs) for the TEL site
were ordered to design and construct the alternate water system. Design
has begun and the system is expected to be on line by summer of 1990.
C. CERCLA Enforcement Activities:
U.S. EPA issued notice letters to the TFT, owner/operator's and five
generators of hazardous substances disposed of at IET, in April 1985,
requesting these PRPs to conduct the RI/FS for IEL. Negotiations were
not successful and U.S. EPA initiated a Fund-financed RI/FS.
In August 1987, U.S. EPA issued notice letters to 10 PRPs, asking them
to submit a good faith proposal for the design and construction of the
alternate water supply operable unit. Negotiations were unsuccessful
and none of the PRPs submitted a good faith proposal. Consequently, in
December 1987, U.S. EPA issued a Section 106 Unilateral Order to the ten
PRPs, ordering them to implement the operable unit. In January 1988,
four of the PRPs began to comply with the Order.
In March 1989, U.S. EPA issued a general notice letter to 12 PRPs,
requesting them to implement the final remedy outlined in the TFT.
Proposed Plan. In May 1989, U.S. EPA issued special notice letters to
15 PRPs for the TEL, final remedy, establishing the statutory 60-day
period for submittal by the PRPs of a "good faith proposal" to conduct
the final remedial action. During the 60-day period, U.S. EPA invokes a
moratorium on conducting remedial action at TFT., if U.S. EPA receives a
"good faith proposal" within the 60-day period, the moratorium will be
extended an additional 60 days.
CgmTunitv Relations History
U.S. EPA and OEPA have conducted extensive community relations
activities at the site. The community near TFT, has been very involved
in site activities throughout the Superfund process. A community group,
Concerned Citizens of lake Township (CCET) , received the first Technical
Assistant Grant (TAG) in the nation. U.S. EPA and OEPA have published
many fact sheets, sponsored several public meetings, and held numerous
availability sessions to keep the community informed of the TFT.
activities.
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-4-
In accordance with CERdA Section 113, U.S. EPA published a notice in a
local newspaper in mid-December 1988 announcing the availability of the
IEL FS and Proposed Plan, the date and time of the availability sessions
and public meeting, and the duration of the public comment period. The
announcement also included a brief analysis of the Proposed Plan and
alternative plans that were considered.
A 120-day public comment period for the ITT. FS was established from
December 21, 1988 until April 19, 1989. The comment period was
subsequently extended until June 1, 1989. The length of the public
comment period well exceeded the 21 days required by the NCP. A public
meeting was held on March 29, 1989 in Uniontown, Ohio in accordance with
CERCLA Section 117. A transcript of the meeting is contained in the IEL
Administrative Record. The Responsiveness Summary contains a response
to each of the significant comments, criticisms, and new data submitted
in written and oral presentations. This Record of Decision serves as
the statement of the basis and purpose of the selected final remedial
action for TFT..
IV. Scope and Role of this Response Action
This Record of Decision addresses the final remedial action for the IEL
site. The action addresses the principal threats at the site, the 30-
acre waste disposal/source area and gases generated within the source
area, and contaminated groundwater.
The Record of Decision (September 1987) for provision of alternate water
to approximately 100 residences near the landfill will ensure safe
drinking water is available to the community near the landfill before
full implementation of the final remedial action.
V. Summrv of Site Characteristics
A. Extent of Source:
Waste materials were disposed of throughout the entire area occupied by
the landfill. Prior to the start of the RI, it was known that
landfilling of household, commercial, and industrial wastes occurred
over approximately 80 to 85 percent of the site property. Many of these
industrial wastes are considered hazardous by current standards. Figure
3 shows the area of the landfill which is estimated to be underlain by
buried wastes. At the IEL site, waste materials typically were buried
immediately adjacent to the property line. During the installation of
MVS monitoring wells, buried wastes also were noted in an off-site area
behind the tire shop located close to the northwest corner of the site.
Due to the varying topography at the site, the depth of the fill ranges
from approximately 60 feet at the northwest corner of the site to
several feet along the south and east portions of the site. Wastes were
not disposed in those areas where the water table was only several feet
below the ground surface (the topographically low eastern portion of the
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I! Vv* Yn—~£
y/y^€af^
AI'I'HOXIMATE LIMIT OF VMf, TL"
i. nxoiisr. i.Aiimii.i.
oouiiTY. oinn
nniinn 3
AI'IMIOXIUAl I! I IMIT 01 VMSII-'
\ M A I MO I n A . i> <:.
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-5-
property).
Along with the landfilling of solid wastes, substantial quantities of
liquid waste were dumped onto the ground either from 55-gallon drums or
from tanker trucks. These liquids typically were mixed with flyash or
dry refuse also disposed of at the site. Table 1 lists the chemicals
known to be taken to TFT.. Table 2 lists the chemicals found in samples
from drums excavated during installation of the MVS. In addition,
witnesses have described the disposal of what they believe had been
solvents and industrial chemicals, which were volatile and/or had foul
odors. According to a past employee, only those drums which could not
be emptied of their contents were landfilled. Others were typically
emptied and returned to the generator. While it is possible that liquid
filled drums may have been disposed of at the landfill, the information
provided by the past employee suggests that this would have been a rare
occurrence.
B. RI Results:
The results of the RI conducted at the IZL site indicate the following:
o The most extensive body of contaminated materials consists of
the wastes and waste-soil mixtures in the landfilled portions
of the site. These waste materials were covered with clean
soil during the site's closure.
o Sampling indicates that surface soil contamination on the site
occurs at two small leachate seep areas. There was also an
area just outside the site's property line which exhibited
polycyclic aromatic hydrocarbons (PAHs). Clean soil
materials, as placed on a portion of the site by U.S. EPA's
Emergency Response Section following the installation of the
MVS, covered this off-site PAH contaminated area.
o Off-site contaminant migration posing a threat to public
health and the environment is associated with the groundwater.
Sampling of private residential and on-site/off-site monitoring wells
has shown groundwater to be contaminated with volatile and semi-volatile
organics and total metals. The most highly contaminated monitoring well
exhibited a concentration of 400 ppb of assorted Hazardous Substance
List (HSL) volatile and semi-volatile organic compounds and a total of
2,000 ppb of tentatively identified organic compounds (TICs). Compounds
of greatest concern found in the monitoring wells include benzene and
1,2-dichloroethane. Vinyl chloride was found in three private wells
located downgradient from the landfill. Barium levels also exceed the
maximum contaminant level (MCL) as stipulated by the Federal Safe
Drinking Water Act (SDWA). Nickel is present at higher than Ambient
Water Quality Criteria (AWQC) levels in eight downgradient residential
wells. The results from one sampling round showed elevated lead levels
in some of the residential well samples. Data obtained from several
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TABLE 1
LISTING OF SOLVENTS AND OTHER MATERIALS DISPOSED AT THE IEL SITE
Information obtained from PRPs
acetone
benzene
n-butanol
n-butyl acetate
ethanol
2-ethoxyethyl acetate
ethyl acetate
gasoline
hexane
n-heptane
isopropyl alcohol
isopropyl acetate
methanol
2-methoxyethanol
1,1,1-trichloroethane
methyl ethyl ketone
methyl isobutyl ketone
methylene chloride
monochlorobenzene
naptha
naptha (aliphatic)
sulfuric acic
tetrahydrofuran
toluene
xvlene
15704/10
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SUMMARY OF DP.UM SAMPLING RESULTS - IE1
Organic Detected Range Frequency'of
Chemicals (ug/kg) Detection
1,1,1-Trichloroethane . 1200 - 1700 3/24
1,1-Dichloroethane 230 1/24
2-Kexanone 6100 1/24
4-Methyl-2-Pentanone 1000 - 32,000 4/24
Acetone 5100 - 12,000 3/2*
Benzene 2200 - 23,000 5/2^
C.hlorobenzene 1800 - 2300 2/2*
Ethylbenzene 3900 - 1.3E7 8/24
Styrene 42,000 - 3,900,000 7/24
Tetrachloroethene 790 - 6200 6/24
Toluene 1000 - 1,100,000 11/24
Xylenes 1400 - 1.2E3 6/24
Trans-l,2-0ichloroethene 8700 i/24
Tn'chloroetnene 1200 - 1400 3/24
1,2-Dichlorobenzene 41,000 1/24
1,4-Dichlorobenzene 11,000 - 15,000 3/24
2-Methylnaphthalene 2.4 - 3,200,000 3/24
2-Methyl phenol 8300 • i/24
'.-Cnloro-3-Methylphenol 2200 - 3200 2/24
l-Methylphenol 4900 - 43,000 3/24
lenzoic Acid 34,000 1/24
is(2-Chlorbethyl)Ether 19,000 ' 1/24
is(2-Ethy!hexyl)Phthalate 16,000 1/24
utylbenzyl Phthalate 2400 - 51,000 2/24
i-N-Butyl Phthalate 8700 - 62,000 2/24
i-N-Octyl Phthalate 4500 - 65,000 5/24
iMethyl Phthalate 150,000 1/24
•Nitrosodiphenylamine 2900 - 32,000 5/24
phthalene 2.1 - 2,500,000 5/24
ntachlorophenol 86,000 - 620,000 2/24
enol 6000 - 280,000 7/24
rene 1700 - 5900 2/24
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-6-
previous and subsequent sampling events at these hones have not shewn
any evidence of elevated lead levels. Therefore, the set of analytical
data exhibiting these elevated lead levels is considered to be an
anomaly which is not truly representative of site conditions.
Groundwater contaminated with volatile and semi-volatile organic
compounds and metals exists beneath and downgradient of the landfill.
Based on monitoring and residential well sampling, this contamination
has been shown to extend several hundred feet downgradient (west) of the
site. Figure 4 shows the extent of inorganic and organic contamination
plumes based on data from monitoring and residential wells. This
sampling has also shown that the ground water contamination is presently
confined to the shallow portions of the sand and gravel aquifer.
Organic and inorganic contaminated soils and sediments exist at
scattered locations on the landfill property. The locations JUTclude two
areas where leachate seeps have been noted and in the sediments of the
on-site ponds.
Metzger Ditch flows southward along the east side of the landfill and
continues southwest beyond the southern boundary of the site. Samples
of surface water, sediment, and soil associated with Metzger Ditch
indicate that site related contaminants have discharged into the ditch,
but at concentrations detected to date which do not pose a risk to human
health or the environment.
Contaminants of interest are the chemicals which have been detected in
the site media and which can be associated with waste disposal
activities at the site. Tables 3 through 5 summarize the
concentrations of the contaminants of interest detected in soil,
groundwater and landfill gas.
VI. S»™naryr of Site pi^ks
As part of the RI at TFT., a Public Health Evaluation (PHE) was conducted
to assess the potential impact on the public health and the environment
from the release of hazardous substances from the site. As part of this
process, quantitative risks assessments were made for the soils,
groundwater, and air exposure pathways at the landfill.
The PHE notes the following contaminants of interest and respective
media as possibly presenting an unacceptable risk at TFT., (where
"unacceptable risk" is defined as a greater than 10"6 excess lifetime
cancer risk or a hazard index for a critical effect subgroup exceeding
one):
o Under the assumed trespassing scenario, the upper bound excess
lifetime cancer risks associated with soil contact (including
ingestion) exceed the 10~6 level for children (2 x 10~6) and
adults (3 x 10~5) under the plausible maximum case, but not
for the average case. The risk in all cases is attributable
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UNIONTOWN
Limit of Matala
Contamination from IEL
Umlt of Organic Contamination
From IEL (Including TlCa)
Scita AooraiimaB. \' • 1100*
INDUSTRIAL EXCESS LANDFILL
STARK COUNTY.OKIO
Figure 4
PRESENT EXTENT CF GROONDWA7=.=.
CCMTAWINAT1CN AT IEL
cc. XJHNSCN 4 uAmora*. p.c.
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TABU 3
ORGANIC CHEHICAIS DETECTED IN SURFACE SOILS
U001IRIAL EXCESS LANDFILL SITE
On Site
Near Site A Down Gradient
Off Site (Background)
Chemical
1 ,4-Olchlorobenzene
2-Butanone
2-Hethylnaphthalene
2-Methylphenol
4.4-DDE
4.4-ODT
4-Methyl-2-Pentanone
4-Methylphenol
Acenaphthene
Aldrin
Anthracene
lleniene
Rcnzo(A)Anthracene
Benzo(A)Pyrene
BenzoJBJFluoranthene
Benio(G.H.I)Perylene
Ben/o(lC)Fluoranthene
Bentolc Acid
Dls(?'Ethylheiy1) Phthalate
Butylbeniylphthalate
Chlordane
Chlorohenrene
' Range*
(pph)
43 (<330)
<10-51
130-15.000
190 (<330)
15-200
O6-170
5 (<10)
350-3.000
94 (<330)
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TAKE 3 (Continued)
ORCAH1C CHEMICALS DETECTED in SORFACE SOILS
IROOSIRIAL EXCESS LANDFILL SITE
On Site
Near Site 4 Down Gradient
Off Site (Background)
Chemical
Chrysene
Ol-N-8utyl Phthalate
DI-N-Octyl Phthalate
Olben/ofuran
Oielhyl Phthalate
Ethylbeniene
Fluoranlhene
Fluorene
Gamna-RHC (l.lndane)
lndeno(l.2.3-CI>) Pyrene
N-Nllrosodiphenylamlne
Naphthalene
•
Range*
(ppb)
<400-4,700
250 (<330)
330 (<330)
44 (O30)
46-50 (<330)
3-980.000
49-12.000
15-73 (<330)
<8.0-61
O30-700
120-4.300
30-l.flOO
Frequency
of
Detection
3/30
1/30
1/30
1/30
2/30
9/30
4/30
2/30
1/30
1/30
7/30
4/30
Frequency
Range of
(ppb) Detection
0/13
268-2.255 4/13
0/13
0/13
0/13
0/13
260-280 (<330) 1/13
0/13
0/13
0/13
0/13
0/13
Range*
(ppb)
« H«
110-290 (<330)
--•
—
—
...
93 (<330)
—
...
—
—
—
Frequency
of
Detection
0/7
3/7
0/7
0/7
0/7
0/7
1/7
0/7
0/7
0/7
0/7
0/7
pens
PCD-IOI6
l'CII-121?
I-CII-I24H
PCI)-1254
Phenanlhrene
Phenol
Pyrene
Telrachlorocthene
Toluene
Total Xylenes
!r IcMoroethene
59-320
2IO-6.600
94-590
<330-8.400
<5-8
3-20
<5-l3.000
<5-l6
3/30
5/30
2/30
2/30
1/30
4/30
8/30
1/30
47-29!
80-380
<5-8lO
<5-5
<5-8
0/13
2/13
0/13
2/13
0/13
7/13
1/13
1/13
110 (<330)
0/7
0/7
0/7
1/7
0/7
0/7
0/7
0/7
<« • chemical not detected, where "<° It the detection limit. A number or range followed hy a number In parentheses Indicates detected values
below the detection limit where the number In parentheses Is the detection Unit.
• frequency of detection Is the nurrf>er of samples In which the chemical was detected over the total number of samples analyied.
157130/13-2
-------
TABLE 3 (Continued)
MEAN 1C CHEMICALS OF INTEREST DETECTED IN SURFACE SOILS
INDUSTRIAL EXCESS LANDFILL SITE
Cyanide
On Site
Near Site A Down Gradient
Off Site (Dackground)
Chemical
Antimony
Arsenic
Uarium
Beryl I iura
Cadmium
Chromium
Cohalt
Copper
l.iMd
M.inij
-------
TABLE 4
HSL CONTAMINANTS OF INTEREST DETECTED IN GROUNDWATER - I EL
CONSTITUENT
C0NCENTRATION RANGE (ppb)
Monitoring Wells
Acenapthene
Benzene
Butyl benzylphthalate
Benzoic Acid
Chlorobenzene
4-Chloro-3-Methylphenol
1,2-Dichloroethane
1,1-Dichloroethane
1,4-Oichlorobenzene
2,4-Dimethylphenol
Di-n-Octylphthalate
Ethyl benzene
2-Methylnapthalene
4-Methylphenol
n-Nitrosodiphenylamine
Napthalene
Phenol
Trans-1,2-Dichloroethene
Toluene
Total Xylenes
Barium
Cadmium (Total)
Copper (Total)
1.2 - 10
1 - 6
0
<5 - 27
1 - 5.2
<5 - 10
<5 - 25
10 - 13
3
1
<5 - 110
2.7 - 3.0
3
<10 - 15
7.9 - 10
3.7
3.8 - 4.3
0.9 - 13
<5 - 355
75 - 1,430
21
<19 - 575
15713C/02
-------
TABLE 4 (Continued)
HSL CONTAMINANTS OF INTEREST DETECTED IN 6ROUNDWATER - IEL
CONSTITUENT
CONCENTRATION RANGE (ppb)
Monitoring Wei Is
Chromium (Elemental)
Lead (Total)
Manganese
Nickel (Total)
Selenium (Total )
Vanadium
5 - 9.2
<3 - 11
39 - 3,060
<14 - 48
<3 - 6.8
3.1 - 17
CONSTITUENT
CONCENTRATION RANGE (ppb)
Residential Wells
Chloroethane
Tetracnloroethene
Vinyl Chloride-
Barium
Cobalt
Cadmium (Total)
1.0 - 2.0
1 - 1.3
1.5 - 7
2.1 - 1,370
<5 - 16
0.1 - 0.58
15713C/02
-------
TABLE 4 (Continued)
HSL CONTAMINANTS OF INTEREST DETECTED IN GROUNDWATER - IEL
«•
CONSTITUENT CONCENTRATION RANGE (oob!
Residential Wells
Chromium (elemental) <5 - 11
Cyanide (Total) <2.3 - 26
Copper (Total ) <4 - 356
Lead (Total) <1 - 15.5
Nickel (Total ) <7 - 43
Silver 0.4 - 12
Selenium (Total) <2 - 20
Vanadium ' <5 - 22
Zinc (Total) <8 - 733
15713C/02
-------
TABLE 5
CONTAMINANTS OF INTEREST DETECTED IN EXTRACTION
SYSTEM'GAS SAMPLES FROM THE INDUSTRIAL
EXCESS METHANE VENTING SYSTEM
Compound
Tenax
Collection
Sumtna
Canister
Vinyl Chloride
1,1-Oichloroethylene
trans 1,2-Dichloroethene
1,1-Oichloroethane
1,2-Dichloroethane
Benzene
Tri chloroethy1ene
Toluene
Tetrachloroethylene
Ethyl Benzene
Xylenes
Styrene
m-Ethyl Toluene
C3 Alkyl Benzene
Methylene Chloride
1,1,1 -Tri ch-1 oroe thane
Chlorobenzene
C5 Hydrocarbons
C6 Hydrocarbons
C7 Hydrocarbons
C8 Hydrocarbons
C9 Hydrocarbons
CIO Hydrocarbons
NO I/
ppb -
620 ppb -1
NO
2200 ppb -'
280 ppb -1
1500 ppb -'
300 ppb -'
1200 ppb -1
1860 ppb -1
65 ppb
73 ppb U
400 ppb -1 -
Det.
Oet.
Det.
310 ppb -'
14 ppm -'
8.9 ppm -
8.0 ppm -
3.3 ppm -'
1.9 ppm -f
6.7 ppm
15713C/02
-------
TABLE 5 (Continued)
CONTAMINANTS OF INTEREST DETECTED IN EXTRACTION
SYSTEM GAS SAMPLES FROM THE INDUSTRIAL
EXCESS METHANE VENTING SYSTEM
Compound
Methane
Ethane
Propane
Propyl ene
Radon
Tenax Summa
Collection Canister
20%
60 ppm
4.4 ppm
10 ppm
516 picocuries/1 i ter
Notes: Anal. 1 - GC/MS Analysis of Tenax Portion of collected tubes.
Anal. 2 - Analyses of Summa Canister.
— Either not detected in analysis or reported concentration biased low due
to breakthrough of target compound to non-analyzed CMS portion of tube.
— Compound signal greater than the range of the instrument calibration.
— Reported values are sums of all measured concentrations of individual
compounds belonging to the specific family of chemical compounds.
Det. - Compound detected but not quantified because of either interferences
in its spectra or no calibration curve for the compound.
1 C 7 i -,<- ir>-~.
-------
-7-
to carcinogenic PAHs which were found in surface soil sanples
outside the site boundary. It does not appear that these
contaminants are related to waste disposal activities at the
site. This area is presently covered with clean fill which
mitigates the threat to public health from direct contact.
For noncarcihogenic effects, hazard indices are all less than
one, for both on-site soils and off-site soil analyzed.
o Long-term (lifetime) consumption of groundwater containing
maximum measured levels of landfill-derived carcinogens
exceeds the 10~6 risk level. The risks are associated with
1,2-dichloroethane (3 x 10~5), benzene (1 x 10~5),
tetrachloroethane (4 x 10~6), and vinyl chloride (5 x 1CT4).
Two year exposure hazard indices for children exceed one for
critical effects subgroups for combined concentrations of
barium and zinc, and lead and manganese.
o Upper bound excess lifetime cancer risk from exposure to
contaminants in air, based on the modeling of emissions from
the landfill flare to the nearest house, are above the 10"6
. level for both children (3 x 1CT6) and adults (6 x 1CT6).
Virtually all of the risk is associated with the presence of
1,1-dichloroethene (up to 5 x 10~6 risk alone) and 1,2-
dichloroethane (up to 2 x 10"^ risk alone).
Table 6 summarizes the contaminants of interest that exceed allowable
exposure based on the risk assessment.
With regard to the risks associated with the air contaminants discussed
above, it should be noted that the data used for this assessment was
obtained during the direct and downwind sampling of the plume produced
by a candle flare which was initially installed at the site. This flare
has since been replaced with a ground flare which is expected to achieve
an increased destruction of the chlorinated organics responsible for the
calculated upper bound cancer risk levels. Sampling data obtained
subsequent to replacement of the candle flare has shown undetected
contaminants in the exhaust gases of the ground flare.
VU. Description of Alternatives
Based on information gathered during the remedial investigation, it was
determined that the remedial alternatives considered should address two
major areas of concern: 1) the landfill waste/soil mixtures, coupled
with the resulting landfill gas production; and 2) the contaminated
groundwater.
Curing the FS, numerous technologies were identified and evaluated to
address the problems at IEL. Applicable technologies were screened in
more detail to limit the number to be retained for detailed evaluation.
The technologies retained for the areas of concern at TFT, are presented
-------
TABLE 6
CONTAMINANTS OF INTEREST
THAT EXCEED ALLOWABLE EXPOSURES
BASED ON THE RISK ASSESSMENT
Soils/Waste Groundwater
Carcinogenic PAHs 1,2-Dichloroethane
Benzene
Tetrachloroethene
Vinyl Chloride
Barium
Nickel
Air
1,1-Oichloroethene
1,2-Dichloroethane
1S713C/C2
-------
-8-
below:
Media/Area
Contaminated Ground water
Landfill Gas
Waste/soil mixture
Technology
Extraction; Air Stripping;
Precipitation/Floe-
culation/Sedimentation ;
Filtration; Carbon Adsorption;
Discharge to Metzger Ditch
Active Collection and Flaring
Capping
All waste/soil mixture treatment technologies were eliminated before the
detailed evaluation portion of the FS. The treatment technologies were
not practicable to inplement because of the large volume (2 million
cubic yards) of heterogenous waste, the lack of "hot spots" of
concentrated contamination, and the difficulty, risk, and cost
associated with conducting a treatment operation. As with nearly every
landfill site on the NFL, containment was found to be the most effective
technology for the waste/soil mixture.
Three alternatives were evaluated in the detailed evaluation portion of
the FS and are briefly described below.
A. Alternative 1 - No Action:
The only response actions associated with the No Action alternative are
the installation of a fence to restrict site access; institutional
controls; and continual monitoring. No further corrective actions would
be taken at the site. Operation and maintenance on the existing methane
venting system (MVS) would be continued by OEPA. the proposed alternate
water system would be implemented as planned, and the in-home air
strippers would remain in place until the water system is on line.
Operation and maintenance would consist of routine monitoring in order
to assess changes in the location and concentration of the contaminant
plume.
Construction Cost: $88,000
Annual O & M: $94,000
Total Present Worth: $864,000
Time to inplement: 3 months
B. Alternative 2A - RCRA Cap, Expanded MVS, Ground water Punp & Treat:
The major components of this alternative are: Fence, institutional
controls, monitoring, RCRA cap, expanded MVS, groundwater collection,
treatment, and discharge to Metzger Ditch.
A fence would be installed to restrict site access. A multilayer cap
would be placed over the site to prevent direct contact with waste
-------
-9-
materials, and prevent infiltration of surface water into contaminated
materials. The cap would be constructed in accordance with KCRA
regulation and guidance, and seeded following construction.
Institutional controls would be imposed to restrict future use of the
site property. For example, the site could not be used as a park, or
for any type of construction. Upon completion of the remedy, the site
would essentially appear as it does now, a large grassy field.
•Die existing methane venting system (MVS) would be expanded to
accommodate increased potential for lateral landfill gas migration due
to the cap.
Groundwater would be collected by a number of extraction wells. The
collected water would be treated, as necessary, by air stripping, carbon
adsorption and flocculation/ sedimentation/filtration to achieve
compliance with the Clean Water Act discharge criteria. The groundwater
collection system would remove the contaminant plume. Indirect
containment would be achieved by lowering the water table, thereby
preventing contact between groundwater and landfill waste materials.
Preventing infiltration by capping the site should result in a lowering
of the groundwater table. In order to protect groundwater from
additional contamination by the landfill, perpetual grcundwater
extraction to maintain a depressed water table may be necessary.
Groundwater treatment would continue only as long as necessary to attain
discharge criteria as required by the Clean Water Act. The criteria are
developed during design and are based on specific site characteristics
such as influent concentrations, location of discharge point, volume and
flow of water in Metzger Ditch, usage of Metzger Ditch, relationship to
other surface water bodies, etc. These criteria may or may not be less
stringent than Safe Drinking Water Act criteria, and the possibility
exists that the extracted groundwater will not need to be treated or
will only be treated for a limited period of time.
As stated above, the purpose of installing a cap over the landfill is to
prevent surface water from coming into contact with buried wastes.
Because wastes were dumped right up to the edge of TFT/s property lines,
the proposed cap will have to extend beyond the perimeter of the site in
order to be fully effective. Based on the conceptual cap design, U.S.
EPA will need at least fifty feet of land adjacent to the northern,
western and southern boundaries of the landfill. U.S. EPA may need
additional footage to ensure continued access to the cap over the long
term. In addition, U.S. EPA proposes to use land along Cleveland Avenue
as a staging area for construction activities and for a water treatment
facility. Current projections indicate that the following properties
would be needed: the staging area would comprise six properties along
Cleveland Avenue - a vacant lot, four occupied residences, and one
vacant real estate office (See Figure 5). Other properties necessary
for the construction of the cap and future access include three
residences and one vacant lot immediately adjacent to the site along
Hilltop Avenue, one residence adjacent to the northwest corner of the
site, two businesses immediately west of the site on Cleveland Avenue,
-------
/ .
*•''
APPROXIMATE
LIMIT OF THE CAP
D A.TE
OCT.. use a
INDUSTRIAL EXCESS LANDFILL
STARK COUNTY, OHIO
CAP OPTION I
FIGURE
-------
-10-
the home at the southwest corner of the site, two residences and two
vacant lots immediately adjacent to the site along Amber Circle, and the
property adjacent to the southern site boundary. U.S. EPA will use the
conceptual design estimates to proceed with the necessary land
acquisition immediately.
land acquisition at TFT, will be handled in accordance with the Uniform
Relocation Assistance and Real Property Acquisition Policies Act, 42
U.S.C. 4601 et sea.. and corresponding regulations (40 CFR Part 4). The
Uniform Act is designed (1) to ensure that citizens whose land is needed
for a federal project are justly compensated; and (2) to enable those
homeowners and businesses who are forced to move to relocate with as
little hardship as possible. In those cases where the Agency needs only
a portion of a landowner's property and the owner will be left with "an
uneconomic remnant," the Agency will offer to acquire the entire
property. 42 U.S.C. §4651(9). The Uniform Act defines an uneconomic
remnant as "a parcel of real property in which the owner is left with an
interest after the partial acquisition of the owner's property and which
the head of the Federal agency concerned has determined has little or
no value or utility to the owner." U.S. EPA has determined that the
following properties will be left with an uneconomic remnant: one
residence at the northwest corner of the landfill, three residences and
one vacant lot adjacent to the landfill along Hilltop Ave., 2 businesses
adjacent to the landfill along Cleveland Ave., and one residence at the
southwest corner of the landfill. The details of property acquisition
will be worked out with individual owners on a case-by-case basis.
Where an uneconomic remnant will result from the Agency's acquisition,
some owners may nevertheless prefer to sell only that portion of their
property required for the landfill cap, while others may elect to sell
their entire property.
Cperation and maintenance will include regular inspection of the cap for
signs of settling, damage due to burrowing animals, deep-rooted plants,
etc., and any necessary repairs. Periodic fertilization and mowing of
the vegetative cover will be required. Continual operation and
monitoring of the ground water extraction system will include equipment
maintenance, sludge removal, replacement of spent carbon, and sampling
and analysis of effluent. The performance of the MVS will be monitored
through routine sampling of gas monitoring wells. Regular inspections
will be conducted and equipment will be replaced as necessary.
Construction Cost: $14,957,000
Annual O & M: $440,000
Total Present Worth: $18,548,000
Time to implement: 12 - 18 months
C. Alternative 2B - RCRA Cap with Retaining Wall, Expanded MVS, Grcundwater
Pump & Treat
The major components of this alternative are: Fence, institutional
-------
-11-
controls, monitoring, RCRA cap with retaining wall, expanded MVS,
groundwater collection, treatment and discharge to Metzger Ditch.
The components of this alternative are identical to those of Alternative
2A, excepting the addition of a retaining wall to the cap design, which
would reduce the amount of adjacent land required for implementation.
There are no functional differences between the alternative. Ihe
retaining wall would be used to limit the extent of the cap along all of
the western and portions of the northern and southern boundaries of the
site. The retaining wall would be 6 to 8 feet in height and designed to
contain the material comprising the RCRA cap. This alternative would
require the acquisition of approximately 25 feet of the properties
adjoining the portion of the site with the retaining wall. _
Approximately 50 feet would be required of the properties immediately
north and south of the site which are not adjacent to the retaining
wall. The staging area and water treatment facility would be located in
the same location and require the same property acquisition as described
in Alternative 2A (see Figure 5).
Operation and maintenance for this alternative would be similar to that
which was described in Alternative 2A. Additional maintenance would be
required for the retaining wall.
Construction Cost: $15,845,000
Annual O & M: $462,000
Total Present Worth: $19,644,000
Time to implement: 12-18 months
VTTT. Summary of Comparative Analysis of Alternatives
The three alternatives carried through to the detailed evaluation
portion of the FS were evaluated against the nine criteria listed below:
1. Overall Protection of Human Health and the Environment addresses
whether or not a remedy adequately eliminates existing or potential
risks, and describes how risks are eliminated, reduced through
treatment; engineering controls, or institutional controls.
2. Compliance with ARARs addresses whether or not a remedy will meet
all of the applicable or relevant and appropriate requirements (ARARs)
of other environmental statutes and/or provide grounds for invoking a
waiver.
3. long-term effectiveness and permanence refers to the ability of a
remedy to maintain reliable protection of human health and the
environment over time, once the remedial goals nave been met.
4. Reduction of toxicity, mobility, or volume evaluates the anticipated
performance of the treatment technologies a remedy may employ.
5. Short-term effectiveness involves the period of time needed to
-------
-12-
achieve protection and any adverse impacts on human health and the
environment that may be posed during the construction and implementation
period until remedial goals are achieved.
6. Implementability is the technical and administrative feasibility of
a remedy, including the availability of goods and services needed to
implement the chosen solution.
7. Post includes capital and operation and maintenance (O&M) costs.
8. Support Agency Acceptance indicates whether, based on its review of
the remedy, the support agency (OEPA) concurs, opposes, or has no
comment on the Record of Decision.
9. Community Acceptance are assessed in the Responsiveness Summary of
this Record of Decision.
Each of the three alternatives was evaluated against the nine criteria
and then compared to one another. A tabular summary of the comparison
is presented in Table 7 and a narrative summary is presented below:
* Overall Protection of Human Health and the Environment:
Alternative 2A and 2B are protective of human health and the
environment, by extracting and treating contaminated
groundwater and landfill gas, and by containing the landfill
wastes. The no action alternative allows for continued
infiltration of surface water into the waste and continued
contamination of groundwater from the wastes.
* Compliance with ARARs: Alternatives 2A and 2B comply with
identified ARARs. The no action alternative does.not comply
with ARARs and does not qualify for a statutory ARAR waiver.
* Long-term Effectiveness and Permanence: Alternatives 2A and
2B provide long-term effectiveness through a well designed and
operated and maintained containment system. The water table
"level will be lowered because infiltration of surface water
will be minimized. In addition, in order to protect
groundwater from any additional contamination by the landfill,
the groundwater will be pumped to lower further the water
table. The expanded MVS system will control landfill gas and
increase the effectiveness of the cap. Long term operation,
maintenance, and monitoring is required for Alternatives 2A
and 2B. The groundwater treatment system provides the only
permanence associated with these alternatives. The no action
alternative is not effective in the long-term and has no
permanent components.
* Reduction of Toxicity, Mobility, or Volume:
The principal component of alternative 2A and 2B is
containment, with elements of treatment. These alternatives
-------
TABLE 7
OMWATIYE SLWW OF R&EDIAL ALTERNATIVES
Evaluation Cn'teria
ALTERATIVE 1
to Action
ALTERNATIVE 2
w/Cap Option 1
without Wall
ALTERNATIVE 2
w/Cap Option 2
with Wall
Short-term Effectiveness
Lonc-term Effectiveness
Reduction of toxicity,
mobility and volirre (TMV)
Irrplerreatability
Cost (a)
Carpi iance with ARARs
Overall Protection of Knan
fealth and the Environment
State Acceptance
Ccrmunity Acceptance
Not effective
Not effective
No reduction in TMV
except for the partial
destrution of landfill
gases by the existing
KV5 and flaring.
Not applicable
$864,000
Does not attain ARARs
existing conditions
are not altered.
Results in unaccept-
able health risks,
Wiich exceeds 10
Provides snort-term Provides short-term
effectiveness effectiveness
Provides long-term Provides long-term
effecti veness effecti veness
The flaring of
landfill gases
provides a reduc-
tion of toxicity,
nobility, and
volurre for the
gaseous media.
Inplerrentable, bat
requires land
acquisition.
$18,548,000
Complies with
ASARs
The flaring of land-
fill gases provides
a reduction of
toxicity, mobility,
and voltne for the
gaseous rredia.
Land acquisition
requirements are less
than those for
Option 1.
$19,644,000
Carpi ies with
ARARs
Provides overall Provides overall
protection of hurran protection of human
health and the 'health and the
environrrent. envirornent.
Does not accept Accepts
Does not accept
Very limited
acceptance
Accepts
Very limited
acceptance
-------
-13-
provide no treatment to reduce the toxicity, mobility or
volume of contaminants associated with the landfill waste
material. Alternatives 2A and 2B utilize treatment to reduce
the toxicity, mobility and volume of contaminants in the
landfill gas through the continual operation of the MVS, which
effectively destroys gaseous contaminants via combustion. The
mobility of contaminants in ground water is reduced by
extraction and treatment. Volume and toxicity of contaminants
are reduced, to a lesser degree, through the regeneration of
spent carbon used in the treatment of groundwater. The no
action alternative provides no reduction in the toxicity,
mobility, or volume of contaminants.
* Short-term Effectiveness: The time to implement Alternatives
2A and 2B is 12 - 18 months. Increased volume of construction
traffic will present some short term risks to the community,
as will the excavation of landfill material necessary to
expand the existing MVS. Construction of the containment
system and water treatment facility will present little risk .
to the community. It is estimated that extraction and
treatment of the existing groundwater contamination will take
approximately 3 years. Thereafter, the pumping of groundwater
may need to continue indefinitely in order to protect
groundwater from additional contamination by the landfill.
The no action alternative takes only 3 months to implement and
has no additional short-term risks.
* Implementability: All components of Alternatives 2A and 2B
are proven technologies which are widely used and easily
implementable. [Delays due to technical difficulties are not
likely. However, administrative delays are possible, with
regard to the acquisition of privately owned property. The no
action alternative presents no implementability problems.
* Cost: Alternative 2A is less expensive than Alternative 2B.
The no action alternative is the least costly as it requires
.only fencing, monitoring, and operation of the existing MVS.
* State Acceptance: The State of Ohio concurs with the selected
remedy. No action is not acceptable to the State.
* Community Acceptance: The community's comments are summarized
and responded to in the Responsiveness Summary.
IX. Selected Remedy
A: Remedy
Based on the evaluation of the alternatives, U.S. EPA selects
Alternative 2A - fence, use restrictions, RCRA cap, expanded MVS, ground
water extraction and treatment, and in order to protect groundwater
-------
-14-
from additional cxsntamination by the landfill, continual groundwater
pumping to maintain lowered water table - as the remedy for the ITT,
Site. The selected remedy is protective of human health and the
environment, attains ARARs, and provides the best balance among the nine
evaluation criteria. By containing the source area to prevent further
groundwater contamination, extracting and treating already contaminated
groundwater, and extracting and flaring landfill gas, the selected
remedy reduces the risk posed by the landfill to an acceptable level.
In combination with the alternate water supply operable unit, the
selected remedy eliminates the threat of exposure to contaminated
groundwater. The chemical specific ARARs and TBCs must be attained in
the groundwater beneath the IEL site and at all points beyond the site
where contaminated groundwater has migrated. Landfill gas
concentrations beyond the site boundary shall not exceed 5 percent
methane. The cleanup levels and performance standards to be achieved by
the selected remedy are presented in Section IX(B).
B. Detailed Remedy and Design Riase Studies Descriptions:
The following is a detailed description of the selected remedy and the
minimira design studies necessary to collect information for design of
the various remedy components. Detailed work plans will be developed
for the design studies to be conducted.
1) The Groundwater Component:
The two main objectives of the groundwater pump and treat component of
the remedy is to:
o Maintain a lowered water table in order to protect groundwater
from additional contamination by the landfill,
o Ensure that the existing contaminated groundwater within,
beneath, and off the site is intercepted, before it has a
chance to move downgradient, and extracted. Extracted
groundwater will be treated to meet discharge criteria.
As mentioned in the RI Report, the water levels in installed monitoring
wells indicate a mounding of groundwater within the landfill. This
situation is most likely due to the accumulation of precipitation which
has percolated through the permeable soil materials used to cover the
site. As a result, portions of the wastes and contaminated soil in the
landfill are likely saturated with groundwater. To alleviate this
situation, A RCRA cap will be installed to prevent surface water
infiltration and, in order to protect groundwater from additional
contamination by the landfill, groundwater extraction wells will be
installed to further lower the water table beneath the landfill. As a
result, there will be reduced contact between the wastes/contaminated
soils and groundwater.
a) Groundwater Extraction
-------
-15-
The conceptual strategy for groundwater extraction was developed
using site specific information from the Remedial Investigation
(RI) Report. During the RE, hydrogeologic characteristics were
determined from rising head tests, water level measurements and
logs from monitoring well borings.
Extraction rates are based on equilibrium flow conditions in an
unconfined (water table) aquifer. Steady state conditions were
used since pumping is expected to be steady and continuous. The
objective was to design a well system that will be effective over
the entire zone of contamination while still minimizing the total
quantity of water needing to be extracted. The throughput rate at
which the water can be economically treated was also considered.
The conceptual system used for cost estimating purposes consists of
four extraction wells located on and around the landfill as shown
on Figure 6. Each well will be pumped at a rate of approximately
400 gallons per minute.
Contamination was found in the shallow monitoring wells, with the
wells located closest to the actual landfill waste (MW01S, MW33S,
MWD4S, MW04S, MW05S, and MW07S) showing the most contamination. In
addition residential wells RW05, RW38, RW39, RW07, RW08, RWD9,
RW40, and RW11 also exhibited various levels of contamination. The
shallow monitoring wells were screened at 5 to 42 feet below the
surface of the ground. Figure 7 shows the locations of all
groundwater samples taken at the site. This includes installed
monitoring wells, the residential wells sampled, and two existing
irrigation wells (located due east of the landfill) used as
monitoring wells. At the TEL site, large variations in surface
elevation and the depth to the water table exists, varying from a
few feet to approximately 45 feet below the ground surface.
Assuming that all groundwater less than 40 feet below the surface
of the water table is contaminated, the bottom of the extraction
well screen will be set at a maximum depth of approximately 85
feet.
Utilizing the previously stated assumptions, the volume of
contaminated groundwater was calculated to be approximately 256
million gallons. For the purpose of estimating the duration of
treatment, it is assumed that three pore volumes of water (768
million gallons) will have to be extracted to reduce contamination
in the aquifer to drinking water criteria.
Based on a total pumping rate of 1,600 gpm and a total volume of
768 million gallons, the duration of pumping is estimated to be 3
years. However, in order to maintain the lowered water table,
pumping may continue indefinitely, but at least as long as
necessary to protect groundwater from additional contamination by
the landfill. Treatment of these extracted groundwaters will be
necessary until the discharge concentrations meet NPDES
-------
I UNIONTOWN
Lirr.it c? r/etals /
Ccnt£rr.in£uCn from !EL
Proposed
Groundwater
Extraction Wells and
Their Radii of
Influence
Limit of Organic Contamination From
. IEL (including TICs)
La*e Center Roac
lie Accrcxi.T.ate. 1" - 1100'
INDUSTRIAL EXCESS LANDFILL
STARK COUNTY.O'IO
FIGURE 6
Groundwater Extraction Wells ar.d Their Radii cf
Influence
C.C. JOtfiSON 4 MALHOTRA. P.O.
-------
Scale As:rci
1100'
• Residential Well Location
Q Monitoring V/ell Location
INDUSTRIAL EXCESS LANDFILL
STARK COUNTY.OKIO
Figure 7
GROUNOWATER SAMPLES
Residential and Monitoring Wells
(95 TOTAL SAMPLE LOCATIONS;
C.C. JCHNSCN i f.-ALHCTSA. P.C.
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-16-
requirements.
The following presents a preliminary recommendation for a
monitoring program which may be implemented at the TFT, site: eight
wells (five shallow, three deep) would be installed downgradient
(west) of the landfill and four (two shallow, one deep and one
intermediate) installed upgradient (east) of the site. In
addition, wells should be installed both to the north (two shallow
and one deep) and the south (two shallow and one deep) of the
landfill. The exact number and location of these wells will be
determined as the initial wells are installed. The depth of these
wells will be dependent upon their location. Shallow wells should
be installed at the top of the water table with deep wells
installed in bedrock.
The new monitoring wells will be installed to serve multiple
purposes. The exact location of these wells will be selected to
assist in further defining the specific areal and vertical extent
of groundwater contamination at the IEL site. They will also be
located to provide additional definition of the "mound" at IEL.
Water level elevation measurements obtained from the array of
existing and newly installed monitoring wells will be used to
provide information concerning flow interactions between Metzger
Ditch and local/regional groundwater.
These wells will also serve to define the eastern extent of
potentially contaminated groundwater flowing from the mound before
changing direction and becoming part of the western regional flow.
The new and the existing monitoring wells will be sampled and
analyzed to further define the groundwater characteristics at and
around IEL. The exact location of the new wells and the
monitoring program will be determined during the RD phase. At this
time the sampling and analysis of groundwater are assumed to be
performed on a quarterly basis druing the first 5 years and
semiannually thereafter. Samples would be analyzed for the full
CLP PAS organic and inorganic compound list in the beginning of the
program and for compounds of concern later on. Conventional
parameters shuch as chloride, sulfate, nitrate, nitrite, specific
conductivity, and alkalinity will also be determined. Radiological
scans will be conducted in accordance with the Safe Drinking Water
Act (i.e. Gross Alpha and Gross Beta) and Analytical l>i-
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-17-
At least two such tests will be conducted, one to the north and one
to the south of the landfill. In the performance of the pumping
tests, piezometer wells will be installed and monitored to evaluate
the drawdown resulting from various punping scenarios. These
piezometers will also serve to establish water levels and assist in
the definition of groundwater flow north, east and south of. the
site ("the mound" and the affects of Metzger Ditch). This testing
program used in conjunction with data from the monitoring well
program will determine the ultimate location of the extraction
wells. The information collected during the design may indicate
modification of the conceptual design is necessary. Such
modifications may affect the number, location, and pumping rate of
the groundwater wells and the number of pore volumes of water to be
removed in order to achieve cleanup levels.
The capital/construction costs for the conceptual groundwater
extraction system are estimated to be $925,430. The annual O&M
costs for this system are estimated to be $154,034. Present worth
costs, based on a 10% discount rate, and carried over a three year
period (the estimated duration of groundwater treatment
activities), are estimated to be $550,710.
b) Groundwater Treatment
The groundwater will be treated to NPDES effluent discharge
standards established for Metzger Ditch. 'The treatment system
would consist of a oxrntercurrent, packed stripping column,
activated charcoal and flocculation, sedimentation and filtration.
The treated effluent will then be pumped and discharged into
Metzger Ditch. If treatment is not necessary, it will not be
provided. Contaminant concentrations in extracted groundwater may
be below NPDES effluent discharge standards allowing for direct
discharge to Metzgers Ditch without treatment.
Flocculation. Sedimentation Filtration - Flocculation/sedimenta-
tion/filtration are combined with air stripping and carbon
adsorption to treat the inorganic contaminants of concern (e.g.
barium and nickel) as well as other metals that may be present.
Flocculation and sedimentatiaon will be used to remove these
compounds. Lime will be used as a coagulant because it is able to
achieve 88 to 95 percent removal of all of these compounds. The
additon of lime would raise the pH to between 8 and 9 causing
dissolved metals to form insoluble metal hydroxides. With the aid
of polymer, insoluble constituents of the waste stream will
aggregate and settle in the settling tank. The treated water will
be filtered to remove residual floe, and acid will be added to
readjust the pH. Sulfuric acid was used to calculate the cost of
pH adjustment. To reduce pressure loss through the filter, it must
be periodically backwashed. This backwash from filtration would be
recycled through the treatment system. The effluent from the
neutralization tank will then be pumped to the air stripper and
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-18-
granular activated carbon unit to remove VDCs.
The other effluent stream for this treatment system is sludge from
the sedimentation process. A plate and frame filter press vil?
used to dewater this sludge. This sludge, which will likely
contain elevated concentrations of barium, nickel and other metals
may be ccnsiiered a Hazardous waste. As such, it zust be managed
as a hazardous waste (i.e., solidified prior to disposal in an
approved, RCRA compliant landfill). The liquid filtrate from this
process will be recycled through the treatment system.
Air Sta-ipper - A pre-designed, portable package-type air stripping
unit, available from several vendors, will be utilized to treat the
groundwater. Based on a flow rate of 1600 gpm, an air stripper 5
feet in diameter containing 20 feet of packing material (1.5 inch
polypropylene rings) will be required. This configuration assumes
an air to water ratio of 30:1. The air stripper will be
constructed of Fiberglass reinforced plastic and can be placed
onsite on a concrete pad.
Following installation, groundwater will be pumped to the top of
the air stripping column at a rate of approximately 1600 gpm where
the influent water will spread thinly over the plastic packing
media in the column as it falls. Air blown upwards through the
packing removes the VDCs from the water by mass transfer. The
discharges from the air stripper shall comply with Federal and
State regulations and requirements.
Mass balance analysis of air and water flows will be used to
monitor the air stripper's performance and efficiency. The results
of these analyses would be used to adjust air to water ratios.
Following the air stripper the groundwater will pass through a
granular activated carbon adsorption (GAG) unit.
Granulated Activated Charcoal - The GAC adsorption system would be
a package unit consisting of two two-in-series 10 feet diameter
carbon columns operated in parallel. Each vessel will contain
approximately 20,000 Ibs. of carbon and will operate at an
individual flow rate of 800 gpm (1,600 gpm overall) in series
configuration. When the carbon has reached its capacity for
effective contaminant removal (breakthrough) in the lead colunn,
that column will be refilled with virgin or regenerated carbon.
Effluent from the second carbon column will be discharged to the
Metzger Ditch along the eastern boundary of the site. Through the
use of the two two-in-series units greater flexibility and
performance capabilities are possible.
The exhausted carbon will be returned to the vendor supplying the
carbon for regeneration. The carbon can be regenerated if PCEs,
dioxin or dibromochloropropane are not present in the contaminated
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-19-
carbon. TET/s groundwater does not contain any of these
contaminants. Therefore, regeneration will be possible. The
treated grpundwater will than be discharged to the Metzger Ditch.
c) Groundwater Disposal
The treated groundwater effluent will be pumped from the onsite
treatment system to the Metzger Ditch which flows along the eastern
portion of the landfill. Water will be conveyed to the ditch
through approximately 600 feet of ten-inch diameter ductile iron
pipe. The effluent will be continually monitored to ensure
compliance with NPDES discharge criteria for Metzger Ditch.
The Metzger ditch flows through two counties, Stark County and
Summit County, and ultimately flows into the Tuscarawas River. The
portion of the ditch within the Stark County boundary was last
dredged in 1975 to facilitate drainage of the surrounding farm
lands and residential property.
The ditch was constructed to handle a maximum flow rate of
approximately 100 ft 3/sec. In Summit County, it is estimated that
the ditch is able to handle similar flow rates. The effect of a
1,600 gpm discharge from the water treatment system to the Metzger
Ditch should be minimal even if 50 percent deterioration of the
ditch capacity is assumed. The Tuscarawas River is the discharge
point of the Metzger Ditch. The river is designated a warm water
aquatic life habitat and is mainly utilized for agricultural,
industrial and recreational activities.
The system will be required to meet the National Pollutant
Discharge Elimination System (NPDES) requirements for surface
discharge. Daily collection of effluent samples and flow
measurements will be required to ensure compliance with these
' requirements. Sampling and flow monitoring will be the
responsibility of the treatment system operating personnel.
d) Groundwater Monitoring
Groundwater monitoring will be required during and after the
implementation of each of the remedial alternatives. Monitoring
will help determine the effectiveness of the remedy and ensure that
further migration is not occurring. Installation of additional
monitoring wells will be required at the IEL site. Compliance
monitoring to determine when groundwater cleanup levels have been
achieved shall be conducted at points beneath the landfill and
along the contaminant plume extending from the landfill to off-site
areas. The exact number and location of these wells will be
determined during performance of the design study. A monitoring
program will be developed to check the effectiveness of the cleanup
and to determine if adjustments to the extraction system are
necessary. The monitoring frequency and analytical parameters will
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-20-
be determined based on the system design to ensure adequate
information is collected.
2) The Soil/Waste Component
This remedy requires the installation of a RCRA cap over the
surface of the landfill. In order to maintain the appropriate side
slopes, this design requires substantial intrusion onto the
adjacent property.
RCRA Cap
Installation of the cap will involve the excavation and removal of
the highest areas, filling in the low lying areas with landfill
surface materials (including wastes) removed during
grading/excavation operations, grading the area, and then capping.
Following excavation/filling the site will be graded and the
operation begun.
Capping techniques are used when iraterials are to be buried or left
in place. These techniques are particularly applicable when the
waste is an extensive subsurface deposit and excavation and removal
are not practicable. Multilayer caps are preferred, especially in
the midwest where swelling and shrinking of the clay layer is a
problem. The synthetic layer helps to prevent excessive swelling
shrinking of the clay layer. The IEL cap design will appropriate
site specific factors into account, including erosion, water
balance, settling, and permeability-
Capping of the contaminated area presently calls for the
construction of a three-layered cap conforming to RCRA guidelines
(See Figure 8). The area to be capped is outlined on Figure 5 and
encompasses approximately 30.0 acres. This operation will first
consist of the placement of a two to three foot clay liner,
conpacted in six inch lifts. A twenty-mil synthetic liner will
then be placed over the clay. Next, a one-foot thick drainage
layer of gravel will be spread and overlain with geotextile fabric.
The geotextile fabric will maintain the drainage layer and help to
stabilize a final layer of two feet of top soil by keeping fine top
soil particles from filling the pore space of the gravel layer.
The top soil will be vegetated to prevent erosion. A drainage
channel will be constructed to direct surface run-off to the
present site drainage (Metzger ditch).
Precipitation that percolates through the top soil will flow
laterally through the gravel and over the impermeable synthetic and
clay barrier and into the drainage channels.
While constructing the cap, provision will be made to retain the
present MVS, and extend it as described later in this ROD.
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FIGURE 8
TYPICAL CROSS-SECTION OF A CAP
3 % minimum slope
f * *_ _M__J
2'
TOPSOIL
-FILTER FABRIC
•' '.'•'• •] '. ••'.'•'' • .'Gravel
: 2 O MIL S YN THE TIC LI HER:
•1' • • •
WA S TE
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-21-
Ihe engineering considerations for a cap include:
o Determination of total area to be covered by defining the
vertical and horizontal boundaries of the waste to be
capped
o Determination of the volume of material required for
cut/fill
o Design and construction of the cap to prevent erosion or
subsidence as per RCRA guidelines/standards
o Site preparation to achieve required slopes
o location of a collection system for stabilization of cap
surface water run-off before being discharged
o Extension of the present Methane Venting System.
The major construction equipment required for the implementation of
this alternative include:
o Bulldozer
o Hydraulic excavator
o Front end loader
o Dump trucks
o Compactor
o Hydroseeding equipment
Due to the presence of very marshy and peaty conditions along the
eastern portion of TFT, (along Metzger Ditch), the soil may require
stabilization for heavy equipment to work.
The cap will be inspected on a regular basis for signs of erosion,
settlement, or subsidence. It is recommended that inspections be
conducted frequently in the first six months because problems are
most likely to appear during this period. Maintenance of the final
cap would include application of fertilizer and periodic mowing to
prevent invasion by deep rooted vegetation. Any signs of
unexpected settling or subsidence should be addressed immediately
by removing the overburden and repairing the affected areas.
Air monitoring will be required during construction to ensure that
a safe working environment is maintained and that no threat to
public health or the environment is created by air emissions from
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-22-
the site during construction.
It may be necessary to install a clay liner which is thicker than
that usually recommended for a RCRA cap. The additional clay will
be designed to provide extra coverage for the manifold piping if
the design of the extended MVS call for the piping to be below the
cap.
3) Die Air/Gaseous Emission Component
The remedy calls for installing active gas extraction wells at
selected locations at the landfill. The number and locations of
wells to be installed within the landfill will be determined as a
result of gas extraction tests conducted during the RD phase. The
extraction wells will be connected using a head/manifold piping
system which will ultimately end up at the blowerhouse and ground
flare. Thus, this extended methane venting system (EMVS) will be
interconnected with the MVS currently in place.
The purpose of these wells will be to: 1) relieve gas pressures
within the landfill, and 2) extract methane and other volatile
gases emanating from within the landfill and to direct these gases
so that they do not migrate off site.
During the RD phase gas extraction tests will be performed at the
TFT, site. These tests should consist of several installed
extraction wells and corresponding gas monitoring probes. The
exact number and location of these extraction wells will be
determined prior to initiation of this program. At this time, U.S.
EPA estimates that at least three such extraction test wells will
be installed at TFT.. Around each test extraction well, at least
five pressure probe nests (3 wells each) will be installed. These
nests will be located to measure pressure changes (as well as
static pressure) throughout the depth of the landfill.
These tests will be used in a model to determine the existing gas
pressure within the landfill (static pressure) and to design the
MVS at TFT.. The objective of the tests is to ensure that the MVS
will be adequate in capacity and location to prevent migration of
the landfill gasses from the site. The system will also be
designed to ensure the integrity of the RCRA cap, (e.g., problems
due to pressure build-ups). It is important to realize that to
achieve both of these objectives the pressure beneath the cover
needs to be slightly higher than atmospheric to prevent the flow of
oxygen and nitrogen into the landfill. The MVS system must also be
designed to ensure that this pressure differential is maintained
without excessive buildup. The existing MVS monitoring well system
will be expanded as part of the design of the overall MVS.
It will also be necessary during these tests to collect additional
gas samples to define the specific gas characteristics to ensure
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-23-
the designed system will be effective in the collection and
treatment of these gases. During the drilling of the on-site
groundwater monitoring wells, gas samples will be collected at
various depths within the landfill ranging from the surface to
maximum depth of waste disposal or to groundwater, whichever is
encountered first. Ihese samples will be analyzed for HSL
compounds, Padon, and will be screened for gross radiation.
Additional radioactive isotopes will be analyzed in the event the
gross screening indicates the potential presence of radioactive
elements. In the course of implementation of this system, ambient
air monitoring will be conducted as necessary.
4) Surface Water/Sediment Component
Surface waters contained in the ponds at IEL will be pumped to the
groundwater treatment system as necessary to meet NPDES discharge
criteria for Metzger Ditch. With the removal of the free water
above the sediments in the on-site ponds, these materials will be
dredged from the ponds and incorporated into the soil/waste mixture
for additional remediation. As necessary, these materials will be
dewatered.
As necessary, the sediments from Metzger Ditch will be dredged and
incorporated with the dredged pond sediments. Proper controls will
be exercised to minimize potential risks of releases from these
operations. An initial part or cnese monitoring efforts will be
the core sampling of sediments in Metzger Ditch adjacent to the
site to ensure RD/RA activities do not adversely impact the ditch,
and to refine previous data on contaminant movement into the ditch.
Core sanples will be analyzed for HSL organic and inorganic
compounds as determined in the sampling plan.
Monitoring of Metzger Ditch and all surface water discharges from
site operations during remediation will be performed and remedial
actions taken as necessary.
5) Land_Requirements
Additional land will be required during implementation of the
remedial action at the IEL site. A staging area will be needed in
order to accommodate the large equipment which will be used during
site remediation. Land will also be needed for construction of
the groundwater treatment plant. Figure 9 shows the location of
the land that needs to be obtained in order to effect the remedial
action at the site. In addition, approximately 50 feet along the
north, south and western boundaries of the site are necessary for
construction of the RCRA cap at 4:1 side slope, drainage ditches,
roadways and fencing as required to implement this alternative.
U.S. EPA will use the conceptual design estimates to proceed with
the land acquisition immediately after issuance of this ROD.
-------
INDUSTRIAL EXCESS
LANDFILL, INC.
I:;..-;...;_•-.-^'-i Approximate area of
|:.-.-Vv:v.-:..y| ^p beyond IEL site
cap beyond
Area for staging &
treatment plant
Scale Approximate, r - 280*
INDUSTRIAL EXCESS LANDFILL
STARK COUNTY, OHIO
FIGURE 9
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-24-
C. Community Participation Daring KD/RA
The community group at TFT,, Concerned Citizens of lake Township
(OUT), has requested U.S. EPA to provide a mechanism for
meaningful canraunity input during the TFT, remedial design and
implementation. U.S. EPA will form a Technical Advisory Committee
(TAG) made up of nnT representatives, other community members,
local officials, Ohio EPA representatives and U.S. EPA
representatives. Providing the TAG member's stipulation to
confidentiality and commitment to a schedule, U.S. EPA will provide
the TAG members the opportunity to review and comment on draft
design and other technical documents generated during the TEL
RD/RA. The TAG will hold regular meetings to review the progress
of the RD/RA and to discuss technical issues. All TAG comments on
draft documents will be submitted to U.S. EPA. U.S. EPA will
consider all comments received, but retains final decision
authority on the content of all documents. The Community Relations
Plan for RD/RA will be amended to reflect this agreed upon level of
community participation.
X. DocuiaaiiLation of Significant Changes
A. RCRA Cap
The containment portion of the preferred alternative described the
conceptual design of a RCRA multilayer cap consisting (from bottom to
top) of:
- clay liner
- 20 ml synthetic liner
- sand drainage layer
- filter fabric
- top soil and vegetation
Several public comments were submitted to U.S. EPA regarding the
multilayer cap's integrity in light of differential settling within the
landfill. The comment noted that differential settling may cause cracks
to form in the clay liner and rupturing of the synthetic liner. As a
result of this comment, U.S. EPA is clarifying the containment portion
of the preferred alternative to provide assurance that all appropriate
site specific factors will be considered during the design of the RCRA
cap, including settling, erosion, water balance, and permeability.
B. Groundwater Extraction and Treatment System and Design Studies
The FS and Proposed Plan described the conceptual design of a
groundwater extraction and treatment system. The conceptual design is
based on currently available information. The FS and Proposed Plan also
outlined the type of design study necessary to collect information to
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-25-
design the extraction and treatment system. U.S. EPA is modifying the
ROD to clarify that the conceptual design of the extraction and
treatment system may need to be modified based on information collected
during the design study. Such modifications may affect the number,
location, and pumping rates of the extraction wells. In addition, other
extraction methods, such as trenches or french drains may be used in
conjunction with extraction wells. The design study will examine
hydrogeologic conditions within, beneath and near the landfill and
whether NAPLs are present. U.S. EPA believes this clarification is
necessary to provide enough flexibility to design the most efficient and
effective extraction and treatment system.
C. Groundwater Extraction
The FS presented a groundwater extraction scenario which called for
perpetual pumping in order to maintain a lowered water table level.
However, if the RCRA cap is effective in preventing and reducing the
infiltration into the site, the groundwater level may be lowered without
the need for pumping or with only minimal pumping. In addition, as a
result of the groundwater design study, U.S. EPA may be able to design
an extraction and treatment system that provides for cleanup of that
portion of the landfill which may remain in the groundwater after the
cap is installed. U.S. EPA is modifying the remedy to clarify that
pumping of groundwater to lower the water table will be conducted in
order to protect groundwater from additional contamination by the
landfill. This length of time may be less than perpetuity. If the
extraction system is terminated, it will be started again should
contaminant levels indicate groundwater quality may be compromised.
This clarification is necessary to provide for cessation to groundwater
pumping in the future if circumstances warrant it.
D. land Acquisition
U.S. EPA is modifying the IEL remedy to clarify when the necessay land
acquisition shall commence. U.S. EPA is confident that at least 50 feet
of the properties on the northern, southern, and western borders of the
site must be acquired to install an effective RCRA cap and that six
complete properties adjacent to the western boundary must be acquired
for a staging area and to construct a groundwater treatment plant.
Accordingly, U.S. EPA will begin the acquisition procedures immediately
after the ROD is issued and the State of Ohio has given assurances that
it will accept transfer of the property following completion of the
remedial action in accordance with Section 104(j) (2) of CERCXA.
In those cases where the Agency needs only a portion of a landowner's
property and the owner will be left with "an uneconomic remnant," the
Agency will offer to acquire the entire property. 42 U.S.C. §4651(9).
The Uniform Act defines an uneconomic remnant as "a parcel of real
property in which the owner is left with an interest after the partial
acquisition of the owner's property and which the head of the Federal
agency concerned has determined has little or no value or utility to the
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-26-
owner." U.S. EPA has determined that the following properties will be
left with an uneconomic remnant: one residence at the northwest corner
of the landfill, three residences and one vacant lot adjacent to the
landfill along Hilltop Ave., 2 businesses adjacent to the landfill along
Cleveland Ave., and one residence at the southwest corner of the
landfill. The details of property acquisition will be worked out with
individual owners on a case-by-case basis. Where an uneconomic remnant
will result from the Agency's acquisition, some owners may nevertheless
prefer to sell only that portion of their property required for the
landfill cap, while others may elect to sell their entire property.
All other portions of the Proposed Plan are incorporated into this
Record of Decision without significant change.
XT. Statutory Determinations
The selected remedy is protective of human health and the environment;
attains ARARs; is cost effective, and utilizes permanent solutions and
alternative treatment technologies or resource recovery to the maximum
extent practicable. The selected remedy does not use treatment that
reduces the toxicity, mobility, or volume of the source of contaminants
as a principal element, however it does use treatment to address other
principal threats, contaminated groundwater and landfill gas.
The following is a summary of how the selected remedy meets or addresses
each of the five (5) statutory requirements:
A. Protection of Human Health and the Environment: The selected
remedy will protect human health and the environment by a
combination of engineered containment, treatment, and
institutional controls. The TFT, site is a source of ground
water contamination. Drinking water wells down gradient from
the landfill are contaminated with vinyl chloride, low levels
of organic solvents, and/or metals. Landfill gas generated
within the site contains volatile organic compounds. The
selected remedy will contain the wastes at the site and reduce
- significantly the infiltration of surface water into the
waste. The existing methane venting system will be expanded
to ensure landfill gas is collected and prevented from
building up beneath the RCRA cap. Existing contaminated
groundwater will be extracted and treated in an on-site
treatment plant. In order to protect groundwater from
contamination by the landfill, the groundwater beneath the
site may need to be pumped continually to maintain the water
table beneath the bottom of the site wastes. Land use
restrictions will be inposed on the site to prevent
incompatible future use of the property. The selected remedy
does not pose unacceptable short-term risks and will not cause
cross-media contamination.
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-27-
B. Attainment of the Applicable or Relevant and Appropriate
Requirements: The selected remedy will attain Federal and
State ARARs in accordance with Section 121 (d) (1) of CERCLA.
In addition, the selected remedy will proceed in accordance
with certain Federal and State environmental criteria,
guidance or policy to be considered (TECs).'
Applicable requirements are cleanup standards, standards of
control, and other substantive environmental protection
requirements, criteria or limitations promulgated under
Federal or State law that specifically address a hazardous
substance, pollutant, contaminant, remedial action, location
or other circumstance at a site. A requirement is
"applicable" if the remedial action or circumstances at the
site satisfy all of the jurisdictional prerequisites of the
requirement.
Relevant and appropriate requirements are cleanup standards,
standards of control, and other environmental protection
requirements, criteria or limitations promulgated under
Federal or State law that, while not legally "applicable" to a
hazardous substance, pollutant, contaminant, remedial action,
location or other circumstance at a site, address problems or
situations sufficiently similar to those encountered at the
site that their use is well suited to that site.
"A requirement that is judged to be relevant and appropriate
must be complied with to the same degree as if it were
applicable. However there is more discretion in this
determination: it is possible for only part of a requirement
to be considered relevant and appropriate, the rest being
dismissed if judged not to be relevant and appropriate in a
given case." (Interim Guidance on Compliance with Applicable
or Relevant and Appropriate Requirements, 52 FR 32496 (August
27, 1987).
While non-promulgated advisories, guidance documents or
•proposed rules issued by Federal or State governments do not
have the status of potential ARARs, they may be considered in
determining the necessary level of cleanup for protection of
human health and the environment. (Interim Guidance on
Compliance with Applicable or Relevant and Appropriate
Requirements, 52 FR 32496 (August 27, 1987).
The following listing of ARARs and TBCs is divided into three
broad categories: those relating to specific chemicals, those
relating to specific actions, and those relating to the
location of the site. As new standards are promulgated, the
remedy will be reviewed and the cleanup level may need to be
adjusted to ensure protection of public health.
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1. Chemical Specific ARARs and TBCs Groundwater
a) MCLs for the following compounds [Relevant and
Appropriate]
Maximum Contaminant Levels (MCLs) are established under the
Safe Drinking Water Act. These are the maximum contaminant
concentrations allowed in regulated public water supplies.
Levels are based on a chemical's toxicity, treatability,
(including cost consideration), and analytical limits of
detection.
Mds are "relevant" to the remedial action at the TFT, site
because groundwater at the site is or may be used for drinking
water. MCLs are "appropriate" because they set enforceable
drinking water standards for public water supplies. As MCLs
apply to water at its point of distribution ("at the tap"),
these levels are appropriate for groundwater at this site
because residential wells that might use the aquifers
underlying the site generally have minimal or no treatment.
Thus, these standards will have to be applied in the
groundwater itself to ensure safe levels at the tap.
Compound Concentration ug/1
*Vinyl chloride 2
*1,2-Dichloroethane 5
*Benzene 5
1,4-Dichlorobenzene 75
Barium 1000
Chromium 50
Lead 50
Arsenic 50
Cadmium 10
Selenium 10
Silver 50
Copper 1000 (secondary MCL)
Iron 300 (secondary MCL)
"Manganese 50 (secondary MCL)
Zinc 5000 (secondary MCL)
b) Proposed MCLs for the following compounds [To Be
Considered]
Proposed MCLs for into the "To Be Considered" category
because, until adopted, they do not constitute promulgated
standards. Nevertheless, the Agency intends to meet and/or
consider the proposed standards for the following compounds.
Compound Concentration ug/1
Toluene 2000
*Tetrachloroethene 5
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Chlorobenzene 100
Ethylbenzene 700
Xylenes 10000
Barium 5000
Chromium 100
I/?ad 5
Arsenic 30
Cadmium 5
Selenium 50
c) Ambient Quality Criteria Adjusted for Drinking Water [To
Be Considered]
Ambient Water Quality Criteria for Human Health (WQC) are
established under the Clean Water Act. The original WQC
assumed that people drank contaminated surface water and ate
contaminated fish that lived in that water. The Superfund
program adapted these criteria to groundwater by calculating
the corresponding contaminant concentration for exposure to
contaminated drinking water alone. (Superfund Public Health
Evaluation Manual, October 1986).
Compound Concentration uq/1
Nickel 15.4
Cyanide 200
d) 1 x 10"^ cumulative cancer risk based on the summation of
the cancer risk from all carcinogenic compounds of
concern. [To Be Considered]
In accordance with the Superfund Public Health Evaluation
Manual, carcinogenic risks are additive. When a mixture
of carcinogenic compounds is found at a site, reduction
in the concentrations of those compounds to a level
whereby the sum of the carcinogenic risk is 1 x 10"^ is
necessary to protect public health. The compounds above
marked with an asterisk are known or suspected
carcinogens (arsenic is a known carcinogen but shall not
be included in the calculation because the levels at the
site are considered to be naturally occurring) and, in
accordance with the SPHEM methodology for risk
calculations, the risk from the sum of the
concentrations of these compounds should not exceed
1 x 10"6.
2. Action Specific ARARs and TBCs
Landfill Cap
a) RCRA Section 3004, 40 CFR 264 and 265, Subpart N.
Establishes technical requirements for landfill closure,
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including cap specifications, sloping, surface drainage
etc. [Relevant and Appropriate]
b) Ohio Air Pollution Control Standards, QAC 3745-15
through, 3745-25. Requires control of fugitive dust
emissions. [Applicable]
Methane Venting System Expansion
a) Ohio Air Pollution Control Standards, QAC 3745-15 through
3745-25. Requires the use of Best Available Technology
to control new sources of air pollution. [Applicable]
b) National Ambient Air Quality Standards, 40 CFR 50-3
hour average for hydro-carbons is 0.160 mg/m3. [Relevant
and Appropriate]
c) RCRA Section 4004 Criteria. Requires methane
concentrations at compliance wells (at boundary of
landfill) to be 5 percent by volume or less. [To Be
Considered]
Ground Water Extraction and Treatment
a) NPDES discharge limitations Clean Water Act Section 402
40 CFR 122, 123, 125 and Subchapter N. Regulates
discharge of water into public water. Includes
contaminated groundwater pumped, treated, and discharged
to surface water. Permit limits shall be established in
accordance with the Ohio EPA Aquatic Life Water OAiality
Criteria applicable to Metzgers Ditch. Table 8 presents
the criteria to be used for establishing NPDES discharge
limitations. [Applicable]
b) RCPA Subtitle C, 40 CFR 260. Regulates the generation,
transport, storage, treatment, and disposal of hazardous
waste in the course of remedial action. Any spent carbon
and/or sludge from the on-site treatment plant considered
to be a hazardous waste must be managed in accordance
with RCRA. [Relevant and Appropriate]
c) RCRA Section 3003, 40 CFR 262 and 263, 40 CFR 170 to 179.
Regulating the transport of hazardous waste. Any spent
carbon and/or sludge from the on-site treatment plant
considered to be a hazardous waste must be transported
in accordance with RCRA transportation regulations.
[Applicable]
d) RCRA Section 3004 (d) and (e). RCRA Land disposal
restrictions. Any spent carbon or sludge from the
treatment plant considered to be a land ban regulated
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TABLE 8
OHIO EPA AQUATIC LIFE WATER QUALITY CRITERIA
(all concentrations in ug/1)
Compound
Acenaphthene
Acetone
Acryloni tri 1e
Aniline
Antimony
Arsenic
Benzene
Bis(2-ethylhexyl )phthalate
^-onoform
2-3utanone
Butyl benzyl phthalate
Carbon tetrachloride
Chlorobenzene
Chi orofortn
2-Chlorophenol "
1, 2 -Di chlorobenzene
1 ,3-Oichlorobenzene
1,4-Oichlorobenzene
1,2-Oichloroethane
1,1-Oichloroethylene
1 ,2-trans-Oichloroethylene
AAC*
67
550,000
460
10
650
360
1,100
1,100
1,500
160,000
230
1,800
590
1,800
200
160
250
110
12,000
1,500
7,000
**
CAC
67
78,000
430
0.44
190
190
560
8.4
. , -_^
7,100
49
280
26
79
8.8
11
87
43
3,500
78
310
a Pentachlorophenol AAC - eCl-005 ' 5'37"]
*
Acute Aquatic Criterion (AAC), ug/1; maximum concentration.
*•*
Chronic Aquatic Criterion (CAC), ug/1; 30 day average.
15713C/02
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TABLE 8 (Continued)
OHIO EPA AQUATIC LIFE WATER QUALITY CRITERIA
(all concentrations 1n ug/1)
Compound
2,4-Oichlorophenol
Di ethyl ami ne
Diethyl phthalate
Dimethyl phthalate
Di-n-butyl phthalate
2,6-Dinitrotoluene
Ethyl benzene
Ethylene glycol
Fluoranthene
Isophorone
Methyl ene chloride
2-Methyl phenol
4-Methyl phenol
Napthalene
Nitrobenzene
4-Nitrophenol
N-Nitrosodiphenylamine
Pentachlorophenol
Phenol (Wannwater Habitat)
(Coldwater Habitat)
a Pentachlorophenol AAC =
b Pentachlorophenol CAC =
*
Acute Aquatic Criterion
AAC*
200
5,600
2,600
1,700
350
950
1,400
4,100,000
400
6,000
9,700
500
140
160
1,350
790
290
a
5,300
5,000
e[1.005(pH) - 4.8725]
e[1.005(pH) - 5.3799]
(AAC), ug/1; maximum concentrat
**
CAC
13
250
120
73
190
42
62
180,000
8.9
900
430
22
6.2
44
740
35
13
b
370
200
ion.
Chronic Aquatic Criterion (CAC), ug/1; 30 day average.
15713C/02
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TABLE 8 (Continued)
OHIO EPA AQUATIC LIFE WATER QUALITY CRITERIA
(all concentrations in ug/1 )
Compound
Styrene
1, 1 ,2,2-Tetrachl o roe thane
Tetrachloroethyl ene
Thallium
Toluene
1,2,4-Trichlorobenzene
1,1,1-Trichloroethane
1,1,2-Trichl o roe thane
Trichloroethylene
2,4,6-Trichlorophenol
a Pentachlorophenol AAC = eL"l-005(pH)
b Pentachlorophenol CAC = eCl.005(PH)
*
AAC
1,250
1,000
540
71
2,400
150
2,000
2,000
1,700
16
- 4.8725]
- 5.3799]
^^
CAC
56
360
73
16
1,700
77
88
650
75
2.5
Acute Aquatic Criterion (AAC), ug/1; maximum concentration.
Chronic-Aquatic Criterion (CAC), ug/1; 30 day average.
15712~/0.7
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waste must be managed in accordance with RCRA. [Relevant
and Appropriate]
e) U.S. EPA Groundwater Protection Strategy, August 1984.
Identifies groundwater quality to be achieved during
remedial actions based on aquifer characteristics and
use. [To Be Considered]
f) CERCXA Section 121 (d) (3). Sets forth requirements that
an off-site facility accepting CERCIA hazardous
substances must nest. [Applicable]
g) Ohio Administrative Code 3745-52, 53. Regulates the
manifesting and transporting of hazardous waste.
[Applicable]
h) Ohio Water Quality Standards, QAC 3745-1. Establishes
minimum requirements for surface water quality.
[Applicable]
i) Ohio Water Pollution Control, QAC 3745-33. Regulates
point source discharges to surface waters of the State.
[Applicable]
j) Ohio Water Pollution Control, QAC 3745-31. Establishes
requirement for Best Available Technology for any new
source of pollution and an anti-degradation policy for
waters of the State. [Applicable]
k) Ohio Regulations for Naturally occurring Radioactive
Materials OAC 3701-70, 71, and 38 if lead-210
concentrations on spent carbon exceed limits.
[Applicable]
1) Federal Stream Dredging Requirements, Section 404 CWA, if
Metzger Ditch needs to be dredged. [Applicable]
~m) State Stream Dredging Requirements, 401-Certification of
dredging projects, if Metzger Ditch needs to be dredged.
[Applicable]
3. Location Specific ARARs
The Agency has identified no location specific ARARs. The
site does not contain a wetland. Nor is it a National
Historic Site.
C. Cost Effectiveness: The selected remedy is cost effective.
It is protective of human health and the environment, attains
ARARs, and through a variety of measures, ensures long-term
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effectiveness with proper operation and maintenance. The
selected remedy is less costly than Alternative 2B while
providing equal protectiveness. Although the no action
alternative is the least expensive, it does not provide
overall protection of human health or the environment and does
not attain ARARs. The selected remedy provides a degree of
protectiveness proportionate to its cost.
D. Utilization of Permanent Solutions and Alternative Treaunerrt
or Resource Recovery Technologies to the Maximum Extent
Practicable: Although permanent treatment technologies are
used to address the existing groundwater contamination and
landfill gas generated in the landfill, the primary source
will be addressed by containment. The selected remedy
represents the maximum extent to which permanent solutions and
treatment can be practicably utilized for this action.
Because of the disposal area size; the fact that there are no
on-site hot spots representing major sources of contamination;
and the difficulties, risk, and cost involved with
implementing a source treatment remedy, it is not practicable
to treat the source area. Compared to the no action
alternative and Alternative 2B, the selected remedy represents
the best balance among the nine criteria and is the most
appropriate solution for the site.
E. Preference for Treatment as a Principal Element: Only a
portion of the selected remedy, ground water extraction and
treatment and landfill gas collection and flaring, satisfies
the statutory preference for treatment. A principal threat,
the landfill/source area will be contained rather than
treated. Because of the disposal area size; the fact that
there are no on-site "hot spots" representing major sources of
contamination; and the difficulties, risk, and cost involved
with implementing a source treatment remedy, it is not
practicable to treat the disposal area.
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