EPA/ROD/R05-97/028
                                     1997
EPA Superfund
     Record of Decision:
     REILLY TAR & CHEMICAL CORP. (DOVER PLANT)
     EPA ID: OHD980610042
     OU01
     DOVER, OH
     03/31/1997

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RECORD OF DECISION DECLARATION
FINAL ACTION REMEDIAL

Reilly Tar and Chemical Company Site
Dover, Ohio

Site Name and Location

The Reilly Tar and Chemical Company site is a 3.66 acre parcel of land situated in Dover, Ohio, on Third
Street, southeast of the junction of State Route 211 and State Route 39, three-quarters of a mile north of
the junction of Sugar Creek and the Tuscarawas River.  Current land use adjacent to the study area is mainly
commercial and residential north of the site toward the Dover downtown area, and industrial to the west and
southwest.

Statement and Basis of Purpose

This decision document represents the selected final remedial action for the Reilly Tar and Chemical Company
site.  This action was developed pursuant to the Comprehensive environmental Response, Compensation, and
Liability Act of 1980  ("CERCLA"), as amended by the Superfund Amendments and Reauthorization Act of 1986
("SARA"), and the National Contingency Plan ("NCP").  This decision is based on the administrative record for
the Reilly Tar and Chemical Company site.  The Ohio Environmental Protection Agency has indicated verbally
that they concur with the selected remedy.  A letter of concurrence is expected by April 4, 1997.

Assessment of the Site

Actual threatened releases of hazardous substances from the site, if not addressed by implementing the
remedial action selected in this Record of Decision, may present an imminent and substantial endangerment to
public health, welfare, or the environment.

Description of the Remedy

The selected remedy, Alternative 3, includes

!       Institutional controls to completely restrict the use of groundwater on-site and to restrict the
       property to industrial/commercial use;

!       Excavation and off-site thermal treatment of drainage ditch and river sediments,  surface soils and
       impacted perched zone material from the collection trench installation contaminated with greater than
       100 ppm Benzo(a)Pyrene- Total Equivalent ("B(a)P-TE"),

!       Excavation and on-site disposal of surface water drainage ditch and river sediments, surface soils and
       impacted perched zone material contaminated with less than 100 ppm B (a)P-TE, and greater than 5 ppm
       B(a)P-TE;

!       Construction of an Ohio Subtitle D Solid Waste Cover over on-site disposed materials; a soil cover
       over the remainder of the site;

!       Off-site disposal of solidified tarry materials,  or recycle of tarry materials as a fuel or feedstock;

!       Hydraulic control and collection of perched ground water;

!       Natural attenuation/long-term monitoring of shallow ground water;

!       Sampling and analysis of sediments in the river to monitor ecological risk to aquatic species.

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Statutory Determinations

The final remedy is protective of human health and the environment, complies with Federal and State
requirements that are legally applicable or relevant and appropriate to the remedial action, and is
cost-effective.  This remedy utilizes permanent solutions and alternative treatment technologies to the
maximum practicable.  The selected alternative also satisfies the preference for treatment as a principal
element.

Because this remedy will result in hazardous substances remaining on-site, a review will be conducted to
ensure that the remedy continues to provide adequate protection of human health and the environment within 5
years after the commencement of this remedial action.



RECORD OF DECISION DECLARATION
FINAL REMEDIAL ACTION
Reilly Tar and Chemical Company Site
Dover, Ohio

Table of Contents

I.      SITE NAME AND LOCATION 	1

II.     SITE HISTORY AND ENFORCEMENT ACTIVITIES 	1
       A.  Site History 	1
       B.  Site Assessment/Enforcement History 	1
       C.  Expedited Response Actions 	2

III.   HIGHLIGHT OF COMMUNITY PARTICIPATION 	3

IV.     SCOPE AND ROLE OF OPERABLE UNIT 	3

V.      SUMMARY OF SITE CHARACTERISTICS 	4
       A.  Physical Characteristics 	4
       B.  Nature and Extent of Contamination 	7

VI.     SUMMARY OF SITE RISKS 	16
       A.  Human Health Risk Assessment 	16
       B.  Ecological Risk Assessment 	21

VII.   DESCRIPTION OF SITE-WIDE ALTERNATIVES 	22
       A.  Remedial Action Objectives and Cleanup Levels 	22
       B.  Applicable or Relevant and Appropriate Requirements 	23
       C.  Alternatives Listing 	25

VIII.  SUMMARY OF COMPARATIVE EVALUATION OF ALTERNATIVES	26
       A.  Threshold Criteria 	27
       B.  Primary Balancing Criteria 	28
       C.  Modifying Criteria 	29

IX.     SELECTED REMEDY 	29

X.      STATUTORY DETERMINATIONS 	32

Appendix A:  Potential Federal and State Applicable or Relevant and Appropriate Regulations
Appendix B:  Administrative Record Index
Appendix C:  State of Ohio Letter of Concurrence

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I.    SITE NAME AND LOCATION

The Reilly Tar and Chemical Company site ("the Site") is a 3.66 acre parcel of land situated in Dover,  Ohio,
on Third Street, southeast of the junction of State Route 211 and State Route 39, three-quarters of a mile
north of the junction of Sugar Creek and the Tuscarawas River (Figure 1).   The Site is bordered on the
northeast by an abandoned canal turning basin, which functions today as a drainage ditch directing storm
water runoff from the City of Dover into the Tuscarawas River.  Current land use adjacent to the study area
is mainly commercial and residential north of the Site toward the Dover downtown area, and industrial to the
west and southwest.  Public power and sewage facilities are immediately east of the Site, and an open and
undeveloped industrial area south of the Site is currently used for fill and borrow disposal.  The area
around the Site is crisscrossed with abandoned and active railroad tracks  (Figure 2).

II.   SITE HISTORY AND ENFORCEMENT ACTIVITIES

A. )   Site History

The former Reilly tar plant in Dover, Ohio and adjacent areas have an extensive industrial history that began
in the mid-1800s.  The development of the Site includes part of the Ohio Canal, which paralleled the
Tuscarawas River, the local pig iron blast furnace industry, a coking plant and foundry, and a coal tar
refinery.  The Site was established by the F. J. Lewis Manufacturing Co.,  on a parcel of land positioned
between the Hanna Furnace Co., a blast furnace facility and the coke oven facility of the Dover By-Products
Coke Company.  The tar refinery was built on top of 10 to 20 feet of slag disposed there earlier by the blast
furnace operations.  A large area south of the refinery was also covered with slag, which was mined out
during the 1940s and 1950s.  This mined area, and the former Ohio Canal running along the east border of this
area, were then used as a city dump from at least 1957 to 1969.   There is some indication from aerial
photographs that portions of the Ohio Canal were filled with municipal waste and trash prior to this period.

Coal tar refining operations were conducted on the Site from approximately 1921 through 1956. During that
time, coal tar wastes accumulated on the ground from spillage and other Site activities.  Reilly Industries,
Inc. owned and operated the Site as a coal tar refinery from at least 1932 to 1956.  The Site has been vacant
and inactive since 1956, when Reilly Tar & Chemical Corporation sold the property.  The property has passed
through several owners since 1956 and is presently owned by Ronald and Lois Quillin.

B.)   Site Assessment/Enforcement History

Reilly submitted a Notification of Hazardous Waste Site form to the U.S.  EPA in June 1981. The form
identified the general and specific types of waste at the Site to be "organic" and "creosote", respectively.



During March of 1985, five ground water monitoring wells were installed on the Site by Herron Consultants,
Inc., with personnel from Ecology & Environment, Inc., and Region V FIT supervising the drilling, soil
sampling, and well installation.  The investigation was performed to generate ground water data for the
Hazard Ranking System model.

Ground water was found to flow east southeast across the Site.  Tar was detected in one well  (EPA Well MW-3).
Ground water sampling was conducted to determine if contaminants were leaking into the ground water.  Three
of the EPA wells, MW-2, MW-4, and MW-5, were found to contain polycyclic aromatic hydrocarbons ("PAH")
(Figure 3).  Volatile organics, primarily chloroform, 1,1,1 Tricholorethane, and carbon tetrachloride were
detected in the off-site and upgradient well  (EPA Well MW-1).  The report summarizing this investigation was
dated February 11, 1986, and titled "Hydrogeologic Report on the Reilly Tar and Chemical Company Site,  Dover,
Ohio" (Ecology and Environment, Inc., 1986).

In July 1988, seven soil samples were collected and analyzed for PAH by the U.S. EPA.   Results of the
analyses indicated the presence of PAH compounds common to coal tar.  The background soil sample detected
only trace amounts of a few PAH compounds.   A Hazard Ranking Score was prepared by EPA for the Site based on
information and assumptions concerning the risk to the local population,  the potential migration of hazardous

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substances in the ground water, the potential contamination of drinking water supplies, and the potential for
direct contact.  The Site was scored at 31.38 and was subseguently proposed for addition to the National
Priorities List  ("NPL") on July 24, 1988.

In early October 1988, under a Consent Order executed by USEPA, Reilly Industries and Ronald and Lois Quillin
erected a fence around the Site.  Pursuant to a Unilateral Administrative Order ("UAO") issued by U.S. EPA to
Reilly Industries and Ronald and Lois Quillin on March 29, 1989, a Remedial Investigation  ("RI") was
undertaken.  The results of this investigation are discussed in detail below.  The Remedial Investigation
Report for the Reilly Tar and Chemical Corporation, Dover, Ohio dated June 1993 may be found in the Site
repository, at the Dover Public Library, and in the Administrative Record.

      C.)    Expedited Response Actions

An Expedited Response Action ("ERA") for removal of surficial coal tar and asphalt materials at the Site was
performed by Reilly Industries during June and July 1990.  All work was performed under U.S. EPA oversight,
in accordance with the Health and Safety Plan prepared for the ERA. U.S. EPA oversight was provided by the
Region V,  Emergency Response Section On-Site Coordinator  ("OSC") and the U.S. EPA Technical Assistance Team
("TAT") contractor, Roy F. Weston, Inc.  A total of 90 truck loads of surficial coal tar materials were
hauled off Site in 40 days.  The total guantity of material removed was 1,442 tons.

Three types of surficial coal tar materials were encountered during the ERA.  These materials included
residual asphaltic coal tar material, highly viscous coal tar, and broken slag saturated with coal tar.  The
residual asphalt was found in many areas of the Site.  Coal tar was found around the perimeter of the main
foundation, within and surrounding two smaller foundations or sumps; within the former canal turning basin;
and in a limited section in the eastern part of the Site.  The slag mixed or saturated with coal tar was
confined to two locations  (the smaller foundations/sumps).



When the ERA was performed and at the present time, the coal tar material is not a listed hazardous waste
under state or federal hazardous waste regulations  (OAC 3745-51 and 40 CFR Part 261).   Representative
composite samples of coal tar,  asphaltic materials, and slag were tested and found to be non-hazardous by the
EP toxicity test.  Thus, the coal tar materials were not a RCRA characteristic hazardous waste.  However,
because the coal tar materials contained hazardous substances  (primarily PAH),  Reilly Industries disposed the
non-hazardous wastes in a RCRA Subtitle C landfill  (Envirosafe Services of Ohio, Oregon, Ohio).

III.  HIGHLIGHTS OF COMMUNITY PARTICIPATION

The U.S. EPA conducted community relations activities throughout the RI and Feasibility Study ("FS") to
provide interested citizens and officials information about progress at the Site.

On May 24, 1990 a letter was sent to all Concerned Citizens detailing the purpose of the ERA. On April 4,
1991 a news release and a letter to concerned citizens was sent out explaining that the Site was now entering
the RI/FS stage.  The site repository was established on April 23, 1991 making available all approved
documents to concerned citizens.  A public information session was then held on April 30, 1991,
representatives from U.S. EPA and OEPA were present in order to answer guestions and concerns the public had
on the proposed work for the site.  Summary fact sheets were distributed May 8, 1991.

Once the RI/FS was completed, a proposed plan was issued to present the selected remedial alternative to the
public.  A public comment period was held from January 15, 1997 to February 15, 1997 during which the public
was allowed to formally comment on the proposed alternative, concerned citizens were able to present their
concerns,  perceived problems or other potentially unknown information which U.S. EPA then considers when
making the final decision on a remedial alternative.  A public information session was held to present the
chosen remedial alternative and to solicit comments and address concerns from the citizens and local
officials on the proposed alternative.  The meeting was held on January 22, 1997.

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IV.   SCOPE AND ROLE OF OPERABLE UNIT

The remedial response action in this Record of Decision encompasses the entire Site,  with the possible
exception that there may be another response forthcoming based on further assessment of ecological risks in
the Tuscarawas River.  More will be said about this under the Summary of Site risks and the Selected Remedy.

V.    SUMMARY OF SITE CHARACTERISTICS

A. )   Physical Characteristics

i.)   Surface Features

Surface features on and surrounding the Site include buildings,  vacant building foundations,  roadways,
parking lots, railroad tracks, telephone/power poles, open fields,  waterways, a power substation and
topographical features.  The surface of the Site is covered primarily by unconsolidated slag and demolition
debris.  Topographically,  the Site is relatively flat with the exception of a steep slope along the east
property boundary near a power substation,  and an abandoned canal turning basin along the northeast property
line.  The Site is approximately 15 feet higher in elevation than the abandoned canal turning basin.

Four building foundations from former Site operations remain on Site.  A large foundation,  approximately 300
feet long and 50 feet wide, is located near the northern property line.  The elevation of the concrete floor
of the large foundation is 874.8 feet above MSL at its southwest end, approximately 8 feet below ground
surface.  The foundation floors are approximately 1 ^L feet thick.  Near the middle of this foundation is a
southern extension approximately 35-feet wide by 35-feet long.  The foundation walls extend about 2 to 3 feet
above ground surface.  Three additional concrete foundations are located to the south and southeast of the
large foundation. Two foundations are located near the center of the Site approximately 65 feet south of the
large foundation.  These concrete foundation walls are flush with the ground surface while the floors extend
about 2 feet below the ground surface.  The third foundation is located approximately 200 feet southeast of
the large foundation.  This concrete foundation extends approximately 2 feet above ground surface.

A storm water drainage ditch  (approximately 350-feet long) parallels the northeast Site property boundary.
Storm water enters the drainage ditch through an 80-inch culvert pipe.  Storm water exits the drainage ditch
into a 48-inch culvert pipe.  The storm water ditch is bounded on the northeast and southwest by steep
slopes.  South of the Site is vacant and undeveloped land that gently slopes to the south.

ii.)  Surface Water

There are no surface water bodies on the Site except for standing water that occasionally lies within the
building foundations and open excavations.   Surface water bodies adjacent to the Site include the storm water
drainage ditch, Sugar Creek and the Tuscarawas River.   The storm water drainage ditch receives water from
the City of Dover storm water sewers in the downtown area. The storm water drainage discharges directly into
the Tuscarawas River, The bottom of the storm water ditch is near the top of the clay layer and may receive
recharge from the perched aguifer during dry periods.   During dry periods, water generally does not flow in
the storm water ditch, however, standing water has usually been observed in portions of the storm water ditch
Sugar Creek is located approximately one-half mile south-southwest of the Site.   Sugar Creek is a shallow
stream generally about 50 feet wide.   Its origin is at the Mead City Dam approximately 9 miles north of the
Site.   Sugar Creek flows southeast and discharges into the Tuscarawas River.  The Tuscarawas River is
located approximately 210 feet east of the Site.   The Tuscarawas River is approximately 150-feet wide and
flows north to south.   The Tuscarawas River is dammed at several locations to maintain constant pool
elevation.   A fixed-head dam is located near the Site and immediately south of the City of Dover waste-water
treatment plant.

iii.) Geology

The Site lies within an ancient river valley, trending roughly northwest-southeast, formed by stream erosion
and subseguently filled with glaciofluvial outwash deposits.   The unconsolidated sediments extend
approximately 185 to 215 feet below the ground surface.   Underlying the unconsolidated sediments are

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Pennsylvania!! Age conglomerates, sandstones, shales, limestones and coals of the Allegheny Plateau.

iv.)   Soils

In general, the Site is underlain by 13 to 19 feet of solidified slag, except in the far western portion.
Surficial material in the far western portion of the Site and off-site locations consists primarily of fill
material  (e.g., sand, gravel, wood, brick, and building rubble).   A 0.3- to 2-foot fill horizon consisting
of slag, silt, sand and gravel is located directly beneath the solidified slag.   A 1.5- to 9.2-foot thick
clay layer exists below the slag and fill layer on Site and at most off-site locations, where tested.   The
clay layer is continuous within the perimeter of the site, but not at all points sampled off-site.   The
surface of the clay layer is relatively flat with typical reliefs of 1 to 2 feet.  Coal tar, asphaltic
material, some small tar pockets, and tar-like odors were observed at 25 of the 74 borings taken during the
RI.   These borings were primarily located in a south-southeast direction from the former foundations and
near the storm water drainage area.   Tar was encountered near the center of the Site,  directly west of the
drainage ditch and near the northern property boundary.  Tar was identified at 16 of the 74 surface borings.
Asphaltic materials were primarily encountered in the central and western portions of the Site in the upper 2
feet of fill. Asphaltic materials were encountered in 8 of the 74 borings sampled.

v. )   Clay Layer

The first natural soil encountered on the Site and some off-site areas consists of a gray clay with brown
mottling.  The mottling is typically interpreted as a result of bioturbation and anaerobic  conditions.  In
addition, root structures were occasionally observed within the clay.  This clay layer was presumably
deposited in a wetland (e.g., swamp)  along the Tuscarawas River flood plain.  The clay layer acts as a
confining layer and ranges in thickness from 1.5 to 9.2 feet on Site and at most off-site locations.

The clay layer appears to act as an impermeable boundary to downward migration of coal tar product and
perched water.  Three Shelby tube clay samples were collected by Reilly for laboratory determination of
hydraulic conductivity (permeability).  Hydraulic conductivity values ranged from 1.4 x 10-7 to 6.0 x 10-9
cm/sec.

vi.)   Ground Water

Ground water in the Dover area is utilized by rural, municipal and industrial consumers.  Ground water at the
Site occurs in three separate aguifer systems:  perched, regional and bedrock.  The perched aguifer is
located above a clay layer.  The saturated thickness averages 3 feet, but varies from as little as 6-inches
to as much as 6 feet.  Well yields in the perched aguifer varied from non-productive to greater than 2
gallons per minute.  The ground water flow in the perched aguifer is influenced by the elevation of the clay
layer.  Ground water will flow from points of high elevation to low elevation due to gravity.  The perched
water zone appears to be interconnected with the storm water drainage ditch.  Typical horizontal hydraulic
gradients in the perched aguifer ranged from 6.84 x 10-3 to 1.58 x 10-2.  This aguifer is not utilized for
water production.

The regional aguifer is divided into three "zones" for the purposes of discussion below:  shallow, mid-depth
and deep.  The zone designated as shallow's anywhere from 19-51 feet below the ground surface; the mid-depth
zone extends from 52-180 feet, and the deep zone extends from 180-290 feet.  The regional aguifer consists of
coarse, permeable, glaciofluvial sand and gravel sediments.  The regional aguifer occurs in the paleo-river
channels and has a saturated thickness greater than 290 feet.  In most areas, the regional aguifer is
hydraulically connected to the Tuscarawas River.  The regional aguifer is widely used for municipal water
supplies for Dover and New Philadelphia and for numerous industrial production wells.  Potentiometric ground
water levels in the regional aguifer indicate that flow is in an east-southeast direction toward the
Tuscarawas River.  Closer to the river, the ground water flows in an easterly direction.  Typical horizontal
hydraulic gradients in the deep and shallow regional aguifer ranged from 1.11 x 10-3 to 2.6 x 10-4 and 1.11 x
10-3 to 1.54 x 10-3, respectively.

Vertical hydraulic flow gradients indicate that there is a downward component of ground water flow in
selected monitoring well clusters.  This suggests that the shallow portion of the aguifer is hydraulically

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interconnected to the Tuscarawas River  (i.e., shallow ground water may discharge to the river), while the
mid-depth and deep portions of the aquifer may not be influenced by the Tuscarawas River.

The bedrock aguifer consists of sandstone, shale, and limestone seguences of the lower Pennsylvanian system
and/or sandstone and shale seguences of the Upper Mississippian system. Primary ground water flow in the
bedrock occurs within the pore space of the consolidated rock. Secondary ground water flow in the bedrock
generally occurs along bedding planes, joints and fractures.



vii.)   Ecology

The following habitat types were identified at the Site and surrounding areas: river, riparian forest
(riverbank and drainage ditch),  meadow, disturbed area  (Site and off-site),  wooded area, and industrial area.
According to information provided by the U.S. Fish and Wildlife Service and the Ohio Department of Natural
Resources (DNR), there are no records of any state-listed or federally-listed threatened or endangered
species in the area.  Although the Indiana bat (Myotis sodalis),  a federally-listed endangered species,
occurs in Ohio, Tuscarawas County is outside of its range.  The Ohio DNR Natural Heritage Program has no
records of threatened or endangered plant or animal species, nor of any nature preserves or unigue ecological
features in the vicinity of the study area.

B.)   Nature and Extent of Contamination

Sampling and analysis was conducted in two phases for the RI.   Subsurface soil, surface soil, surface water
and ground water samples were analyzed for target compound list ("TCL" - a common list of organic compounds)
constituents and subsurface soil and ground water samples were also analyzed for target analyte list ("TAL" -
a common list of metal compounds)  constituents during Phase I  (Figure 4).  Analytical data from Round 1
ground water samples and Phase I soil and sediment samples were used to determine the contaminants of concern
("COG") that would be investigated during the Phase II program.  COG are as follows:

         Table 1:  Contaminants of Concern

         VOLATILES       METALS      SEMIVOLATILES

         benzene         arsenic     phenol

         toluene         barium      naphthalene

         ethylbenzene    chromium    PAH compounds

         xylenes         lead        2-methylphenol

         styrene                     3 + 4-methylphenol

Additionally, Toxicity Characteristic Leaching Procedure  ("TCLP" - a procedure that replaced the EP toxicity
test)  analyses were performed on tar and asphalt samples and TAL metals analyses were performed on slag
samples.

Seven different media were sampled and analyzed.   The media include:

     !        surface soils,
     !        subsurface soils,
     !        surface water,
     !        sediments,
     !        slag
     !        groundwater
     !        tar and asphalt.

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i.)   Surface Soils

31 samples were collected from a sample depth of 2 to 3 feet below ground surface and analyzed for TCL
volatiles and semivolatiles.   Two additional samples were collected for BTEX, styrene, PAH, phenolics, and
naphthalene analys e s.

Volatiles

The following volatiles were detected in the surface soil samples: benzene, toluene, ethylbenzene, styrene,
and xylene.

Benzene was detected at four of the 31 sample locations analyzed at concentrations ranging from 0.018 mg/kg
to 18.0 mg/kg.  Toluene was detected in eight sample locations at concentrations ranging from 0.003 to 46.0
mg/kg.  Ethylbenzene was detected in six surface soil sample locations with concentrations ranging from 0.037
to 13.0 mg/kg.  Styrene was detected in five soil sample locations and ranged in concentration from 0.031 to
23.0 mg/kg.  Xylene was detected in seven sample locations and ranged in concentration from 0.006 to 110
mg/kg.  Samples collected directly southwest of the drainage ditch contained elevated concentrations of BTEX.
These samples were saturated with water, very odorous, and exhibited a  hydrocarbon sheen.

Semivolatiles

Semivolatile compounds were generally detected across the Site in all surface soil samples.  The distribution
of semivolatile organic compounds is summarized into four separate groups:  total non-carcinogenic polycyclic
aromatic hydrocarbons  ("TNP"), total carcinogenic polycyclic aromatic hydrocarbons  ("TCP"), phenolics and
naphthalene.  TNP compounds include acenaphthene, acenaphthylene, anthracene, fluoranthene, fluorene,
phenanthrene, pyrene,  and benzo(g,h,i)perylene.  TCP compounds include:  benzo(a)anthracene, chrysene,
benzo(b)fluoranthene,  benzo(k)fluoranthene, benzo(a)pyrene, indeno(1,2,3,c,d)pyrene, and
dibenz(a,h)anthracene.  Phenolics include phenol, 2-methylphenol, 4-methylphenol and 2, 4-dimethylphenol.

TNP concentrations ranged from a low of 0.681 mg/kg to a high of 7,763 mg/kg.  TCP concentrations in surface
soil samples ranged from a low of 0.32 mg/kg to a high of 3,310 mg/kg in.  Phenolics were detected in only
one sample at a concentration of 0.71 mg/kg.  Naphthalene was detected all but two of the 31 surface soil
sample analyzed.  Naphthalene concentrations ranged from 0.1 to 2,300 mg/kg.

In summary, relatively high levels  (greater than 100 mg/kg) of TNP and TCP were detected in surface soils
primarily in the center of the Site and west of the storm water drainage ditch.  Naphthalene was also detected
in the same areas.  Phenolics were only detected in one surface soil sample.  These analytical results
support the field observations of coal tar, sheens or odors in the surface soil samples.

ii.)  Subsurface Soils

Twenty-two subsurface soil samples were collected from borings and analyzed for volatiles, semivolatile, and
metals.   Only the natural materials, i.e., the clay, and sand and gravel units were sampled.

Volatiles

Benzene, toluene, styrene, xylene and ethylbenzene were detected in the subsurface soils.

Benzene was detected in only two samples at concentrations of 0.003 and 0.055 mg/kg.  Toluene, styrene, and
ethylbenzene were detected in one sample at concentrations of 0.056, 0.032, and 0.028 mg/kg, respectively.
Xylene was detected in three samples at 0.004 mg/kg, 0.014 mg/kg, and 0.210 mg/kg.  BTEX, present in low
concentrations in coal tar, were only found in samples from three borings, two on-site borings and one boring
off-site (RI-5S), which is located adjacent to the southern Site boundary.

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Semivolatiles

TNP were found in the majority of subsurface samples, as described above.  However, concentrations were
relatively low compared to surface soil concentrations.  The highest concentration of TNP was detected in a
sample adjacent to the Site's southern property boundary, and at a depth of 24 to 26 feet.  This sample was
taken from the bottom of the clay.  TNP were not detected in samples collected near bedrock.

The highest concentration of TCP  (12.9 mg/kg) was detected at RI-5S at the 24- to 26-foot depth.  The
remainder of TCP concentrations were less than 5 mg/kg.  Phenolics were only found in two borings, with the
24- to 26-foot depth sample in RI-5S again showing the highest concentration  (18.8 mg/kg). Naphthalene was
present in several samples, but at relatively low concentrations compared with concentrations found in the
surface soils.

In summary, semivolatiles were detected in subsurface soils on the top of the clay, at the bottom of the clay
and in the sand and gravel.  However, the highest concentrations were found in the clay.  Semivolatiles were
also detected in the upgradient off-site boring MWRI-1S.  Please note that free coal tar was not sampled.

Inorganics (TAL Metals and Cyanide)

Twenty four subsurface soils collected during Phase I sampling were analyzed for 23 TAL Metals and cyanide.
Antimony, cadmium, mercury, silver,  thallium and cyanide were not detected in any subsurface soil samples
above method guantitation limits.  Selenium was detected in two samples  (RI-2S-8 and RI-2S-10) at
concentrations of 1.8 and 1.1 mg/kg, respectively.  Based on these findings, these metals are not considered
constituents of interest at the Site.

iii.) Surface Waters

Three surface water samples were collected from the drainage ditch; i.e., upstream (RI-SW-1), midpoint
(RI-SW-2), and downstream  (RI-SW-3)  locations.  Samples were analyzed for TCL volatiles and semivolatiles.
Volatile organics were not detected above guantitation limits in the three surface water samples.  Two
semivolatile compounds were detected 1,2-dichlorobenzene was detected in RI-SW-3 at a concentration of 0.001
mg/1 and in RI-SW-3D (duplicate) at a concentration of 0.002 mg/1.  Bis(2-ethylhexyl)phthalate was detected
in each surface water sample.  Concentrations ranged from 0.019 mg/1 in RI-SW-1 to 0.003 mg/1 in RI-SW-2 and
RI- SW-3.  Bis(2-ethylhexyl)phalate is a common laboratory contaminant.

iv.)   Sediments

Four sediment samples and one duplicate were collected from the storm water drainage ditch.  Three sediment
samples were also collected along the western bank of the Tuscarawas River.

Storm Water Drainage Ditch

Volatiles were not detected in the upstream sediment sample or the midstream sample.   Benzene, toluene,
ethylbenzene, xylenes and styrene were detected in the three downstream sediment samples.  This finding
correlates well with the observance of tar-like material in the downstream drainage ditch sediments.
Semivolatile organic compounds were detected in each of the storm water drainage ditch sediment samples.

TNP compounds were detected in each of the drainage ditch sediment samples.  TNP concentrations ranged from
9.2 mg/kg to 3,650 mg/kg.  TCP compounds were also detected in each of the sediment samples and ranged in
concentrations from 7.7 mg/kg to 1,062 mg/kg. Phenolics were detected in only one downstream sample at a
concentration of 241 mg/kg. Naphthalene was detected in three of the four sediment sample locations and
ranged from 3.0 mg/kg to 2,600 mg/kg.

In summary, the finding of BTEX in the downstream drainage ditch sediment samples correlates well with the
observance of tar-like material at these locations.  Semivolatiles were found in both upstream and downstream
locations.  This suggests that a component of the semivolatiles is entering the drainage ditch from storm
water sources within the City of Dover.

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Tuscarawas River Sediments

Two samples were collected adjacent to the storm water culvert pipe discharge location.  One sample showed
BTEX to be present, while the second sample showed no BTEX present.  Volatiles were not present upstream nor
downstream of this location.  Semivolatiles were found both upstream and near the culvert pipe discharge
location.  These data, coupled with physical observations of tar-like material in the samples near the
culvert pipe discharge, suggest the storm water drainage ditch may be a route of migration of coal tar from
the drainage ditch to the river. TNP concentrations ranged from 3.98 to 591 mg/kg and TCP concentrations
ranged from 3.15 to 311.4 mg/kg.  Phenolics were not detected in the river sediment samples and naphthalene
was detected at one location at 3.1 mg/kg.

v. )    Slag

Three slag samples were collected and analyzed to characterize the metals content of slag.  The locations
were selected to provide representative coverage across the Site.  These samples were free of visible tar or
asphaltic material, did not contain any loose fill materials typically observed above and below the slag, and
were considered representative of the undisturbed slag material.

The following metals were not detected in the slag above guantitation limits: antimony, cadmium, copper,
mercury, nickel, selenium, silver, and thallium.  Cyanide was also not detected above guantitation limits in
each slag sample.  Aluminum, calcium, iron, magnesium, manganese, potassium, and sodium were detected at
relatively high concentrations.  Barium was also detected at concentrations ranging from 193 mg/kg to 1,250
mg/kg.

vi.)   Ground Water

Monitoring wells installed in conjunction with the Phase I RI were sampled and analyzed during the first
round for TCL volatiles, semivolatiles, pesticides and PCBS, and TAL metals  (dissolved and total).  The
results of Sampling Round I demonstrated that pesticides, PCBS, and metals, except lead, chromium, arsenic
and barium, could be excluded from Sampling Round 2 analyses.  Additionally, each monitoring well sampled
during Round 2 was analyzed for low level  (ng/1 or parts per trillion) PAH.  The analyses performed during
Sampling Round 3 were revised and reduced based on the results of Round 1 and Round 2 data.  The revised list
included BTEX, styrene, PAH, phenolics, arsenic, barium, chromium and lead.  Deep, mid-depth and off-site
shallow wells were also analyzed for low level PAH compounds.

a.)    Volatile Organics Characterization

Perched Aguifer

Ground water samples were collected and analyzed from four of seven perched monitoring wells. In accordance
with the approved Phase II Work Plan, three perched wells (MWRI-3P, -7P, and - 12P),  which underlie the site,
were not sampled, as coal tar was visible in each well.

BTEX were detected in three of the four wells (MWRI-8P, IIP, and -BW) .  Perched well -8P is located south and
MWRI-11P and -BW are located to the north of the Site.  Based on ground water flow direction projected for
the perched water aguifer beneath the Site, it is possible that perched water from the Site is moving  out
radially in the direction of all three wells (Figure 7).

Benzene concentrations ranged from 0.082-0.68 mg/1, toluene ranged from 0.005-0.63 mg/1, ethylbenzene ranged
from 0.02-0-15 mg/1, and xylene from 0.22-0.63 mg/1.

Shallow Regional Aguifer

BTEX and styrene were detected in five of eleven shallow monitoring wells  (Table 2).

Table 2:  VOC Concentrations in Shallow Monitoring Wells (mg/1)

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Compound
Benzene
Toluene
Xylene
Ethyl Benzene
Styrene

0
0
0
0
0.
MWRI-
.28-0.
.031-0
.07-0.
.016-0
0007-0
3S
78
.28
35
.05
.091
MWRI-
0.002-0
0.006-0
0.006-0
0.01-0.
0.003-0
4S
.014
.013
.066
034
.006
MWRI-5S
0.21-0.
0.044-0.
0.066-0.
0.016-0.
0.004-0.
,39
,13
,086
,033
,005
MWRI-6S
0.014-0.032
0.003
0.01-0.022
0.013-0.015
ND
MWRI-11S
0
0
0
0

.076
.02
.034
.01
ND
MCLs
0.005
1.0
10
0.7
0.1
The above results show that BTEX and styrene were found in on-site shallow monitoring wells  (MWRI-3S, -4S and
-6S).   These compounds were also found in the off-site downgradient well MWRI-5S, however, this well is in
close proximity to the Site's southern property boundary and is thus considered representative of Site
conditions.  No other downgradient monitoring well contained BTEX or styrene, suggesting that these compounds
are primarily contained within the Site boundary.  BTEX was also found in the upgradient shallow well
(MWRI-11S).  Of these compounds, only benzene exceeded maximum contaminant levels ("MCLS").  Downgradient
shallow wells were free of BTEX compounds.

Mid-Depth Regional Aquifer

Toluene was detected in mid-depth monitoring wells located on-site.  Toluene ranged from 0.002 to 0.017 mg/1.
Toluene was not detected off-site nor adjacent to the Tuscarawas River.  The results show toluene is present
on-site at mid-depth in the regional aguifer, but at relatively low concentrations,  well beneath MCLS or
action levels.

Deep Regional Aguifer

Toluene was detected during Sampling Round 1 at low levels on-site, In MWRI-3D  (0.01 mg/1) and MWRI-7D  (0.008
mg/1).   Toluene was not detected in the upgradient, deep well  (MWRI- 11D) nor the two downgradient deep wells
(MWRI-8D and -9D).

b.)   Semivolatile Organics Characterization

Perched Aguifer

Semivolatiles were detected in each of the four perched wells sampled.  The following concentrations of TNP,
TCP, phenolics and naphthalene were detected (Table 3):

Table 3:  Semivolatiles in Perched Aguifer (mg/1)
Well Number TNP
MWRI-8P
MWRI-11P
MWRI-BW
MWRI-14P
0.52
2.248
0.105
0.031
TCP
BDL (a)
0.344
BDL
0.002
PHENOLICS
1.
0.
,09
,128
BDL
0.
,052
NAPHTHALENE
5.
9.
0.
0.
,3
,3
,18
,009
(a)   BDL - below detection level

Semivolatiles were found in all of the perched wells (since coal tar was observed in on-site perched wells,
it is assumed Semivolatiles are present).   A perched well north of the Site  (MWRI- IIP) contained the highest
concentrations of TNP and TCP.  This is likely the result of coal tar being present above the clay.  However,

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the other well north of the Site  (MWRI-BW) contained no TCP or phenolics.  The visible extent of coal tar in
the perched aquifer is shown in Figure A.

Shallow Regional Aguifer

Semivolatiles were detected in all shallow wells, except the downgradient well located adjacent to the river
and the lateral gradient wells.  TNP were detected in seven monitoring wells at the following concentration
ranges:  MWRI-1S  (0.005 mg/1) ,  MWRI-3S  (0.232 to 0.572 mg/1), MWRI-4S  (0.195 to 0.346 mg/1), MWRI-5S  (0.001
to 0.046 mg/1), MWRI-6S (0.257 to 0.892 mg/1), MWRI-8S  (0.057 mg/1), and MWRI-11S  (0.098 mg/1).

TCP were detected in three of the 11 monitoring wells using standard CLP methods.  However, highly sensitive
parts per trillion ("ppt") analyses showed TCP to be present in eight of the shallow monitoring wells.  TCP
was not detected in downgradient well MWRI-9S and lateral wells MWRI-10S and -13S.  TCP were detected in the
following shallow monitoring wells using CLP and ppt analytical methods.

          Table 4:  Low Level TCP in Shallow Monitoring Wells  (ppt)

          WELL NUMBER         CLP METHOD           LOW LEVEL PPT METHOD

          MWRI-1S        BDL (a)                 1,877 and 380 ng/1

          MWRI-2S        BDL                     5400 ng/1

          MWRI-3S        0.009 mg/1              12,390 ng/1

          MWRI-4S        0.008 to 0.06 mg/1      45,500 ng/1

          MWRI-5S        BDL                     1,945 ng/1

          MWRI-6S        BDL to 0.078 mg/1       38,800 ng/1

          MWRI-8S        BDL                     6,680 ng/1

          MWRI-11S       BDL                     20,410 ng/1

          (a) BDL - below detection level.

Phenolics were detected in 2 of the 11 shallow monitoring wells (MWRI-3S an MWRI-5S) at concentrations of
0.205 to 2.06 mg/1 respectively.  Naphthalene was detected in 6 of the 11 shallow monitoring wells at the
following concentrations:   MWRI-1S (0.004 mg/1), MWRI-3S (1.1 to 5.6 mg/1), MWRI-5S  (0.002 to 0.11 mg/1),
MWRI-6S (0.002 to 0.17 mg/1), MWRI-8S  (0.01 mg/1), and MWRI-11S (0.011 mg/1).

In summary,  semivolatile organics were generally detected in on-site shallow wells.  TNP and naphthalene were
detected in the downgradient well (MWRI-8S) but not in MWRI-9S located adjacent to the Tuscarawas River.  TNP
and naphthalene concentrations in MWRI-8S are similar to concentrations detected in on-site wells.  In
addition,  TNP and naphthalene were also detected in the upgradient well  (MWRI-11S) at similar concentrations
detected in on-site monitoring wells.

TCP were detected in all monitoring wells using ppt analyses, except for MWRI-10S and MWRI- 13S  (lateral
monitoring wells) and MWRI-9S  (downgradient monitoring well).  TCP concentrations in the upgradient well
(MWRI-11S)  were similar to concentrations in the on-site wells.  TCP compounds were also detected in
downgradient well MWRI-8S, however,  concentrations were higher than two of the five on-site monitoring wells.

Mid-Depth Regional Aguifer

Phenolics and naphthalene were the only semivolatiles detected using CLP procedures in the two on-site
mid-depth monitoring wells and only during one sampling round.  Phenolics were detected once in each of the

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on-site mid-depth wells, 0.002 mg/1 in MWRI-3MD and 0.005 mg/1 in MWRI- 7MD.  Naphthalene was only detected
during Sampling Round 1 in MWRI-7MD at 0.004 mg/1.

Semivolatile organics were not detected in downgradient well MWRI-9MD.  TCP and TNP were not detected in
on-site wells MWRI-3MD, MWRI-7MD.

TNP and TCP were not detected using standard CLP, however, TCP compounds were detected using ppt procedures.
TCP were detected in each of the three mid-depth monitoring wells using ppt analytical methods.  The
concentrations of TCP compounds during Sampling Round 3 ranged from 125 to 193 ng/1.

Deep Regional Aguifer

TCP and TNP were not detected in the deep monitoring wells using standard CLP procedures, however, TCP were
detected in all deep wells using ppt procedures.  TCP concentrations ranged from 42 to 74 ng/1.  Phenolics
were detected in the off-site upgradient well  (MWRI-11D) and the two off-site downgradient deep wells
(MWRI-8D and -9D).   Concentrations ranged from 0.006 to 0.019 mg/1.  Naphthalene was detected in only one
on-site deep well (MWRI-3D)  at a concentration of 0.0008 mg/1.

c.)   Pesticides and PCBS

Pesticides and PCBS were analyzed as part of Sampling Round 1.  No PCBS were detected and only one pesticide
(Delta BHC) was found above guantitation limits.  Based on these results, pesticides and PCBS were not COCs
and were removed from future rounds of sampling and analyses.

d.)   Metals

Seventeen metals and cyanide were analyzed.  Metals of interest include arsenic, barium, chromium, and lead;
their analytical results are discussed below.

Perched Aguifer

Total arsenic was not detected in any perched well sampled, while dissolved arsenic was only detected in one
perched well.  Total and dissolved barium were detected in each of the three perched monitoring wells
sampled.  Total chromium was detected in two perched wells and dissolved chromium was detected in only one
perched well.  Total lead was detected in two perched wells while dissolved lead was not detected in these
perched wells.

Shallow Regional Aguifer

Arsenic was sporadically detected in shallow wells at concentrations less than the MCL of 0.050 mg/1.  Barium
was consistently detected in the shallow monitoring wells.  Barium concentrations were highest in the
laterally upgradient well (MWRI-1S) and downgradient well MWRI-8S. Total barium concentrations exceeded the
MCL (1.0 mg/1) in these same two wells.  Total and dissolved barium concentrations were less than the MCL in
the on-site wells.   Chromium was detected only twice, once in a total metals sample and once in a dissolved
metals sample.  Additionally, the chromium concentrations in these samples were well below the MCL of 0.10
mg/1.   Total lead was generally detected in similar concentrations in each shallow monitoring well and only
one sample contained concentrations of lead greater than the action level of 0.015 mg/1.  In addition,
dissolved lead was detected in two of the 11 shallow wells and at concentrations well below the action level.




Mid-depth Regional Aguifer

Arsenic and chromium were not detected in mid-depth wells, while barium and lead were detected, but well
below MCLS and action levels.

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Deep Regional Aquifer

Arsenic was not detected in any on-site or off-site deep wells.  Barium was detected in both on-site and
off-site wells, and chromium and lead were only detected in on-site wells.  In general, concentrations of
barium, chromium and lead are similar in each deep well.  The concentrations are less than their respective
MCLs and action levels, except for one lead analysis from MWRI-3D.  Subsequent analyses of MWRI-3D did not
detect lead above the action level.

e.)   Tar and Asphalt

Nine tar and asphaltic material samples were collected during the RI investigation for chemical
characterization by TCLP.  Three subsurface tar samples failed TCLP for benzene.  The tar sample in each of
these samples was collected directly above the clay layer.  The remaining six samples passed the TCLP.

VI.   SUMMARY OF SITE RISKS

A. )   Human Health Risk Assessment

A human health risk assessment was performed by Reilly Industries, per Risk Assessment Guidance for
Superfund, Volume I, Human Health Evaluation Manual, (Part A).  This assessment follows the standard steps of
identification of Chemicals of Potential Concern  ("CPCs:), exposure assessment, toxicity assessment, and risk
characterization.

i.)   Identification of Chemicals of Potential Concern:

This step of the risk assessment process involves reviewing the chemicals detected in various media sampled
during the RI, and identifying the most toxic, prevalent, mobile, and/or persistent chemicals.  Based on this
analysis, the CPCs are selected for inclusion in the remainder of the risk assessment.  CPCs include the
following:

     !         VOC
           •  benzene
           •  ethylbenzene
           •  styrene
           •  toluene
           •  xylene (total)

     !         SVOC
           •  benzoic acid
           •  bis(2-ethylhexyl)phthalate
           •  dibenzofuran
           •  2,4-dimethylphenol
           •  2-methylphenol
           •  4-methylphenol
           •  -phenol

     !         PAH

Of the CPCs listed above, PAH and BTEX are the primary constituents which present risk to human health and
the environment at the Site.   In order to evaluate the feasibility and effectiveness of remediation options,
it is important to understand the properties of these compounds and how they behave in the environment.  The
following is a brief description of these compounds, their fate in the environment, and their physical
properties.

PAH

PAH are a group of organic compounds consisting of two or more rings each made up of six carbon atoms.  Each

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of these rings is termed aromatic because of the nature of the bonds holding the ring together.  These bonds
affect the phyBiochemical properties of the rings and the resulting molecule.  The number of rings affects
the properties of the molecule.  For example, the two-ring molecule naphthalene is relatively water soluble
(32 mg/1) and adheres weakly to soils while the 5-ring benzo(a)pyrene is very insoluble  (0.0038 mg/1)  and
adheres strongly to solids.  The PAH of primary toxicologic concern are large with four or five rings.  In
general, all PAH are characterized by the following physiochemical properties:

      !        Poor chemical reactivity:   under normal environmental conditions,  these PAH are resistant to
              chemical breakdown.

      !        Biodegradation by microorganisms:   under typical conditions biodegradation rates may be
              increased by supplying nutrients and/or introducing organisms that are adapted to degrading
              PAR.

      !        Slow rates of volatilization to the atmosphere.

      !        Moderate to high rates of phyotolysis:   if these PAHs are exposed to sunlight,  they will
              degrade.

      !        Poor water solubility.

      !        High degree of sorption to solids.

      !        High retardation rates in ground water.

Typically, a few processes control the fate and transport of a chemical in the environment.  While photolysis
has the potential to rapidly degrade PAH, this reaction is limited by the lack of light penetration into the
soil.  In soil and ground water environments, the processes of sorption to solids and biodegradation are
likely to dominate the fate and transport of PAH.  Thus, PAH are likely to move very slowly through
subsurface soils above and below the water table.  The rate of movement in the saturated zone is likely to be
10 to 20,000 times slower than the rate of water movement.  The most significant means of degrading PAH,
in-situ, is likely to be by biological means.  The rate of biodegradation can vary dramatically depending
upon the number and type of microorganisms present, the concentration of PAH, and the availability of
nutrients.  Unless biodegradation is encouraged  (for example, by adding nutrients), the PAH are likely to
persist in the soil for long periods of time.

As mentioned above, each of the PAH of concern has a distinct set of chemical and physical properties.  The
two fate and transport processes that are likely to be of importance at the Site, biodegradation and
sorption, will vary in rate according to the size of the PAH molecule.  The relative ability of the PAH of
interest to adsorb to solids is as follows:

Naphthalene < Anthracene < Benzo(a)anthracene = Chrysene < dibenzo(a,h)anthracene < Benzo(a)pyrene <
Benzo(b)fluoranthene < Indeno(1,2,3-c,d)pyrene.

The relative rate of biodegradation is likely to follow the opposite order of sorption.  This is due to the
fact that, in general, more complex molecules are degraded more slowly and more likely to adsorb to solids,
and compounds that adsorb well to solids are less available to microorganisms for degradation.

BTEX Compound

BTEX compounds are the principle VOCs which were detected at the Site.  Due to their volatility, the
transport of BTEX through the air-filled pores of unsaturated soils is an important transport mechanism for
near-surface soils.  The rate of volatilization from soil is influenced by soil porosity, soil moisture,
temperature, convection currents,  and barometric pressure changes. Their behavior and fate in the environment
is described as follows:

      !        poor chemical reactivity under normal environmental conditions;

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     !         potential for degradation by microorganisms;

     !         potential to volatilize to the atmosphere;

     !         poor sorption to soils; and

     !         soluble in water.

The primary BTEX constituent of interest on-site, with respect to risk, is benzene.  Benzene, C6H6, is a
volatile, colorless, and flammable liguid aromatic hydrocarbon which possesses a characteristic odor.  Its
structure is such that all of the carbon and hydrogen atoms are coplanar and all of the six carbon-to-carbon
bonds are identical.  Due to its volatility, the transport of benzene through the air-filled pores of
unsaturated soils is an important transport mechanism for near-surface soils.  The rate of volatilization
from soil is influenced by soil porosity, soil moisture,  temperature, convection currents, and barometric
pressure changes.  For ground water, however, volatilization into soil pore spaces is not likely to be a
significant transport mechanism for removal of benzene.  This is due to relatively slow movement by diffusion
of vapor phase benzene through the unsaturated zone.  The Henry's Law Constant for benzene (5.5 x 10-3 atm-m
3/mol)  indicates that benzene, upon reaching surface water via ground water discharge, is likely to
volatilize from the surface water body.  Benzene would transfer readily from the agueous phase to the vapor
phase by air stripping.

Benzene is weakly adsorbed by soils and is likely to be mobile in ground water.  However, based on benzene's
retardation factor, it would still be likely to migrate more slowly than ground water at the Site.  Under
normal environmental conditions, benzene is not expected to undergo hydrolysis, oxidation or reduction
reactions in the soil/ground water environment.  However, numerous studies have shown biodegradation to be
effective in removing benzene from ground water.  Benzene would be degraded to carbon dioxide and water.

ii.)  Exposure Assessment

The objective of the exposure assessment is to evaluate the magnitude and freguency of potential exposure to
CPCs.  Potential human receptors are identified based on characteristics of the Site and surrounding area.
Potential routes of exposure to Site-related CPCs are identified and the extent of a receptor's exposure by
this route is estimated.  While these scenarios represent hypothetical people and activities,  hey reflect
the physical description of the Site and the surrounding industrial and residential areas as well as the
activities that typically occur in these areas.

The receptors evaluated include an on-site resident, an on-site worker, a Construction worker, a trespassing
teenager, and an off-site resident.  Although the Site is currently zoned for industrial use and is owned by
a construction company, it is possible that sometime in the future the Site may be developed for residential
use.  Therefore, as a health protective measure, an on-site resident was included in the risk assessment.

Potential exposure pathways ("PEPs") are the routes by which potential receptors may be exposed to CPCs.
Direct exposure pathways are those in which the potential human receptor comes in direct contact with a CPC
in an environmental medium such as air, water, or soil. Indirect exposure pathways involve exposure to CPCs
through the food chain.  The following direct and indirect exposure pathways were included in the risk
assessment.

     !         Inhalation of soil as dust and vapors;
     !         Dermal contact and incidental ingestion of  soils;
     !         Dermal contact and incidental ingestion of  surface water;
     !         Dermal contact and incidental ingestion of  sediment;
     !         Groundwater exposure (inhalation,  ingestion,  dermal contact);  and
     !         Ingestion of fish.

In accordance with EPA guidance a reasonable maximum exposure ("RME") scenario was performed in this risk
assessment.

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iii.) Risk Characterization

In the risk characterization the results of the exposure assessment are combined with the results of the
toxicity assessment to derive pathway-specific quantitative estimates of potential health risks.  The
estimates for each exposure pathway are then summed to give total risk estimates for the Site.   Separate
quantitative estimates of potential risk are derived for carcinoqenic effects and for noncarcinoqenic
effects.  Results are presented in Table 5 below.

Table 5:  Summary of Site Risks

   Exposure Scenario        Non-Carcinoqenic Risk       Carcinoqenic Risk

On-site Resident                   2.87                   1.3 x 10E-3

Trespassinq Teenaqer              0.092                   1.25 x 10E-4

Off-site Resident                0.00065                  2.4 x 10E-7

On-site Worker                   0.4416                   6.5 x 10E-4

Construction Worker               0.064                   9.6 x 10E-6

The total carcinoqenic risk for the on-site resident is 1.3 x 10-3, well above the threshold acceptable risk
ranqe of 10-6- 10-4.  Approximately 91 percent of this risk estimate  (4.0 x 10-4)  is associated with
inqestion of and dermal contact with carcinoqenic PAH in surface soil.  The total RME noncarcinoqenic hazard
index associated with this scenario is 2.87, indicatinq that there are unacceptably hiqh toxic health effects
from contamination on-site to a theoretical resident. Approximately 86 percent of the potential
noncarcinoqenic hazard index is associated with exposure to the methylphenols in the qroundwater.

The total carcinoqenic risk for an on-site worker is 6.5 x 10-4, also above the threshold risk ranqe.  The
non-carcinoqenic risk to an on-site worker is below 1.0.  Exposure to surface soil by the trespassinq
teenaqer poses a risk estimated to be 1.25 x 10-4, 94 percent of which is associated with exposure to
carcinoqenic PAH in surface soil.

Total potential carcinoqenic risk to the construction worker is below 1 x 10-4 and risks to an off-site
resident livinq across the Tuscarawas River east of the Site is below 1 x 10-6.  The total hazard indices for
an off-site resident livinq east of the Tuscarawas River,  the trespassinq teenaqer, and the construction
worker are below 1, which indicates that no potential noncarcinoqenic health effects associated with these
exposure scenarios are expected to occur.

B.)   Ecoloqical Risk Assessment

In accordance with The Risk Assessment Guidance for Superfund Environmental Evaluation Manual (OSWER
Directive 9285.7-01, March 1989), a baseline ecoloqical risk assessment was conducted to qualitatively and
quantitatively evaluate the potential for adverse ecoloqical effects to occur due to the presence of
Site-related chemicals in the environment.  The habitats and indiqenous species present on the Site and
surroundinq areas were identified durinq two Site visits conducted in April and July of 1992.  Accordinq to
the U.S. Fish and Wildlife Service and the Ohio Department of Natural Resources, there are no threatened or
endanqered species in this area.

The potential ecoloqical exposure pathways included the inqestion of and/or direct contact with CPCs in the
surface water and sediments of the Tuscarawas River and the drainaqe ditch, and the inqestion of and/or
direct contact with CPCs in soils both on and off the Site.  The food chain exposure pathway, i.e., the
inqestion of orqanisms and plants containinq Site-related chemicals, was also assessed.

Information on the habitats, CPCs, and potential exposure pathways were evaluated to develop a conceptual
Site model for the risk assessment.  The key species and habitats, those most likely to be exposed to

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Site-related chemicals, were identified for analysis.  The habitats included the Tuscarawas River, the
drainage ditch, and the Site.  Aquatic and benthic species were evaluated as representatives of the surface
water and sediment environments of the Tuscarawas River and the drainage ditch, and the cottontail rabbit was
assessed as a representative of the terrestrial environment.  Screening assessments were conducted on the
surface water, sediment, and terrestrial habitats.

The results of the terrestrial screening assessment indicate that cottontail rabbits are not likely to
experience adverse effects from exposure to CPCs in the surface water and sediments of the drainage ditch,
and in on-site soils and vegetation.  Extrapolating from the results of the cottontail rabbit analysis, based
on the chemical properties of the CPCs and the limited terrestrial potential exposure pathways, the potential
for adverse effects on terrestrial species in the area of the Site is likely to be minimal.

The results of the aquatic screening assessment were inconclusive.  While acute and chronic toxicity effects
are not likely to occur to aquatic species residing in the Tuscarawas River, surface water concentrations of
CPCs may exceed chronic toxicity levels in the drainage ditch.  Moreover, the results of the sediment
screening assessment indicate that chronic toxicity effects are likely to occur to benthic species in the
Tuscarawas River sediments in the vicinity of the drainage ditch outfall.  Sediment concentrations of CPCs
may exceed toxicity levels in the drainage ditch.

Based on the conclusions of the aquatic, sediment, and terrestrial screening assessments, monitoring the
river appears to be warranted regarding the effects on contaminants in the surface water sediments in the
drainage ditch and in the outfall of the Tuscarawas river on aquatic species.

VII.  DESCRIPTION OF SITE-WIDE REMEDIAL ALTERNATIVES

The presence of coal tar CPC, particularly BTEX and PAH, in the soil, in free tar product on the surface, in
sediments and in groundwater present a risk to human health and a potential threat to the environment, as
stated above.  Several Site-wide alternative cleanup methods were evaluated in the FS and in addenda to the
FS, which can be found in the Site repository and in the Administrative Record.  These alternatives were
developed and evaluated on the basis of a number of criteria which are discussed below.

A.)   Remedial Action Objectives and Cleanup Levels

Remedial action objectives ("RAO's") for each environmental media are developed in the FS, subsequent to the
RI and risk assessment.  RAOs serve as the basis on which remedial response alternatives are designed.  RAOs
must account for each pathway in which a risk or a potential risk to human health or the environment exists.
Cleanup levels in each media are also determined in the FS.  Cleanup levels are derived from within the
acceptable residual carcinogenic risk range of 10-6 - 10-4, based in part on future land use and other
criteria such as practicability.  For this Site, cleanup levels were derived based on a residual carcinogenic
risk level of approximately 1.0 x 10-5, in an industrial future use scenario.  Non-carcinogenic risks in the
industrial use scenario were beneath the threshold hazard quotient of 1.0, and therefore are not of concern.

The following RAOs were developed for the Site:

!       Prevent worker exposure to CPC in the surface soil,  tarry materials and sediments which pose an excess
       cancer risk of approximately 10-5 or greater;

!       Prevent worker exposure to CPC in the sub-surface soil which pose an excess cancer risk of
       approximately 10-5 or greater;

!       Prevent exposure to CPC in the perched aquifer above MCLs;

!       Prevent exposure to CPC in the regional aquifer above MCLs;

!       Prevent migration of CPC in surface and subsurface soils, and tarry materials to the regional aquifer;

!       Prevent migration of CPC in sediments that would result in exceedences in ambient water quality

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       criteria in the Tuscarawas River;

!       Prevent migration of CPC in the perched aquifer migrating to the drainage ditch or the regional
       aquifer;

!       Prevent migration of CPC in the regional aquifer.

B.)   Applicable or Appropriate and Relevant Requirements

CERCLA Section 121(d) requires that remedial actions take into consideration the requirements of all federal
and state environmental regulations.  Those pertinent regulations are referred to as applicable or relevant
and appropriate requirements  ("ARARs").

Applicable requirements are 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, or other circumstance at a CERCLA Site.

Relevant and appropriate requirements are standards, standards of control, and other substantive
environmental protection requirements, criteria, or limitations promulgated under federal or state law that,
while not applicable to a hazardous substance, pollutant, contaminant, remedial action, or other
circumstances at a CERCLA Site, are well suited for use at the CERCLA Site because they address problems or
situations sufficiently similar.  In some circumstances, a requirement may be relevant to the particular
Site-specific situation but will not be appropriate because of differences in the purpose of the requirement,
the duration of the regulated activity, or the physical size or characteristic of the situation it is
intended to address.  Only those requirements that are determined to be both relevant and appropriate must be
complied with.

A requirement that is judged to be relevant and appropriate must be complied with to the same degree as if it
were applicable.  Relevant and appropriate requirements that are more stringent than applicable requirements
take precedence.  There is more discretion in the determination of relevant and appropriate requirements than
in the determination of applicable requirements.  It is possible for only a part of a requirement to be
relevant and appropriate.

In addition to the legally binding requirements established as ARARs, many federal and state programs have
developed criteria, advisories, guidelines, or proposed standards that may provide useful information or
recommend procedures if no ARARs address a particular situation or if existing ARARs do not provide
protection.  In such situations, these "to be considered" ("TBC") criteria or guidelines should be used to
set remedial action levels.  Examples of criteria to be considered are reference doses ("RFD")  and slope
factors for ingestion of non-carcinogenic and carcinogenic compounds, respectively, for the risk assessment.

The potential ARARs for the Site were developed based on the July 29, 1994 letter from U.S. EPA Region 5 to
Mr. James Bratina of Reilly Industries, transmitting a listing of potential ARARs.  ARARs were then
identified based on the specific characteristics of the Site, constituents of interest identified in soil and
ground water, and potential alternatives available to remediate those constituents.  The applicability of
each of the potential ARARs listed in the July 29, 1994 letter was evaluated to assess the potential ability
of technologies to comply with ARARs.

CERCLA Section 121 (e) exempts any response action conducted entirely on Site from having to obtain federal,
state, or local permits.  On-Site actions need to comply only with the substantive aspects of ARARs, and not
the corresponding administrative requirements.  Therefore, permit applications and other administrative
reviews and reporting, and record keeping requirements are not considered ARARs for actions conducted
entirely on Site (USEPA 1988).  Where a waiver from requirements set by an ARAR is needed to apply an
alternative, a description and justification for the waiver is discussed in the detailed evaluation.

Based on the CERCLA statutory requirements, the remedial alternatives developed in this FS are analyzed for
compliance with federal and state ARARs.  This process involves the initial determination of potential
requirements, the evaluation of the potential requirements for applicability or relevance and

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appropriateness, and finally, a determination of the ability of the remedial alternatives to achieve the
ARARs.

Three classifications or requirements are defined in the ARAR determination process and are summarized below:

      !        chemical-specific;
      !        location- specific;  and
      !        action-specific.

Chemical-specific ARARs include those laws and regulations governing the release of materials possessing
certain chemical or physical characteristics, or containing specific chemical compounds.  Examples include
drinking water standards, and ambient air quality standards. These requirements generally set health or
risk-based concentration limits or discharge limitations after treatment in various environmental media for
specific hazardous substances.

A Site's location is a fundamental determinant of its impact on human health and the environment.
Location-specific ARARs are restrictions placed on the concentration of hazardous substances or the conduct
of activities solely because they are in specific locations.  Some examples of special locations include
flood plains, wetlands, historic places, and sensitive ecosystems or habitats.  Action-specific ARARs are
usually technology- or activity-based requirements or limitations on actions taken with respect to hazardous
wastes.  These requirements are triggered by the particular remedial activities that are selected to
accomplish a remedy.  Since there are usually several alternative actions  for any remedial Site, very
different requirements can come into play. These action-specific requirements are not the driving force in
determining the remedial alternative; rather, they indicate how a selected alternative must be achieved.

Potential Federal and State ARARs identified by U.S. EPA and OEPA for this Site are attached in Appendix A.

C.)    Alternative Listing

The following alternatives evaluated in the FS and in addenda to the FS were presented to the Public through
the Proposed Plan/Public meeting in Dover, Ohio on January 22, 1997:

Alternative 1 - No Action

The inclusion of the no action alternative is required by law and gives U.S. EPA a basis for comparison.
This alternative will not reduce any potential public health or environmental risks currently associated with
the Site.  This alternative does not include any institutional controls preventing the use of ground water or
surface water.

!       Net Present Worth Cost:   $0

Alternative 2 - Institutional controls, excavation and thermal treatment of surface water drainage ditch and
river sediments, surface soils and impacted perched zone material contaminated with greater than 100 ppm
B(a)P-TE, and off-site disposal of solidified tarry materials; excavation and on-site disposal of surface
water drainage ditch sediments, and surface soils contaminated with less than 100 ppm B(a)P-TE, and greater
than 5 ppm B(a)P-TE.  Ohio RCRA Subtitle D Solid Waste Cap over on-site disposed materials.  Soil cover over
remainder of the Site.  Natural attenuation and long-term monitoring of shallow ground water.  Sampling and
analysis of sediments in the river.

Under this alternative, the Site will continue to be zoned for industrial use only, a deed restriction will
be placed on-site banning all use of groundwater, and limiting disturbance of the land; impacted surface
water drainage ditch sediments and contaminated surficial soils above the 100 ppm contamination level for
B(a)P-TE - approximately 2480 cubic yards will be excavated and treated off-site in a cement kiln, impacted
surface water drainage ditch sediments and contaminated surficial soils between 5 ppm and 100 ppm B(a)P-TE -
approximately 5500 cubic yards, will be placed on-site within the building foundation and capped with an Ohio
RCRA Subtitle D Solid Waste Cap; tarry materials will be solidified and disposed off-site, or recycled reused
as fuel/feedstock; the remainder of the Site will be covered with soil and vegetated. Sediments in the river

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will be sampled and analyzed to further determine possible impacts on the river ecosystem.

Capital Cost:                     $1,257,000
30 yrs. Operation & Maintenance   $  965,000
Total Present Worth:              $2,220,000

Alternative 3 - Institutional controls, excavation and thermal treatment of surface water drainage ditch
sediments, surface soils and impacted perched zone material contaminated with greater than 100 ppm B(a)P-TE,
and off-site disposal of solidified tarry materials or recycle/reuse of tarry materials as fuel or feedstock;
excavation and on-site disposal of surface water drainage ditch and river sediments, surface soils and
impacted perched zone soils, from collection trench excavation, contaminated with less than 100 ppm B(a)P-TE,
and greater than 5 ppm B(a)P-TE.  Ohio RCRA Subtitle D Solid Waste Cap over on-site disposed materials.  Soil
cover over remainder of the Site; hydraulic control and collection of perched ground water and natural
attenuation and long-term monitoring of shallow ground water.  Sampling and analysis of sediments in the
river.

Under this alternative, all action items in alternative 2 will be implemented.  In addition, a french drain
will be placed in the perched aguifer to maintain a hydraulic barrier to perched tarry materials and
groundwater migration off-site.

Capital:                $1,379,100
O&M:                    $1,431,200
Present Worth           $2,810,300

Alternative 4 - Institutional controls, excavation and off-site treatment of drainage ditch sediments,
surface soils and impacted perched zone soils from the collection trench installation, contaminated with
greater than 5 ppm B(a)P-TE; solidification and off-site disposal of tarry materials, or recycle/reuse of
tarry materials as fuel or feedstock; a soil cover over the Site; hydraulic control and collection of perched
ground water and natural attenuation and long-term monitoring of shallow ground water.  Sampling and analysis
of sediments in the river.

Under this alternative, all excavated soils and sediments, approximately 8000 cubic yards, will be treated
off-site in a cement kiln, eliminating the need for a solid waste cap.  Tarry materials will be solidified
prior to disposal.  Other action items will be implemented as above.

Capital:                $2,238,200
O&M:                    $1,431,200
Present Worth           $3,669,400

VIII.  SUMMARY OF COMPARATIVE EVALUATION OF ALTERNATIVES

The NCP reguires that the alternatives be evaluated on the basis of the following nine evaluation criteria:
(1) Overall protection of human health and the environment;   (2) Compliance with ARARs; (3) Long-term
effectiveness and permanence;  (4) Reduction of toxicity, mobility, or volume through treatment; (5)
Short-term effectiveness; (6) Implementability; (7) Cost;  (8) State acceptance; and  (9) Community acceptance.
This section compares the alternatives with regard to these nine evaluation criteria, which are further
defined below:

Overall Protection of Human Health and the Environment addresses whether or not the remedy provides adeguate
protection and describes how risks are eliminated, reduced or controlled through treatment, engineering
controls, or institutional controls.

Compliance with ARARs addresses whether or not the remedy will meet all of the applicable or relevant and
appropriate reguirements of other Federal and State environmental statutes and/or provide grounds for
invoking a waiver.

Long-term Effectiveness and Permanence refers to the ability of a remedy to maintain reliable protection of

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human health and the environment over time once cleanup goals have been met.

Reduction of Toxicity, Mobility, or Volume Through Treatment is the anticipated performance of the treatment
technologies a remedy may employ.

Short-term Effectiveness involves the period of time needed to achieve protection and any adverse impacts on
human health and the environment that may be posed during the construction and implementation period until
cleanup goals are achieved.

Implementability is the technical and administrative feasibility of a remedy, including the availability of
goods and services needed to implement the chosen solution.

Cost includes capital and operation and maintenance costs.

Support Agency Acceptance indicates whether, based on its review of the RI/FS and Proposed Plan,  the support
agency concurs, opposes, or has no comment on the preferred alternative.

Community Acceptance addresses the public's comments on and concerns about the Proposed Plan and the FS
Report.  The specific responses to public comments will be addressed in the Responsiveness Summary attached
to the Amended Record of Decision.

A.)   Threshold Criteria:  Overall Protection Of Human Health And The Environment and compliance With ARARs:

Alternative 1, the No Action Alternative, satisfies none of the RAOs above and obviously does not satisfy the
threshold criterion of overall protectiveness of human health and the environment. The risks to human health
and potential risks to the environment remain.

Alternative 2 satisfies some but not all of the RAOs and is not protective of human health or the
environment.  Specifically, the CPC in the free phase coal tar, which resides in the perched zone, would
continue to migrate off-site unabated.  The spread of coal tar CPC in the perched zone to the drainage ditch
and potentially to the regional aguifer present potential threats to human health and the environment.

Alternatives 3 and 4 both satisfy RAOs and protect of human health and the environment through treatment of
principal threats, and both meet ARARs as well.  The remainder of this evaluation will be limited to
alternatives 3 and 4.

B.)   Primary balancing Criteria:  Long term effectiveness and permanence; Reduction in toxicity, mobility
and volume through treatment; Short term effectiveness, implementability; and cost.

Long term effectiveness and permanence are substantially, if not entirely satisfied by alternatives 3 and 4.
Both alternatives employ treatment of principal threats at the Site.  Alternative 4 calls for the off-site
thermal treatment of all Site soils and sediments in excess of 5 ppm B(a)P- TE, whereas alternative 3 calls
for thermal destruction of soils and sediments which contain B(a)P-TE of 100 ppm or greater, and on-site
containment of lightly contaminated soils and sediments  (B(a)P-TE < 100 ppm, and > 5 ppm).  Each alternative
employs a drain to capture, pump and treat subsurface perched water with coal tar CPC in the perched zone.

A completely permanent remedy would entail excavation of any and all coal tar CPC on or underneath the Site.
This approach was screened out due to its impracticability.  Alternatives 3 and 4 are effective in the long
term because surficial risks are effectively mitigated and underlying coal tar CPC are eventually drained out
of the perched zone and treated in the local POTW. Alternative 3 is not entirely permanent, because it
employs a containment component.

Alternative 4 fully satisfies the criteria to reduce toxicity, mobility and volume of CPC in soil and
sediment through treatment.  Surficial coal tar is either thermally treated, stabilized or recycled.
Alternative 3 satisfies this criteria for the heavily contaminated soils and sediments, and for subsurface
coal tar CPC, but not for lightly contaminated soils and sediments.

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The short term effectiveness of alternatives 3 and 4 are approximately equal, the only difference being the
amount of soil removed off-site and the construction of an Ohio Solid Waste Cap.  The time to haul three
times the amount of soil off-site in alternative 4 is off-set by the time to  construct a cap.  Risks posed
to construction workers during remedial action were calculated in the risk assessment and are below levels of
concern.

Both alternatives 3 and 4 are implementable.  A cement kiln has been identified to receive the contaminated
soils.  The civil engineering and construction requirements to build an on-site vault, and install the french
drain on-site are well understood and should pose no difficulty to design and remedial action.  The net
present worth of alternative 3 is $2.8 million.  The net present worth of alternative 4 is 30% higher, at
$3.67 million.

A cost-benefit analysis evaluates remedial response alternatives within the context of how completely each of
the balancing criteria above are satisfied against the total cost of each remedy.  Between two remedies, a
cost benefit analysis identifies the incremental increase in benefit (based on the balancing criteria  above
minus cost)  and identifies a value for this against the actual incremental increase in cost associated with
that incremental benefit.  A cost benefit analysis is not an analysis of cost versus protectiveness.   Both
alternatives under consideration are fully protective of human health and the environment and meet ARARs.

In this case, alternative 4 presents the incremental benefit of removing 5500 cubic yards of lightly
contaminated soils and sediment from the Site, making an on-site vault unnecessary.  The specific cost
benefit analysis question here is based on whether this benefit is worth the additional $850,000, which is
the approximate cost difference between the two alternatives.

USEPA considers it more cost effective to keep lightly contaminated soils contained on-site for two reasons.
First, from an environmental perspective, while lightly contaminated soils will remain on-site in a vault,
the principle CPC, B(a)P-TE, is virtually immobile, and the likelihood, of off Site migration or a long term
breach in the effectiveness of this remedy is very remote. Secondly, from an economic and development
perspective, this Site will be limited to commercial/industrial use, and well development will be prohibited.
Therefore, unrestricted use is not an option, making the removal of all surficially contaminated soils
off-site unnecessary.  Each alternative will equally permit the development of the Site for industrial use.
Therefore, USEPA recommends alternative 3.

C.)   Modifying Criteria: State Agency Acceptance and Community Acceptance

OEPA agrees that alternative 3 is the most cost effective remedy and supports its recommendation.  A public
meeting was held on January 22, 1997 in Dover, Ohio to present the selected remedy.  There were no public
comments during the meeting and no public comments were received subsequently, indicating that there is no
objection to this remedial alternative.

IX.   SELECTED REMEDY

Alternative 3 is the selected remedy for this Site:

Institutional controls, excavation and off-site thermal treatment of drainage ditch and river sediments,
surface soils and impacted perched zone material from the collection trench installation contaminated with
greater than 100 ppm B(a)P-TE, and off-site disposal of solidified tarry materials, excavation and on-site
disposal of surface water drainage ditch and river sediments, surface soils and impacted perched zone
material contaminated with less than 100 ppm B(a)P-TE, and greater than 5 ppm B(a)P-TE; an Ohio RCRA Subtitle
D Solid Waste Cap over on-site disposed materials; a soil cover over the remainder of the Site; hydraulic
control and collection of perched ground water and natural attenuation and long-term monitoring of shallow
ground water. Sampling and analysis of sediments in the river.

The selected remedy is discussed in more detail below.

Institutional Controls

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Regional planning indicates that the area will continue to be zoned only for industrial use.  Deed
restrictions will be placed on the affected property to prohibit Site disturbance and groundwater use.   The
City of Dover passed Ordinance No. 34-96 which bans installing ground water wells for human consumption
throughout the City.  Efforts are currently underway to ban all ground water use (i.e., industrial,
agricultural, irrigation) in the Site area.  The Mayor of Dover has been receptive to banning all ground
water use in the Site area, and this proposal was presented to the Dover City Council on August 19,  1996.
The current owner of the Site and property south and west has agreed to place deed restrictions on these
properties to prohibit ground water use and limit disturbance of the land.  The Site will continue to be
secured with chain-link fencing and a locked gate until the existing exposure risks at the Site have been
addressed.

Excavation and Off-site Thermal Treatment of Surface Water Drainage Ditch Sediments, Surface Soils and
Impacted Perched Zone Material with B(a)P-TE greater than 100 ppm

Surficial soils with B(a)P-TE greater than 100 ppm  (approximately 2,730 cubic yards) will be excavated and
treated in an off-site cement kiln.  Impacted surface water drainage ditch sediment (approximately 120 cubic
yards)  will be excavated and treated in an off-site cement kiln. Impacted perched zone material from the
collection trench excavation will be treated in an off-site cement kiln.  The trench will be backfilled with
high permeability fill and clean spoils from the excavation.  The surface water ditch will be lined to
eliminate the hydraulic connection between the surface water and perched zone.

Excavation and On-site Disposal of Surface Water Drainage Ditch Sediments, Surface Soils, Impacted Perched
Zone Material with B(a)P-TE less than 100 ppm and Greater than 5 ppm

Surficial soils with B(a)P-TE less than 100 ppm and greater than 5 ppm  (approximately 5500 cubic yards)  will
be excavated and placed in the building foundation.  The cracks in the floors and walls of the building
foundation will be sealed to ensure the integrity of the structure.  The Site will be grubbed and graded.
Soil, concrete and/or slag removed to facilitate grading activities will be placed in the building
foundation.  The building foundation will be capped with an Ohio Solid Waste Cap, pursuant to 40 CFR 261
(Subtitle D) and Ohio Administrative Code Section 3745-27-08, and the remainder of the Site will be covered
with soil and vegetated.

Off-site Disposal or Recycling of Tarry Materials

The tarry materials will be solidified with lime, cement and/or flyash and will be disposed off-site, or may
be recycled as a feedstock.  To the extent that these materials are RCRA Characteristic Hazardous Waste,
off-site disposal must comply with Land Ban regulations pursuant to 40 CFR Section 268 Subpart D, and with U
S. EPA's off-site Rule, 58 Fed Reg 49200  (September 22, 1993), for disposal in an approved RCRA Subtitle C
landfill.  Transportation and storage of these materials would need to comply with 40 CFR 262, and 263 as
well.  It is estimated that a 20% volume increase would occur due to the solidification process.

The recycling option will depend largely on material handling issues and the ability to segregate coal tar
from the soils and sediments.  To the extent that these materials are RCRA Characteristic Hazardous Waste,
recycling of these materials must comply with Ohio Administrative Code Section 3745-50-311 through
3745-50-315, which govern criteria by which recycling variances to classification as a waste are granted.

Hydraulic Control and Collection of Perched Ground Water

A horizontal trench will be installed within the saturated portion of the perched zone, on top of the
underlying clay to a depth of approximately 15 to 18 feet below the surface (approximately 863 feet MSL) to
recover perched ground water.  The trench will be located in the central portion of the Site and will be
approximately 400 linear feet.  The trench will be constructed to maximize drainage of perched contaminants
while maintaining the integrity of the perched clay zone.  Top of clay topography will, for the most part,
determine the natural collection point of the trench where perched water will be pumped to an oil/water
separator and discharged to the sanitary sewer line that leads to the City of Dover POTW.

A permit will be obtained from the City of Dover to discharge the water recovered from the trench to the

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POTW.  Discharge to the POTW must comply with the POTW pretreatment program, including POTW-specific
pollutants, pursuant to 40 CFR 403.5:  Discharge to Publicly Owned Treatment Works.  The permit will
establish appropriate pre-treatment limits pursuant to 40 CFR 403.  Any waste to be discharged to the POTW
will, if necessary, be treated to satisfy the standards set forth in the permit, prior to discharge.  The
discharge from the collection trench is expected to be approximately 2,900 to 7,200 gallons per day.

Natural Attenuation and Long-Term Monitoring of Shallow Ground Water

At the present time, no CPC present in the regional aguifer downgradient of the Site exceeds Safe Drinking
Water MCLS.  CPC degradation and migration will be monitored in the shallow regional ground water to assess
the effectiveness of natural attenuation on an on-going basis.  Monitoring wells will be in both upgradient
and downgradient locations around the Site to achieve these goals.

Sampling and Analysis of Tuscarawas River Sediments to Monitor Ecological Effects

Monitor river sediments in the outfall and immediately downstream for 3-5 years to ensure that there are no
risks to the aguatic ecosystem.

X.   STATUTORY DETERMINATIONS

US EPA's selected alternative provides the best balance of tradeoffs among the alternatives with respect to
the criteria used to evaluate the remedies.  Based on the information available at this time,  U.S. EPA
believes the selected alternative will protect human health and the environment, will comply with ARARs, will
be cost-effective, and will utilize permanent solutions and alternative treatment technologies to the maximum
extent practicable.  The selected alternative also satisfies the preference for treatment as a principal
element.

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APPENDIX A

FEDERAL AND STATE APPLICABLE OR RELEVANT AND APPROPRIATE REGULATIONS






















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TABLE C-3

Federal Chemical-Specific Potential Applicable or Relevant and Appropriate Requirements
         Chemical Name

       NAAQS (a)  (Clean Air Act)
             Requirements
       Carbon monoxide
       Lead
Not to exceed 9 ppm over 8-hour period and not to exceed 35
ppm over a 1-hour period (primary); no secondary standards.

Not to exceed 1.5 Iq/m 3 based on a quarterly averaqe.
       Nitroqen dioxide  Not to exceed 0.053 ppm annually.
       Particulate
       matter (PM 10)

       Ozone
       Sulfur oxides
Not to exceed 50 Iq/m 3 annually.
Not to exceed 150 Iq/n 3 /24-hour period.

Not to exceed 0.12 ppm/hr.
                         Not to exceed 0.03 ppm annually.
                         Not to exceed 0.14 ppm/24-hour period.
                         Not to exceed 0.5 ppm/3-hour period.
                                                                      Prerequisites for
                                                                        Applicability
                                                                   Major stationary and mobile
                                                                   sources.

                                                                   Major stationary sources.
                                                                   Major stationary and mobile
                                                                   sources.

                                                                   Major stationary sources.
                                                                   Major stationary and mobile
                                                                   sources.

                                                                   Major stationary sources.
       (a)   NAAQS are translated into source-specific requirements State Implementation Plans (SIPS).













  Citation
Q CFR Part
50 (CAA)

40 CFR Part
50 (CAA)

40 CFR Part
50 (CAA)

40 CFR Part
50 (CAA)

40 CFR Part
50 (CAA)

40 CFR Part
50 (CAA)

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ADMINIS.
 CODE
SECTION
                      OHIO ADMINISTRATIVE CODE (OAC) ARARs
                        REILLY  TAR           TUSCARAWAS  COUNTY
PERTINENT
PARAGRAPH
TITLE OR  SUBJECT
 OF REGULATION
                                                                                          Appendix A cont.
 DESCRIPTION
OF REGULATION
 APPLICATION
OF REGULATION
ARAR
TYPE
                                   LIST OF ENDANGERED PLANT SPECIES
                                                                              PLANT  SPECIES CONSIDERED ENDANGERED IN OHIO.
                                   SOIL AND  DRAINAGE
1501-14-4         1-3
                                                                              REQUIREMENTS FOR  RECLAMATION  OF  SURFACE MINED AREAS
                                                                              ISOLATION OF ACID DRAINAGE. RESTRICTION ON  SURFACE WATER
                                                                              IMPOUNDMENTS. RULES  FOR USE OF  EXPLOSIVES.  PROTECTION  OF
                                                                              UNDERGROUND WATER SUPPLIES, SAFETY OF HIGHWALLS, RESOILING,
                                                                              REVEGETATION, DAMS AND DIVERSIONS.

                                                                              REQUIRES  SURVEY AND  OTHER  INFORMATION FOR  SURFACE MINING.
                                                                                                                                            CONSIDER  FOR SITES WITH  SOIL BORROW AREAS OR  EXTENSIVE
                                                                                                                                            EXCAVATION.
                                                                                                                                                               CONSIDER FOR  SITE WITH BORROW SOURCE AREA OR EXTENSIVE
                                                                                                                                                               EXCAVATION.
                                   LIST OF ENDANGERED ANIMAL SPECIES
                                   ANALYTICAL  AND COLLECTION
                                   PROCEDURES
                                                          SPECIFIES ANALYTICAL METHODS  AND COLLECTION PROCEDURES FOR
                                                          SURFACE WATER  DISCHARGES.
                                                                                                                     PERTAINS  TO BOTH DISCHARGES TO  SURFACE WATERS  AS A
                                                                                                                     RESULT  OF REMEDIATION AND ANY ON-SITE SURFACE  WATERS
                                                                                                                     AFFECTED  BY SITE CONDITIONS.
3745-1-04       A,B,C,D,E
                                   THE "FIVE  FREEDOMS"  FOR SURFACE
                                   WATER
                                                          ALL SURFACE WATERS OF THE  STATE SHALL  BE FREE FROM:
                                                          A)  OBJECTIONABLE SUSPENDED SOLIDS,
                                                          B)  FLOATING DEBRIS, OIL AND SCUM,
                                                          C)  MATERIALS  THAT CREATE A NUISANCE,
                                                          D)  TOXIC, HARMFUL OR LETHAL SUBSTANCES,
                                                          E)  NUTRIENTS  THAT CREATE NUISANCE GROWTH.
                                                                                                                     PERTAINS  TO BOTH DISCHARGES TO  SURFACE WATERS  AS A
                                                                                                                     RESULT  OF REMEDIATION AND ANY ON-SITE SURFACE  WATERS
                                                                                                                     AFFECTED  BY SITE CONDITIONS.
                                  ANTIDEGRADATION POLICY  FOR
                                  SURFACE WATER
                                                          PREVENTS DEGRADATION OF SURFACE WATER  QUALITY BELOW
                                                          DESIGNATED USE  OR EXISTING  WATER QUALITY.  EXISTING IN STREAM
                                                          USES  SHALL BE MAINTAINED AND PROTECTED THE MOST STRINGENT
                                                          CONTROLS FOR TREATMENT SHALL BE REQUIRED BY THE DIRECTOR TO
                                                          BE  EMPLOYED FOR ALL NEW AND EXISTING POINT SOURCE
                                                          DISCHARGES. PREVENTS ANY DEGRADATION OF "STATE RESOURCE
                                                          WATERS".
                                                                                                                     REQUIRES  THAT BEST AVAILABLE TECHNOLOGY  (BAT)  BE USED
                                                                                                                     TO TREAT  SURFACE WATER DISHARGES.  DWQPA USES  THIS RULE
                                                                                                                     TO SET  STANDARDS WHEN EXISTING  WATER QUALITY  IS BETTER
                                                                                                                     THAN THE  DESIGNATED  USE.
                                  MIXING ZONES  FOR SURFACE  WATER
                                                                               (A)  PRESENTS THE  CRITERIA FOR  ESTABLISHING NON-THERMAL MIXING
                                                                              ZONES  FOR POINT SOURCE DISCHARGES (B) PRESENTS THE CRITERIA
                                                                              FOR  ESTABLISHING  THERMAL MIXING ZONES
                                                                              FOR  POINT SOURCE  DISCHARGES.
                                                                                                                                            APPLIED AS  A TERM OF DISCHARGE PERMIT TO INSTALL (PTI).
                                                                                                                                            WOULD PERTAIN TO AN ALTERNATIVE WHICH RESULTED  IN A
                                                                                                                                            POINT SOURCE DISCHARGE.
                                  WATER QUALITY CRITERIA
                                                                              ESTABLISHES WATER  QUALITY CRITERIA FOR POLLUTANTS WHICH DO
                                                                              NOT HAVE SPECIFIC  NUMERICAL OR NARRATIVE  CRITERIA IDENTIFIED IN
                                                                              TABLES  7-1 THROUGH 7-15 OF THIS RULE.
                                                                                                                                            PERTAINS  TO BOTH DISCHARGES TO SURFACE WATERS  AS  A
                                                                                                                                            RESULT OF  REMEDIAL ACTION AND ANY  SURFACE WATERS
                                                                                                                                            AFFECTED  BY SITE CONDITIONS.
                                                                                                                                                                                                      CHEMICAL
                                                                                                                                                                                                      ACTION
3745-1-24
                                  WATER USE  DES  FOR MUSKINGUM RIVER
                                                                              ESTABLISHES WATER  USE DESIGNATIONS FOR
                                                                              WITHIN  THE MUSKINGUM RIVER BASIN.
                                                                                                                         STREAM SEGMENTS
                                                                                                                                            PERTINENT  IF  STREAM OR  STREAM SEGMENT IS ON-SITE AND IS
                                                                                                                                            EITHER AFFECTED BY SITE CONDITIONS  OF IF REMEDY  INCLUDES
                                                                                                                                            DIRECT DISCHARGE. USED  BY DWQPA TO  ESTABLISH WASTE
                                                                                                                                            LOAD ALLOCATIONS.

-------
ADMINIS.
 CODE
SECTION
                      OHIO ADMINISTRATIVE  CODE  (OAC)  ARARs
                        REILLY  TAR           TUSCARAWAS COUNTY
PERTINENT
PARAGRAPH
TITLE OR SUBJECT
 OF REGULATION
 DESCRIPTION
OF REGULATION
 APPLICATION
OF REGULATION
ARAR
TYPE
                                   MALFUNCTION S MAINTENANCE OF  AIR
                                   POLL  CONTROL EQUIPMENT
                                   MR POLLUTION NUISANCES PROHIBITED
                                                           ESTABLISHES SCHEDULED MAINTENANCE AND SPECIFIES WHEN
                                                           POLLUTION  SOURCE MUST BE SHUT  DOWN DURING MAINTENANCE.

                                                           DEFINES  AIR POLLUTION NUISANCE AS THE EMISSION OR  ESCAPE
                                                           INTO THE AIR FROM ANY SOURCE(S)  OF SMOKE,  ASHES, DUST,  DIRT,
                                                           GRIME, ACIDS, FUMES,  GASES, VAPORS, ODORS  AND COMBINATIONS
                                                           OF THE ABOVE THAT ENDANGER HEALTH, SAFETY OR WELFARE  OF THE
                                                           PUBLIC OR  CAUSE PERSONAL INJURY OR PROPERTY DAMAGE  SUCH
                                                           NUISANCES  ARE PROHIBITED.
                                                                                                                      PERTAINS  TO ANY SITE  WHICH UTILIZES OR WILL UTILIZE  AIR
                                                                                                                      POLLUTION CONTROL  EQUIPMENT ON-SITE.

                                                                                                                      PERTAINS  TO ANY SITE  WHICH CAUSES,  OR MAY  REASONABLY
                                                                                                                      CAUSE, AIR POLLUTION  NUISANCES  CONSIDER  FOR SITES  THAT
                                                                                                                      WILL UNDERGO EXCAVATION, DEMOLITION, CAP INSTALLATION,
                                                                                                                      METHANE  PRODUCTION,  CLEARING AND GRUBBING,  WATER
                                                                                                                      TREATMENT,  INCINERATION AND WASTE FUEL RECOVERY.
                                   STACK  HEIGHT REQUIREMENTS
                                                                               ESTABLISHES  ALLOWABLE  STACK HEIGHT FOR AIR CONTAMINANT
                                                                               SOURCES BASED ON GOOD  ENGINEERING PRACTICE.
                                                                                                                                             PERTAINS  TO ANY SITE  THAT HAS  OR WILL HAVE  AN AIR
                                                                                                                                             CONTAMINANT SOURCE  ONSITE  (PARTICULATE, DUST, FUMES,
                                                                                                                                             GAS, MIST,  SMOKE, VAPOR, ODORS)  EMITTED FROM A STACK
                                                                                                                                             CONSIDER  FOR REMEDIES INCORPORATING INCINERATION, WASTE
                                                                                                                                             FUEL RECOVERY AND WASTEWATER TREATMENT.
                                   PARTICULATE AMBIENT AIR QUALITY
                                   STANDARDS
                                   PARTICULATE NON-DEGRADATION
                                   POLICY
                                   VISIBLE  PARTICULATE EMISSION
                                   CONTROL
                                   EMISSION RESTRICTIONS FOR  FUGITIVE
                                   DUST
                                                           ESTABLISHES SPECIFIC STANDARDS  FOR TOTAL  SUSPENDED
                                                           PARTICULATES.
                                                           DEGRADATION OF AIR  QUALITY IN  ANY AREA WHERE AIR QUALITY IS
                                                           BETTER  THAN REQUIRED BY 3145-17-02 IS PROHIBITED.
                                                           SPECIFIES  THE ALLOWABLE OPACITY FOR PARTICULATE EMISSIONS,
                                                           PROVIDES  EXCEPTIONS  FOR UNCOMBINED WATER.
                                                           START-UP/SHUTDOWN  OF FUEL BURNING EQUIPMENT,  MALFUNCTIONS.

                                                           ALL EMISSIONS OF FUGITIVE DUST  SHALL BE  CONTROLLED.
                                                                                                                      PERTAINS  TO ANY SITE  THAT MAY  EMIT MEASURABLE
                                                                                                                      QUANTITIES  OF PARTICULATE MATTER (BOTH  STACK AND
                                                                                                                      FUGITIVE).  CONSIDER FOR SITES  THAT WILL UNDERGO
                                                                                                                      EXCAVATION, DEMOLITION, CAP  INSTALLATION,  CLEARING  AND
                                                                                                                      GRUBBING,  INCINERATION AND WASTE FUEL RECOVERY.

                                                                                                                      PERTAINS  TO SITES  IN  CERTAIN LOCATIONS  THAT MAY EMIT  OR
                                                                                                                      ALLOW  THE  ESCAPE OF PARTICULATES (BOTH  STACK AND
                                                                                                                      FUGITIVE).  CONSIDER FOR SITES  THAT WILL UNDERGO
                                                                                                                      EXCAVATION, DEMOLITION, CAP  INSTALLATION,  CLEARING  AND
                                                                                                                      GRUBBING,  INCINERATION.

                                                                                                                      PERTAINS  TO ANY EMISSION OF  PARTICULATE FROM A STACK
                                                                                                                      CONSIDER  FOR INCINERATION AND  FUEL BURNING.
                                                                                                                                             PERTAINS  TO SITES WHICH MAY HAVE FUGITIVE  EMISSIONS
                                                                                                                                             (NON-STACK)  OF DUST.  CONSIDER  FOR SITES  THAT WILL
                                                                                                                                             UNDERGO GRADING, LOADING OPERATIONS, DEMOLITION,
                                                                                                                                             CLEARING  AND GRUBBING AND CONSTRUCTION.
                                                                                                                                                    CHEMICAL
                                                                                                                                                    LOCATION
                                   INCINERATOR PARTIC EMISSION  f,  ODOR
                                   RESTRICTIONS
                                                           ESTABLISHES PARTICULATE EMISSION LIMITATIONS AND
                                                           DESIGN-OPERATION  REQUIREMENTS  TO PREVENT  THE EMISSION OF
                                                           OBJECTIONABLE ODORS.
                                                                                                                                                                 PERTAINS  TO ANY REMEDY  INCORPORATING INCINERATION.
                                   FUEL  BURNING PARTIC EMISSION
                                   RESTRICTIONS
                                   SULFUR DIOXIDE AMBIENT AIR  QUALITY
                                   STANDARDS
                                                           ESTABLISHES PARTICULATE EMISSION LIMITATIONS FOR FUEL BURNING
                                                           EQUIPMENT.
                                                           ESTABLISHES PRIMARY  AND SECONDARY AMBIENT  AIR QUALITY
                                                           STANDARDS  FOR SULFUR DIOXIDE.
                                                                                                                      PERTAINS  TO ANY REMEDY INCORPORATING FUEL  BURNING
                                                                                                                      (WASTE  FUEL RECOVERY).

                                                                                                                      PERTAINS  TO ANY SITE  THAT EMITS  OR WILL  EMIT SULFUR
                                                                                                                      DIOXIDE.  CONSIDER  FOR INCINERATION, FUEL BURNING  (WASTE
                                                                                                                      FUEL RECOVERY).
                                                                                                                                                   ACTION
                                                                                                                                                   CHEMICAL

-------
ADMINIS.
 CODE
SECTION
                      OHIO ADMINISTRATIVE  CODE  (OAC)  ARARs
                        REILLY  TAR           TUSCARAWAS COUNTY
PERTINENT
PARAGRAPH
TITLE OR SUBJECT
 OF REGULATION
 DESCRIPTION
OF REGULATION
 APPLICATION
OF REGULATION
ARAR
TYPE
                 A,B,C,E,F
                 A,C
                                   SULFUR DIOXIDE MEASUREMENT
                                   METHODS AND PROCEDURES
                                   SULFUR DIOXIDE AMBIENT MONITORING
                                   REQUIREMENTS
                                   SULFUR DIOXIDE  EMISSION LIMIT
                                   PROVISIONS
                                   OPEN  BURNING STANDARDS IN
                                   RESTRICTED AREAS
                                                           SPECIFIES  TESTING  METHODS AND  PROCEDURES  FOR SULFUR DIOXIDE
                                                           EMISSIONS  COMPLIANCE TESTING.
                                                           THE DIRECTOR OF THE  OHIO EPA  MAY REQUIRE  ANY SOURCE  OF
                                                           SULFUR  DIOXIDE EMISSIONS TO INSTALL, OPERATE AND MAINTAIN
                                                           MONITORING DEVICES,  MAINTAIN  RECORDS AND  FILE REPORTS.

                                                           ESTABLISHES GENERAL  LIMIT PROVISIONS FOR  SULFUR DIOXIDE.
                                                           OPEN BURNING WITHOUT PRIOR AUTHORIZATION  FROM OHIO  EPA IS
                                                           PROHIBITED.
                                                                                                                      PERTAINS  TO ANY  SITE THAT WILL EMIT SULFUR DIOXIDE.
                                                                                                                      CONSIDER  FOR SITES  THAT WILL  UTILIZE  INCINERATION  OR FUEL
                                                                                                                      RECOVERY  (WASTE  FUEL RECOVERY)

                                                                                                                      PERTAINS  TO ANY  SITE THAT EMITS OR WILL  EMIT SULFUR
                                                                                                                      DIOXIDE CONSIDER FOR INCINERATION, FUEL  BURNING  (WASTE
                                                                                                                      FUEL RECOVERY).

                                                                                                                      PERTAINS  TO ANY  SITE THAT WILL EMIT SULFUR DIOXIDE
                                                                                                                      CONSIDER  FOR SITES  THAT WILL  UNDERGO  INCINERATION  OR
                                                                                                                      FUEL BURNING  (WASTE FUEL RECOVERY).

                                                                                                                      PERTAINS  TO SITES WITHIN A  RESTRICTED AREA (WITHIN THE
                                                                                                                      BOUNDARY  OF A MUNICIPALITY  AND A ZONE EXTENDING  BEYOND
                                                                                                                      SUCH MUNICIPALITY).
                                                                                                                                                   ACTION
                                                                                                                                                   CHEMICAL
                                                                                                                                                   ACTION
                                                                                                                                                   CHEMICAL
                                                                                                                                                                                                                            ACTION
                                                                                                                                                                                                                            CHEMICAL
                  B,C,D
                                   OPEN  BURNING STANDARDS IN
                                   UNRESTRICTED AREAS
                                   AMBIENT  AIR QUALITY STANDARDS  AND
                                   GUIDELINES
                                   METHODS  OF AMBIENT  AIR QUALITY
                                   MEASUREMENT
                                                           OPEN BURNING WITHOUT PRIOR AUTHORIZATION  FROM OHIO  EPA IS
                                                           PROHIBITED.
                                                           ESTABLISHES SPECIFIC AIR QUALITY STANDARDS FOR CARBON
                                                           MONOXIDE,  OZONE AND NON METHANE HYDROCARBONS.
                                                           SPECIFIES  MEASUREMENT METHODS  TO DETERMINE AMBIENT  AIR
                                                           QUALITY  FOR THE FOLLOWING CONSTITUENTS:  CARBON MONOXIDE,
                                                           OZONE AND  NON-METHANE HYDROCARBONS.
                                                                     PERTAINS  TO SITES WITHIN AN UNRESTRICTED  AREA  (OUTSIDE
                                                                     THE BOUNDARY OF A MUNICIPALITY  AND A ZONE EXTENDING
                                                                     BEYOND  SUCH MUNICIPALITY).

                                                                     PERTAINS  TO ANY SITE  WHICH WILL EMIT CARBON OXIDES,
                                                                     OZONE OR  NON-METHANE  HYDROCARBONS. CONSIDER FOR SITES
                                                                     THAT WILL UNDERGO WATER TREATMENT, INCINERATION AND
                                                                     FUEL BURNING (WASTE  FUEL RECOVERY)

                                                                     PERTAINS  TO ANY SITE  WHICH WILL EMIT CARBON MONOXIDE,
                                                                     OZONE OR  NON-METHANE  HYDROCARBONS CONSIDER FOR FOR
                                                                     SITES WHERE TREATMENT SYSTEMS WILL RESULT IN AIR
                                                                     EMISSIONS.
                                                                                                                                                                                                     LOCATION
                                                                                                                                                                                                     ACTION
                                                                                                                                                                                                     CHEMICAL
                                                                                                                                                                                                     ACTION
                                                                                                                                                                                                     CHEMICAL
                                                                                                                                                                                                     ACTION
                                   NON-DEGRADATION  POLICY
                 A,B,G,I,J        ORGANIC MATERIALS  EMISSION
                                   CONTROL:  STATIONARY SOURCES
                                                                               PROHIBITS  SIGNIFICANT AND AVOIDABLE DETERIORATION OF  AIR
                                                                               QUALITY.
                                                           REQUIRES  CONTROL  OF  EMISSIONS  OF ORGANIC  MATERIALS  FROM
                                                           STATIONARY SOURCES.  REQUIRES  BEST AVAILABLE TECHNOLOGY.
                                                                                                                      PERTAINS  TO ANY  SITE WHICH WILL EMIT CARBON OXIDES,
                                                                                                                      CARBON  OXIDES, AND  NON-METHANE  HYDROCARBONS.
                                                                                                                      CONSIDER  FOR SITES  THAT WILL  UNDERGO WATER TREATMENT,
                                                                                                                      INCINERATION AND FUEL BURNING (WASTE FUEL RECOVERY).

                                                                                                                      PERTAINS  TO ANY  SITE WHICH IS EMITTING  OR WILL EMIT
                                                                                                                      ORGANIC MATERIAL,  CONSIDER FOR  SITES THAT WILL UNDERGO
                                                                                                                      WATER TREATMENT  (AIR STRIPPING),  INCINERATION AND  FUEL
                                                                                                                      BURNING (WASTE FUEL RECOVERY).
                                                                                                                                                   ACTION
                                                                                                                                                   CHEMICAL
                 A,E
                                                                               REQUIRES  ANY STATIONARY SOURCE  OF CARBON  MONOXIDE  TO
                                                                               MINIMIZE  EMISSIONS  BY THE USE OF BEST AVAILABLE CONTROL
                                                                               TECHNOLOGIES AND OPERATING PRACTICES IN ACCORDANCE WITH
                                                                               BEST CURRENT TECHNOLOGY.

                                                                               ESTABLISHES LIMITATIONS FOR EMISSIONS OF  VOLATILE  ORGANIC
                                                                               COMPOUNDS  FROM STATIONARY SOURCES.
                                                                                                                                             PERTAINS  TO ANY SITE WHICH  IS  EMITTING  OR WILL EMIT
                                                                                                                                             CARBON  MONOXIDE.  CONSIDER FOR  SITES THAT  WILL UNDERGO
                                                                                                                                             WATER TREATMENT,  INCINERATION  AND FUEL  BURNING  (WASTE
                                                                                                                                             FUEL RECOVERY).
                                                                                                                                                                                                     ACTION
                                                                                                                                                                                                     CHEMICAL

-------
ADMINIS.
 CODE
SECTION
                      OHIO ADMINISTRATIVE  CODE  (OAC)  ARARs
                        REILLY  TAR           TUSCARAWAS  COUNTY
PERTINENT
PARAGRAPH
TITLE OR  SUBJECT
 OF REGULATION
 DESCRIPTION
OF REGULATION
 APPLICATION
OF REGULATION
ARAR
TYPE
                                   NITROGEN DIOXIDE AMBIENT AIR
                                   QUALITY  STANDARDS
                                                           ESTABLISHES  A MAXIMUM AMBIENT AIR QUALITY  STANDARD FOR
                                                           NITROGEN  DIOXIDE.
                                                                                                                      PERTAINS  TO  ANY SITE WHICH IS EMITTING OR WILL EMIT
                                                                                                                      NITROGEN  DIOXIDE CONSIDER FOR SITES THAT WILL UNDERGO
                                                                                                                      WATER TREATMENT, INCINERATION AND  FUEL BURNING (WASTE
                                                                                                                      FUEL RECOVERY).
                                                                                                                                                   CHEMICAL
                                                                                                                                                   ACTION
                 A,B
                                   MEASUREMENT METHODS  FOR
                                   NITROGEN DIOXIDE
                                                           SPECIFIES  METHODS OF  MEASUREMENT  FOR NITROGEN DIOXIDE  TO
                                                           DETERMINE  AMBIENT AIR.
                                                                                                                      PERTAINS  TO  ANY SITE WHICH WILL  EMIT NITROGEN DIOXIDE.
                                                                                                                      QUALITY CONSIDER FOR SITES WHERE TREATMENT  SYSTEMS MAY  RESULT
                                                                                                                      IN NITROGEN  DIOXIDE EMISSIONS, ESP,  THERMAL TREATMENT
                                                                                                                      SYSTEMS.
                                                                                                                                                   ACTION
                                                                                                                                                   CHEMICAL
                                   NITROGEN DIOXIDE NONDEGRADATION
                                   POLICY
                                   NITROGEN OXIDES EMISSION
                                   CONTROLS:  STATIONARY SOURCE
                                                           PROHIBITS  THE SIGNIFICANT AND AVOIDABLE DETERIORATION  OF AIR
                                                           QUALITY BY THE RELEASE OF NITROGEN DIOXIDE  EMISSIONS.
                                                           REQUIRES  THAT ALL STATIONARY SOURCES OF NITROGEN OXIDE
                                                           MINIMIZE  EMISSIONS BY  THE USE OF  THE LATEST  AVAILABLE CONTROL
                                                           TECHNIQUES  AND OPERATING PRACTICES IN ACCORDANCE WITH BEST
                                                           CURRENT TECHNOLOGY ESTABLISHES  LIMIT FOR NITROGEN OXIDE
                                                           EMISSIONS  FROM COMBUSTION.
                                                                     PERTAINS  TO ANY SITE WHICH IS EMITTING OR WILL EMIT
                                                                     NITROGEN  DIOXIDE. CONSIDER FOR  SITES THAT WILL UNDERGO
                                                                     WATER TREATMENT, INCINERATION AND  FUEL BURNING (WASTE
                                                                     FUEL RECOVERY).

                                                                     PERTAINS  TO ANY SITE WHICH WILL  EMIT NITROGEN OXIDES.
                                                                     CONSIDER  FOR SITES WHERE TREATMENT SYSTEMS WILL RESULT
                                                                     IN NITROGEN OXIDE EMISSIONS, ESP,  THERMAL TREATMENT.
                                                                                                                                                                                                    ACTION
                                                                                                                                                                                                    CHEMICAL
                                                                                                                                                                                                    ACTION
                                                                                                                                                                                                    CHEMICAL
                                   EMISSION CONTROL ACTION PROGRAMS
                                                                               REQUIRES PREPARATION  FOR AIR POLLUTION ALERTS
                                                                               EMERGENCIES.
                                                                                                                                            AND
                                                                                                                                             PERTAINS TO  ANY SITE WHICH IS EMITTING OR MAY  EMIT AIR
                                                                                                                                             CONTAMINANTS.
                                   EXEMPTIONS TO SOLID WASTE
                                   REGULATIONS
                                                           DEFINES  EXEMPTIONS  TO  SOLID WASTE  REGULATIONS AND
                                                           ESTABLISHES  LIMITATIONS ON TEMPORARY STORAGE  OF PUTRESCIBLE
                                                           WASTE OR ANY SOLID  WASTE WHICH  CAUSES A NUISANCE OR HEALTH
                                                           HAZARD STORAGE OF PUTRESCIBLE WASTE BEYOND  SEVEN DAYS  IS
                                                           CONSIDERED  OPEN DUMPING.
                                                                                                                      PERTAINS  TO  ANY SITE AT  WHICH SOLID WASTE WILL BE
                                                                                                                      MANAGED.  CONSIDER ESPECIALLY FOR  OLD LANDFILLS WHERE
                                                                                                                      SOLID WASTE  MAY BE EXCAVATED AND/OR CONSOLIDATED
                                   AUTHORIZED,  LIMITED 5 PROHIBITED
                                   SOLID WASTE  DISPOSAL
                                                           ESTABLISHES  ALLOWABLE  METHODS OF  SOLID WASTE  DISPOSAL:
                                                           SANITARY  LANDFILL,  INCINERATION,  COMPOSTING PROHIBITS
                                                           MANAGEMENT  BY OPEN  BURNING AND  OPEN DUMPING.
                                                                                                                      PERTAINS  TO  ANY SITE At  WHICH SOLID WASTES WILL BE
                                                                                                                      MANAGED PROHIBITS MANAGEMENT BY  OPEN BURNING  AND
                                                                                                                      OPEN DUMPING.
                A, B
                                   REQUIRED TECHNICAL  INFORMATION
                                   FOR SANITARY LANDFILLS
                                   LOCATION CRITERIA  FOR SOLID WASTE
                                   DISPOSAL PERMIT
                                                           SPECIFIES  THE MINIMUM TECHNICAL  INFORMATION  REQUIRED  OF  A
                                                           SOLID WASTE PERMIT  TO INSTALL  INCLUDED ARE A HYDROGEOLOGIC
                                                           INVESTIGATION REPORT,  LEACHATE PRODUCTION AND MIGRATION
                                                           INFORMATION,  SURFACE  WATER DISCHARGE INFORMATION, DESIGN
                                                           CALCULATIONS, PLAN  DRAWINGS.
                                                           SPECIFIES  LOCATIONS  IN WHICH SOLID WASTE  LANDFILLS ARE  NOT TO
                                                           BE SITED.  INCLUDES FLOODPLAINS,  SAND OR GRAVEL PITS,  LIMESTONE
                                                           OR SANDSTONE QUARRIES,  AREAS ABOVE SOLE SOURCE AQUIFERS,
                                                           WETLANDS,  ETC.
                                                                                                                      THIS PARAGRAPH PRESENTS  SUBSTANTIVE REQUIREMENTS OF A
                                                                                                                      SOLID WASTE  PERMIT TO  INSTALL PERTAINS TO ANY NEW SOLID
                                                                                                                      WASTE DISPOSAL FACILITY  CREATED  ON-SITE AND  EXPANSIONS
                                                                                                                      OF EXISTING  SOLID WASTE  LANDFILLS  ALSO PERTAINS TO
                                                                                                                      EXISTING AREAS OF CONTAMINATION  THAT ARE CAPPED PER
                                                                                                                      SOLID WASTE  RULES. THIS  RULE ESTABLISHES THE  MINIMUM
                                                                                                                      INFORMATION  REQUIRED DURING THE  REMEDIAL DESIGN STAGE.

                                                                                                                      THIS RULE  PREVENTS THE  ESTABLISHMENT OF NEW  SOLID WASTE
                                                                                                                      LANDFILLS  AND EXPANSIONS OF EXISTING SOLID WASTE
                                                                                                                      LANDFILLS  IN CERTAIN UNFAVORABLE LOCATIONS ALSO MAY
                                                                                                                      PROHIBIT THE LEAVING OF  WASTE IN PLACE IN CERTAIN
                                                                                                                      UNFAVORABLE  LOCATIONS.
                D,F,G,H
                                   ADDITIONAL CRITERIA FOR SANITARY
                                   LANDFILL APPROVAL
                                                           ADDITIONAL  SITING REQUIREMENTS  WITH RESPECT  TO GEOLOGY,
                                                           WATER SUPPLIES. OCCUPIED PROPERTIES PARKLANDS AND MINE
                                                           SUBSIDENCE  AREAS GOVERNS EXPANSION OF EXISTING SITES.
                                                                                                                      PERTAINS  TO  NEW SANITARY LANDFILLS  FOR SOLID  WASTE
                                                                                                                      DISPOSAL  AND EXPANSIONS  OF EXISTING FACILITIES
                                                                                                                                                   LOCATION
                                                                                                                                                   ACTION

-------
ADMINIS.
 CODE
SECTION
                      OHIO ADMINISTRATIVE  CODE  (OAC)  ARARs
                        REILLY  TAR           TUSCARAWAS  COUNTY
PERTINENT
PARAGRAPH
TITLE OR  SUBJECT
 OF REGULATION
 DESCRIPTION
OF REGULATION
 APPLICATION
OF REGULATION
ARAR
TYPE
                   C,D,H
                                   CONSTRUCTION SPECIFICATIONS  FOR
                                   SANITARY LANDFILLS
                                                           SPECIFIES  THE MINIMUM REQUIREMENTS FOR THE  SOIL/CLAY  LAYERS,
                                                           GRANULAR DRAINAGE  LAYER,  GEOSYNTHETICS,  LEACHATE
                                                           MANAGEMENT SYSTEM,  GAS MONITORING SYSTEM,  ETC. ALSO
                                                           ESTABLISHES CONSTRUCTION REQUIREMENTS FOR  FACILITIES  TO BE
                                                           LOCATED IN GEOLOGICALLY UNFAVORABLE AREAS.
                                                                                                                      PERTAINS  TO ANY NEW  SOLID WASTE  DISPOSAL  FACILITY
                                                                                                                      CREATED ON-SITE AND  ANY EXPANSIONS TO EXISTING SOLID
                                                                                                                      WASTE LANDFILLS. PORTIONS ALSO  PERTAIN TO AREAS OF
                                                                                                                      CONTAMINATION THAT ARE  CAPPED PER SOLID WASTE RULES.
                                                                                                                      MAY SERVE  AS SITING  CRITERIA.
                                   SANITARY LANDFILL  GROUND WATER
                                   MONITORING
                                                           GROUND WATER MONITORING PROGRAM MUST BE  ESTABLISHED  FOR
                                                           ALL SANITARY LANDFILL FACILITIES THE SYSTEM MUST CONSIST OF A
                                                           SUFFICIENT  NUMBER OF  WELLS THAT ARE LOCATED SO THAT  SAMPLES
                                                           INDICATE  BOTH UPGRADIENT  (BACKGROUND) AND  DOWNGRADIENT
                                                           WATER SAMPLES. THE  SYSTEM MUST  BE DESIGNED PER THE MINIMUM
                                                           REQUIREMENTS SPECIFIED IN THIS  RULE. THE SAMPLING AND  ANALYSIS
                                                           PROCEDURES  USED MUST  COMPLY WITH THIS RULE.
                                                                                                                      PERTAINS  TO ANY NEW  SOLID WASTE  FACILITY AND ANY
                                                                                                                      EXPANSIONS  OF EXISTING SOLID WASTE LANDFILLS ON-SITE.
                                                                                                                      ALSO MAY  PERTAIN TO  EXISTING AREAS OF CONTAMINATION
                                                                                                                      THAT ARE  CAPPED IN-PLACE PER THE SOLID WASTE RULES.
                                   FINAL  CLOSURE OF  SANITARY LANDFILL
                                   FACILITIES
                                                           REQUIRES  CLOSURE OF  A LANDFILL  IN A MANNER WHICH MINIMIZES THE
                                                           NEED FOR  POST CLOSURE MAINTENANCE AND MINIMIZES
                                                           POST-CLOSURE FORMATION AND RELEASE OF LEACHATE AND
                                                           EXPLOSIVE GASES TO AIR,  SOIL  GROUND WATER  OR SURFACE  WATER.
                                                           SPECIFIES ACCEPTABLE CAP DESIGN,  SOIL BARRIER LAYER,  GRANULAR
                                                           DRAINAGE  LAYER, SOIL AND VEGETATIVE LAYER  PROVIDES  FOR USE
                                                           OF COMPARABLE MATERIALS  TO THOSE  SPECIFIED WITH APPROVAL OF
                                                           DIRECTOR.
                                                                                                                      SUBSTANTIVE REQUIREMENTS PERTAIN TO ANY NEW SOLID
                                                                                                                      WASTE LANDFILLS CREATED ON-SITE.  ANY EXPANSIONS OF
                                                                                                                      EXISTING  SOLID WASTE  LANDFILLS  ON-SITE AND  ANY EXISTING
                                                                                                                      AREAS OF  CONTAMINATION THAT ARE CAPPED IN-PLACE PER  THE
                                                                                                                      SOLID WASTE RULES.
                  !V,B,D,E,MN
                                   SANITARY LANDFILL  EXPLOSIVE  GAS
                                   MONITORING
                                                           ESTABLISHES WHEN AN  EXPLOSIVE  GAS  MONITORING PLAN  IS
                                                           REQUIRED  FOR SOLID WASTE LANDFILLS. SPECIFIES THE  MINIMUM
                                                           INFORMATION REQUIRED IN SUCH A PLAN, INCLUDING DETAILED
                                                           ENGINEERING PLANS, SPECIFICATIONS,  INFORMATION ON  GAS
                                                           GENERATION POTENTIAL,  SAMPLING AND MONITORING PROCEDURES,
                                                           ETC. MANDATES WHEN REPAIRS MUST BE MADE  TO  AN EXPLOSIVE
                                                           GAS MONITORING SYSTEM.  THIS RULE ONLY APPLIES TO LANDFILLS
                                                           WHICH RECEIVED "PUTRESCIBLE" SOLID WASTES.
                                                                                                                      PERTAINS  TO ANY SITE  WHICH HAS  HAD OR WILL  HAVE
                                                                                                                      PUTRESCIBLE SOLID WASTES PLACED ON-SITE AND WHICH HAS  A
                                                                                                                      RESIDENCE  OR OTHER OCCUPIED STRUCTURE LOCATED WITHIN
                                                                                                                      1000 FEET  OF THE EMPLACED SOLID WASTE.
                                                                                                                                                    ACTION
                                                                                                                                                    LOCATION
                  I, J
                                   EXPLOSIVE GAS MONITORING
                                   SANITARY LANDFILLS
                                                           IDENTIFIES  PARAMETERS  AND SCHEDULE FOR EXPLOSIVE GAS
                                                           MONITORING.
                                                                                                                      PERTAINS  TO ANY DISPOSAL SITE WHERE EXPLOSIVE
                                                                                                                      GENERATION AND MIGRATION MAY BE  A THREAT.
                                                                                                                                                    ACTION
                                                                                                                                                    CHEMICAL
                                   DISTURBANCES WHERE  HAZ OR
                                   WASTE  FAC WAS OPERATED
                                                           REQUIRES  THAT A DETAILED PLAN  BE PROVIDED  TO DESCRIBE  HOW ANY
                                                           PROPOSED  FILLING, GRADING, EXCAVATING, BUILDING, DRILLING OR
                                                           MINING ON LAND WHERE  A HAZARDOUS WASTE FACILITY OR  SOLID
                                                           WASTE FACILITY WAS  OPERATED WILL BE ACCOMPLISHED THIS
                                                           INFORMATION MUST DEMONSTRATE THAT THE PROPOSED ACTIVITIES
                                                           WILL NOT  CREATE A NUISANCE OR  ADVERSELY AFFECT THE  PUBLIC
                                                           HEALTH OR THE ENVIRONMENT. SPECIAL TERMS TO CONDUCT  SUCH
                                                           ACTIVITIES  MAY BE IMPOSED BY THE DIRECTOR  TO PROTECT  THE
                                                           PUBLIC AND  THE ENVIRONMENT.
                                                                                                                      PERTAINS  TO ANY SITE  AT WHICH  HAZARDOUS OR SOLID WASTE
                                                                                                                      HAS BEEN  MANAGED,  EITHER INTENTIONALLY OR  OTHERWISE
                                                                                                                      DOES NOT  PERTAIN TO AREAS THAT  HAVE HAD ONE-TIME LEAKS
                                                                                                                      OR SPILLS.
                                   POST  CLOSURE CARE  OF SANITARY
                                   LANDFILL FACILITIES
                                                           SPECIFIES  THE REQUIRED POST-CLOSURE CARE  FOR SOLID WASTE
                                                           FACILITIES.  INCLUDES  CONTINUING OPERATION OF LEACHATE  AND
                                                           SURFACE WATER MANAGEMENT SYSTEMS.  MAINTENANCE OF THE  CAP
                                                           SYSTEM AND GROUND WATER MONITORING.
                                                                                                                      SUBSTANTIVE REQUIREMENTS PERTAIN TO ANY NEWLY CREATED
                                                                                                                      SOLID WASTE LANDFILLS  ON-SITE,  ANY EXPANSIONS OF
                                                                                                                      EXISTING  SOLID WASTE  LANDFILLS  ON-SITE AND  ANY EXISTING
                                                                                                                      AREAS OF  CONTAMINATION THAT ARE CAPPED PER  THE SOLID
                                                                                                                      WASTE RULES.

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                      OHIO ADMINISTRATIVE  CODE  (OAC)  ARARs
                        REILLY  TAR           TUSCARAWAS  COUNTY
ADMINIS.
 CODE
SECTION
PERTINENT
PARAGRAPH
TITLE OR  SUBJECT
 OF REGULATION
 DESCRIPTION
OF REGULATION
 APPLICATION
OF REGULATION
ARAR
TYPE
                   A,D
                                   SOLID WASTE INCINERATOR 5
                                   COMPOSTING OPERATIONS
                                                           ESTABLISHES  OPERATIONAL REQUIREMENTS FOR SOLID WASTE
                                                           INCINERATORS AND COMPOSTING FACILITIES.
                                                                                                                      PERTAINS TO  ANY SITE AT  WHICH SOLID WASTE WILL  BE EITHER
                                                                                                                      INCINERATED  OR COMPOSTED ON-SITE.
                                   SANITARY  LANDFILL  GENERAL
                                   OPERATIONAL REQUIREMENTS
                                                           SPECIFIES  GENERAL OPERATIONAL REQUIREMENTS  FOR SOLID WASTE
                                                           LANDFILLS.  INCLUDES  REQUIREMENTS  FOR PREPARATIONS FOR
                                                           OPERATING  DURING INCLEMENT WEATHER,  MANAGEMENT TO MINIMIZE
                                                           NOISE, DUST AND ODORS,  VECTOR CONTROL; ADEQUATE FIRE
                                                           CONTROL EQUIPMENT; NOT  CAUSING A  NUISANCE OR HEALTH HAZARD
                                                           OR WATER POLLUTION MINIMIZATION OF  DISTURBED AREA; CHEMICAL
                                                           COMPATIBILITY TESTING,  IF NECESSARY.  SPECIFIES THAT BULK
                                                           LIQUIDS, HAZARDOUS WASTE, PCBs AND  INFECTIOUS WASTE MAY  NOT
                                                           BE ACCEPTED FOR DISPOSAL.
                                                                                                                      PERTAINS TO  NEW SOLID WASTE DISPOSAL FACILITIES  TO BE
                                                                                                                      CREATED ON-SITE AND EXISTING LANDFILLS THAT WILL BE
                                                                                                                      EXPANDED DURING REMEDIATION. PORTIONS ALSO MAY  PERTAIN
                                                                                                                      TO EXISTING  AREAS OF CONTAMINATION  THAT WILL  BE  CAPPED
                                                                                                                      IN PLACE PER SOLID WASTE  RULES.
                                   SANITARY  LANDFILL  OPERATIONS
                                   CONSTRUCTION COMPLIANCE
                                                           REQUIRES  THE OWNER/OPERATOR TO  IMPLEMENT MEASURES TO
                                                           ATTAIN COMPLIANCE WITH REQUIREMENTS OF THESE  RULES IN  THE
                                                           EVENT THAT  TESTING  INDICATES THAT  A COMPONENT OR PORTION OF
                                                           THE LANDFILL HAVE NOT  BEEN CONSTRUCTED IN ACCORDANCE WITH
                                                           THOSE RULES.
                                                                                                                      PERTAINS TO  "NEW" SOLID  WASTE DISPOSAL FACILITIES TO BE
                                                                                                                      CREATED ON-SITE AND EXISTING LANDFILLS THAT WILL BE
                                                                                                                      EXPANDED DURING REMEDIATION. ALSO  PERTAINS TO
                                                                                                                      CONSTRUCTION OF FINAL  COVER SYSTEMS.
                                   SANITARY  LANDFILL  OPERATIONS
                                   FINAL  COVER
                                                           INCLUDES  REQUIREMENTS  FOR THE FINAL CAP SYSTEM FOR AREAS  AT
                                                           FINAL ELEVATIONS.
                                                                                                                      PERTAINS TO  NEW SOLID WASTE DISPOSAL FACILITIES  TO BE
                                                                                                                      CREATED ON-SITE AND EXISTING LANDFILLS THAT WILL BE
                                                                                                                      EXPANDED DURING REMEDIATION. PORTIONS ALSO MAY  PERTAIN
                                                                                                                      TO EXISTING  AREAS OF CONTAMINATION  THAT WILL  BE  CAPPED
                                                                                                                      IN PLACE PER SOLID WASTE  RULES.
                                   SANITARY  LANDFILL  OPERATIONS  -  PCBs
                                   AND HAZARDOUS WASTE
                                                           REQUIRES  OWNERS/OPERATORS TO CONDUCT A PROGRAM TO DETECT
                                                           PCS WASTE  AND HAZARDOUS  WASTE PRIOR TO DISPOSAL UPON
                                                           DETECTION  ON SUSPECTED DETECTION  OF SUCH WASTES, REQUIRES
                                                           THOSE WASTES TO NOT BE PLACED AT  THE WORKING FACE OF  THE
                                                           LANDFILL  AND TO MANAGE THOSE WASTES IN ACCORDANCE WITH
                                                           APPLICABLE LAWS AND REGULATIONS.
                                                                                                                      PERTAINS TO  NEW SOLID WASTE DISPOSAL FACILITIES  TO BE
                                                                                                                      CREATED ON-SITE AND EXISTING LANDFILLS THAT WILL BE
                                                                                                                      EXPANDED DURING REMEDIATION.
                                   SANITARY  LANDFILL  OPERATIONS
                                   SURFACE WATER MGMNT.
                                                           SURFACE WATER MUST BE  DIVERTED  FROM AREAS WHERE SOLID
                                                           WASTE IS  BEING, OR HAS BEEN, DEPOSITED. ALSO  REQUIRES  RUN
                                                           AND RUN-OFF  TO BE CONTROLLED TO MINIMIZE INFILTRATION  THROUGH
                                                           THE COVER MATERIALS AND TO MINIMIZE EROSION OF THE CAP
                                                           SYSTEM.
                                                                                                                      PERTAINS TO  NEW SOLID WASTE DISPOSAL FACILITIES  TO BE
                                                                                                                      ON CREATED ON-SITE AND  EXISTING LANDFILLS THAT WILL BE
                                                                                                                      EXPANDED DURING REMEDIATION.  PORTIONS ALSO MAY PERTAIN
                                                                                                                      TO EXISTING  AREAS OF CONTAMINATION  THAT WILL  BE  CAPPED
                                                                                                                      IN-PLACE PER SOLID WASTE  RULES.
                                   SANITARY  LANDFILL  OPERATIONS
                                   LEACHATE  MANAGEMENT
                                                           REQUIRES  REPAIR OF LEACHATE OUTBREAKS; COLLECTION AND
                                                           TREATMENT  OF LEACHATE  ON THE SURFACE OF THE  LANDFILL; AND
                                                           ACTIONS TO MINIMIZE,  CONTROL OR  ELIMINATE  CONDITIONS CAUSING
                                                           LEACHATE  OUTBREAKS.
                                                                                                                      PERTAINS TO  NEW SOLID WASTE DISPOSAL FACILITIES  TO BE
                                                                                                                      CREATED ON-SITE AND EXISTING LANDFILLS THAT WILL BE
                                                                                                                      EXPANDED DURING REMEDIATION. PORTIONS ALSO MAY  PERTAIN
                                                                                                                      TO EXISTING  AREAS OF CONTAMINATION  THAT WILL  BE  CAPPED
                                                                                                                      IN-PLACE PER SOLID WASTE  RULES.
                                   SANITARY  LANDFILLS  PROHIBITIONS
                                   AND CLOSURE
                                                           SPECIFIES  CERTAIN OPERATIONAL AND  LOCATION  STANDARDS  FOR
                                                           LANDFILLS  ACCEPTING WASTE AFTER  JUNE 1, 1994,  ALSO REQUIRES
                                                           CLOSURE OF EXISTING UNITS WHICH  DO NOT MEET THOSE STANDARDS
                                                           BY OCTOBER 6,  1996.
                                                                                                                      PERTAINS TO  NEW SOLID WASTE DISPOSAL FACILITIES  TO BE
                                                                                                                      CREATED ON-SITE AND EXISTING LANDFILLS THAT WILL BE
                                                                                                                      EXPANDED DURING REMEDIATION PORTIONS

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ADMINIS.
 CODE
SECTION
                      OHIO ADMINISTRATIVE  CODE  (OAC)  ARARs
                        REILLY  TAR           TUSCARAWAS COUNTY
PERTINENT
PARAGRAPH
TITLE OR SUBJECT
 OF REGULATION
 DESCRIPTION
OF REGULATION
 APPLICATION
OF REGULATION
ARAR
TYPE
                                      PROHIBITIONS AND CLOSURE
                   C,D,I,J,K,L,M,N   ADDITIONAL CRITERIA FOR  SOLID
                                      WASTE INCINERATOR PTI
                                                              RULES  FOR NEW AND EXISTING  SITES, LOCATION RULES  WITH
                                                              RESPECT TO FLOOD  PLAINS, AIRPORTS, GEOLOGIC FAULTS  PLUS LINER
                                                              /LEACHATE REQUIREMENTS.

                                                              RULES  FOR LOCATION OF INCINERATOR  (SETBACK FROM WATER
                                                              SUPPLIES, FLOODPLAINS, PARKLANDS, DOMICILES). CONSTRUCTION
                                                              GUIDELINES INCLUDING LEACHATE CONTROL  SYSTEM.
                                                                                                                                                                    PERTAINS  TO SOLID WASTE LANDFILLS OPENED  AFTER 06/01/94.
                                                                                                                                                                    OR EXISTING FACILITIES RECEIVING WASTE AFTER 06/01/94.
                                                                                                                         PERTAINS TO SOLID WASTE INCINERATORS WHICH MAY  BE
                                                                                                                         CONSTRUCTED AS  PART OF REMEDIATION EFFORTS AT SITE.
                                      OPERATION OF  SOLID WASTE
                                      INCINERATOR FACILITIES
                                      FINAL CLOSURE,  SOLID WASTE
                                      INCINERATOR
                                                              RULES  FOR SAFE  OPERATION OF  INCINERATOR INCLUDING ACCESS
                                                              CONTROL,  FIRE CONTROL, RECORD KEEPING,  EMERGENCY  PLANS,
                                                              ON-SITE STORAGE,  WASTES FORBIDDEN FROM  INCINERATION,
                                                              GROUNDWATER MONITORING, LEACHATE CONTROL,  WASTE HANDLING.

                                                              REQUIRES  INCINERATOR SITE  TO BE DECONTAMINATED UPON CLOSURE
                                                              AND  LEACHATE SYSTEM DECOMMISSIONED TO PREVENT FUTURE
                                                              POLLUTION PROBLEMS.
                                                                                                                         PERTAINS TO INCINERATORS WHICH MAY BE  CONSTRUCTED  AS
                                                                                                                         PART  OF ON-SITE  REMEDIATION  EFFORTS.
                                                                                                                                                                    APPLICABLE TO SITES  WHICH INCINERATED HAZARDOUS WASTES.
                                      WATER/AIR PERMIT CRITERIA  FOR
                                      DECISION BY THE  DIRECTOR
                                      WATER QUALITY  CRITERIA  FOR
                                      DECISION BY THE  DIRECTOR
                                                              A PERMIT TO INSTALL (PTI)  OR PLANS MUST  DEMONSTRATE BEST
                                                              AVAILABLE TECHNOLOGY (BAT)  AND SHALL  NOT INTERFERE WITH OR
                                                              PREVENT THE ATTAINMENT OR  MAINTENANCE OF APPLICABLE AMBIENT
                                                              AIR  QUALITY STANDARDS.

                                                              SPECIFIES SUBSTANTIVE CRITERIA FOR SECTION 401 WATER QUALITY
                                                              CRITERIA FOR DREDGING,  FILLING,  OBSTRUCTING OR ALTERING
                                                              WATERS  OF THE  STATE.
                                                                                                                         PERTAINS TO ANY  SITE THAT WILL DISCHARGE TO ON-SITE
                                                                                                                         SURFACE WATER OR WILL EMIT  CONTAMINANTS  INTO THE  AIR.
                                                                                                                         PERTAINS TO ANY  SITE THAT  HAS OR WILL  AFFECT WATERS  OF
                                                                                                                         THE  STATE.
                                      PROHIBITION OF  UNAUTHORIZED
                                      INJECTION
                                                              UNDERGROUND INJECTION IS  PROHIBITED WITHOUT AUTHORIZATION
                                                              FROM  THE DIRECTOR.
                                                                                                                         PERTAINS TO SITES  AT WHICH  MATERIALS ARE TO BE  INJECTED
                                                                                                                         UNDERGROUND CONSIDER FOR  TECHNOLOGIES  SUCH AS
                                                                                                                         BIOREMEDIATION AND SOIL FLUSHING.
                                                                                  THE UNDERGROUND  INJECTION OF  FLUID CONTAINING ANY
                                                                                  CONTAMINANT INTO AN UNDERGROUND SOURCE  OF DRINKING WATER
                                                                                  IS PROHIBITED OF THE PRESENCE OF THAT CONTAMINANT  MAY CAUSE A
                                                                                  VIOLATION OF THE PRIMARY DRINKING WATER STANDARDS  OR OTHER
                                                                                  WISE ADVERSELY AFFECT THE HEALTH OF PERSONS.
                                                                                                                                                PERTAINS TO SITES  AT WHICH MATERIALS
                                                                                                                                                UNDERGROUND CONSIDER FOR TECHNOLOGIES
                                                                                                                                                BIOREMEDIATION AND SOIL FLUSHING.
                                                                                                                                                                  \RE TO BE  INJECTED
                                                                                                                                                                   SUCH AS
                   A,B
                                      PETITIONS TO  EXCLUDE A  LISTED
                                      WASTE AT A FACILITY
                                                              ALLOWS  FOR PETITIONS TO EXCLUDE HAZARDOUS WASTES  FROM A
                                                              PARTICULAR FACILITY FROM  THE  LISTS  IN  RULES 3745-51-30 TO
                                                              3745-51-31 OF  THE  OAC. ALSO  STATES  THAT  OHIO EPA  WILL
                                                              RECOGNIZE USEPA'S  DECISION TO GRANT OR DENY SUCH  PETITIONS  ON
                                                              THE  FEDERAL LEVEL.
                                                                                                                         PERTAINS TO ANY  SITE WHICH  HAS WASTES  THAT WILL  BE
                                                                                                                         DELISTED BY USEPA.  SHOULD OHIO LIST WASTES NOT
                                                                                                                         ADDRESSED BY USEPA,  THIS RULE WOULD ALLOW OHIO EPA THE
                                                                                                                         OPPORTUNITY TO DELIST THESE WASTES.
                                      RECYCLING VARIANCES FROM
                                      CLASSIFICATION  AS A WASTE
                                                                                  PRESENTS  CRITERIA  BY WHICH DIRECTOR MAY  GRANT REQUESTS FOR
                                                                                  VARIANCE  FROM CLASSIFYING CERTAIN MATERIALS AS A WASTE
                                                                                                                                                PERTAINS TO ANY  SITE THAT HAS  WASTES
                                                                                                                                                RECYCLED OR RECLAIMED
                                                                                                                                                                                                            THAT  MAY BE
                                                                                                                                                                                                        ACTION
                                                                                                                                                                                                        CHEMICAL

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                      OHIO ADMINISTRATIVE CODE (OAC) ARARs
                        REILLY  TAR           TUSCARAWAS  COUNTY
ADMINIS.
 CODE
SECTION
PERTINENT
PARAGRAPH
TITLE OR  SUBJECT
 OF REGULATION
 DESCRIPTION
OF REGULATION
 APPLICATION
OF REGULATION
ARAR
TYPE
                                   ADD'L REG  OF CERTAIN  HAZ  WASTE
                                   RECYCLING  ACTIVITIES
                                                          DIRECTOR MAY  REGULATE HAZARDOUS WASTES  OTHERWISE  EXEMPTED
                                                          BECAUSE OF RECYCLING ACTIVITIES AS HAZARDOUS WASTES  ON A
                                                          CASE-BY-CASE  BASIS THE CRITERIA TO MAKE THIS DECISION ARE
                                                          PROVIDED BY THIS  RULE.
                                                                                                                     PERTAINS  TO ANY SITE  THAT HAS  HAZARDOUS WASTES THAT
                                                                                                                     WILL BE  EXEMPTED  FROM THE HAZARDOUS WASTE  RULES PER
                                                                                                                     OAC 3745-51-06  (RECYCLING EXEMPTIONS).
                                                                                                                                                  ACTION
                                                                                                                                                  CHEMICAL
3745-50-44
3745-50-44
3745-50-44
                                   PERMIT  INFO REQUIRED  FOR ALL HA
                                   WASTE FACILITIES
                                   PERMIT  INFO REQ FOR ALL HAZ WASTE
                                   LAND DISP  FACILITIES
                                   ADD'L PERMIT INFO: HAZ  WASTE
                                   STORAGE  IN  CONTAINERS
                                   ADD'L PERMIT INFO: HAZ  WASTE
                                   STORAGE/TREAT IN TANKS
                                   ADD'L PERMIT INFO: HAZ  WASTE
                                   STOR/TREAT  IN SURF IMPOUND
                                   ADD'L PERMIT INFO: HAZ  WASTE
                                   STOR/TREAT  IN WASTE  PILES
                                                          ESTABLISHES  THE  SUBSTANTIVE  HAZARDOUS  WASTE PERMIT
                                                          REQUIREMENTS  NECESSARY FOR OHIO EPA  TO DETERMINE  FACILITY
                                                          COMPLIANCE INCLUDES INFORMATION SUCH AS FACILITY
                                                          DESCRIPTION,  WASTE CHARACTERISTICS,  EQUIPMENT DESCRIPTIONS,
                                                          CONTINGENCY  PLAN,  FACILITY LOCATION, TOPOGRAPHIC  MAP,  ETC.
                                                          ESTABLISHES  THE  SUBSTANTIVE  HAZARDOUS  WASTE LAND  DISPOSAL
                                                          PERMIT REQUIREMENTS NECESSARY FOR OHIO EPA TO DETERMINE
                                                          ADEQUATE PROTECTION OF THE GROUND WATER INCLUDES
                                                          INFORMATION  SUCH AS GROUND WATER MONITORING DATA,
                                                          INFORMATION  ON  INTERCONNECTED AQUIFERS,  PLUME(S)  OF
                                                          CONTAMINATION,  PLANS AND  REPORTS ON GROUND WATER
                                                          MONITORING PROGRAM, ETC.

                                                          ESTABLISHES  THE  SUBSTANTIVE  HAZARDOUS  WASTE PERMIT
                                                          REQUIREMENTS  NECESSARY FOR OHIO EPA TO DETERMINE  ADEQUACY
                                                          OF  CONTAINER STORAGE INCLUDES INFORMATION SUCH AS
                                                          DESCRIPTION  OF  CONTAINMENT SYSTEM, DETAILED DRAWINGS,  ETC.
                                                          SEE OAC 3745-55-70 THROUGH 3745-55-78  FOR ADDITIONAL
                                                          CONTAINER REQUIREMENTS.
                                                          ESTABLISHES  SUBSTANTIVE HAZARDOUS WASTE  PERMIT
                                                          REQUIREMENTS  NECESSARY FOR OHIO EPA  TO  DETERMINE ADEQUACY
                                                          OF  TANK TREATMENT AND STORAGE UNITS.  INCLUDES INFORMATION
                                                          SUCH AS ASSESSMENT OF STRUCTURAL INTEGRITY, DETAILED PLANS
                                                          OF  TANK SYSTEM(S), DESCRIPTION OF SECONDARY CONTAINMENT
                                                          SYSTEM, ETC.  SEE OAC 3745-55-90 THROUGH  3745-55-99  FOR
                                                          ADDITIONAL REQUIREMENTS.

                                                          ESTABLISHES  SUBSTANTIVE HAZARDOUS WASTE  PERMIT
                                                          REQUIREMENTS  NECESSARY FOR OHIO EPA  TO  DETERMINE ADEQUACY
                                                          OF  BOTH NEW  SURFACE IMPOUNDMENTS AND  EXTENSIONS OF
                                                          EXISTING SURFACE IMPOUNDMENTS USED TO STORE OR TREAT
                                                          HAZARDOUS WASTE.  INCLUDES  INFORMATION SUCH AS WASTE
                                                          CHARACTERISTICS,  DETAILED  PLANS AND  REPORTS, INFORMATION ON
                                                          STRUCTURAL INTEGRITY, CLOSURE INFORMATION, ETC. SEE OAC
                                                          3745-56-20 THROUGH 3745-56-33 FOR ADDITIONAL SURFACE
                                                          IMPOUNDMENT  REQUIREMENTS.

                                                          ESTABLISHES  SUBSTANTIVE HAZARDOUS WASTE  PERMIT
                                                          REQUIREMENTS  NECESSARY FOR OHIO EPA  TO  DETERMINE ADEQUACY
                                                          OF  SURFACE IMPOUNDMENTS USED TO TREAT OR STORE HAZARDOUS
                                                          WASTE INCLUDES  INFORMATION SUCH AS WASTE CHARACTERISTICS,
                                                          DETAILED DESIGN PLANS AND  REPORTS, CONTROL OF RUN-ON AND
                                                          RUN-OFF, CLOSURE INFORMATION, ETC. SEE  OAC 3745-56-20 THROUGH
                                                          3745-56-33 FOR  ADDITIONAL  SURFACE IMPOUNDMENT REQUIREMENTS.
                                                                                                                     PERTAINS  TO ANY SITE  WHICH WILL  HAVE TREATMENT,  STORAGE
                                                                                                                     OR DISPOSAL OF HAZARDOUS WASTE OCCURRING ON-SITE OR
                                                                                                                     HAS EXISTING AREAS  OF HAZARDOUS  WASTE CONTAMINATION
                                                                                                                     ON-SITE  THAT WILL BE  CAPPED  IN-PLACE. THIS,  ALONG WITH
                                                                                                                     OTHER  PARAGRAPHS OF THIS RULE, ESTABLISHES  THE MINIMUM
                                                                                                                     INFORMATION REQUIRED  DURING  THE  REMEDIAL DESIGN STAGE.

                                                                                                                     PERTAINS  TO ANY FACILITY/SITE WHICH WILL HAVE HAZARDOUS
                                                                                                                     WASTE  DISPOSED OF ON-SITE OR HAS EXISTING AREAS OF
                                                                                                                     HAZARDOUS  WASTE CONTAMINATION ON-SITE THAT  WILL BE
                                                                                                                     CAPPED IN  PLACE THIS,  ALONG  WITH OTHER PARAGRAPHS OF
                                                                                                                     THIS RULE,  ESTABLISHES THE MINIMUM INFORMATION REQUIRED
                                                                                                                     DURING THE REMEDIAL DESIGN STAGE.
                                                                                                                     PERTAINS  TO ANY SITE  AT WHICH  STORAGE OF HAZARDOUS
                                                                                                                     WASTE ON-SITE WILL  OCCUR IN CONTAINERS, CONSIDER FOR
                                                                                                                     WASTES  AND CONTAMINATED SOILS  THAT ARE STORED PRIOR
                                                                                                                     TO TREATMENT OR DISPOSAL. THIS,  ALONG WITH  OTHER
                                                                                                                     PARAGRAPHS OF THIS  RULE AND OAC  3745-55-70  THROUGH
                                                                                                                     3745-55-78, ESTABLISHES THE MINIMUM INFORMATION REQUIRED
                                                                                                                     DURING  THE REMEDIAL DESIGN STAGE.

                                                                                                                     PERTAINS  TO ANY SITE  AT WHICH  STORAGE OR TREATMENT OF
                                                                                                                     HAZARDOUS  WASTE IN  TANKS WILL  OCCUR ON-SITE.  THIS,
                                                                                                                     ALONG WITH OTHER  PARAGRAPHS OF THIS RULE AND  OAC
                                                                                                                     3745-55-90 THROUGH  3745-55-99, ESTABLISHES  THE MINIMUM
                                                                                                                     INFORMATION REQUIRED  DURING THE  REMEDIAL DESIGN STAGE.
                                                                                                                     PERTAINS  TO ANY SITE  AT WHICH  EITHER A NEW  SURFACE
                                                                                                                     IMPOUNDMENT WILL BE  INSTALLED  OR AN EXISTING SURFACE
                                                                                                                     IMPOUNDMENT WILL BE  EXPANDED.  THIS, ALONG WITH OTHER
                                                                                                                     PARAGRAPHS OF THIS RULE AND OAC  3745-20-50  THROUGH
                                                                                                                     3745-33-60, ESTABLISHES THE MINIMUM INFORMATION REQUIRED
                                                                                                                     DURING  THE REMEDIAL  DESIGN STAGE.
                                                                                                                     PERTAINS  TO SITE AT  WHICH HAZARDOUS WASTE WILL DE
                                                                                                                     STORED  OR TREATED  IN SURFACE  IMPOUNDMENTS.  THIS, ALONG
                                                                                                                     WITH OTHER PARAGRAPHS OF THIS  RULE AND OAC  3745-56-20
                                                                                                                     THROUGH 3745-56-33,  ESTABLISHES  THE MINIMUM INFORMATION
                                                                                                                     REQUIRED  DURING THE  REMEDIAL  DESIGN STAGE.

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                      OHIO ADMINISTRATIVE CODE  (OAC) ARARs
                        REILLY  TAR           TUSCARAWAS  COUNTY
ADMINIS.
 CODE
SECTION
PERTINENT
PARAGRAPH
TITLE OR  SUBJECT
 OF REGULATION
 DESCRIPTION
OF REGULATION
 APPLICATION
OF REGULATION
ARAR
TYPE
                                   ADD'L PERMIT  INFO: HAZ  WASTE
                                   TREAT/DISP  BY LAND TREAT
3745-50-44
                                   ADD'L PERMIT  INFO: ENVIRONMENTAL
                                   PERFORMANCE  STANDARDS
                                                          ESTABLISHES SUBSTANTIVE HAZARDOUS WASTE  PERMIT
                                                          REQUIREMENTS NECESSARY FOR  OHIO EPA TO DETERMINE ADEQUACY
                                                          OF  LAND TREATMENT  TO TREAT  OR DISPOSE OF HAZARDOUS  WASTES
                                                          INCLUDES INFORMATION SUCH AS  WASTE CHARACTERISTICS,  DESIGN
                                                          MEASURES TO MAXIMIZE TREATMENT, DIMENSIONS OF TREATMENT
                                                          ZONE,  DESIGN OF  UNIT, INFORMATION ON POTENTIAL CROPS,  ETC. SEE
                                                          OAC 3745-56-70  THROUGH 3745-56-83 FOR ADDITIONAL LAND
                                                          TREATMENT REQUIREMENTS.

                                                          ESTABLISHES SUBSTANTIVE HAZARDOUS WASTE  PERMIT
                                                          REQUIREMENTS NECESSARY FOR  OHIO EPA TO DETERMINE ADEQUACY
                                                          OF  SURFACE IMPOUNDMENTS, WASTE PILES, LAND TREATMENT UNITS,
                                                          LANDFILLS, AND  UNDERGROUND  INJECTION WELLS USED TO  TREAT,
                                                          STORE  OR DISPOSE OF HAZARDOUS WASTE INCLUDES INFORMATION
                                                          SUCH AS WASTE CHARACTERISTICS, DETAILED  DESIGN PLANS AND
                                                          REPORTS, CONTROL OF RUN-ON  AND RUN-OFF,  CLOSURE INFORMATION,
                                                          ETC.  SEE OAC 3745-57-01 ADDITIONAL REQUIREMENTS.
                                                                                                                     PERTAINS  TO ANY SITE AT WHICH LAND  TREATMENT WILL BE
                                                                                                                     USED TO TREAT OR DISPOSE OF HAZARDOUS WASTES.  THIS,
                                                                                                                     ALONG WITH OTHER PARAGRAPHS OF  THIS RULE AND OAC
                                                                                                                     3745-20-50 THROUGH 3745-33-60,  ESTABLISHES THE MINIMUM
                                                                                                                     INFORMATION REQUIRED DURING THE  REMEDIAL DESIGN STAGE.
                                                                                                                     PERTAINS  TO SITE AT WHICH HAZARDOUS  WASTE WILL  BE OR
                                                                                                                     HAS BEEN  STORED, TREATED OR DISPOSED OF IN SURFACE
                                                                                                                     IMPOUNDMENTS,  WASTE PILES,  LAND  TREATMENT UNITS,
                                                                                                                     LANDFILLS  OR UNDERGROUND INJECTION WELLS. THIS,  ALONG
                                                                                                                     WITH OTHER PARAGRAPHS  OF THIS RULE AND OAC 3745-57-01
                                                                                                                     ESTABLISHES THE MINIMUM INFORMATION  REQUIRED  DURING
                                                                                                                     THE REMEDIAL DESIGN STAGE.
3745-50-44
3745-50-44
                                   ADD'L PERMIT  INFO: HAZ  WASTE
                                   DISPOSAL  IN  LANDFILLS
                                   ADD'L PERMIT  INFO: HAZ  WASTE
                                   TREATMENT  BY  INCINERATION
                                   ADD'L PERMIT  INFO: HAZ  WASTE T/S/D
                                   IN MISC UNITS
                                                          ESTABLISHES SUBSTANTIVE HAZARDOUS WASTE  PERMIT
                                                          REQUIREMENTS NECESSARY FOR  OHIO EPA TO DETERMINE ADEQUACY
                                                          OF  LANDFILLS USED FOR DISPOSAL OF HAZARDOUS WASTE.
                                                          INCLUDES INFORMATION SUCH AS  WASTE CHARACTERISTICS,  DETAILED
                                                          DESIGN PLANS AND REPORTS, CONTROL OF  RUN-ON AND RUN-OFF,
                                                          CLOSURE INFORMATION, ETC. SEE OAC 3745-57-02 THROUGH
                                                          3745-57-18 FOR  ADDITIONAL LANDFILL REQUIREMENTS.

                                                          ESTABLISHES SUBSTANTIVE HAZARDOUS WASTE  PERMIT
                                                          REQUIREMENTS NECESSARY FOR  OHIO EPA TO DETERMINE ADEQUACY
                                                          OF  INCINERATORS  USED TO TREAT HAZARDOUS  WASTE INCLUDES
                                                          INFORMATION SUCH AS WASTE CHARACTERISTICS,  DETAILED  DESIGN
                                                          PLANS  AND REPORTS,  TRIAL BURN DATA, CLOSURE INFORMATION,
                                                          ETC.  SEE OAC 3745-57-40 THROUGH 3745-57-51  FOR ADDITIONAL
                                                          INCINERATOR REQUIREMENTS.

                                                          ESTABLISHES SUBSTANTIVE HAZARDOUS WASTE  PERMIT
                                                          REQUIREMENTS NECESSARY FOR  OHIO EPA TO DETERMINE ADEQUACY
                                                          OF  MISCELLANEOUS UNITS USED TO TREAT  OR  STORE HAZARDOUS
                                                          WASTE  INCLUDES  INFORMATION  SUCH AS WASTE CHARACTERISTICS,
                                                          DETAILED DESIGN  PLANS AND REPORTS, CONTROL  OF RUN-ON AND
                                                          RUN-OFF, CLOSURE INFORMATION,  ETC. SEE OAC  3745-57-90
                                                          THROUGH 3745-57-93  FOR ADDITIONAL REQUIREMENTS FOR
                                                          MISCELLANEOUS UNITS.
                                                                                                                     PERTAINS  TO SITE AT WHICH HAZARDOUS  WASTE WILL  BE OR
                                                                                                                     HAS BEEN  DISPOSED OF  IN LANDFILLS.  THIS, ALONG  WITH
                                                                                                                     OTHER PARAGRAPHS OF THIS RULE AND  OAC 3745-57-02
                                                                                                                     THROUGH 3745-57-18, ESTABLISHES  THE  MINIMUM  INFORMATION
                                                                                                                     REQUIRED  DURING THE REMEDIAL DESIGN  STAGE.
                                                                                                                     PERTAINS  TO SITE AT WHICH HAZARDOUS  WASTE WILL  BE
                                                                                                                     TREATED BY INCINERATION.  THIS, ALONG WITH OTHER
                                                                                                                     PARAGRAPHS OF THIS RULE AND OAC  3745-57-40 THROUGH
                                                                                                                     3745-57-51,  ESTABLISHES THE MINIMUM  INFORMATION REQUIRED
                                                                                                                     DURING THE REMEDIAL DESIGN STAGE.
                                                                                                                     PERTAINS  TO FACILITY/SITE AT WHICH  HAZARDOUS WASTE WILL
                                                                                                                     BE STORED,  TREATED OR  DISPOSED OF  IN MISCELLANEOUS
                                                                                                                     UNITS.  THIS,  ALONG WITH OTHER PARAGRAPHS OF THIS RULE
                                                                                                                     AND OAC 3745-57-90 THROUGH 3745-57-93,  ESTABLISHES THE
                                                                                                                     MINIMUM INFORMATION  REQUIRED DURING THE REMEDIAL
                                                                                                                     DESIGN  STAGE.

-------
ADMINIS.
 CODE
SECTION
                      OHIO ADMINISTRATIVE  CODE  (OAC)  ARARs
                        REILLY  TAR           TUSCARAWAS  COUNTY
PERTINENT
PARAGRAPH
TITLE OR  SUBJECT
 OF REGULATION
 DESCRIPTION
OF REGULATION
 APPLICATION
OF REGULATION
ARAR
TYPE
                                   HAZARDOUS  WASTE  FACILITY PERMIT
                                   CONDITIONS
                                   TRIAL  BURN FOR  INCINERATORS
                                                           ESTABLISHES GENERAL  PERMIT CONDITIONS APPLIED TO ALL
                                                           HAZARDOUS  WASTE FACILITIES IN  OHIO INCLUDES  CONDITIONS  SUCH
                                                           AS OPERATION AND MAINTENANCE,  SITE ACCESS, MONITORING,  ETC.

                                                           SPECIFIES  REQUIREMENTS OF A TRIAL BURN.
                                                                                                                      PERTAINS  TO ALL ALTERNATIVES THAT WILL  INCORPORATE
                                                                                                                      TREATMENT,  STORAGE  OR DISPOSAL  OF HAZARDOUS  WASTE.
                                                                                                                                                                 PERTAINS TO  ANY ALTERNATIVE INCORPORATING ON-SITE
                                                                                                                                                                 INCINERATION.
                                   REQ FOR CONDITIONALLY EXEMPT
                                   SMALL  QUANTITY GENERATORS
                                   REQUIREMENTS FOR  RECYCLED
                                   MATERIALS
                                                           SPECIFIES  REQUIREMENTS FOR CONDITIONALLY  EXEMPT SMALL
                                                           QUANTITY GENERATORS  OF HAZARDOUS  WASTE PROVIDES RELIEF
                                                           FROM MANY  OF THE HAZARDOUS WASTE  REGULATIONS.
                                                           DEFINES  RECYCLED HAZARDOUS WASTES  AND ESTABLISHES SPECIFIC
                                                           EXEMPTIONS  FOR THESE  WASTES FROM THE HAZARDOUS WASTE
                                                           REGULATIONS.
                                                                                                                      CONSIDER  FOR SITES WHERE THE QUANTITY OF  HAZARDOUS
                                                                                                                      WASTE GENERATED BY AN ON-SITE ACTION WILL BE LESS THAN
                                                                                                                      100 KG  PER MONTH MONTHLY LIMIT  FOR ACUTE  HAZARDOUS
                                                                                                                      WASTE IS  ONE (1) KG.

                                                                                                                      PERTAINS  TO ANY SITE  AT WHICH RECYCLING OF HAZARDOUS
                                                                                                                      WASTES  MAY TAKE PLACE.  CONSIDER FOR SITES AT WHICH  THE
                                                                                                                      FOLLOWING MATERIALS ARE PRESENT:
                                                                                                                         INDUSTRIAL ETHYL ALCOHOL
                                                                                                                         USED BATTERIES
                                                                                                                         USED OIL
                                                                                                                         SCRAP  METAL
                                                                                                                         PETROLEUM PRODUCTS
                                                                                                                         K087 COAL AND COKE TAR SLUDGE
                                                                                                                                                   ACTION
                                                                                                                                                   CHEMICAL
                                                                                                                                                   ACTION
                                                                                                                                                   CHEMICAL
                   A,B
                                   RESIDUES  OF HAZ WASTES IN EMPTY
                                   CONTAINERS
                                                           EXEMPTS  THE RESIDUES  OF HAZARDOUS  WASTES  FROM EMPTY
                                                           CONTAINERS  FROM THE HAZARDOUS WASTE REGULATIONS. PROVIDES
                                                           SPECIFIC DEFINITIONS  FOR THESE  RESIDUES.
                                                                                                                      PERTAINS  TO ANY ALTERNATIVE THAT  INCORPORATES
                                                                                                                      OF HAZARDOUS WASTE  ON-SITE IN  CONTAINERS.
                                                                                                                                                                                                                   STORAGE
                                   EVALUATION OF WASTES
                                                                               ANY PERSON  GENERATING  A WASTE MUST DETERMINE  IF THAT WASTE
                                                                               IS A HAZARDOUS WASTE  (EITHER THROUGH LISTING  OR BY
                                                                               CHARACTERISTIC).
                                                                                                                                             PERTAINS  TO SITES AT  WHICH WASTES  OF ANY  TYPE (BOTH
                                                                                                                                             SOLID AND HAZARDOUS)  ARE LOCATED.
                                                                                                                                                                                                    CHEMICAL
                                                                                                                                                                                                    ACTION
                                   HAZARDOUS  WASTE MANIFEST -
                                   GENERAL  REQUIREMENTS
                                                           REQUIRES  A GENERATOR WHO TRANSPORTS OR OFFERS FOR
                                                           TRANSPORTATION HAZARDOUS WASTE  FOR OFF-SITE TREATMENT.
                                                           STORAGE OR DISPOSAL  TO PREPARE  A UNIFORM  HAZARDOUS WASTE
                                                           MANIFEST.
                                                                                                                      PERTAINS  TO SITES WHERE HAZARDOUS  WASTE WILL BE
                                                                                                                      TRANSPORTED OFF-SITE  FOR TREATMENT,  STORAGE  OR
                                                                                                                      DISPOSAL
                                                                                                                                                   CHEMICAL
                                                                                                                                                   ACTION
                                   HAZARDOUS  WASTE MANIFEST -
                                   NUMBER  OF  COPIES
                                                                               SPECIFIES  THE NUMBER  OF MANIFEST  COPIES TO  BE PREPARED.
                                                                                                                                             PERTAINS  TO SITES WHERE HAZARDOUS  WASTE WILL BE
                                                                                                                                             TRANSPORTED OFF-SITE  FOR TREATMENT,  STORAGE  OR
                                                                                                                                             DISPOSAL
                                                                                                                                                                                                    CHEMICAL
                                                                                                                                                                                                    ACTION
                                   HAZARDOUS  WASTE MANIFEST - USE
                                                                               SPECIFIES  PROCEDURES  FOR THE USE  OF HAZARDOUS  WASTE
                                                                               MANIFESTS  INCLUDING A REQUIREMENT THAT THEY  BE HAND SIGNED
                                                                               BY THE GENERATOR.
                                                                                                                                             PERTAINS  TO SITES WHERE HAZARDOUS  WASTE WILL BE
                                                                                                                                             TRANSPORTED OFF-SITE  FOR TREATMENT,  STORAGE  OR
                                                                                                                                             DISPOSAL
                                                                                                                                                                                                    CHEMICAL
                                                                                                                                                                                                    ACTION
                                   HAZARDOUS  WASTE  PACKAGING
                                                                               REQUIRES A  GENERATOR  TO PACKAGE  HAZARDOUS WASTE IN
                                                                               ACCORDANCE  WITH U.S.  DOT REGULATIONS FOR TRANSPORTATION
                                                                               OFF-SITE.
                                                                                                                                             PERTAINS  TO ANY SITE  WHERE HAZARDOUS WASTE  WILL BE
                                                                                                                                             GENERATED BY ON-SITE  ACTIVITIES  AND SHIPPED OFF-SITE  FOR
                                                                                                                                             TREATMENT AND/OR DISPOSAL.
                                                                                                                                                                                                    CHEMICAL
                                                                                                                                                                                                    ACTION
                                   HAZARDOUS  WASTE  LABELING
                                                                               REQUIRES  PACKAGES OF  HAZARDOUS WASTE TO BE  LANDFILLED  IN
                                                                               ACCORDANCE  WITH U.S.  DOT REGULATIONS FOR OFF-SITE
                                                                               TRANSPORTATION.
                                                                                                                                             PERTAINS  TO ANY SITE  WHERE HAZARDOUS WASTE  WILL BE
                                                                                                                                             GENERATED BY ON-SITE  ACTIVITIES  AND SHIPPED OFF-SITE  FOR
                                                                                                                                             TREATMENT AND/OR DISPOSAL
                                                                                                                                                                                                    CHEMICAL
                                                                                                                                                                                                    ACTION

-------
ADMINIS.
 CODE
SECTION
                      OHIO ADMINISTRATIVE  CODE  (OAC)  ARARs
                        REILLY  TAR           TUSCARAWAS  COUNTY
PERTINENT
PARAGRAPH
TITLE OR  SUBJECT
 OF REGULATION
 DESCRIPTION
OF REGULATION
 APPLICATION
OF REGULATION
ARAR
TYPE
                                   HAZARDOUS  WASTE MARKING
                                                                               SPECIFIES  LANGUAGE FOR MARKING PACKAGES OF HAZ
                                                                               PRIOR TO OFF-SITE TRANSPORTATION.
                                                                                                                                 iRDOUS WASTE
                                                                                                                                             PERTAINS TO  ANY SITE WHERE HAZARDOUS WASTE WILL BE
                                                                                                                                             GENERATED  BY ON-SITE ACTIVITIES AND SHIPPED  OFF-SITE FOR
                                                                                                                                             TREATMENT  AND/OR DISPOSAL.
                                                                                                                                                                                                    CHEMICAL
                                                                                                                                                                                                    ACTION
                                                                               GENERATOR  SHALL PLACARD  HA
                                                                               TRANSPORTATION.
                                                                                                           5ARDOUS  WASTE PRIOR TO OFF-SITE
                                                                                                                                             PERTAINS TO  ANY SITE WHERE HAZARDOUS WASTE WILL BE
                                                                                                                                             GENERATED  BY ON-SITE ACTIVITIES AND SHIPPED  OFF-SITE FOR
                                                                                                                                             TREATMENT  AND/OR DISPOSAL.
                                                                                                                                                                                                    CHEMICAL
                                                                                                                                                                                                    ACTION
                                   ACCUMULATION TIME  OF HAZARDOUS
                                   WASTE
                                                           IDENTIFIES  MAXIMUM  TIME PERIODS  THAT A GENERATOR MAY
                                                           ACCUMULATE  A HAZARDOUS  WASTE WITHOUT BEING  CONSIDERED  AN
                                                           OPERATOR  OF A STORAGE  FACILITY ALSO ESTABLISHES STANDARDS
                                                           FOR MANAGEMENT OF HAZARDOUS WASTES BY GENERATORS.
                                                                                                                      PERTAINS  TO A SITE WHERE HAZARDOUS  WASTE WILL BE
                                                                                                                      GENERATED AS A RESULT  OF THE REMEDIAL ACTIVITIES
                                                                                                                                                   CHEMICAL
                                                                                                                                                   ACTION
                                   GENERAL  ANALYSIS  OF  HAZARDOUS
                                   WASTE
                                                           PRIOR TO  ANY TREATMENT,  STORAGE  OR DISPOSAL OF HAZARDOUS
                                                           WASTES, A REPRESENTATIVE SAMPLE  OF THE WASTE MUST BE
                                                           CHEMICALLY AND PHYSICALLY ANALYZED.
                                                                                                                      PERTAINS  TO ANY SITE AT WHICH HAZARDOUS IS  TO BE
                                                                                                                      TREATED,  STORED OR DISPOSED OF  (OR HAS BEEN DISPOSED OF)
3745-54-15
                                   SECURITY FOR HAZARDOUS WASTE
                                   FACILITIES
                                   INSPECTION REQUIREMENTS FOR
                                   HAZARDOUS  WASTE FACILITIES
                                                           HAZARDOUS  WASTE FACILITIES MUST  BE SECURED  SO THAT
                                                           UNAUTHORIZED AND UNKNOWING ENTRY ARE MINIMIZED OR
                                                           PROHIBITED.

                                                           HAZARDOUS  WASTE FACILITIES MUST  BE INSPECTED REGULARLY TO
                                                           DETECT MALFUNCTIONS,  DETERIORATIONS, OPERATIONAL ERRORS  AND
                                                           DISCHARGES ANY MALFUNCTIONS OR DETERIORATIONS DETECTED
                                                           SHALL BE  REMEDIED  EXPEDITIOUSLY.
                                                                                                                      PERTAINS  TO ANY SITE AT WHICH HAZARDOUS IS  TO BE
                                                                                                                      TREATED,  STORED
                                                                                                                      OR DISPOSED OF (OR HAS  BEEN DISPOSED OF).

                                                                                                                      PERTAINS  TO ANY SITE AT WHICH HAZARDOUS IS  TO BE
                                                                                                                      TREATED,  STORED OR DISPOSED OF  (OR HAS BEEN DISPOSED OF)
                                   REQ FOR  IGNITABLE,  REACTIVE  OR
                                   INCOMPATIBLE HAZ WASTES
                                                           PRESENTS  GENERAL PRECAUTIONS  TO  BE TAKEN  TO PREVENT
                                                           ACCIDENTAL  IGNITION  OR REACTION  OF IGNITABLE,  REACTIVE  OR
                                                           INCOMPATIBLE WASTES.
                                                                                                                      PERTAINS  TO ANY SITE AT WHICH POTENTIALLY  REACTIVE,
                                                                                                                      IGNITABLE  OR
                                                                                                                      INCOMPATIBLE WASTES ARE PRESENT.
                                                                                                                                                   ACTION
                                                                                                                                                   LOCATION
                                   LOCATION STANDARDS  FOR
                                   HAZARDOUS WASTE T/S/D FACILITIES
                                   DESIGN  f,  OPERATION  OF HAZARDOUS
                                   WASTE FACILITIES
                                                           RESTRICTS  THE SITING  OF HAZARDOUS  WASTE FACILITIES  IN  AREAS OF
                                                           SEISMIC ACTIVITY OR FLOODPLAINS.

                                                           HAZARDOUS  WASTE FACILITIES MUST  BE DESIGNED,  CONSTRUCTED,
                                                           MAINTAINED AND OPERATED TO MINIMIZE THE POSSIBILITY OF FIRE,
                                                           EXPLOSION  OR UNPLANNED RELEASE OF  HAZARDOUS  WASTE OR
                                                           HAZARDOUS  CONSTITUENTS TO THE AIR, SOIL OR  SURFACE WATER
                                                           WHICH COULD THREATEN  HUMAN HEALTH  OR THE  ENVIRONMENT.
                                                                                                                      PERTAINS  TO ANY SITE AT WHICH HAZARDOUS IS  TO BE
                                                                                                                      TREATED,  STORED OR DISPOSED OF  (OR HAS BEEN DISPOSED OF).
                                                                                                                      PERTAINS  TO ANY SITE AT WHICH HAZARDOUS IS  TO BE
                                                                                                                      TREATED,  STORED OR DISPOSED OF  (OR HAS BEEN DISPOSED OF).
                 A,B,C,D
                                   REQUIRED EQUIPMENT  FOR HAZARDOUS
                                   WASTE  FACILITIES
                                                           ALL HAZARDOUS WASTE  FACILITIES  MUST BE EQUIPPED WITH
                                                           EMERGENCY  EQUIPMENT,  SUCH AS AN ALARM SYSTEM,  FIRE CONTROL
                                                           EQUIPMENT  AND A TELEPHONE OR RADIO.
                                                                                                                      PERTAINS  TO ANY SITE AT WHICH HAZARDOUS IS  TO BE
                                                                                                                      TREATED,  STORED OR DISPOSED OF  (OR HAS BEEN DISPOSED OF).
                                   TESTING  S,  MAINTENANCE OF
                                   EQUIPMENT,  HAZ WASTE FACILITIES
                                   ACCESS  TO COMMUNICATIONS OR
                                   ALARM SYSTEM HAZ WASTE FAC
                                                           ALL HAZARDOUS WASTE  FACILITIES  MUST TEST AND MAINTAIN
                                                           EMERGENCY  EQUIPMENT  TO ASSURE PROPER OPERATION.

                                                           WHENEVER HAZARDOUS WASTE IS BEING HANDLED  ALL PERSONNEL
                                                           INVOLVED SHALL HAVE  IMMEDIATE ACCESS TO AN INTERNAL ALARM
                                                           OR EMERGENCY COMMUNICATION DEVICE.
                                                                                                                      PERTAINS  TO ANY SITE AT WHICH HAZARDOUS WASTE IS TO BE
                                                                                                                      TREATED,  STORED OR DISPOSED OF  (OR HAS BEEN  DISPOSED OF).
                                                                                                                      PERTAINS  TO ANY SITE AT WHICH HAZARDOUS WASTE IS TO BE
                                                                                                                      TREATED,  STORED OR DISPOSED OF  JOB HAS BEEN  DISPOSED OF).

-------
ADMINIS.
 CODE
SECTION
                      OHIO ADMINISTRATIVE  CODE (OAC) ARARs
                        REILLY  TAR           TUSCARAWAS  COUNTY
PERTINENT
PARAGRAPH
TITLE OR  SUBJECT
 OF REGULATION
 DESCRIPTION
OF REGULATION
 APPLICATION
OF REGULATION
ARAR
TYPE
                                   REQUIRED  AISLE SPACE  AT HAZ WASTE
                                   FACILITIES
                                                          ADEQUATE AISLE  SPACE SHALL BE MAINTAINED TO ALLOW
                                                          UNOBSTRUCTED  MOVEMENT OF  PERSONNEL,  FIRE EQUIPMENT,  SPILL
                                                          CONTROL EQUIPMENT AND DECONTAMINATION EQUIPMENT  INTO ANY
                                                          AREA OF THE FACILITY OPERATION IN  THE EVENT OF AN EMERGENCY.
                                                                                                                     PERTAINS TO ANY  SITE AT WHICH  HAZARDOUS WASTE IS TO  BE
                                                                                                                     TREATED, STORED  OR DISPOSED  OF (OR HAS BEEN DISPOSED OF).
                                                                                                                     CONSIDER FOR SITES WHERE WASTES  WILL BE STORED IN
                                                                                                                     CONTAINERS.
                                   ARRANGEMENTS/AGREEMENTS  WITH
                                   LOCAL AUTHORITIES
                                                          ARRANGEMENTS  OR AGREEMENTS  WITH LOCAL AUTHORITIES,  SUCH AS
                                                          POLICE, FIRE  DEPARTMENT AND EMERGENCY RESPONSE  TEAMS MUST
                                                          BE  MADE. IF LOCAL AUTHORITIES WILL NOT COOPERATE,
                                                          DOCUMENTATION OF THAT NON-COOPERATION SHOULD BE  PROVIDED.
                                                                                                                     PERTAINS TO ANY  SITE AT WHICH  HAZARDOUS WASTE IS TO  BE
                                                                                                                     TREATED, STORED  OR DISPOSED  OF (OR HAS BEEN DISPOSED OF).
                                   CONTENT OF  CONTINGENCY PLAN; HAZ
                                   WASTE FACILITIES
                                                          HAZARDOUS WASTE FACILITIES  MUST HAVE  A CONTINGENCY PLAN
                                                          THAT ADDRESSES  ANY UNPLANNED RELEASE  OF HAZARDOUS  WASTES
                                                          OR HAZARDOUS  CONSTITUENTS  INTO THE AIR, SOIL OR  SURFACE
                                                          WATER. THIS  RULE ESTABLISHES THE MINIMUM REQUIRED
                                                          INFORMATION  OF  SUCH A PLAN.
                                                                                                                     PERTAINS TO ANY  SITE AT WHICH  HAZARDOUS WASTE IS TO  BE
                                                                                                                     TREATED, STORED  OR DISPOSED  OF (OR HAS BEEN DISPOSED OF).
                                   COPIES OF  CONTINGENCY  PLAN;
                                   HAZARDOUS  WASTE FACILITIES
                                                           COPIES OF THE  CONTINGENCY  PLAN REQUIRED BY 3745-54-50 MUST  BE
                                                           MAINTAINED AT  THE FACILITY AND SUBMITTED TO ALL  LOCAL POLICE
                                                           DEPARTMENTS,  FIRE DEPARTMENTS, HOSPITALS LOCAL EMERGENCY
                                                           RESPONSE TEAMS AND THE  OHIO EPA.
                                                                                                                     PERTAINS TO ANY  SITE AT WHICH  HAZARDOUS WASTE IS TO  BE
                                                                                                                     TREATED, STORED  OR DISPOSED  OF (OR HAS BEEN DISPOSED OF).
3745-54-54
                                  AMENDMENT  OF CONTINGENCY PLAN;
                                  HAZ WASTE  FACILITIES
                                  EMERGENCY  COORDINATOR;
                                  HAZARDOUS  WASTE FACILITIES
                                                           THE CONTINGENCY PLAN MUST  BE AMENDED  IF IT FAILS  IN AN
                                                           EMERGENCY,  THE  FACILITY  CHANGES  (IN  ITS DESIGN,  CONSTRUCTION,
                                                           MAINTENANCE  OR  OPERATION),  THE LIST  OF EMERGENCY
                                                           COORDINATORS  CHANGE OR THE  LIST OF EMERGENCY EQUIPMENT.

                                                           AT  ALL TIMES  THERE SHOULD  BE AT LEAST ONE EMPLOYEE EITHER  ON
                                                           THE PREMISES  OR ON CALL  TO  COORDINATE ALL EMERGENCY
                                                           RESPONSE MEASURES.
                                                                                                                     PERTAINS TO ANY  SITE AT WHICH  HAZARDOUS WASTE IS TO  BE
                                                                                                                     TREATED, STORED  OR DISPOSED  OF (OR HAS BEEN DISPOSED OF).
                                                                                                                     PERTAINS TO ANY  SITE AT WHICH  HAZARDOUS WASTE IS TO  BE
                                                                                                                     TREATED, STORED  OR DISPOSED  OF (OR HAS BEEN DISPOSED OF).
                                  EMERGENCY  PROCEDURES;  HAZARDOUS
                                  WASTE FACILITIES
                                  GROUND WATER PROTECTION;
                                  APPLICABILITY
                                                           SPECIFIES THE  PROCEDURES  TO BE FOLLOWED IN THE  EVENT OF AN
                                                           EMERGENCY.

                                                           ESTABLISHES  CIRCUMSTANCES  UNDER WHICH AN OPERATOR OF A
                                                           HAZARDOUS WASTE FACILITY  MUST IMPLEMENT A GROUND  WATER
                                                           PROTECTION PROGRAM OR A CORRECTIVE ACTION PROGRAM.
                                                                                                                     PERTAINS TO ANY  SITE AT WHICH  HAZARDOUS WASTE IS TO  BE
                                                                                                                     TREATED, STORED  OR DISPOSED  OF (OR HAS BEEN DISPOSED OF).

                                                                                                                     PERTAINS TO ALL  SITES WITH LAND-BASED HAZARDOUS WASTE
                                                                                                                     UNITS  (SURFACE IMPOUNDMENTS, WASTE PILES,  LAND
                                                                                                                     TREATMENT UNITS,  LANDFILLS). THIS INCLUDES EXISTING
                                                                                                                     LAND-BASED AREAS  OF
                                                                                                                     CONTAMINATION.
                                  REQ GROUND  WATER PROGRAMS FOR
                                  HAZ WASTE FACILITIES
                                                           PRESENTS THE  GROUND WATER MONITORING  AND RESPONSE
                                                           PROGRAMS REQUIRED FOR HAZARDOUS WASTE LAND BASED UNITS.
                                                                                                                     PERTAINS TO ALL  SITES WITH  LAND-BASED HAZARDOUS WASTE
                                                                                                                     UNITS  (SURFACE IMPOUNDMENTS,  WASTE PILES,  LAND
                                                                                                                     TREATMENT UNITS,  LANDFILLS).  THIS INCLUDES EXISTING
                                                                                                                     LAND-BASED AREAS  OF CONTAMINATION.
                                  GROUND WATER PROTECTION
                                  STANDARD,  HAZ WASTE FACILITIES
                                                           COMPLIANCE MUST BE ATTAINED WITH THE  CONDITIONS  SPECIFIED  IN
                                                           THE PERMIT TO  ENSURE THAT  HAZARDOUS  CONSTITUENTS  (SEE
                                                           3745-54-93)  DO NOT EXCEED  THE PROMULGATED LIMITS  (SEE
                                                           3745-54-94).
                                                                                                                     PERTAINS TO ALL  SITES WITH  LAND-BASED HAZARDOUS WASTE
                                                                                                                     UNITS  (SURFACE IMPOUNDMENTS,  WASTE PILES,  LAND
                                                                                                                     TREATMENT UNITS,  LANDFILLS).  THIS INCLUDES EXISTING
                                                                                                                     LAND-BASED AREAS  OF CONTAMINATION.
                                                                                                                                                  ACTION
                                                                                                                                                  CHEMICAL

-------
ADMINIS.
 CODE
SECTION
                      OHIO ADMINISTRATIVE  CODE  (OAC)  ARARs
                        REILLY  TAR           TUSCARAWAS  COUNTY
PERTINENT
PARAGRAPH
TITLE OR  SUBJECT
 OF REGULATION
 DESCRIPTION
OF REGULATION
 APPLICATION
OF REGULATION
ARAR
TYPE
3745-54-94
                   A,B
                                   HAZARDOUS  CONSTITUENTS IN GROUND
                                   WATER,  HAZ WASTE FAC
                                   CONCENTRATION LIMITS  FOR GROUND
                                   WATER;  HAZ  WASTE FAC
                                                           REQUIRES  THAT PERMIT  SPECIFY HAZARDOUS CONSTITUENTS TO WHICH
                                                           THE GROUND  WATER PROTECTION STANDARD OF 3745-54-92 APPLIES
                                                           HAZARDOUS CONSTITUENTS  ARE CONSTITUENTS IDENTIFIED IN THE
                                                           APPENDIX  OF THIS RULE  THAT HAVE BEEN DETECTED  IN GROUND
                                                           WATER IN  THE UPPERMOST  AQUIFER UNDERLYING THE  UNIT(S) AND  ARE
                                                           REASONABLY  EXPECTED TO  BE IN OR DERIVED FROM WASTE
                                                           CONTAINED IN THE UNIT(S).

                                                           PRESENTS  THE METHODOLOGY FOR DETERMINING CONCENTRATION
                                                           LIMITS AND  ALTERNATIVE  CONCENTRATION LIMITS.
                                                                                                                      PERTAINS TO ALL SITES WITH LAND BASED HAZARDOUS  WASTE
                                                                                                                      UNITS (SURFACE  IMPOUNDMENTS,  WASTE  PILES, LAND
                                                                                                                      TREATMENT UNITS,  LANDFILLS).  THIS  INCLUDES EXISTING
                                                                                                                      LAND BASED AREAS  OF CONTAMINATION.
                                                                                                                      PERTAINS TO ALL SITES WITH LAND BASED HAZARDOUS  WASTE
                                                                                                                      UNITS (SURFACE  IMPOUNDMENTS,  WASTE  PILES, LAND
                                                                                                                      TREATMENT UNITS,  LANDFILLS).  THIS  INCLUDES EXISTING
                                                                                                                      LAND-BASED AREAS  OF CONTAMINATION.
                   A,B
                                   POINT OF  COMPLIANCE  FOR GROUND
                                   WATER;  HAZ  WASTE FACIL
                                                           ESTABLISHES  POINT OF  COMPLIANCE AT  VERTICAL  SURFACE LOCATED
                                                           AT THE HYDRAULICALLY  DOWNGRADIENT  LIMIT OF THE WASTE
                                                           MANAGEMENT AREA THAT  EXTENDS DOWN  INTO THE UPPERMOST
                                                           AQUIFER UNDERLYING THE  UNIT(S).
                                                                                                                      PERTAINS TO ALL SITES WITH LAND BASED HAZARDOUS  WASTE
                                                                                                                      UNITS (SURFACE  IMPOUNDMENTS,  WASTE  PILES. LAND
                                                                                                                      TREATMENT UNITS,  LANDFILL).  THIS  INCLUDES EXISTING
                                                                                                                      LAND BASED AREAS  OF CONTAMINATION.
                                                                                                                                                   ACTION
                                                                                                                                                   CHEMICAL
                                   COMPLIANCE PERIOD  FOR GROUND
                                   WATER;  HAZ WASTE FACIL
                                                           A COMPLIANCE  PERIOD DURING WHICH  THE GROUND  WATER
                                                           PROTECTION  STANDARDS APPLY WILL BE  SPECIFIED IN THE PERMIT.
                                                           RULE REQUIRES THAT THE  COMPLIANCE  PERIOD FOR A FACILITY
                                                           UNDERGOING  A  CORRECTIVE ACTION PROGRAM WILL  EXTEND UNTIL  IT
                                                           CAN BE DEMONSTRATED THAT THE GROUND WATER PROTECTION
                                                           STANDARD OF OAC 3745-54-92 HAS NOT  BEEN EXCEEDED FOR A
                                                           PERIOD OF THREE CONSECUTIVE YEARS.
                                                                                                                      PERTAINS TO ALL SITES WITH LAND-BASED HAZARDOUS  WASTE
                                                                                                                      UNITS (SURFACE  IMPOUNDMENTS,  WASTE  PILES, LAND
                                                                                                                      TREATMENT UNITS,  LANDFILLS).  THIS  INCLUDES EXISTING
                                                                                                                      LAND BASED AREAS  OF CONTAMINATION.
                                                                                                                                                   ACTION
                                                                                                                                                   CHEMICAL
                                   GEN GROUND WATER MONITORING
                                   REQUIREMENTS; HAZ WASTE FAC
                                                           PRESENTS GENERAL GROUND WATER MONITORING PROGRAM
                                                           REQUIREMENTS,  INCLUDES  NUMBER, LOCATION AND  DEPTH OF WELLS,
                                                           CASING REQUIREMENTS,  SAMPLING AND  ANALYSIS PROCEDURES,  ETC.
                                                                                                                      PERTAINS TO ALL SITES WITH LAND BASED HAZARDOUS  WASTE
                                                                                                                      UNITS (SURFACE  IMPOUNDMENTS,  WASTE  PILES, LAND
                                                                                                                      TREATMENT UNITS,  LANDFILLS).  THIS  INCLUDES EXISTING
                                                                                                                      LAND BASED AREAS  OF CONTAMINATION.
                                                                                                                                                   ACTION
                                                                                                                                                   CHEMICAL
                                   GROUND WATER DETECTION
                                   MONITORING PROG; HAZ  WASTE FAC
                                                                              PRESENTS REQUIREMENTS OF  GROUND WATER DETECTION  PROGRAM.
                                                                                                                                            PERTAINS TO ALL  SITES WITH  LAND BASED  HAZARDOUS WASTE
                                                                                                                                            UNITS  (SURFACE  IMPOUNDMENTS,  WASTE PILES,  LAND
                                                                                                                                            TREATMENT UNITS,  LANDFILLS)  AT WHICH HAZARDOUS
                                                                                                                                            CONSTITUENTS HAVE NOT BEEN  DETECTED IN THE GROUND
                                                                                                                                            WATER.  THIS INCLUDES EXISTING LAND BASED AREAS OF
                                                                                                                                            CONTAMINATION.
                                                                                                                                                                                                    ACTION
                                                                                                                                                                                                    CHEMICAL
                                   GROUND WATER COMPLIANCE
                                   MONITORING PROG; HAZ  WASTE FAC
                                                           PRESENTS  REQUIREMENTS  OF GROUND WATER COMPLIANCE
                                                           MONITORING  PROGRAM.
                                                                                                                      PERTAINS TO ALL SITES WITH LAND-BASED HAZARDOUS  WASTE
                                                                                                                      UNITS (SURFACE  IMPOUNDMENTS,  WASTE  PILES, LAND
                                                                                                                      TREATMENT UNITS,  LANDFILLS)  AT WHICH  HAZARDOUS
                                                                                                                      CONSTITUENTS  HAVE BEEN  DETECTED. THIS INCLUDES  EXISTING
                                                                                                                      LAND BASED AREAS  OF CONTAMINATION.
                                                                                                                                                   ACTION
                                                                                                                                                   CHEMICAL
3745-55-01
                                   GROUND WATER CORRECTIVE ACTION
                                   PROGRAM;  HAZ WASTE  FAC
                                                           PRESENTS  THE  REQUIREMENTS OF A GROUND WATER  CORRECTIVE
                                                           ACTION PROGRAM THAT  PREVENTS HAZARDOUS CONSTITUENTS FROM
                                                           EXCEEDING THEIR RESPECTIVE CONCENTRATION LIMITS  AT THE
                                                           COMPLIANCE  POINT BY  EITHER REMOVAL  OR TREATMENT  OF THESE
                                                           HAZARDOUS  CONSTITUENTS.
                                                                                                                      PERTAINS TO ALL SITES WITH LAND-BASED HAZARDOUS  WASTE
                                                                                                                      UNITS (SURFACE  IMPOUNDMENTS,  WASTE  PILES, LAND
                                                                                                                      TREATMENT UNITS,  LANDFILLS)  AT WHICH  HAZARDOUS
                                                                                                                      CONSTITUENTS  HAVE BEEN  DETECTED THIS  INCLUDES EXISTING
                                                                                                                      LAND-BASED AREAS  OF CONTAMINATION.
                                                                                                                                                   ACTION
                                                                                                                                                   CHEMICAL

-------
                      OHIO ADMINISTRATIVE  CODE (OAC) ARARs
                        REILLY  TAR           TUSCARAWAS  COUNTY
ADMINIS.
 CODE
SECTION
PERTINENT
PARAGRAPH
TITLE OR  SUBJECT
 OF REGULATION
 DESCRIPTION
OF REGULATION
 APPLICATION
OF REGULATION
ARAR
TYPE
                                   CORRECTIVE  ACTION  FOR WASTE
                                   MANAGEMENT  UNITS
                                                           REQUIRES AN  APPLICANT  FOR A HAZARDOUS  WASTE PERMIT TO
                                                           INSTITUTE  CORRECTIVE ACTION FOR ALL  RELEASES  OF  HAZARDOUS
                                                           WASTE OR CONSTITUENTS  FFIOM ANY WASTE  MANAGEMENT UNIT,
                                                           REGARDLESS OF  THE TIME  AT WHICH WASTE  WAS PLACED IN SUCH
                                                           UNIT.
                                                                                                                     PERTAINS TO ALL  SITES WITH  LAND BASED  HAZARDOUS WASTE
                                                                                                                     UNITS  (SURFACE  IMPOUNDMENTS,  WASTE PILES,  LAND
                                                                                                                     TREATMENT UNITS,  LANDFILLS)  AT WHICH HAZARDOUS
                                                                                                                     CONSTITUENTS HAVE BEEN DETECTED THIS INCLUDES EXISTING
                                                                                                                     LAND BASED AREAS  OF CONTAMINATION.
                                   GENERAL  CLOSURE PERFORMANCE
                                   STANDARD,  HAZ WASTE  FACIL
                                                           REQUIRES THAT  ALL HAZARDOUS WASTE  FACILITIES  BE  CLOSED  IN
                                                           MANNER THAT  MINIMIZES  THE  NEED FOR FURTHER MAINTENANCE,
                                                           CONTROLS, MINIMIZES, ELIMINATES OR PREVENTS POST-CLOSURE
                                                           ESCAPE OF HAZARDOUS WASTE,  HAZARDOUS  CONSTITUENTS,
                                                           LEACHATE, CONTAMINATED RUN-OFF OR  HAZARDOUS WASTE
                                                           DECOMPOSITION  PRODUCTS TO  THE GROUND  OR SURFACE  WATER OR
                                                           THE ATMOSPHERE.
                                                                                                                     PERTAINS TO ANY  SITE AT WHICH HAZARDOUS  WASTE IS  TO BE
                                                                                                                     TREATED, STORED  OR DISPOSED  OF (OR HAS  BEEN TREATED,
                                                                                                                     STORED OR DISPOSED OF).
                                   CONTENT  OF  CLOSURE  PLAN;  HAZ
                                   WASTE FACILITIES
                                                           SPECIFIES  THE  MINIMUM  INFORMATION  REQUIRED IN A CLOSURE PLAN
                                                           FOR OHIO EPA  TO DETERMINE  THE ADEQUACY OF THE PLAN.
                                                                                                                     SUBSTANTIVE REQUIREMENTS  PERTAIN TO ANY  SITE AT WHICH
                                                                                                                     HAZARDOUS WASTE  IS TO BE  TREATED, STORED OR DISPOSED
                                                                                                                     OF  (OR HAS BEEN  TREATED,  STORED OR DISPOSED OF).
3745-55-14
                                   DISPOSAL/DECON OF  EQUIPMENT,
                                   STRUCTURES  S SOILS
                                                           REQUIRES THAT  ALL CONTAMINATED EQUIPMENT, STRUCTURES AND
                                                           SOILS BE PROPERLY DISPOSED OF OR DECONTAMINATED  REMOVAL OF
                                                           HAZARDOUS WASTES OR CONSTITUENTS FROM A UNIT MAY
                                                           CONSTITUTE  GENERATION OF  HAZARDOUS  WASTES.
                                                                                                                     PERTAINS TO ANY  SITE AT WHICH HAZARDOUS  WASTE IS  TO BE
                                                                                                                     TREATED, STORED  OR DISPOSED  OF (OR HAS  BEEN TREATED,
                                                                                                                     STORED OR DISPOSED OF).
                                   POST-CLOSURE CARE
                                   PROPERTY
                                                       \ND USE OF
                                                           SPECIFIES  THE  POST-CLOSURE CARE REQUIREMENTS,  INCLUDING
                                                           MAINTENANCE, MONITORING  AND POST-CLOSURE USE  OF  PROPERTY.
                                                                                                                     PERTAINS TO ALL  SITES WITH  LAND-BASED  HAZARDOUS WASTE
                                                                                                                     UNITS  (LANDFILLS  AND SURFACE  IMPOUNDMENTS,  WASTE  PILES,
                                                                                                                     LAND  TREATMENT UNITS AND  TANKS THAT MEET REQUIREMENTS
                                                                                                                     OF  LANDFILLS AFTER
                                                                                                                     CLOSURE). THIS INCLUDES EXISTING LAND-BASED AREAS  OF
                                                                                                                     CONTAMINATION.
                                                                              PRESENTS THE  INFORMATION NECESSARY FOR OHIO EPA  TO  DETERMINE
                                                                              THE  ADEQUACY  OF  A POST-CLOSURE PLAN.
                                                                                                                                            PERTAINS  TO ALL  SITES WITH LAND BASED HAZARDOUS WASTE
                                                                                                                                            UNITS  (LANDFILLS AND SURFACE  IMPOUNDMENTS,  WASTE PILES,
                                                                                                                                            LAND TREATMENT UNITS AND TANKS  THAT MEET  REQUIREMENTS
                                                                                                                                            OF LANDFILLS AFTER CLOSURE).  THIS INCLUDES  EXISTING
                                                                                                                                            LAND-BASED AREAS OF CONTAMINATION.
3745-55-19
                                                                              REQUIRES THAT A RECORD OF  THE TYPE,  LOCATION AND  QUANTITY OF
                                                                              HAZARDOUS WASTES DISPOSED  OF  IN EACH  UNIT BE SUBMITTED TO
                                                                              THE  LOCAL LAND  AUTHORITY AND  THE DIRECTOR OF THE  OHIO EPA.
                                                                              ALSO REQUIRES THAT A NOTATION TO THE  DEED TO THE  FACILITY
                                                                              PROPERTY BE MADE INDICATING THAT THE  LAND WAS USED  TO
                                                                              MANAGE HAZARDOUS WASTES AND THAT CERTAIN USE RESTRICTIONS
                                                                              MAY  APPLY TO THE PROPERTY.
                                                                                                                                            PERTAINS  TO ALL  SITES WITH LAND BASED HAZARDOUS WASTE
                                                                                                                                            UNITS  (LANDFILLS AND SURFACE  IMPOUNDMENTS,  WASTE PILES,
                                                                                                                                            LAND TREATMENT UNITS AND TANKS  THAT MEET  REQUIREMENTS
                                                                                                                                            OF LANDFILLS AFTER CLOSURE).  THIS INCLUDES  EXISTING
                                                                                                                                            LAND-BASED AREAS OF CONTAMINATION.
3745-55-71
                                                                              CONTAINERS HOLDING HAZARDOUS  WASTE MUST  BE MAINTAINED IN
                                                                              GOOD  CONDITION  (NO RUST OR  STRUCTURAL  DEFECTS).
                                                                                                                                            PERTAINS  TO ANY  SITE AT WHICH  HAZARDOUS WASTE WILL  BE
                                                                                                                                            STORED  IN CONTAINERS.
                                   COMPATIBILITY OF WASTE WITH
                                   CONTAINERS
                                                           HAZARDOUS WASTES PLACED  IN CONTAINER MUST NOT  REACT WITH
                                                           THE CONTAINER MATERIAL OR LINER MATERIAL.
                                                                                                                     PERTAINS TO ANY  SITE AT WHICH HAZARDOUS  WASTE WILL  BE
                                                                                                                     STORED IN CONTAINERS.

-------
ADMINIS.
 CODE
SECTION
                      OHIO ADMINISTRATIVE  CODE (OAC) ARARs
                        REILLY  TAR           TUSCARAWAS  COUNTY
  PERTINENT
  PARAGRAPH
TITLE OR  SUBJECT
 OF REGULATION
 DESCRIPTION
OF REGULATION
 APPLICATION
OF REGULATION
ARAR
TYPE
                                   MANAGEMENT  OF CONTAINERS
                                                                              CONTAINERS HOLDING HAZARDOUS  WASTE MUST  BE CLOSED  (EXCEPT
                                                                              TO ADD OR REMOVE  WASTE) AND MUST NOT  BE  HANDLED  IN  A
                                                                              MANNER THAT MAY RUPTURE THE CONTAINER OR CAUSE IT TO LEAK.
                                                                                                                                              PERTAINS TO ANY SITE AT WHICH HAZARDOUS  WASTE WILL BE
                                                                                                                                              STORED IN CONTAINERS.
                                  CONTAINER  INSPECTIONS
                                                                              REQUIRES AT LEAST  WEEKLY  INSPECTIONS  OF  CONTAINER  STORAGE
                                                                              AREAS.
                                                                                                                                              PERTAINS TO ANY SITE AT WHICH HAZARDOUS  WASTE WILL BE
                                                                                                                                              STORED IN CONTAINERS.
                                  CONTAINER  STORAGE AREA
                                  CONTAINMENT  SYSTEM
                                                             REQUIRES  THAT CONTAINER STORAGE  AREAS HAVE  A CONTAINMENT
                                                             SYSTEM AND SPECIFIES  THE MINIMUM REQUIREMENTS OF SUCH  A
                                                             SYSTEM.
                                                                                                                     PERTAINS TO ANY  SITE AT WHICH HAZARDOUS  WASTE WILL  BE
                                                                                                                     STORED IN CONTAINERS.
                                  CONTAINER  REQUIREMENTS  FOR
                                  IGNITABLE/REACTIVE WASTES
                                                             PRESENTS  GENERAL PRECAUTIONS  TO  BE TAKEN  TO  PREVENT
                                                             ACCIDENTAL IGNITION  OR REACTION  OF IGNITABLE OR REACTIVE
                                                             WASTES  THAT WILL BE  STORED IN  CONTAINERS.
                                                                                                                     PERTAINS TO ANY  SITE AT WHICH POTENTIALLY REACTIVE  OR
                                                                                                                     IGNITABLE WASTES  THAT ARE  STORED, OR ARE  TO BE STORED,
                                                                                                                     IN  CONTAINERS.
                                                                                                                                                   ACTION
                                                                                                                                                   CHEMICAL
                                  CONTAINER  REQUIREMENTS  FOR
                                  INCOMPATIBLE WASTES
                                                             PRESENTS  GENERAL PRECAUTIONS  TO  BE TAKEN WHEN DEALING  WITH
                                                             INCOMPATIBLE WASTES.
                                                                                                                     PERTAINS TO ANY  SITE AT WHICH POTENTIALLY INCOMPATIBLE
                                                                                                                     WASTES  ARE
                                                                                                                     PRESENT.
                                                                                                                                                   ACTION
                                                                                                                                                   CHEMICAL
                                  CONTAINER  CLOSURE REQUIREMENTS
                                                                              SPECIFIES CLOSURE  REQUIREMENTS FOR CONTAINERS AND
                                                                              CONTAINMENT SYSTEM.
                                                                                                                                              PERTAINS TO ANY SITE AT WHICH HAZARDOUS  WASTE WILL BE
                                                                                                                                              STORED IN CONTAINERS.
3745-55-91      A,B,D
                                  ASSESSMENT  OF EXISTING TANK
                                  SYSTEMS  INTEGRITY
                                                             REQUIRES  THAT EACH  EXISTING TANK USED TO  STORE OR TREAT
                                                             HAZARDOUS  WASTE THAT  DOES NOT  HAVE SECONDARY CONTAINMENT
                                                             BE TESTED  TO
                                                             ASSURE  TANK INTEGRITY.
                                                                                                                     PERTAINS TO ANY  SITE WHICH  HAS  EXISTING  HAZARDOUS
                                                                                                                     WASTE  TREATMENT  OR STORAGE  TANKS THAT  LACK
                                                                                                                     SECONDARY CONTAINMENT.
                   , G
                                  DESIGN 5  INSTALLATION  OF NEW TANK
                                  SYSTEMS OR  COMPONENTS
                                                             REQUIRES  A SECONDARY  CONTAINMENT  SYSTEM FOR TANKS AND
                                                             ASSESSMENT TO DETERMINE TANK  INTEGRITY
                                                                                                                     PERTAINS TO ANY  SITE AT WHICH HAZARDOUS  WASTE WILL  BE
                                                                                                                     EITHER STORED OR TREATED  IN  TANKS.
3745-55-94
3745-55-95
A,G, I


A,B,C


A,D


A,B,C,E


A,B
                                  CONTAINMENT  AND DETECTION OF
                                  RELEASES  FOR TANK SYSTEMS
                                  GENERAL OPERATING REQUIREMENTS
                                  FOR TANK  SYSTEMS
                                  INSPECTIONS  OF TANK  SYSTEMS
                                  RESPONSE  TO LEAKS OR  SPILLS OF
                                  TANK SYSTEMS
                                  CLOSURE AND POST-CLOSURE CARE
                                  FOR TANK  SYSTEMS
                                    REQUIRES  SECONDARY CONTAINMENT AND LEAK DETECTION SYSTEMS
                                    FOR TANKS.
                                                                              SPECIFIES GENERAL OPERATING REQUIREMENTS  FOR TANK  SYSTEMS.
                                                                              REQUIRES INSPECTIONS AT LEAST ONCE EACH  OPERATING  DAY.
                                    REQUIRES  THAT UNFIT  TANKS BE REMOVED FROM USE  AND FURTHER
                                    RELEASES  BE  PREVENTED.
                                                             SPECIFIES  CLOSURE AND POST-CLOSURE REQUIREMENTS FOR TANK
                                                             SYSTEMS.
                                                                    PERTAINS TO ANY SITE AT WHICH HAZARDOUS  WASTE WILL BE
                                                                    EITHER STORED  OR TREATED  IN TANKS.
                                                                                                                     PERTAINS TO ANY  SITE AT WHICH HAZARDOUS  WASTE WILL  BE
                                                                                                                     EITHER STORED OR TREATED  IN  TANKS.
                                                                                                                                                                PERTAINS  TO ANY SITE  AT WHICH HAZARDOUS WASTE  WILL BE
                                                                                                                                                                EITHER STORED OR TREATED IN TANKS.
                                                                    PERTAINS TO ANY SITE AT WHICH HAZARDOUS  WASTE WILL BE
                                                                    EITHER STORED  OR TREATED  IN TANKS.
                                                                                                                     PERTAINS TO ANY  SITE AT WHICH HAZARDOUS  WASTE WILL  BE
                                                                                                                     EITHER STORED OR TREATED  IN  TANKS.

-------
ADMINIS.
 CODE
SECTION
                      OHIO ADMINISTRATIVE  CODE  (OAC)  ARARs
                        REILLY  TAR           TUSCARAWAS COUNTY
PERTINENT
PARAGRAPH
TITLE OR SUBJECT
 OF REGULATION
 DESCRIPTION
OF REGULATION
 APPLICATION
OF REGULATION
ARAR
TYPE
                                   TANK  REQUIREMENTS  FOR
                                   IGNITABLE/REACTIVE WASTES
                                                           PRESENTS  GENERAL PRECAUTIONS  TO BE TAKEN  TO PREVENT
                                                           ACCIDENTAL IGNITION  OR REACTION OF IGNITABLE OR REACIIVE
                                                           WASTES  THAT ARE TREATED OR STORED IN TANKS.
                                                                                                                      PERTAINS  TO ANY SITE  AT WHICH  POTENTIALLY  REACTIVE  OR
                                                                                                                      IGNITABLE WASTES ARE  STORED OR TREATED  (OR TO BE STORED
                                                                                                                      OR TREATED)  IN EXISTING TANKS.
                 A,B
                                   TANK  REQUIREMENTS  FOR
                                   INCOMPATIBLE WASTES
                                                           PRESENTS  GENERAL PRECAUTIONS  TO BE TAKEN  WHEN DEALING WITH
                                                           POTENTAILLY INCOMPATIBLE WASTES THAT ARE  STORED OR  TREATED
                                                           IN TANKS.
                                                                                                                      PERTAINS  TO ANY SITE  AT WHICH  POTENTIALLY  INCOMPATIBLE
                                                                                                                      WASTES ARE STORED  OR  TREATED  (OR TO BE  STORED OR
                                                                                                                      TREATED)  IN TANKS.
                                   DESIGN  5  OPERATING REQUIREMENTS
                                   SURFACE  IMPOUNDMENTS
                                                           PRESENTS  DESIGN AND  OPERATING  CRITERIA  FOR
                                                           IMPOUNDMENTS.
                                                                                                                      PERTAINS  TO ANY SITE  AT WHICH  HAZARDOUS WASTE WILL  BE
                                                                                                                      TREATED OR STORED  IN  SURFACE IMPOUNDMENTS  (LAGOONS).
                                                                                                                      PERTAINS  TO SITES  WHICH HAVE SURACE IMPOUNDMENTS THAT
                                                                                                                      WILL NOT  BE (OR HAVE  NOT BEEN)  CLEAN CLOSED.
                                   MONITORING f, INSPECTION OF
                                   SURFACE  IMPOUNDMENTS
                                                           REQUIRES  INSPECTION  OF LINERS  DURING CONSTRUCTION ALSO
                                                           REQUIRES  WEEKLY AND  AFTER STORM INSPECTIONS.
                                                                                                                      PERTAINS  TO ANY SITE  AT WHICH  HAZARDOUS WASTE WILL  BE
                                                                                                                      TREATED OR STORED  IN  SURFACE IMPOUNDMENTS  (LAGOONS).
                                                                                                                      PERTAINS  TO SITES  WHICH HAVE SURACE IMPOUNDMENTS THAT
                                                                                                                      WILL NOT  BE (OR HAVE  NOT BEEN)  CLEAN CLOSED.
                                   EMERGENCY REPAIRS  5  CONTINGENCY
                                   PLANS;  SURFACE  IMPOUND
                                                           SPECIFIES  WHEN AND  HOW SURFACE  IMPOUNDMENTS SHOULD  BE
                                                           REMOVED  FROM SERVICE  FOR REPAIRS.
                                                                                                                      PERTAINS  TO ANY SITE  AT WHICH  HAZARDOUS WASTE WILL  BE
                                                                                                                      TREATED OR STORED  IN  SURFACE IMPOUNDMENTS  (LAGOONS).
                                                                                                                      PERTAINS  TO SITES  WHICH HAVE SURACE IMPOUNDMENTS THAT
                                                                                                                      WILL NOT  BE (OR HAVE  NOT BEEN)  CLEAN CLOSED.
                                   CLOSURE  5  POST-CLOSURE OF  SURFACE
                                   IMPOUNDMENTS
                                                           PROVIDES  CLOSURE AND  POST-CLOSURE REQUIREMENTS FOR  SURFACE
                                                           IMPOUNDMENTS.
                                                                                                                      PERTAINS  TO ANY SITE  AT WHICH  HAZARDOUS WASTE WILL  BE
                                                                                                                      TREATED OR STORED  IN  SURFACE IMPOUNDMENTS  (LAGOONS).
                                                                                                                      PERTAINS  TO SITES  WHICH HAVE SURACE IMPOUNDMENTS THAT
                                                                                                                      WILL NOT  BE (OR HAVE  NOT BEEN)  CLEAN CLOSED.
                                   SURFACE  IMP. REQUIREMENTS  FOR
                                   IGNITABLE/REACTIVE  WASTES
                                                           PRESENTS  GENERAL PRECAUTIONS  TO BE TAKEN  WHEN DEALING WITH
                                                           POTENTAILLY IGNITABLE OR REACTIVEE WASTES  THAT ARE  STORED OR
                                                           TREATED  IN SURFACE  IMPOUNDMENTS.
                                                                                                                      PERTAINS  TO ANY SITE  AT WHICH  POTENTIALLY  IGNITABLE  OR
                                                                                                                      REACTIVE  HAZARDOUS  WASTE WILL  BE TREATED OR STORED IN
                                                                                                                      SURFACE  IMPOUNDMENTS  (LAGOONS).  PERTAINS TO SITES
                                                                                                                      WHICH HAVE SURACE  IMPOUNDMENTS  THAT WILL NOT BE  (OR
                                                                                                                      HAVE NOT  BEEN)  CLEAN  CLOSED.
                                                                                                                                                   ACTION
                                                                                                                                                   CHEMICAL
                                   SURFACE  IMPOUND  REQUIREMENTS
                                   FOR  INCOMPATIBLE  WASTES
                                                           PRESENTS  GENERAL PRECAUTIONS  TO BE TAKEN  WHEN DEALING WITH
                                                           POTENTAILLY INCOMPATIBLE WASTES THAT ARE  STORED OR  TREATED
                                                           IN SURFACE IMPOUNDMENTS.
                                                                                                                      PERTAINS  TO ANY SITE  AT WHICH  POTENTIALLY  INCOMPATIBLE
                                                                                                                      HAZARDOUS  WASTE WILL  BE TREATED OR STORED  IN SURFACE
                                                                                                                      IMPOUNDMENTS (LAGOONS).  PERTAINS TO SITES  WHICH HAVE
                                                                                                                      SURACE  IMPOUNDMENTS  THAT WILL  NOT BE  (OR HAVE NOT
                                                                                                                      BEEN) CLEAN CLOSED.
                                                                                                                                                   ACTION
                                                                                                                                                   CHEMICAL
                                   CONSTRUCTION INSPECTIONS OF
                                   SURFACE  IMPOUNDMENTS
                                                           ALLOWS  OHIO EPA OPPORTUNITY  TO  INSPECT  SURFACE
                                                           IMPOUNDMENTS DURING CONSTRUCTION AND INSTALLATION.
                                                                                                                      PERTAINS  TO ANY SITE  AT WHICH  HAZARDOUS WASTE WILL  BE
                                                                                                                      TREATED OR STORED  IN  SURFACE IMPOUNDMENTS  (LAGOONS).
                                                                                                                      PERTAINS  TO SITES  WHICH HAVE SURACE IMPOUNDMENTS THAT
                                                                                                                      WILL NOT  BE (OR HAVE  NOT BEEN)  CLEAN CLOSED.
3745-56-51
                                   DESIGN  S  OPERATING REQUIREMENTS
                                   FOR WASTE PILES
                                                           SPECIFIES  THE DESIGN  AND OPERATION REQUIREMENTS FOR  WASTE
                                                           PILES  INCLUDES LINER  SYSTEM,  LEACHATE COLLECTION AND REMOVAL
                                                           SYSTEM, WIND DISPERSAL PREVENTION AND RUN-ON/RUN-OFF
                                                           CONTROL.
                                                                                                                      PERTAINS  TO ANY SITE  AT WHICH  HAZARDOUS WASTE WILL  BE
                                                                                                                      EITHER  STORED OR TREATED IN WASTE PILES.

-------
ADMINIS.
 CODE
SECTION
                      OHIO ADMINISTRATIVE  CODE  (OAC)  ARARs
                        REILLY  TAR           TUSCARAWAS  COUNTY
PERTINENT
PARAGRAPH
TITLE OR  SUBJECT
 OF REGULATION
 DESCRIPTION
OF REGULATION
 APPLICATION
OF REGULATION
ARAR
TYPE
                 A,B


                 A,B
               MONITORING S  INSPECTION OF  WASTE
               PILES
                                   WASTE  PILE REQUIREMENTS FOR
                                   IGNITABLE/REACTIVE  WASTES
                                    WASTE  PILES MUST BE  MONITORED  DURING CONSTRUCTION OR
                                    INSTALLATION AND OPERATION.

                                    PRESENTS  GENERAL PRECAUTIONS TO BE TAKEN  WHEN DEALING WITH
                                    POTENTAILLY IGNITABLE OR REACTIVE HAZARDOUS WASTES  THAT ARE
                                    STORED OR TREATED  IN WASTE PILES.
                                                                     PERTAINS  TO ANY SITE  AT WHICH HAZARDOUS WASTE WILL BE
                                                                     EITHER STORED OR TREATED IN WASTE  PILES.

                                                                     PERTAINS  TO ANY SITE  AT WHICH POTENTIALLY  IGNITABLE OR
                                                                     REACTIVE  HAZARDOUS WASTE WILL BE  EITHER STORED OR
                                                                     TREATED IN  WASTE PILES.
                                                                                                                                                                                                                           ACTION
                                                                                                                                                                                                                           CHEMICAL
                                   WASTE  PILE REQUIREMENTS FOR
                                   INCOMPATIBLE WASTES
                                                           PRESENTS  GENERAL PRECAUTIONS  TO  BE TAKEN WHEN DEALING WITH
                                                           POTENTAILLY INCOMPATIBLE WASTES  THAT ARE STORED OR  TREATED
                                                           IN WASTE  PILES.
                                                                                                                      PERTAINS  TO ANY SITE  AT WHICH  POTENTIALLY  INCOMPATIBLE
                                                                                                                      HAZARDOUS  WASTE WILL  BE EITHER STORED OR TREATED IN
                                                                                                                      WASTE PILES.
                                                                                                                                                   ACTION
                                                                                                                                                   CHEMICAL
                                   CLOSURE  S,  POST-CLOSURE CARE  FOR
                                   WASTE  PILES
                                                           SPECIFIES  CLOSURE AND POST-CLOSURE CARE REQUIREMENTS  FOR
                                                           WASTE PILES.
                                                                                                                      PERTAINS  TO ANY SITE  AT WHICH HAZARDOUS WASTE WILL BE
                                                                                                                      EITHER STORED OR TREATED IN WASTE  PILES.
                                   CONSTRUCTION INSPECTIONS FOR
                                   WASTE  PILES
                                                           ALLOWS OHIO EPA THE  OPPORTUNITY  TO INSPECT  WASTE PILES
                                                           DURING CONSTRUCTION.
                                                                                                                      PERTAINS  TO ANY SITE  AT WHICH HAZARDOUS WASTE WILL BE
                                                                                                                      EITHER STORED OR TREATED IN WASTE  PILES.
                                   ENVIRONMENTAL PERFORMANCE
                                   STANDARDS,  LAND BASED UNITS
                                                           SPECIFIES  LOCATION,  DESIGN, CONSTRUCTION,  OPERATION,
                                                           MAINTENANCE AND CLOSURE REQUIREMENTS FOR  LANDFILLS, WASTE
                                                           PILES,  SURFACE IMPOUNDMENTS AND  UNDERGROUND INJECTION
                                                           WELLS.
                                                                                                                      PERTAINS  TO ALL STIES  THAT EITHER HAVE OR  WILL HAVE AT
                                                                                                                      LEAST ONE  OF THE FOLLOWING UNITS  ON-SITE LANDFILLS,
                                                                                                                      WASTE PILES,  SURFACE  IMPOUNDMENTS,  LAND TREATMENT
                                                                                                                      FACILITIES  AND UNDERGROUND INJECTION WELLS  (THIS
                                                                                                                      INCLUDES  EXISTING LAND-BASED AREAS  OF CONTAMINATION).
                                   LANDFILL DESIGN AND OPERATING
                                   REQUIREMENTS
                                                           PRESENTS  DESIGN AND  OPERATING  REQUIREMENTS  FOR LANDFILLS
                                                           INCLUDES  LINER, LEACHATE COLLECTION AND REMOVAL,
                                                           RUN-ON/RUN-OFF CONTROL,  ETC.
                                                                                                                      PERTAINS  TO ALL STIES  AT WHICH  A HAZARDOUS  WASTE
                                                                                                                      LANDFILL  WILL EITHER BE LOCATED OR AN EXISTING LANDFILL
                                                                                                                      WILL BE EXPANDED THIS  RULE ALSO PERTAINS  TO EXISTING
                                                                                                                      LAND BASED  AREAS OF CONTAMINATION.
                                   MONITORING AND  INSPECTIONS OF
                                   LANDFILLS
                                                           REQUIRES  INSPECTION  OF LANDFILLS  DURING CONSTRUCTION  OR
                                                           INSTALLATION AND OPERATION.
                                                                                                                      PERTAINS  TO ALL SITES  AT WHICH  A HAZARDOUS  WASTE
                                                                                                                      LANDFILL  WILL EITHER BE LOCATED OR AN EXISTING LANDFILL
                                                                                                                      WILL BE EXPANDED. THIS RULE PERTAINS TO EXISTING
                                                                                                                      LAND-BASED  AREAS OF CONTAMINATION.
                                   LANDFILL CLOSURE AND POST-CLOSURE
                                   CARE
                                                           SPECIFIES  CLOSURE AND POST-CLOSURE REQUIREMENTS FOR
                                                           HAZARDOUS  WASTE LANDFILLS INCLUDES FINAL  COVER AND
                                                           MAINTENANCE.
                                                                                                                      PERTAINS  TO ALL SITES  AT WHICH  A HAZARDOUS  WASTE
                                                                                                                      LANDFILL  WILL EITHER BE LOCATED OR AN EXISTING LANDFILL
                                                                                                                      WILL BE EXPANDED. THIS RULE PERTAINS TO EXISTING
                                                                                                                      LAND-BASED  AREAS OF CONTAMINATION.
                                   LANDFILL REQUIREMENTS FOR
                                   IGNITABLE/REACTIVE  WASTES
                                                           PROHIBITS  THE DISPOSAL OF IGNITABLE OR REACTIVE WASTE  IN A
                                                           LANDFILL,  UNLESS THE  WASTE IS  TREATED, RENDERED OR MIXED SO
                                                           THAT THE  RESULTANT MATERIAL NO LONGER MEETS  THE DEFINITION OF
                                                           IGNITABLE  OR REACTIVE WASTE.
                                                                                                                      PERTAINS  TO ALL SITES  AT WHICH  POTENTIALLY  IGNITABLE  OR
                                                                                                                      REACTIVE  HAZARDOUS WASTE MAY BE  LANDFILLED.
                                                                                                                                                   ACTION
                                                                                                                                                   CHEMICAL
                                   LANDFILL REQUIREMENTS FOR
                                   INCOMPATIBLE WASTES
                                                           PROHIBITS  THE DISPOSAL OF INCOMPATABLE WASTE IN THE  SAME CELL
                                                           OF A LANDFILL.
                                                                                                                      PERTAINS  TO ALL SITES  AT WHICH  POTENTIALLY  INCOMPATIBLE
                                                                                                                      HAZARDOUS  WASTE MAY  BE LANDFILLED.
                                                                                                                                                   ACTION
                                                                                                                                                   CHEMICAL

-------
ADMINIS.
 CODE
SECTION
                      OHIO ADMINISTRATIVE  CODE  (OAC)  ARARs
                        REILLY  TAR           TUSCARAWAS  COUNTY
PERTINENT
PARAGRAPH
TITLE OR  SUBJECT
 OF REGULATION
              DESCRIPTION
             OF  REGULATION
 APPLICATION
OF REGULATION
ARAR
TYPE
                                   LANDFILL REQUIREMENTS FOR BULK S
                                   CONTAINERIZED LIQUIDS
                                                           THE PLACEMENT OF BULK OR NON-CONTAINERIZED  LIQUID HAZARDOUS
                                                           WASTE OR  HAZARDOUS WASTES CONTAINING FREE LIQUIDS  (WHETHER
                                                           OR NOT ABSORBANTS HAVE BEEN ADDED)  IN ANY LANDFILL IS
                                                           PROHIBITED.
                                                                                                                      PERTAINS  TO  ALL SITES  AT WHICH A  LIQUID HAZARDOUS WASTE
                                                                                                                      OR HAZARDOUS WASTE CONTAINING FREE  LIQUIDS ARE
                                                                                                                      CONSIDERED FOR LANDFILLING.
                 A,B
                                   LANDFILL REQUIREMENTS FOR
                                   CONTAINERS
                                                           UNLESS THEY ARE VERY  SMALL, CONTAINERS MUST  EITHER BE  AT
                                                           LEAST 908  FULL WHEN PLACED IN  THE  LANDFILL OR
                                                           CRUSHED/SHREDDED PRIOR TO PLACEMENT IN THE LANDFILL.
                                                                                                                      PERTAINS  TO  ALL SITES  AT WHICH A  HAZARDOUS WASTE
                                                                                                                      LANDFILL  WILL EITHER BE  LOCATED OR AN EXISTING LANDFILL
                                                                                                                      WILL BE EXPANDED AND CONTAINERS ARE TO BE DISPOSED OF  IN
                                                                                                                      THE LANDFILL.
                                   DISPOSAL OF SMALL  CONTAINERS  OF
                                   HAZ WASTES IN OVERPACKS
                                                           LAB PACKS  CONTAINING  HAZARDOUS WASTE MAY BE  PLACED IN  A
                                                           LANDFILL  IF CERTAIN REQUIREMENTS  ARE MET.
                                                                                                                      PERTAINS  TO  ALL SITES  AT WHICH A  HAZARDOUS WASTE
                                                                                                                      LANDFILL  WILL EITHER BE  LOCATED OR AN EXISTING LANDFILL
                                                                                                                      WILL BE EXPANDED AND LAB PACKS ARE TO BE PLACED IN THE
                                                                                                                      LANDFILL.
                                   LANDFILL CONSTRUCTION INSPECTIONS
                                                                              ALLOWS OHIO  EPA OPPORTUNITY TO  INSPECT LANDFILL DURING
                                                                              CONSTRUCTION.
                                                                                                                                             PERTAINS TO  ALL SITES AT  WHICH A  HAZARDOUS WASTE
                                                                                                                                             LANDFILL WILL EITHER BE  LOCATED OR  AN EXISTING LANDFILL
                                                                                                                                             WILL BE EXPANDED.  THIS  RULE PERTAINS  TO EXISTING
                                                                                                                                             LAND-BASED AREAS OF CONTAMINATION.
                                   SPECIAL  REQUIREMENTS  FOR "F"
                                   WASTES  IN LANDFILLS
                                                           PROHIBITS  THE PLACEMENT OF HAZARDOUS WASTES  F020, F021,  F022
                                                           F023, F026 AND F027  IN LANDFILLS.
                                                                                                                      PERTAINS  TO  ALL SITES  AT WHICH A  HAZARDOUS WASTE
                                                                                                                      LANDFILL  WILL EITHER BE  LOCATED OR AN EXISTING LANDFILL
                                                                                                                      WILL OF EXPANDED AND F-WASTES ARE BEING CONSIDERED FOR
                                                                                                                      LANDFILLING.
                                                                                                                                                                ACTION
                                                                                                                                                                CHEMICAL
                                   WASTE ANALYSIS FOR  INCINERATORS
                                                                               REQUIRES WASTE ANALYSIS  BE PERFORMED FOR TRIAL BURN AND  FOR
                                                                               NORMAL OPERATION OF  INCINERATOR.
                                                                                                                                             PERTAINS TO  ANY ALTERNATIVE THAT WILL INCORPORATE
                                                                                                                                             INCINERATION OF HAZARDOUS  WASTES.
                                                                                                                                                                                                    CHEMICAL
                                                                                                                                                                                                    ACTION
3745-57-44
                                   PRINCIPAL ORGANIC  HAZARDOUS
                                   CONSTITUENTS; INCINERATORS
                                   PERFORMANCE STANDARDS FOR
                                   INCINERATORS
                                   INCINERATOR TRIAL  BURNS
                                   ALTERNATIVE DATA
                                                                               ESTABLISHES  METHOD BY WHICH POHCS  WILL BE SPECIFIED.
SPECIFIES PERFORMANCE STANDARDS THAT ALL INCINERATORS MUST
MEET  (DESTRUCTION  REMOVAL  EFFICIENCIES,  HCL EMISSIONS,
PARTICULATE EMISSIONS).

REQUIRES  TRIAL BURN TO DETERMINE FINAL  OPERATING  CONDITIONS.
                                                                                                                                             PERTAINS TO  ANY ALTERNATIVE THAT WILL INCORPORATE
                                                                                                                                             INCINERATION OF HAZARDOUS  WASTES.
                                                                                                                                             PERTAINS TO  ANY ALTERNATIVE THAT WILL INCORPORATE
                                                                                                                                             INCINERATION OF HAZARDOUS  WASTES.
                                                                                                                                             PERTAINS TO  ANY ALTERNATIVE THAT WILL INCORPORATE
                                                                                                                                             INCINERATION OF HAZARDOUS  WASTES.
                                                                                                                                                                                                    CHEMICAL
                                                                                                                                                                                                    ACTION
                                                                                                                                                                                                    CHEMICAL
                                                                                                                                                                                                    ACTION
                                                                                                                                                                                                    ACTION
                                                                                                                                                                                                    CHEMCIAL
3745-57-45
                                   INCINERATOR OPERATING
                                   REQUIREMENTS
                                   MONITORING AND INSPECTION OF
                                   INCINERATORS
                                                           SPECIFIES  GENERAL OPERATING REQUIREMENTS  FOR ALL
                                                           INCINERATORS.
                                                           REQUIRES  THE MONITORING OF CERTAIN PARAMETERS ON A
                                                           CONTINUOUS  BASIS AND  INSPECTIONS  OF EQUIPMENT.
                                                                                                                      PERTAINS  TO  ANY ALTERNATIVE THAT  WILL INCORPORATE
                                                                                                                      INCINERATION OF HAZARDOUS WASTES.
                                                                                                                      PERTAINS  TO  ANY ALTERNATIVE THAT  WILL INCORPORATE
                                                                                                                      INCINERATION OF HAZARDOUS WASTES.
                                                                                                                                                                ACTION
                                                                                                                                                                CHEMCIAL
                                   CLOSURE  OF INCINERATORS
                                                                               REQUIRES THAT  ALL HAZARDOUS WASTE  AND HAZARDOUS  WASTE
                                                                               RESIDUES BE  REMOVED FROM THE INCINERATOR SITE.
                                                                                                                                             PERTAINS TO  ANY ALTERNATIVE THAT WILL INCORPORATE
                                                                                                                                             INCINERATION OF HAZARDOUS  WASTES.

-------
ADMINIS.
 CODE
SECTION
                      OHIO ADMINISTRATIVE  CODE (OAC) ARARs
                        REILLY  TAR           TUSCARAWAS  COUNTY
PERTINENT
PARAGRAPH
TITLE OR  SUBJECT
 OF REGULATION
 DESCRIPTION
OF REGULATION
 APPLICATION
OF REGULATION
ARAR
TYPE
                                   ENVIRONMENTAL PERFORMANCE
                                   STANDARDS  FOR MISC UNITS
                                   MONITORING,  INSPECTING,  ANALYZING,
                                   FOR MISC  UNITS
                                                           ESTABLISHES  LOCATION,  DESIGN, CONSTRUCTION, OPERATION,
                                                           MAINTENANCE  AND CLOSURE  REQUIREMENTS  FOR MISCELLANEOUS
                                                           UNITS USED TO TREAT,  STORE OR DISPOSE OF HAZARDOUS WASTES.

                                                           REQUIRES THAT MONITORING,  ANALYSIS,  INSPECTION,  RESPONSE,
                                                           REPORTING AND CORRECTIVE ACTION BE  CONDUCTED  AS  NECESSARY
                                                           AT MISCELLANEOUS UNITS  TO ASSURE  THAT HUMAN HEALTH AND  THE
                                                           ENVIRONMENT  ARE PROTECTED.
                                                                                                                     PERTAINS TO ANY  ALTERNATIVE THAT INCORPORATES
                                                                                                                     TREATMENT, STORAGE OR DISPOSAL OF HAZARDOUS WASTES  IN
                                                                                                                     MISCELLANEOUS  UNITS.

                                                                                                                     PERTAINS TO ANY  ALTERNATIVE THAT INCORPORATES
                                                                                                                     TREATMENT, STORAGE OR DISPOSAL OF HAZARDOUS WASTES  IN
                                                                                                                     MISCELLANEOUS  UNITS.
                                                                                                                                                   ACTION
                                                                                                                                                   CHEMCIAL
                                   POST-CLOSURE CARE  FOR MISC
                                   DISPOSAL  UNITS
                                                           REQUIRES POST-CLOSURE  CARE OF MISCELLANEOUS UNITS THAT ARE
                                                           DISPOSAL UNITS AND OF  TREATMENT OR  STORAGE MISCELLANEOUS
                                                           UNITS THAT  THAT LEAVE  CONTAMINATED  SOILS OR GROUND WATER
                                                           AFTER CLOSURE.
                                                                                                                     PERTAINS TO ANY  ALTERNATIVE THAT INCORPORATES
                                                                                                                     TREATMENT, STORAGE OR DISPOSAL OF HAZARDOUS WASTES  IN
                                                                                                                     MISCELLANEOUS  UNITS.
                                   PROHIBITIONS,  HAZARDOUS WASTE
                                   BURNED  FOR ENERGY  RECOVERY
                                   STANDARDS  FOR GENERATORS OF
                                   HAZARDOUS  WASTE FUEL
                                                           DESCRIBES  THE TYPES OF  FURNACES,  BOILERS OR  CEMENT KILNS  IN
                                                           WHICH HAZARDOUS WASTE MAY BE BURNED FOR ENERGY RECOVERY.

                                                           ESTABLISHES  STANDARDS FOR GENERATORS OF HAZARDOUS WASTE
                                                           WHICH IS USED AS A FUEL OR USED TO  PRODUCE A FUEL. ALSO
                                                           ESTABLISHES  STANDARDS FOR GENERATORS WHO ARE ALSO BURNERS
                                                           OF HAZARDOUS  WASTE FUEL.
                                                                                                                     PERTAINS TO ANY  SITE WHERE  HAZARDOUS  WASTE HAS  BTU
                                                                                                                     VALUE AND MAY  BE BURNED  FOR ENERGY RECOVERY ON-SITE.
                                                                                                                     PERTAINS TO ANY  SITE WHERE  HAZARDOUS  WASTE HAS  BTU
                                                                                                                     VALUE AND MAY  BE BURNED  FOR ENERGY RECOVERY ON-SITE.
3745-58-46
                 A,C,D,E


                 C,E


                 A,B
               STANDARDS APPLICABLE TO BURNERS
               OF HAZARDOUS WASTE  FUEL
               HAZARD  WASTES RESTRICTED FROM
               LAND  DISPOSAL-EXCEPTIONS
                                   DILUTION  PROHIBITED  AS A SUBSTITUTE
                                   FOR TREATMENT
                                    SPECIFIES  THE OPERATING REQUIREMENTS FOR  INDUSTRIAL FURNACES
                                    AND BOILERS  THAT BURN  HAZARDOUS WASTE FUEL.

                                    LISTS TYPE OF RESTRICTED WASTES THAT MAY  BE  LAND DISPOSED
                                    LISTS TYPE OF HAZARDOUS WASTES NOT SUBJECT TO LDRs.

                                    PROHIBITS  DILUTION OF  A RESTRICTED WASTE  OR  THE RESIDUAL FROM
                                    TREATMENT  OF A RESTRICTED WASTE AS A SUBSTITUTE FOR
                                    ADEQUATE TREATMENT IN  ORDER TO LAND DISPOSE  HAZARDOUS
                                    WASTE. DILUTION OF WATER WASTES IS NOT IMPERMISSIBLE DILUTION
                                    UNLESS A METHOD HAS  BEEN SPECIFIED AS A TREATMENT STANDARD.
                                                                     PERTAINS TO ANY SITE WHERE HAZARDOUS  WASTE HAS  BTU
                                                                     VALUE AND MAY  BE BURNED  FOR ENERGY  RECOVERY ON-SITE.
                                                                     PERTAINS TO ANY ALTERNATIVE THAT  INCORPORATES  DISPOSAL
                                                                     OF  HAZARDOUS  WASTES ON-SITE.
                                                                                                                                            PERTAINS TO ANY  ALTERNATIVE  THAT INCORPORATES DISPOSAL
                                                                                                                                            OF HAZARDOUS WASTE ON-SITE.
3745-59-04
                                   TREATMENT  SURFACE  IMPOUNDMENT
                                   EXEMPTION
                                                           WASTES PROHIBITED FROM  LAND DISPOSAL MAY BE  TREATED IN A
                                                           SURFACE IMPOUNDMENT PROVIDED THAT  THE CONDIDTIONS STATED  IN
                                                           PARAGRAPH A  ARE MET.
                                                                                                                     PERTAINS TO ANY  SITE AT WHICH ON-SITE  HAZARDOUS WASTES
                                                                                                                     WILL BE TREATED  IN A SURFACE IMPOUNDMENT.
                                   WASTE ANALYSIS OF HAZARDOUS
                                   WASTE
                                                           GENERATOR  SHALL TEST  THE  WASTE OR  TEST AN EXTRACT OF THE
                                                           WASTE ACCORDING TO THE  FREQUENCY AND TEST METHODS
                                                           DESCRIBED  IN  THE RULES,  TO DETERMINE IF THE WASTE IS RESTRICTED
                                                           FROM LAND  DISPOSAL.
                                                                                                                     PERTAINS TO AN  ALTERNATIVE  THAT INCORPORATES DISPOSAL
                                                                                                                     OF  HAZARDOUS WASTE ON-SITE.
                                   SPECIAL  RULES REGARDING WASTE
                                   THAT EXHIBIT A CHARACTERISTIC
                                                           PROHIBITS  LAND DISPOSAL  OF CHARACTERISTIC WASTE  UNLESS  THE
                                                           WASTE COMPLIES WITH THE  TREATMENT  STANDARDS OF  LISTED
                                                           WASTES IF  THE WASTE IS BOTH LISTED AND EXHIBITS  A
                                                           CHARACTERISTIC,  THE TREATMENT STANDARD FOR THE  LISTED WASTE
                                                           WILL OPERATE  IN LIEU OF  THE STANDARD FOR THE  CHARACTERISTIC
                                                           WASTE.
                                                                                                                     PERTAINS TO ANY  SITE IN WHICH ON-SITE  DISPOSAL  OF
                                                                                                                     HAZARDOUS WASTE  IS AN ALTERNATIVE.
                                                                                                                                                   ACTION
                                                                                                                                                   CHEMICAL

-------
ADMINIS.
 CODE
SECTION
                      OHIO ADMINISTRATIVE CODE  (OAC)  ARARs
                        REILLY TAR           TUSCARAWAS COUNTY
PERTINENT
PARAGRAPH
TITLE OR  SUBJECT
 OF REGULATION
 DESCRIPTION
OF REGULATION
 APPLICATION
OF REGULATION
ARAR
TYPE
3745-59-41
                 A,B,C,D
                 A,D,E,F
                                  WASTE SPECIFIC  PROHIBITIONS
                                  DIOXIN WASTE  PROHIBITIONS
                                   CALIFORNIA LIST  WASTES PROHIBITIONS
                 A,B,C,D,E,F,G  FIRST THIRD WASTES  PROHIBITIONS


                 A,H





                 A,B,C
              SECOND THIRD WASTES PROHIBITIONS
              THIRD THIRD WASTES PROHIBITIONS
                                 APPLICABILITY OF  TREATMENT
                                 STANDARDS
                                 TREATMENT STANDARDS AS
                                 CONCENTRATIONS  IN WASTE EXTRACTS
                                 TREATMENT STANDARDS EXPRESSED
                                 AS  SPECIFIED TECHNOLOGIES
                                   PROHIBITS SPENT  SOLVENT WASTES  OR CONTAMINATED SOIL AND
                                   DEBRIS RESULTING FROM A RESPONSE ACTION UNDER CERCLA OR  RCRA
                                   TO  BE LAND DISPOSED UNLESS GENERATOR MEETS  TREATMENT
                                   STANDARDS (3745-59-40 TO 44)  OR HAS BEEN GRANTED AN EXTENSION
                                   OR  EXEMPTION.

                                   PROHIBITS ON-SITE DISPOSAL OF DIOXIN WASTE  UNLESS IT MEETS
                                   TREATEMENT STANDARDS OF RULES 3745-59-40 TO 44 OR THE
                                   GENERATOR HAS BEEN GRANTED AN EXTENSION OR  EXEMPTION.

                                   PROHIBITS LAND DISPOSAL OF FOLLOWING WASTES:
                                   1.  LIQUID WASTES WITH PH <2 OR  PH = 2
                                   2.  LIQUID WASTES CONTAINING PCBs WITH CONC  = 50 OR CONC  >  50
                                   PPM
                                   3.  LIQUID WASTES WITH HALOGENATED ORGANIC LOADING OF > OR  =
                                   1000mg/l AND LESS THAN 10,000 mg/1.

                                   PROHIBITS ON-SITE LAND DISPOSAL OF FIRST THIRD WASTES UNLESS
                                   REQUIREMENTS OF  PARAGRAPHS D,E,F,G ARE MET.

                                   PROHIBITS ON-SITE LAND DISPOSAL OF SECOND THIRD WASTES UNLESS
                                   REQUIREMENTS OF  PARAGRAPHS D,E,F,G ARE MET.

                                   PROHIBITS ON-SITE LAND DISPOSAL OF THIRD THIRD WASTES UNLESS
                                   REQUIREMENTS OF  PARAGRAPHS D,E,F,G ARE MET.

                                   PROHIBITS ON-SITE LAND DISPOSAL OF RESTRICTED WASTE UNLESS
                                   THE WASTE IS TESTED USING TEST  METHOD IN THE APPENDIX TO RULE
                                   OAC 3745-21-24 OR THIS RULE AND THE CONCENTRATION OF ANY
                                   HAZARDOUS CONSITUENT DOES NOT EXCEED THE CONCENTRATION
                                   SHOWN IN TABLE CCWE OF RULE 3745-59-41 OR TABLE CCW OF RULE
                                   3745-59-43.  A WASTE TREATED USING A TECHNOLOGY SPECIFIED
                                   UNDER RULE 3745-59-42 OR EQUIVALENT MAY BE  LAND DISPOSED.

                                   RESTRICTED WASTE SHOULD BE TREATED TO CONCENTRATION LEVELS
                                   SPECIFIED IN THIS RULE USING  TEST METHOD IN THE APPENDIX TO RULE
                                   3745-51-24 OR THE APPENDIX TO RULE 3745-59-40.

                                   ESTABLISHES TREATMENT STANDARDS FOR LIQUID  HAZARDOUS WASTE
                                   CONTAINING PCBs,  NON-LIQUID HAZARDOUS WASTE CONTAINING
                                   HALOGENATED ORGANIC COMPOUNDS (HOCs)  AND LAB PACKS
                                   RADIOACTIVE HAZARDOUS MIXED WASTES ARE NOT  SUBJECT TO
                                   TREATMENT STANDARDS.
                                                                                                                                                              PERTAINS  TO ANY SITE  IN WHICH ON-SITE LAND DISPOSAL OF
                                                                                                                                                              HAZARDOUS WASTE IS AN ALTERNATIVE.
                                                                                                                                                              PERTAINS  TO ANY SITE  IN WHICH ON-SITE LAND DISPOSAL OF
                                                                                                                                                              DIOXIN  WASTE IS AN ALTERNATIVE.
                                                                                                                                                              PERTAINS  TO ANY SITE  IN WHICH ON-SITE LAND DISPOSAL OF
                                                                                                                                                              PCB OR  HOC CONTAMINATED WASTE IS  AN ALTERNATIVE.
                                                                                                                                           PERTAINS TO ANY SITE IN WHICH ON-SITE LAND DISPOSAL OF
                                                                                                                                           FIRST THIRD HAZARDOUS WASTES  IS AN ALTERNATIVE.
                                                                                                                                           PERTAINS TO ANY SITE IN WHICH ON-SITE LAND DISPOSAL OF
                                                                                                                                           SECOND THIRD  HAZARDOUS WASTES IS AN ALTERNATIVE.
                                                                                                                                           PERTAINS TO ANY SITE IN WHICH ON-SITE LAND DISPOSAL OF
                                                                                                                                           THIRD THIRD HAZARDOUS WASTES  IS AN ALTERNATIVE.
                                                                                                                                           PERTAINS TO ANY SITE IN WHICH ON-SITE LAND DISPOSAL OF
                                                                                                                                           RESTRICTED WASTE MAY BE AN  ALTERNATIVE.
                                                                                                                                           PERTAINS TO ANY SITE IN WHICH ON-SITE LAND DISPOSAL OF
                                                                                                                                           RESTRICTED WASTE IS AN ALTERNATIVE.
                                                                                                                                           PERTAINS TO ANY SITE IN WHICH ON-SITE TREATMENT AND
                                                                                                                                           DISPOSAL OF HAZARDOUS WASTE  CONTAINING  EITHER PCB
                                                                                                                                           LIQUID WASTE  OR HOC NON-LIQUID WASTE MIGHT  TAKE PLACE.
                                                                                                                                                                                                                        ACTION
                                                                                                                                                                                                                        CHEMICAL
                                                                                                                                                                                                                        CHEMICAL
                                                                                                                                                                                                                        ACTION
                                                                                                                                                                                                                        CHEMICAL
                                                                                                                                                                                                                        ACTION
                                                                                                                                                 CHEMICAL
                                                                                                                                                 ACTION
                                                                                                                                                 CHEMICAL
                                                                                                                                                 ACTION
                                                                                                                                                 CHEMICAL
                                                                                                                                                 ACTION
                                                                                                                                                 CHEMICAL
                                                                                                                                                 ACTION
                                                                                                                                                 ACTION
                                                                                                                                                 CHEMICAL
 3745-59-43     A,B,C
                                                                              IDENTIFIES THE  RESTRICTED WASTES AND THE  CONCENTRATIONS  OF
                                                                              THEIR ASSOCIATED HAZARDOUS  CONSITUENTS WHICH MAY NOT BE
                                                                              EXCEEDED BY THE  WASTE OR TREATMENT RESIDUAL FOR THE
                                                                              ALLOWABLE LAND  DISPOSAL OF  SUCH WASTE OR  RESIDUAL.
                                                                                                                                           PERTAINS TO ANY SITE IN WHICH ON-SITE TREATMENT AND
                                                                                                                                           DISPOSAL OF RESTRICTED WASTE  IS AN ALTERNATIVE.

-------
ADMINIS.
 CODE
SECTION
                      OHIO ADMINISTRATIVE  CODE  (OAC)  ARARs
                        REILLY  TAR           TUSCARAWAS  COUNTY
PERTINENT
PARAGRAPH
TITLE OR  SUBJECT
 OF REGULATION
 DESCRIPTION
OF REGULATION
 APPLICATION
OF REGULATION
ARAR
TYPE
                 A,B,C,D,E
                                   PROHIBITION ON STORAGE OF
                                   RESTRICTED WASTE
                                                           PROHIBITS  ON-SITE STORAGE OF HAZARDOUS WASTES  RESTRICTED
                                                           FROM LAND  DISPOSAL BEYOND A SPECIFIED TIME  FRAME STATED  IN
                                                           THE RULE.
                                                                                                                      PERTAINS TO  ANY SITE  IN  WHICH STORAGE OF HAZARDOUS
                                                                                                                      WASTE WILL OCCUR ON-SITE TO FACILITATE PROPER  RECOVERY.
                                                                                                                      TREATMENT OR DISPOSAL  IN SOME CASES  STORAGE  OF
                                                                                                                      RESTRICTED WASTES BEYOND ONE YEAR  IS ALLOWED.
                 A,B
                                   CLOSURE  PERFORMANCE  STANDARD
                                                                              OWNER SHALL  CLOSE FACILITY IN MANNER THAT MINIMIZES NEED  FOR
                                                                              FURTHER MAINTENANCE AND  REDUCES OR  ELIMINATES  POLLUTION OF
                                                                              GROUND WATER,  SURFACE WATER OR ATMOSHPERE.
                                                                                                                                            CONSIDER FOR  REMEDIAL PLANS THAT MAY  REQUIRE  EXTENDED
                                                                                                                                            OPERATION AND MAINTENANCE  OF EQUIPMENT.  CONSIDER
                                                                                                                                            ALTERNATIVES  WITH LESS  LONG TERM OSM.  APPLICABLE FOR
                                                                                                                                            RCRA FACILITIES,  APPROPRIATE AND RELEVANT FOR OTHER
                                                                                                                                            SITES.
3745-81-11
                                   AMBIENT  AIR QUALITY  STANDARDS  -
                                   LEAD
                                   MAXIMUM  CONTAMINANT  LEVELS FOR
                                   INORGANIC CHEMICALS
                                                           THE AMBIENT  QUALITY  STANDARD FOR  LEAD SHALL  BE A MAXIMUM
                                                           ARITHMETIC MEAN OF 1.5  MICROGRAMS  PER CUBIC  METER DURING ANY
                                                           CALENDAR  QUARTER.

                                                           PRESENTS  MAXIMUM CONTAMINANT LEVELS FOR INORGANICS.
                                                                                                                      CONSIDER FOR SITES WHERE  INCINERATION OR WASTE  FUEL
                                                                                                                      RECOVERY MAY TAKE PLACE.
                                                                                                                                            PERTAINS TO ANY SITE WHICH HAS CONTAMINATED GROUND OR
                                                                                                                                            SURFACE WATER THAT IS EITHER BEING USED, OR HAS  THE
                                                                                                                                            POTENTIAL FOR USE, AS A  DRINKING WATER SOURCE.
                 A,E
                                   MAXIMUM  CONTAMINANT  LEVELS FOR
                                   ORGANIC  CHEMICALS
                                   MAXIMUM  CONTAMINANT  LEVELS FOR
                                   TURBIDITY
                                   MAXIMUM  MICROBIOLOGICAL
                                   CONTAMINANT LEVELS
                                   MICROBIOLOGICAL CONTAMINANT
                                   SAMPLING S ANALYTICAL REQ
                                   TUBIDITY  CONTAMINANT  SAMPLING  S,
                                   ANALYTICAL REQUIREMENTS
                                   INORGANIC CONTAMINANT MONITORING
                                   REQUIREMNENTS
                                                                               PRESENTS MCLS  FOR ORGANICS.
                                                                               PRESENTS MCLS  FOR TURBIDITY.
                                                                               PRESENTS MCLS  FOR MICROBIOLOGICAL  CONTAMINANTS.
                                                           PRESENTS  SAMPLING AND  ANALYTICAL  REQUIREMENTS  FOR
                                                           MICROBIOLOGICAL CONTAMINANTS.
                                                                               PRESENTS SAMPLING AND ANALYTICAL  REQUIREMENTS  FOR TURBIDITY
                                                           PRESENTS MONITORING  REQUIREMENTS  FOR INORGANIC
                                                           CONTAMINANTS.
                                                                                                                      PERTAINS TO  ANY SITE WHICH HAS CONTAMINATED  GROUND OR
                                                                                                                      SURFACE WATER THAT IS  EITHER BEING USED, OR  HAS  THE
                                                                                                                      POTENTIAL  FOR USE, AS  A DRINKING WATER SOURCE.

                                                                                                                      PERTAINS TO  ANY SITE WHICH HAS CONTAMINATED  GROUND OR
                                                                                                                      SURFACE WATER THAT IS  EITHER BEING USED, OR  HAS  THE
                                                                                                                      POTENTIAL  FOR USE, AS  A DRINKING WATER SOURCE.

                                                                                                                      PERTAINS TO  ANY SITE WHICH HAS CONTAMINATED  GROUND OR
                                                                                                                      SURFACE WATER THAT IS  EITHER BEING USED, OR  HAS  THE
                                                                                                                      POTENTIAL  FOR USE, AS  A DRINKING WATER SOURCE.

                                                                                                                      PERTAINS TO  ANY SITE WHICH HAS CONTAMINATED  GROUND OR
                                                                                                                      SURFACE WATER THAT IS  EITHER BEING USED, OR  HAS  THE
                                                                                                                      POTENTIAL  FOR USE, AS  A DRINKING WATER SOURCE.

                                                                                                                      PERTAINS TO  ANY SITE WHICH HAS CONTAMINATED  GROUND OR
                                                                                                                      SURFACE WATER THAT IS  EITHER BEING USED, OR  HAS  THE
                                                                                                                      POTENTIAL  FOR USE, AS  A DRINKING WATER SOURCE.

                                                                                                                      PERTAINS TO  ANY SITE WHICH HAS CONTAMINATED  GROUND OR
                                                                                                                      SURFACE WATER THAT IS  EITHER BEING USED, OR  HAS  THE
                                                                                                                      POTENTIAL  FOR USE, AS  A DRINKING WATER SOURCE.
                 A,E
                 A,E
                                   ANALYTICAL TECHNIQUES
                                                                               PRESENTS MONITORING REQUIREMENTS  FOR ORGANIC  CONTAMINANTS.
                                                                               PRESENTS GENERAL ANALYTICAL TECHNIQUES FOR MCLS.
                                                                                                                                            PERTAINS TO ANY SITE WHICH HAS CONTAMINATED GROUND OR
                                                                                                                                            SURFACE WATER THAT IS EITHER BEING USED, OR HAS  THE
                                                                                                                                            POTENTIAL FOR USE, AS A  DRINKING WATER SOURCE.

                                                                                                                                            PERTAINS TO ANY SITE WHICH HAS CONTAMINATED GROUND OR
                                                                                                                                            SURFACE WATER THAT IS EITHER BEING USED, OR HAS  THE
                                                                                                                                            POTENTIAL FOR USE, AS A  DRINKING WATER SOURCE.

-------
ADMINIS.
 CODE
SECTION
                      OHIO ADMINISTRATIVE  CODE  (OAC)  ARARs
                        REILLY  TAR           TUSCARAWAS COUNTY
PERTINENT
PARAGRAPH
TITLE OR SUBJECT
 OF REGULATION
 DESCRIPTION
OF REGULATION
 APPLICATION
OF REGULATION
ARAR
TYPE
3745-81-71
                                   REQUIREMENTS FOR  A VARIANCE  FROM
                                   MCLS
                                   ALTERNATIVE TREATMENT TECHNIQUE
                                   VARIANCE
                                   SANITARY SURVEYS
                                   GEN REQ  FOR FILTRATION S
                                   DISINFECTION FOR  SURFACE WATER
                                   DISINFECTION OF WATER FROM
                                   SURFACE  WATER SOURCES
                                   FILTRATION OF WATER FROM SURFACE
                                   WATER  SOURCES
                                   TURBIDITY AND DISINFECTION MONIT
                                   REQ.  FOR SURFACE  WATER
                                   LOCATION/SITING OF  NEW GW WELLS
                                                           PROVIDES  CRITERIA  BY  WHICH DIRECTOR MAY  GRANT VARIANCE FROM
                                                           MCLS.
                                                           ALLOWS  FOR THE USE  OF ALTERNATIVE TREATMENT TECHNIQUES TO
                                                           ATTAIN  MCLS.
                                                                               SANITARY  SURVEY REQUIREMENTS FOR SITES WHICH DO NOT  COLLECT
                                                                               FIVE OR MORE ROUTINE  TOTAL COLIFORM SAMPLES  PER MONTH.
                                                           TREATMENT  STANDARDS  FOR GIARDIA LAMBLIA,  VIRUSES,
                                                           HETEROTROPHIC PLATE  COUNT BACTERIA, LEGIONELLA, TURBIDITY.
                                                                               DISINFECTION REQUIREMENTS AND  TREATMENT OF  SURFACE WATER.
                                                           CONVENTIONAL FILTRATION, SLOW  SAND FILTRATION, OR OTHER
                                                           FILTRATION TREATMENT  TECHNOLOGIES FOR TREATMENT OF  SURFACE
                                                           WATER.

                                                           TURBIDITY  AND DISINFECTION MONITORING REQUIREMENTS  FOR
                                                           SURFACE WATER SYSTEMS.
                                                                               MANDATES  THAT GROUND  WATER WELLS  BE:
                                                                               A)  LOCATED  AND MAINTAINED SO AS  TO PREVENT  CONTAMINANTS
                                                                               FROM ENTERING WELL.
                                                                               B)  LOCATED  SO AS TO BE ACCESSIBLE FOR CLEANING AND
                                                                               MAINTENANCE.
                                                                                                                      PERTAINS  TO ANY SITE  WHICH HAS  CONTAMINATED GROUND  OR
                                                                                                                      SURFACE WATER THAT  IS EITHER BEING USED,  OR HAS THE
                                                                                                                      POTENTIAL FOR USE,  AS A DRINKING WATER  SOURCE.

                                                                                                                      PERTAINS  TO ANY SITE  WHICH HAS  CONTAMINATED GROUND  OR
                                                                                                                      SURFACE WATER THAT  IS EITHER BEING USED,  OR HAS THE
                                                                                                                      POTENTIAL FOR USE,  AS A DRINKING WATER  SOURCE.

                                                                                                                      PERTAINS  TO ANY SITE  WHICH HAS  CONTAMINATED GROUND  OR
                                                                                                                      SURFACE WATER THAT  IS EITHER BEING USED,  OR HAS THE
                                                                                                                      POTENTIAL FOR USE,  AS A DRINKING WATER  SOURCE.

                                                                                                                      PERTAINS  TO ANY SITE  WHICH HAS  CONTAMINATED SURFACE
                                                                                                                      WATER THAT IS EITHER  BEING USED,  OR HAS  THE POTENTIAL FOR
                                                                                                                      USE, AS A DRINKING  WATER SOURCE.

                                                                                                                      PERTAINS  TO ANY SITE  WHICH HAS  CONTAMINATED SURFACE
                                                                                                                      WATER THAT IS EITHER  BEING USED,  OR HAS  THE POTENTIAL
                                                                                                                      FOR USE,  AS A DRINKING WATER SOURCE.

                                                                                                                      PERTAINS  TO ANY SITE  WHICH HAS  CONTAMINATED SURFACE
                                                                                                                      WATER THAT IS EITHER  BEING USED,  OR HAS  THE POTENTIAL FOR
                                                                                                                      USE, AS A DRINKING  WATER SOURCE.

                                                                                                                      PERTAINS  TO ANY SITE  WHICH HAS  CONTAMINATED SURFACE
                                                                                                                      WATER THAT IS EITHER  BEING USED,  OR HAS  THE POTENTIAL FOR
                                                                                                                      USE, AS A DRINKING  WATER SOURCE.

                                                                                                                      PERTAINS  TO ALL GROUND WATER WELLS ON THE SITE THAT
                                                                                                                      EITHER WILL BE INSTALLED OR HAVE BEEN INSTALLED SINCE FEB.
                                                                                                                      15, 1975,  WOULD PERTAIN DURING  THE FS IF  NEW WELLS  ARE
                                                                                                                      CONSTRUCTED FOR TREATABILITY STUDIES.
                                                                                                                                                                                                                           CHEMICAL
                                                                                                                                                                                                                           ACTION
                                                                                                                                                   ACTION
                                                                                                                                                   CHEMICAL
                                                                                                                                                                                                                           ACTION
                                                                                                                                                                                                                           CHEMICAL
                                                                                                                                                                                                                           LOCATION
                                                                                                                                                                                                                           ACTION
                 A1,B-H
                 A,B,D,E
                                   CASING  REQUIREMENTS  FOR NEW  GW
                                   WELLS
                                                           SPECIFIES  MINIMUM  CONSTRUCTION  REQUIREMENTS FOR NEW  GROUND
                                                           WATER WELLS IN REGARDS TO CASING MATERIAL,  CASING DEPTH,
                                                           POTABLE WATER, ANNULAR SPACES,  USE OF DRIVE SHOE, OPENINGS
                                                           TO ALLOW WATER ENTRY,  CONTAMINANT ENTRY.

                                                           ESTABLISHES SPECIFIC  REQUIREMENTS FOR WELL  CASINGS,  SUCH AS
                                                           SUITABLE MATERIAL,  DIAMETERS AND CONDITION.
                                                                                                                      PERTAINS  TO ALL GROUND WATER WELLS ON THE  SITE THAT
                                                                                                                      EITHER WILL BE INSTALLED OR HAVE BEEN INSTALLED SINCE  FEB.
                                                                                                                      15, 1975,  WOULD PERTAIN DURING  THE FS IF NEW WELLS ARE
                                                                                                                      CONSTRUCTED FOR TREATABILITY STUDIES.

                                                                                                                      PERTAINS  TO ALL GROUND WATER WELLS ON THE  SITE THAT
                                                                                                                      EITHER WILL BE INSTALLED OR HAVE BEEN INSTALLED SINCE  FEB.
                                                                                                                      15, 1975,  WOULD PERTAIN DURING  THE FS IF NEW WELLS ARE
                                                                                                                      CONSTRUCTED FOR TREATABILITY STUDIES.
                                   SURFACE  DESIGN OF  NEW GW WELLS
                                                                               ESTABLISHES  SPECIFIC  SURFACE DESIGN REQUIREMENTS, SUCH AS
                                                                               HEIGHT ABOVE GROUND,  WELL VENTS,  WELL PUMPS.  ETC.
                                                                                                                                             PERTAINS  TO ALL GROUND WATER WELLS ON THE  SITE THAT
                                                                                                                                             EITHER WILL BE INSTALLED OR HAVE  BEEN INSTALLED SINCE  FEB.
                                                                                                                                             15, 1975,  WOULD PERTAIN DURING  THE FS IF NEW WELLS ARE
                                                                                                                                             CONSTRUCTED FOR TREATABILITY STUDIES.

-------
ADMINIS.
 CODE
SECTION
                      OHIO ADMINISTRATIVE CODE  (  OAC)  ARARs
                        REILLY TAR           TUSCARAWAS COUNTY
PERTINENT
PARAGRAPH
TITLE OR SUBJECT
 OF REGULATION
 DESCRIPTION
OF REGULATION
 APPLICATION
OF REGULATION
ARAR
TYPE
                                   START  UP S OPERATION OF GW  WELLS
                                                                               REQUIRE  DISINFECTION OF NEW  WELLS AND USE OF POTABLE WATER
                                                                               FOR PRIMING PUMPS.
                                                                                                                                             PERTAINS TO ALL  GROUND WATER WELLS ON  THE SITE  THAT
                                                                                                                                             EITHER WILL BE  INSTALLED  OR HAVE BEEN  INSTALLED SINCE FEB.
                                                                                                                                             15,  1975,  WOULD  PERTAIN DURING THE FS  IF NEW WELLS ARE
                                                                                                                                             CONSTRUCTED FOR  TREATABILITY STUDIES.
                 A,C,D1,E-G
                                   MAINTENANCE f, OPERATION OF  GW
                                   WELLS
                                                           ESTABLISHES SPECIFIC MAINTENANCE AND MODIFICATION
                                                           REQUIREMENTS FOR  CASING, PUMP AND WELLS  IN GENERAL.
                                                                                                                      PERTAINS TO ALL  GROUND WATER WELLS ON  THE SITE  THAT
                                                                                                                      EITHER WILL BE  INSTALLED  OR HAVE BEEN  INSTALLED SINCE FEB.
                                                                                                                      15,  1975,  WOULD  PERTAIN DURING THE FS  IF NEW WELLS ARE
                                                                                                                      CONSTRUCTED FOR  TAEATABILITY STUDIES.
3745-9-11
                                   ABANDONMENT OF  TEST HOLES  S,  GW
                                   WELLS
                                   USE OF  WELLS FOR DISPOSAL
                                                           FOLLOWING COMPLETION OF USE,  WELLS AND  TEST HOLES  SHALL BE
                                                           COMPLETELY FILLED  WITH GROUT  OR SIMILAR MATERIAL  OR SHALL BE
                                                           MAINTAINED IN COMPLIANCE OF ALL REGULATIONS.

                                                           NO PERSON SHALL USE ANY WELL  TO INJECT  OR REINJECT ANY
                                                           SUBSTANCE INTO THE GROUND WITHOUT NECESSARY PERMITS.
                                                                                                                      PERTAINS TO ALL  GROUND WATER WELLS ON  THE SITE  THAT
                                                                                                                      EITHER WILL BE  INSTALLED  OR HAVE BEEN  INSTALLED SINCE FEB.
                                                                                                                      15,  1975.

                                                                                                                      MAY  PERTAIN TO  SYSTEMS THAT ENTAIL INJECTION OR
                                                                                                                      REINJECTION OF  FLUID INTO THE GROUND.  CONSIDER  FOR IN-SITU
                                                                                                                      BIOREMEDIATION,  SOIL FLUSHING AND GROUND WATER  PLUME
                                                                                                                      CONTAINMENT.

-------
ADMINIS.
 CODE
SECTION
                     OHIO  REVISED CODE  (ORC) ARARs
                       REILLY  TAR           TUSCARAWAS COUNTY
PERTINENT
PARAGRAPH
TITLE OR SUBJECT
 OF REGULATION
 DESCRIPTION
OF REGULATION
 APPLICATION
OF REGULATION
ARAR
TYPE
                                  ENDANGERED  PLANT SPECIES
                                  PROHIBITS VIOLATION OF AIR POLLUTION
                                  CONTROL RULES
                                                            PROHIBITS  EMISSION OF AN AIR  CONTAMINANT IN VIOLATION SEC.
                                                            3704 OR ANY RULES, PERMIT,  ORDER OR VARIANCE  ISSUED
                                                            PURSUANT TO THAT SECTION OF THE ORC.
                                                                                                                     Applies to  remediatiON-SITEs  where chemicals may harm endangered
                                                                                                                     species.  Clearly establishes  that receptor plant species must be
                                                                                                                     considered  in risk assessments.  This act may require consideration of
                                                                                                                     endangered  species in remediations that involve  movement or
                                                                                                                     displacement  of large volumes of surface soil.

                                                                                                                     MAY PERTAIN TO ANY SITE WHERE EMISSIONS OF AN AIR
                                                                                                                     CONTAMINANT OCCURS EITHER AS  A PRE-EXISTING CONDITION OF
                                                                                                                     THE SITE  OR AS A RESULT OF  REMEDIAL ACTIVITIES  SHOULD OF
                                                                                                                     CONSIDERED  FOR VIRTUALLY ALL  SITES.
                                                                                                                                                    CHEMICAL
                                                                                                                                                    ACTION
                                  DEMOLITION DEBRIS  FACILITIES-VIOLATIONS
                                  PROHIBITED
                                                            PROHIBITS  VIOLATIONS OF ANY  SECTION OF CHAPTER  3714
                                                            CONCERNING CONSTRUCTION AND  DEMOLITION DEBRIS DISPOSAL
                                                            FACILITIES OR ANY RULE OR  ORDER ISSUED PURSUANT TO IT.
                                                            DISPOSAL OF ASBESTOS IS SPECIFICALLY PROHIBITED WITHOUT
                                                            AUTHORIZATION.
                                                                                                                     PERTAINS  TO  CONSTRUCTION AND  DEMOLITION DEBRIS  FACILITIES
                                                                                                                     WHERE HAZARDOUS WASTE OR HAZARDOUS CONSTITUENTS  HAVE
                                                                                                                     COME TO BE LOCATED. CONSIDER  FOR SITES WHERE  REMEDIAL
                                                                                                                     ACTION WILL  INCLUDE DEMOLITION  OF STRUCTURES  OR  ASBESTOS
                                                                                                                     HAS COME  TO  BE LOCATED.
                                  EXEMPTIONS  TO  SOLID 5 HAZ. WASTE  T/S/D
                                  REQUIREMENTS
                                  "DIGGING" WHERE  HAZ OR SOLID WASTE
                                  FACILITY WAS  LOCATED
                                                            PROVIDES AUTHORITY AND CONDITIONS BY WHICH THE  DIRECTOR
                                                            MAY EXEMPT  ANY PERSON FROM  PERMITTING OR OTHER
                                                            REQUIREMENTS  GOVERNING THE  GENERATION, STORAGE,
                                                            TREATMENT,  TRANSPORT OR DISPOSAL OF SOLID OR HAZARDOUS
                                                            WASTE.
                                                            FILLING,  GRADING,  EXCAVATING,  BUILDING, DRILLING OR MINING ON
                                                            LAND WHERE  HAZARDOUS WASTE  OR  SOLID WASTE FACILITY WAS
                                                            OPERATED  IS PROHIBITED WITHOUT PRIOR AUTHORIZATION FROM
                                                            THE DIRECTOR OF THE OHIO EPA.
                                                                                                                     PERTAINS  TO  ANY SITE AT WHICH  SOLID OR HAZARDOUS  WASTE
                                                                                                                     HAS COME  TO  BE LOCATED. CERTAIN ALTERNATIVES  INCLUDE
                                                                                                                     EXCAVATION ACTIVITIES WHICH  MAY UNCOVER SOLID AND/OR
                                                                                                                     HAZARDOUS WASTE.  SHOULD THOSE  ACTIVITIES REQUIRE  THE
                                                                                                                     MANAGEMENT OF SOLID/HAZARDOUS  WASTES ON-SITE,  AN
                                                                                                                     EXEMPTION TO PERMITTING AND  OTHER REQUIREMENTS  MAY BE
                                                                                                                     WARRANTED.

                                                                                                                     PERTAINS  TO  ANY SITE AT WHICH  HAZARDOUS OR SOLID  WASTE
                                                                                                                     HAS COME  TO  BE LOCATED CERTAIN ALTERNATIVES  INCLUDE
                                                                                                                     EXCAVATION ACTIVITIES WHICH  MAY UNCOVER SOLID AND/OR
                                                                                                                     HAZARDOUS WASTE.  SHOULD THOSE  ACTIVITIES REQUIRE  THE
                                                                                                                     MANAGEMENT OF SOLID/HAZARDOUS  WASTES ON-SITE,  AN
                                                                                                                     EXEMPTION TO PERMITTING AND  OTHER REQUIREMENTS  MAY BE
                                                                                                                     WARRANTED.
                                                                                                                                                    LOCATION
                                                                                                                                                    ACTION
                                  AIR EMISSIONS  FROM HAZARDOUS WASTE
                                  FACILITIES
                                                            NO HAZARDOUS  WASTE FACILITY  SHALL EMIT ANY PARTICULATE
                                                            MATTER, DUST,  FUMES, GAS, MIST,  SMOKE, VAPOR OR ODOROUS
                                                            SUBSTANCE  THAT INTERFERS WITH  THE COMFORTABLE  ENJOYMENT
                                                            OF LIFE OR PROPERTY OR IS INJURIOUS TO PUBLIC  HEALTH.
                                                                                                                     PERTAINS  TO  ANY SITE AT WHICH  HAZARDOUS WASTE  WILL BE
                                                                                                                     MANAGED SUCH THAT AIR EMISSIONS  MAY OCCUR. CONSIDER
                                                                                                                     FOR SITES  THAT WILL UNDERGO  MOVEMENT OF EARTH  OR
                                                                                                                     INCINERATION.
                                  PROHIBITS OPEN  DUMPING OR BURNING
                                                                               PROHIBITS  OPEN BURNING  OR  OPEN DUMPING OF  SOLID WASTE OR
                                                                               TREATED  OR UNTREATED INFECTIOUS WASTE.
                                                                                                                                           PERTAINS  TO ANY SITE AT WHICH SOLID WASTE HAS  COME TO BE
                                                                                                                                           LOCATED OR WILL BE GENERATED DURING A REMEDIAL ACTION
                                  EXPLOSIVE GAS  MONITORING
                                                                               REQUIRES  EXPLOSIVE GAS MONITORING PLANS FOR SANITARY
                                                                               LANDFILLS  AND PROVIDES AUTHORITY TO THE DIRECTOR OF OHIO
                                                                               EPA  TO  ORDER AN OWNER OR  OPERATar OF A FACILITY TO
                                                                               IMPLEMENT  AN EXPLOSIVE GAS  MONITORING AND  REPORTING PLAN.
                                                                                                                                           PERTAINS  TO ALL SANITARY  LANDFILLS EXCEPT  FOR THOSE THAT
                                                                                                                                           DISPOSED  OF NONPUTRESCIBLE  WASTES.
                                                                                                                                                                                                   LOCATION
                                                                                                                                                                                                   ACTION
                                  HAZARDOUS WASTE  FACILITY ENVIRONMENTAL
                                  IMPACT
                                                            A HAZARDOUS  WASTE FACILITY  INSTALLATION AND OPERATION
                                                            PERMIT  SHALL NOT BE APPROVED  UNLESS IT PROVES  THAT THE
                                                            FACILITY  REPRESENTS THE MINIMUM ADVERSE ENVIRONMENTAL
                                                            IMPACT, CONSIDERING THE STATE OF AVAILABLE TECHNOLOGY, THE
                                                            NATURE  AND  ECONOMICS OF VARIOUS ALTERNATIVES AND OTHER
                                                            PERTINENT CONSIDERATIONS.
                                                                                                                     PERTAINS  TO  ALL SITES AT WHICH  HAZARDOUS WASTE  HAS  COME
                                                                                                                     TO BE LOCATED AND/OR AT WHICH HAZARDOUS WASTE WILL  BE
                                                                                                                     TREATED,  STORED OR DISPOSED  OF  MAY FUNCTION AS  SITING
                                                                                                                     CRITERIA.

-------
ADMINIS.
 CODE
SECTION
                      OHIO REVISED CODE  (ORC)  ARARs
                        REILLY  TAR           TUSCARAWAS  COUNTY
PERTINENT
PARAGRAPH
TITLE OR  SUBJECT
 OF REGULATION
 DESCRIPTION
OF REGULATION
 APPLICATION
OF REGULATION
ARAR
TYPE
                  (D)6,d,g,h   HAZARDOUS WASTE SITING  CRITERIA
                                                                               (D),6,d. A  HAZARDOUS WASTE FACILITY INSTALLATION AND
                                                                               OPERATION PERMIT SHALL  NOT BE APPROVED UNLESS  IT PROVES
                                                                               THAT THE FACILITY
                                                                               REPRESENTS  THE MINIMUM  RISK OF ALL  OF THE FOLLOWING
                                                                               (1)CONTAMINATION OF GROUND AND SURFACE WATERS
                                                                                (11)  FIRES  OR EXPLOSIONS  FROM TREATMENT, STORAGE OR DISPOSAL
                                                                               METHODS
                                                                                (ill)ACCIDENT DURING TRANSPORTATION
                                                                                (Iv)  IMPACT ON PUBLIC  HEALTH AND SAFTEY
                                                                                (v)   AIR POLLUTION
                                                                                (vl)  SOIL  CONTAMINATION
                                                                               (D)6,g,h. PROHIBITS THE FOLLOWING LOCATIONS  FOR TREATMENT,
                                                                               STORAGE AND  DISPOSAL OF ACUTE HAZARDOUS WASTE:
                                                                                (1)   WITHIN 2000 FEET  OF  ANY RESIDENCE, SCHOOL, HOSPITAL,  JAIL
                                                                               OR PRISON;
                                                                                (11)  ANY NATURALLY OCCURRING WETLAND
                                                                                (111)ANY FLOOD HAZARD  AREA
                                                                                (Iv)  WITHIN ANY STATE  PARK OR NATIONAL PARK OR RECREATION
                                                                               AREA
                                                                                                                                             PERTAINS TO  ALL SITES AT  WHICH HAZARDOUS WASTE  HAS COME
                                                                                                                                             TO BE LOCATED AND/OR AT WHICH HAZARDOUS WILL  BE
                                                                                                                                             TREATED, STORED OR DISPOSED OF MAY  FUNCTION AS  SITING
                                                                                                                                             CRITERIA.
                                                                                                                                                                                                    ACTION
                                                                                                                                                                                                    LOCATION
3734.It.I
                               CONDITIONS  FOR DISPOSAL OF ACUTE
                               HAZARDOUS WASTE
                                                           PROHIBITS  DISPOSAL OF  ACUTE HAZARDOUS WASTE  UNLESS IT:  (1)
                                                           CANNOT BE  TREATED, RECYCLED OR  DESTROYED,  (2)  HAS BEEN
                                                           REDUCED  TO ITS LOWEST  LEVEL OF  TOXICITY, AND (3)  HAS  BEEN
                                                           COMPLETELY ENCAPSULATED OR PROTECTED TO PREVENT LEACHING.
                                                                                                                      PERTAINS  TO  ANY SITE WHERE ACUTE  HAZARDOUS WASTE HAS
                                                                                                                      COME TO BE LOCATED.
                                                                                                                                                   CHEMICAL
                                                                                                                                                   ACTION
                               PROHIBITION  OF NUISANCES
                                                                               PROHIBITS NOXIOUS EXHALATIONS OR  SMELLS AND  THE
                                                                               OBSTRUCTION  OF WATERWAYS.
                                                                                                                                             PERTAINS TO  ANY SITE THAT  MAY HAVE  NOXIOUS SMELLS OR
                                                                                                                                             MAY OBSTRUCT WATERWAYS.
                                                                                                                                                                                                    ACTION
                                                                                                                                                                                                    CHEMICAL
                               PROHIBITION  OF NUISANCES
                               CONSERVANCY  DISTRICTS
                               ACTS OF POLLUTION PROHIBITED
                                                           PROHIBITION AGAINST  THROWING REFUSE,  OIL,  OR FILTH INTO LAKES
                                                           STREAMS,  OR DRAINS.

                                                           BOARD OF  DIRECTORS OF  A CONSERVANCY DISTRICT MAY MAKE  AND
                                                           ENFORCE RULES AND REGULATIONS  PERTAINING  TO  CHANNELS,
                                                           DITCHES,  PIPES, SEWERS.  ETC.

                                                           POLLUTION OF WATERS  OF THE STATE  IS PROHIBITED.
                                                                                                                                                                PERTAINS TO ALL  SITES LOCATED ADJACENT  TO LAKES,  STREAMS,
                                                                                                                                                                OR  DRAINS.
                                                                                                                                                                THIS  STATUTE  PERTAINS TO  ANY SITE THAT  MAY AFFECT  A
                                                                                                                                                                CONSTRUCTION  WITHIN A CONSERVANCY DISTRICT.
                                                                                                                                                                PERTAINS TO ANY  SITE WHICH  HAS CONTAMINATED ON-SITE
                                                                                                                                                                GROUND OR SURFACE WATER OR  WILL HAVE  A DISCHARGE  TO
                                                                                                                                                                ON-SITE SURFACE  OR GROUND WATER.
                                                                                                                                                                                                    ACTION
                                                                                                                                                                                                    CHEMICAL
                               RULES REQUIRING COMPLIANCE WITH NATIONAL
                               EFFLUENT  STDS
                                                           ESTABLISHES  REGULATIONS  REQUIRING COMPLIANCE  WITH NATIONAL
                                                           EFFLUENT  STANDARDS.
                                                                                                                      PERTAINS  TO  ANY SITE WHICH WILL HAVE A POINT  SOURCE
                                                                                                                      DISCHARGE.
                               INJECTION OF  SEWAGE OR  WASTES INTO WELLS
                                                                               ESTABLISHES  A REGULATORY PROGRAM  FOR THE INJECTION OF
                                                                               WASTES INTO  WELLS THAT  PREVENTS THE  CONTAMINATION OF
                                                                               UNDERGROUND  SOURCES OF  DRINKING WATER.
                                                                                                                                             PERTAINS TO  ANY SITE THAT  EITHER HAS  OR INTENDS  TO INJECT
                                                                                                                                             WASTES OF ANY TYPE INTO  WELLS.
                               WATER POLLUTION CONTROL REQUIREMENTS
                               DUTY TO COMPLY
                                                           PROHIBITS  FAILURE TO  COMPLY WITH  REQUIREMENTS  OF SECTIONS
                                                           6111.01  TO 6111.08 OR ANY RULES PERMIT OR  ORDER ISSUED
                                                           UNDER THOSE SECTIONS.
                                                                                                                      PERTAINS  TO  ANY SITE WHICH HAS  CONTAMINATED  GROUND
                                                                                                                      WATER OR  SURFACE WATER  OR WILL  HAVE A DISCHARGE TO
                                                                                                                      ON-SITE SURFACE OR GROUND WATER.

-------
APPENDIX B

ADMINISTRATIVE RECORD INDEX

ADMINISTRATIVE RECORD
 (Index and Documents)

FOR THE

REILLY TAR A CHEMICAL CORP. SUPERFUND SITE
DOVER, OHIO

APRIL 1991

United States Environmental Protection Agency
Region V
230 South Dearborn Street
Chicago, Illinois 60604



-------
04/27/91
ADMINISTRATIVE RECORD INDEX
WILLY TAR & CHEMICAL CORP. SUPERFUND SITE
DOVER, OHIO
    FICHE/FRAME PAGES DATE        TITLE
                16    90/05/18    Administrative Order
                                  By Consent Pursuant to
                                  complete emergency
                                  removal activities at
                                  the site

                5     84/04/30    Preliminary Assessment
                                  Report

               100    85/12/06    Inspection Report for
                                  Reilly Tar and Chemical
                                  Corporation

               190    86/11/19    Hazard Ranking System
                                  scoring Package with
                                  attachments

               29     89/09/26    Revised Analytical
                                  Report Proj.# 88WT08

               88     89/12/00    Health and Safety
                                  Plan RI/FS

               42     90/03/00    Community Relations
                                  Plan for Reilly Tar
                                  & Chemical site

               70     90/04/26    Work Plan for
                                  Expedited Response
                                  Action for Surficial
                                  Contamination at the
                                  Reilly Tar & Chemical
                                  CorporatiON-SITE

               204    90/08/00    Expedited Response
                                  Action Report for
                                  Removal of Surficial
                                  Contamination
AUTHOR
                           RECIPIENT
                                                DOCUMENT TYPE
U.S. EPA - Niedersgang,N. Reilly Tar & Chem.    Pleadings/Orders
                          Corp.
McCoy,N. - U.S. EPA
CN2N HILL
Ecology & Environment
U.S. EPA
Wadsworth/Alert
LaboraTaries, Inc.

ENSR Consulting and
Engineering

U.S. EPA
McCoy,N. - Ohio EPA   Reports/Studies
                          U.S. EPA
                          U.S. EPA
                      Reports/Studies
                      Reports/Studies
Omara,M.& Weston,R.   Reports/Studies
Reilly Industries,    Reports/Studies
Inc.

                      Reports/Studies
Quillin Excavating Co.    Reilly Industries,    Reports/Studies
Reilly Industries, Inc.   Inc.
ENSR Consulting and
Engineering
 Reilly Tar & Chem.   Reports/Studies
 Corp.
                                          DOCNUMBER

                                             7
                                                                       10
11
12
                                                                       13
                                             14
15

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04/27/91
ADMINISTRATIVE RECORD INDEX
WILLY TAR & CHEMICAL CORP. SUPERFUND SITE
DOVER, OHIO
    FICHE/FRAME PAGES DATE

                121   91/01/25



                190   91/03/00



                161   91/03/00


                459   91/04/00
TITLE

Quality Assurance
Project Plan RI/FS
Technical Oversight

Site - Specific
Sampling Plan
RI/FS

Work Plan
RI/FS

Quality Assurance
Project Plan RI/FS
AUTHOR

B&V Waste Science
and Technology Corp.
ENSR Consulting and
Engineering
ENSR Consulting and
Engineering

ENSR Consulting and
Engineering
 RECIPIENT

U.S. EPA
Reilly Ter
Chem.Corp.

Reilly
Industries, Inc.
DOCUMENT TYPE

Reports/Studies
Reilly Industries,    Reports/Studies
Inc.
Reports/Studies
Reports/Studies
DOCNUMBER

   16



   17



   18


   19


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DOC#      DATE      AUTHOR

 15      10/01/96   Smith, E.,  U.S. EPA


 16      11/20/96   Smith, E.,  U.S. EPA
 17      12/03/96   Rivers,  P., Reilly
                    Industries, Inc,
 18      12/06/96   Rivers,  P., Reilly
                    Industries, Inc.
 19      12/10/96   Smith,  E.,  U.S. EPA
                                  RECIPIENT

                                  Rivers,  P.,  Reilly
                                  Industries,  Inc.

                                  Rivers,  P,,  Reilly
                                  Industries,  Inc.

                                  Smith,  E.,  U.S.  EPA
                                  Smith,  E.,  U.S.  EPA
                                  Rivers,  P.,  Reilly
                                  Industries,  Inc.
  TITLE/DESCRIPTION                             PAGES

Letter re: U.S. EPA/Ohio EPA's Final Comments      9
on the August 30,  1996 Feasibility Study

Letter re: Feasibility Study Addendum for the      2
Reilly Tar Site

Letter re: Reilly Tar's Response to U.S.          16
EPA's November 20, 1996 Letter Concerning the
Feasibility Study Addendum

Letter Forwarding Attached Replacement Pages      12
for the Soil Volume Figures to the October
18, 1996 Feasibility Study Addendum

Letter re: Feasibility Study Addendum              2
 20
01/00/97   U.S.  EPA
                                                                 Proposed Plan
                                                                                                                   10

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APPENDIX C

STATE OF OHIO LETTER OF CONCURRENCE




State of Ohio Environmental Protection Agency

STREET ADDRESS:                                                                                     MAILING
ADDRESS:
 1800 WaterMark Drive                   TELE:  (614) 644-3020 FAX:  (614) 644-2329                        P.O.
Box 1049
Columbus, OH 43215-1099
Columbus, OH 43216-1049

April 2, 1997

Mr. William Muno
Regional Administrator
United States Environmental Protection Agency
Region V
77 West Jackson Boulevard
Chicago, Illinois 60604-3590

Dear Mr. Muno:

The Ohio Environmental Protection Agency  (Ohio EPA) has received and reviewed the final Record of Decision
(ROD) for the Reilly Tar and Chemical Site in Tuscarawas County, Ohio.  The final ROD has incorporated Ohio's
comments dated March 27, 1997.

The Ohio EPA concurs with alternative #3, the selected remedial alternative for this site. The selected
alternative includes the following components:

     !  Excavation and off-site thermal treatment of drainage ditch and river sediments,  surface soils and
       impacted perched zone material from the collection trench installation contaminated with greater than
       100 ppm Benzo(a)pyrene toxic eguivalents (B(a)P-TE);

     !  Off-site disposal of solidified tarry materials, or recycle tarry materials as a fuel or feedstock;

     !  Excavation and on-site disposal of surface water drainage ditch and river sediments,  surface soils and
       impacted perched zone material contaminated with less than 100 ppm B(a)P-TE but greater than 5 ppm
       B(a)P-TE;

     !  Construction of an Ohio Subtitle D Solid Waste Cap over on-site disposed materials; a soil cover over
       the remainder of the site;

     !  Hydraulic control and collection of perched ground water;

     !  Natural attenuation/long-term monitoring of shallow regional ground water;

     !  Sampling and analysis of sediments in the river to monitor ecological risk to aguatic species; and

     !  Institutional controls to completely restrict the use of ground water on-site and to restrict the
       property to industrial/commercial use.

The estimated net present worth of the selected remedy is $2,810,300. The total estimated operation and

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maintenance costs over a 30 year period are $1,431,200.

The Ohio EPA believes that the selected remedy provides the best balance among the alternatives for the
Reilly Tar and Chemical CorporatiON-SITE.

George V. Voinovich, Governor
Nancy P. Hollister, Lt. Governor
Donald R. Schregardus, Director



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