1
972812
x>EPA
United States
Environmental Protection
Agency
Statement of Basis
for
Bway Corporation
Cincinnati, Ohio
EPA ID NO.
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Table Of Contents
Section I: Introduction and Purpose of the Statement of Basis Error ! Bookmark not defined
Section II: Facility Background
Section III: Summary of Environmental Investigation
Section IV: Summary of Risk Evaluation
Section V: Corrective Action Objectives
Section VI: Proposed Final Remedy and Evaluation
Section VII.Financial Assurance
Section VIII. Public Participation and Information Repository
Section IX. References
Attachments
Attachment 1: Figures
Figure 1 Bway Facility Location
Figure 2 Facility Layout and Features
Figure 3 Locations of SWMUs, AOCs and AOIs
Figure 4 Geologic Cross Section
Figure 5 RFI Sampling Locations and Groundwater Flow
Figure 6 Regional Groundwater Elevations and Flow
Figure 7 Groundwater Sampling Locations and Results
Figure 8 Summary Statistics for Groundwater Dissolved Arsenic
Figure 9 Summary Statistics for Groundwater Dissolved Iron
Figure 10 Summary Statistics for Groundwater Dissolved Manganese
Attachment 1: Tables
Table 1 List of SWMUs, AOCs and AOIs
Table 2 Facility Administrative Record Index
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ACRONYMS
AOC
Area of Concern
AOI
Area of Interest
BGS
Below Ground Surface
CAO
Corrective Action Objective
CCR
Current Conditions Report
CMS
Corrective Measures Study
COC
Constituent of Concern
ESL
Ecological Screening Level
El
Environmental Indicators
EPA
U.S. Environmental Protection Agency
HHRA
Human Health Risk Assessment
HI
Hazard Index
HQ
Hazard Quotient
IC
Institutional Control
MCL
Maximum Contaminant Level (Drinking Water)
PA/VSI
Preliminary Assessment/Visual Site Inspection
PRG
Preliminary Remediation Goal
RCRA
Resource Conservation and Recovery Act
RSL
Regional Screening Level
RFI
RCRA Facility Investigation Report
SB
Statement of Basis
SVOCs
Semi-Volatile Organic Compounds
SWMU
Solid Waste Management Unit
U.S.C.
United States Code
UST
Underground Storage Tank
VOCs
Volatile Organic Compounds
WQS
Water Quality Standards
SECTION I: INTRODUCTION AND PURPOSE ¦ -I '1,1 , I Hi 1ENT OF BASIS
This Statement of Basis (SB) presents the United States Environmental Protection Agency's (EPA)
proposed remedy to address contaminated soil and its potential effects on surface water and ground
water at the Bway Corporation, 8200 Broadwell Road, Cincinnati, Ohio, (Bway or the Property or the
Facility or the Site). This SB describes the nature and scope of the Site investigation, identifies EPA
selected remedies, and discusses EPA's reasons for selecting the proposed remedies. EPA will select a
final remedy after considering all the public comments received during the 30-day public comment
period.
EPA is issuing this SB as part of its public participation responsibilities under the Resource Conservation
and Recovery Act (RCRA). It summarizes information that can be found in greater detail in the RCRA
Facility Investigation (RFI), Environmental Indicator (El) documents, Corrective Measures Study (CMS),
and other pertinent documents contained in the Administrative Record. An Index to the Administrative
Record is attached. EPA encourages the public to review these documents to gain a more
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comprehensive understanding of the RCRA corrective action activities conducted at the Bway facility
over the last thirteen years.
EPA may modify the proposed remedy or select another remedy based on new information or public
comments. Therefore, EPA encourages the public to review and comment on the SB. All documents
supporting this SB are contained in the Administrative Record located at the Cincinnati Public Library,
Anderson Branch, 7450 State Road, Cincinnati, Ohio and the EPA, Region 5 Record Center (7th Floor), 77
W. Jackson Boulevard, Chicago, Illinois 60604.
In September 2007, EPA and Bway signed an Administrative Order on Consent (Consent Order) requiring
that Bway investigate and clean up chemical wastes released at the Site. The Consent Order was issued
under the authority of Section 3008(h) of the Solid Waste Disposal Act (commonly referred to as the
RCRA of 1976) as amended by the Hazardous and Solid Waste Amendments of 1984, 42 U.S.C. § 6928(h).
The work required by EPA was designed and implemented to protect human health and/or the
environment. The RCRA program oversees the cleanup of the Site under the Corrective Action program.
The Corrective Action program is responsible for ensuring that facilities investigate and clean up releases
of hazardous waste and hazardous constituents on their properties and any releases that have spread
beyond the property boundaries, and which pose an unacceptable risk to human health or the
environment. The selected remedies, or clean-up actions, were chosen based upon the current and next
anticipated use of the Site. Bway continues to manufacture three-piece steel cans at the Facility and its
future anticipated use for the property is to remain as an industrial facility.
Remedy Summary
After reviewing the results of soil, groundwater, surface water, and sediment sampling, past
environmental practices, historical investigations, and remedial activities. EPA is proposing that Bway
implement deed restrictions to limit current and future groundwater use and land use of the property.
Additionally, the deed restrictions will include the maintenance of the paved surface in the soil impacted
areas. These legal restrictions will limit the migration of contaminants from soil to groundwater, limit
the land use to industrial purposes and limit the use of groundwater on the property for industrial
purposes and as a drinking water source. For a full explanation of the proposed remedies, see Section
VI: Proposed Final Remedy and Evaluation of the selected remedy.
SECTION II: FACILITY BACKGROUND
Location and Setting
The Facility is located at 8200 Broadwell Road in the Township of Anderson, Ohio. Anderson Township is
in the east-central portion of Hamilton County, which is located in the southwestern portion of Ohio.
The Facility is comprised of two parcels totaling 77 acres and is bound by Broadwell Road to the south; a
Norfolk and Western railroad to the east; and gravel pit ponds to the north and west (See Figure 1 in
Attachment 1).
Most of the Facility is either covered with buildings or is paved. The primary features at the Facility
include: the main manufacturing building and warehouse with connected offices; a treated sanitary
wastewater storage pond, a sanitary biological treatment plant and land-application spray field located
in the northeast corner of the Facility. The area to the north and west is occupied by abandoned gravel
pits and undeveloped land. The area to the east consists of industrial manufacturing plants, offices, and
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warehouses. The area to the southwest is bounded by residential properties along Broadwell Road.
South of Broadwell Road opposite the plant property, around an abandoned gravel pit is an inactive
landfill that was closed in 1986 and operated as an open dump prior to 1964 (See Figure 2 in
Attachmentl).
Ownership History
The Site on which the Facility is located was farmland until Baldwin Piano purchased the land and built a
single manufacturing building in 1952. Baldwin Piano manufactured pianos on the Facility until 1958
when it was sold to Heekin Can. Heekin operated its three-piece steel can manufacturing process on the
property until it was acquired by the Ball Corporation (Ball) in March 1993. Ball sold the Property to
Milton Can, a division of Bway in 1996. The Mauser Packaging Solutions-Bway Corporation currently
manufactures three-piece steel cans and two-piece aluminum cans at the Facility. The previous
owner/operator, Ball, is working with Bway to fulfill the requirements of the Consent Order.
Manufacturing, Release, and Regulatory History
Currently, three-piece can manufacturing operations generate tin-plate scrap metal from the can lines.
Manufacturing processes at the Facility have not changed significantly since two-piece aluminum can
operations were discontinued in 1989. Under Ohio Environmental Protection Agency's (Ohio EPA)
oversight, changes to waste management practices throughout the Facility have been made to manage
and minimize waste streams.
Historical operations at the Facility have influenced key areas on the property concerning waste
management practices. An area east of the Facility was excavated as a gravel pit as early as 1938 and
was later used as a disposal area for various waste streams within the Facility. Formerly treated process
wastewater from the drawn and iron process was discharged into an off-Property gravel pit to the north
from approximately 1973 to 1987 through a sewer line. Outdoor drum storage (empty, chemical
product, and waste) was a waste management practice started in the early 1960s that was discontinued
no later than 2001. Between 1987 and 1990, Ohio EPA inspected the Facility on five separate occasions
for hazardous waste compliance. As a result of violations stemming from these inspections, Ohio EPA
and Heekin Can, the predecessor to Bway entered into a Consent Order in October 1992. The Consent
Order required the responsible party to implement a comprehensive waste minimization plan. Ohio EPA
closed the Consent Order in March 1996, after Heekin Can completed its obligations. Currently, the
Facility holds a small-quantity generator permit for hazardous waste. The Facility also maintains a permit
for industrial stormwater discharge under Ohio EPA's National Pollutions Discharge Elimination System
general permit program. In 2002, Bway received the closure certification from Ohio EPA for the gravel
pit debris area.
EPA's 1989 Preliminary assessment/Visual Site Inspection (PA/VSI) report identified 23 Solid Waste
Management Units (SWMUs) and one Area of Concern (AOC) as having the potential to release
hazardous constituents to the environment. In September 2007, EPA and Bway entered into a Consent
Order. Upon conducting and completing the 2007 Current Conditions Report (CCR), an additional eight
Areas of Interest (AOIs) and two SWMUs were added to the list to document the current environmental
conditions at the Facility. These evaluations resulted in the selection of seven SWMUs, one AOC, and six
AOIs as part of the RFI. Due to the lack of documented releases, indoor operations, and storage on
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concrete pads, the majority of the SWMUs were removed from further investigation. While some of the
AOIs, such as underground storage tanks (USTs), achieved State closure through excavation, followed by
confirmation sampling, the CCR recommended soil sampling in these areas to verify that there were no
past releases of hazardous waste or hazardous constituents which pose an unacceptable risk to human
health and the environment from the use of these units.
Table 1 in Attachment 1 provides a description of the SWMUs and AOIs and the rationale for selecting
the areas for further sampling as part of the RFI.
Physical Setting and Site Characteristics
The area surrounding the Facility is mixed industrial, commercial, and residential, with an industrial
manufacturing area to the east of the Facility and residences south and southwest of Broadwell Road.
Soil
The unconsolidated sediments beneath the Facility consist of silt, clay, sand, and gravel deposits. The
nature of the unconsolidated material is variable but in the vicinity of the plant, it consists of about 80
feet of sand and gravel underlain by about 30 feet of clay followed by a six-foot sand and gravel lens on
top of shale bedrock which was encountered at 102 feet bgs.
Geology
The unconsolidated deposits beneath the Facility and in the vicinity of the Property generally consist of
about 80 feet of sand and gravel deposits overlying about 30 feet of fine-grained, very-low permeability,
glacial tills on top of bedrock. The underlying bedrock is composed of interbedded layers of shale and
limestone belonging to the Kope Formation of the Ordovician Age. The bedrock typically yields less than
5 gallons per minute to drilled wells and is not considered to be a significant aquifer.
Hydrogeology
The Little Miami River flows southwest of the Site. The Facility is located over a buried valley which is
approximately 100 feet thick, and 1 mile wide assigned to a portion of the EPA designated Greater
Miami Sole Source Aquifer system. Based on maps published by the Ohio EPA, the Facility is not located
within a well-field protection district.
Localized GW Flow Direction
The general direction of groundwater flow in the buried valley is from upstream to downstream and
from the edge of the buried valley towards the Little Miami River. The Little Miami River receives flow
from the groundwater during periods of low flow. The direction of groundwater movement in the
vicinity of the Facility was determined to be northwest towards the adjacent flooded quarry pond which
is upgradient to the Little Miami River. The flow of groundwater reverses occasionally during times of
groundwater elevation changes. The rate of groundwater movement under the Facility is in the range of
1 to 10 feet per day. The depth to the groundwater table is approximately 50 to 70 feet (around 495 feet
AMSL) below the ground surface in that area of the Facility.
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Water Supplies and Groundwater Use
Based on the district maps published by the Ohio EPA, the Facility is not located within a well-field
protection district. The unconsolidated aquifer beneath the Facility is assigned to a portion of the EPA
designated Greater Miami Sole Source Aquifer system. Water for the plant operation is currently
provided by Cincinnati Water Works. There are public water supplies in the area which obtain their
source of water from wells completed in the buried valley deposits readily available from the public
distribution systems of Cincinnati, Milford, or Indian Hill municipalities.
Wastewater Treatment and Groundwater Management
Before the construction of the land-application treatment system in 1987, the Facility industrial
wastewater treatment consisted of chromium reduction, pH adjustment, flocculation, and settling. The
former effluent from the Facility industrial wastewater treatment was characterized by high
concentrations of chemical oxygen demand, dissolved solids, sulfates, chlorides, and fluorides. Based on
Ohio EPA's request following an inspection in 2017, the facility upgraded its On-Site wastewater
treatment system as part of the Land Application Permit renewal. The wastewater treatment and
disposal system at the Facility is designed to disperse sanitary effluent in small quantities over large
areas. The system pumps pretreated wastewater to eight soil absorption zones where the water drips
out of tubing at regular intervals. The drip distribution system reportedly micro doses the drip tubing
zones to ensure the soil absorption area remains unsaturated.
Ecological Setting
Most of the Facility is either occupied with buildings or is paved (see Figure 3). The various buildings
house manufacturing operations, warehouses, and offices. The southern portion of the Facility consists
of a landscaped area, with a small cemetery, that is regularly maintained and offers little to no ecological
value. A Process Pond (SWMU 22) is in the northeast portion of the Facility, along with the Land
Application Treatment Area (SWMU 23) or spray field. To the north and west of the Facility lies a closed
sand and gravel quarry (AOI B) that is currently filled with water. In the eastern portion of the Facility is
a historical debris area (AOI C) that contains two small ponds.
The permitted spray field is regularly maintained, such that the grass does not grow much higher than a
typical residential lawn. A narrow band of deciduous trees surrounds the field, ranging in width from
approximately 100 feet on the southern end of the field to approximately 150 feet between the
northern edge of the spray field and the quarry pond to the north. Wildlife that may use the spray field
is likely limited to transient, urban-tolerant species (e.g., American robin, European starling, Norway rat)
given: (1) the industrial nature of the site and the surrounding area; (2) that the field is regularly
maintained; and (3) that the spray field was engineered for a slow rate spray application. For these
reasons, SWMU 23 represents a very low-value ecological habitat.
SECTION III: SUMMARY OF ENVIRONMENTAL INVESTIGATION
The purpose of a Corrective Action RFI is to determine whether hazardous waste or hazardous
constituents were released into the environment at a Site and if so, to evaluate the significance of the
releases in terms of risk to human health and the environment. The investigation is governed by a
conceptual site model (CSM) which illustrates site physical characteristics, sources of contaminants,
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their fate and transport affected environmental media, and potentially exposed people (in categories
such as office and construction workers) and ecological receptors (plants and animals).
During the investigation phases, environmental media such as soil, groundwater, surface water, and
sediments are sampled and analyzed for contamination. Where contaminated media are found,
subsequent sampling is usually completed to refine the CSM and define the extent of contamination
(how far it may have traveled and how deeply), and to collect enough information for analysis of
exposure effects in risk assessments. After each sampling event or investigation phase, EPA evaluates
the CSM to determine the adequacy of the data to support decision-making. If found to be inadequate,
additional data collection is necessary.
Site Investigation and Data Evaluation
All environmental sampling data including groundwater, surface water, sediments, pore water, and soil
gas have been evaluated in accordance with Sampling and Analysis Work Plans submitted between 2008
and 2014. All on-site risk assumptions used for evaluating the conditions at the Facility are based upon
Bway's status as an active manufacturer that is expected to continue operating for the foreseeable
future. Most of the Facility is covered by buildings, asphalt, and gravel/concrete except the former
wastewater discharge lines (AOC B) and the land application treatment area (SWMU 23). In May 2014,
Bway installed four new monitoring wells with two co-located installations for both shallow and deep
wells (for a total of six). Groundwater data for metals and Volatile Organic Compounds (VOCs) were
collected from 2014 through 2018 for the Site. Trichloroethylene (TCE) sampling in selected on-Site wells
was conducted from 2014 through 2021.
As part of the RFI characterization, Bway completed soil contaminant source characterization at a total
of twelve SWMUs, AOCs, and AOIs. These areas consisted of six outdoor former drum storage areas,
four former underground storage tank areas (SWMUs 10, 11, 12, 13,15, and 22, AOC A, AOI B, D, E, and
G), and a spray field area as identified in Table 1 and Figure 3 of Attachment 1. Soil samples were
analyzed for VOCs, Semi-Volatile Organic Compounds (SVOCs), and Target Analyte List (TAL) metals.
Collected samples were screened against risk-based screening levels calculated using the methodologies
and conservative exposure factors for deriving Regional Screening Levels (RSLs) for both residential and
industrial land use at a target cancer risk level (TCRL) of 10E-05 and a target hazard quotient (HQ) of 1
for non-carcinogenic constituents. Sediment data were compared to residential and industrial direct
contact screening levels in the EPA regional screening table. An additional assessment of the sediments
was conducted considering a trespasser exposure scenario. In addition, sediments were compared to
Region 5 Ecological Screening Levels (ESLs) to evaluate exposure to ecological receptors. All surface
water data were screened against both the EPA Maximum Content Level (MCL) and/or tap water criteria
and the EPA National Ambient Water Quality Criteria (AWQC) for wildlife to evaluate effects on both
human and ecological receptors. The lower (more stringent) of the EPA MCL and EPA RSL tap water Risk
Based Concentration (RBC) was used to evaluate facility groundwater data for risks to human health.
The potential risk from groundwater was evaluated for current and future commercial/industrial,
construction, and intrusive maintenance workers via direct contact (i.e., dermal and inhalation of
volatiles) to groundwater less than 20 feet bgs. The facility geological cross section (Figure 4) and RFI
sampling locations (Figure 5) are shown in Attachment 1.
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Summary of Results
Soil
Surface and subsurface soil contaminant screening evaluation indicated no exceedance of contaminants
above the applicable screening criteria except for perchloroethylene (PCE) at SWMU 11. The PCE levels
in soil at a depth of 6ft bgs, slightly exceeded the industrial soil volatilization to indoor air criterion. As
the nearest building is 150 feet away from the tetrachloroethylene exceedance, the indoor vapor
intrusion pathway is considered incomplete. Based on the low levels of constituents detected in soil at
the Site, the risk associated with human health exposure is found to be insignificant for industrial
workers and trespassers.
Groundwater
Table 1 below shows the screening evaluation of the groundwater data for the constituents of concern
during the quarterly sampling events from 2014 to 2018.
Table 1: On-Site Groundwater Data
On Site
Groundwater
Well ID
Constituent
Date of
Sampling
Maximum
Concentration
of Total Metals
Drinking Water Criteria
(MCLorRBC)
OW-6D
Arsenic
9/17/2014
13
10
OW-3
Iron
9/17/2014
20000
14,000
OW-3
Manganese
12/16/2014
1400
430
OW-3
Trichloroethylene
(TCE)
3/4/2014
46
5
All levels are in ng/L.
TCE was detected at the highest concentration of 46 ug/L along with Iron and Manganese at the on-site
monitoring well OW-3 side gradient of SWMU 23. The source of TCE is a result of groundwater migration
from the adjacent Senco Property. The upgradient Senco Property at the eastern edge of the property
has documented concern for groundwater impacts (see Figure 6 in Attachment 1) due to long-term
manufacturing use and chlorinated waste generation. The contamination found at a single monitoring
well location does not pose ingestion or inhalation risk. There are no buildings closer to this location and
the wells downgradient to OW-3 showed no detects for TCE or PCE in groundwater. Additionally, the
annual groundwater sampling for TCE in wells OW1, OW-2, OW-3 and MW-4 did not show any detects in
2020 and 2021.
Soil to Groundwater Migration Pathway
The soil to groundwater migration screening criteria (GMSC) was based on default EPA MCLs or Tap
water RSLs adjusted to a dilution attenuation factor of 20. Based on this data screening, concentrations
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of arsenic, bis(2-Ethylhexyl) phthalate, trivalent chromium (cr III) iron, manganese, PCE, and TCE in one
or more soil boring locations exceed the soil screening criteria protective of groundwater. EPA has
determined that AOCs are AOIs D, E, G, and SWMUs 10,11,12, 13,15, and 23. Further evaluation of the
exceedance of the soil to groundwater exceedance criteria is shown in Table 5.
Surface Water
Surface water data was compared to the same drinking water criteria used to assess groundwater. This
approach is very conservative because neither on-Site nor off-site surface water is used as an actual
drinking water source. Exceedances of drinking water criteria were observed at four of six sampling
locations at AOI B; two locations in AOI C and one location at SWMU 22. None of these
locations are a drinking water source. Table 2 below lists the maximum metals concentrations in surface
water with an exceedance of drinking water criteria.
Table 2: Screening Evaluation of Surface Water Data
Contaminant of Concern
Maximum Concentration
Drinking water criteria (MCL or Risk Based)
Antimony
10
6
Mercury
2.2
2
Thallium
5.8
2
All levels are in ng/L.
Sediment
Co-located sediment samples were collected at the same locations as surface water locations. Sediment
pore water samples were co-located with the sample's locations from AOI B. Sediment sampling results
were compared to screening levels for residential and routine worker direct contact with soil.
Constituents were reported above these screening levels in four locations at AOI B, four locations at AOI
C, and three locations at SWMU 22. Exceedances are listed in Table 3 below.
Table 3: Sediment Data Screening Evaluation
Contaminant
Maximum level
Industrial Direct
Contact criteria
Residential Direct
Contact Criteria
Aluminum
90,200
92,000
76,000
Arsenic
13.2
16
3.9
Iron
25,100
31,000
23,000
Benzo pyrene
3.2
2.1
0.62
Di-benzanthracene
0.69
2.1
0.62
All levels are in mg/Kg.
Ecological Evaluation
As part of the RFI, an ecological risk assessment (ERA) was conducted to assess the potential for
significant exposures of ecological receptors to Facility-related releases of hazardous waste and/or
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hazardous constituents characterized during the RFI. The ERA conducted for this RFI was comprised of a
screening-level ecological risk assessment (SLERA), and Step 3a of a baseline ecological risk assessment
(BERA), which consisted of a refinement of the exposure estimates and risk calculations used in the
SLERA. The ERA used the Site characterization data collected during the RFI to assess potential risks to
ecological receptors that may be exposed to Facility-related constituents in soil, sediment, and surface
water at and near the Site. A summary of the findings and the conclusion of the ERA are as follows:
• Threatened and endangered species are not likely present within the study area.
• Several chemicals are present in surface water, sediment, and surface soil at concentrations that
exceed relevant conservative screening values; exceedances of these criteria indicated that more
detailed and focused BERA was warranted.
The refined ecological risk characterization involves the calculation of HQs, which are the ratio of the
maximum exposure estimate with the ecotoxicological screening values identified in the screening level
ecological effects characterization. The unitless HQs are considered a measurement endpointthat can
provide an understanding of potential ecological risks. A HQ equal to or less than a value of 1 (to one
significant figure) indicates that adverse impacts are considered unlikely.
Iterative evaluations in the BERA included a comprehensive desk-top analysis of available information
regarding the above-listed assessment endpoints using well-accepted EPA equilibrium partitioning, food
web modeling, and other appropriate analyses related to refined exposure and effects assumptions for
evaluating the potential risks associated with constituents that exceeded screening criteria. The BERA
also considered the additive toxicity of classes of compounds, such as PAHs and metal mixtures.
No constituents were identified in SWMU 23 surface soil that required further evaluation. Constituents
in surface water, sediment, and surface soil at concentrations that exceeded relevant conservative
screening values. For constituents detected in surface water, sediment, pore water, and soil, state, and
federal water quality criteria such as Ohio EPA's outside mixing zone average (OMZA), Ohio-specific
sediment reference values and EPA ecological soil screening levels were used for screening-level risk
characterization. An iterative and refined screening evaluation was then conducted for selected
constituents and SWMUs as part of the baseline ecological risk assessment. Exceedances of these
criteria indicated that a more detailed and focused risk assessment was warranted.
Based on the above observations, the following assessment endpoints were modified for the BERA. The
specific assessment endpoints considered for this BERA were:
• Maintenance of the current functioning level of benthic invertebrate community structure
in SWMU 22, AOI B, and AOI C.
• Maintenance of the current functioning level of fish community structure in AOI B.
• Maintenance of the current survival and reproduction level of the aquatic-feeding bird
and mammal populations in SWMU 22 (birds only), AOI B, and AOI C and
• Maintenance of the current survival and reproduction level of the terrestrial-feeding bird
and mammal populations in AOI C.
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SECTION IV: SUMMARY OF RISK EVALUATION
Human Health Risk Evaluation
The information and data collected in the RFI are used to determine whether the contamination
presents an unacceptable risk to human health. This is done in a human health risk assessment (HHRA),
which can be found in the Human Health Indicators Report for the Facility (part of the Administrative
Record). EPA has developed a cancer risk range to evaluate what is acceptable to protect the public.
Cancer risk is often expressed as the maximum number of new cases of cancer projected to occur in a
population due to exposure to the cancer-causing substance over a 70-year lifetime. For example,
cancer risk of one in one million means that in a population of one million people, not more than one
additional person would be expected to
develop cancer because of an exposure to the substance causing that risk. EPA utilizes the acceptable
exposure level, or "risk goal," defined within the National Contingency Plan (NCP) for general site
enforcement and cleanup decisions. The NCP defines the acceptable excess additional lifetime cancer
risk as generally a range between lxl0"6to lxlO"4for determining remediation goals. This represents a
range from one in ten thousand to one in one million. If the contaminants are noncancer-causing but
could cause other health problems, then a hazard index (HI) quotient is used. To be acceptable to the
EPA, the HI quotient for all contaminants must be less than 1 (to one significant figure). The HI is the
ratio of the concentration of a contaminant to its human health screening value.
Soil
The potential risk from soil and groundwater was evaluated for current and future
commercial/industrial, construction, trespassers, and intrusive maintenance workers via direct contact
(i.e., dermal and inhalation of volatiles) to groundwater less than 20 feet bgs. The HHRA concluded that
there was not an unacceptable risk associated with direct contact with industrial workers or
trespassers.
Groundwater
The HHRA did not evaluate the risk associated with exposure to COCs in groundwater via ingestion
because the use of groundwater as a drinking water source is not a current or likely future exposure
pathway. Potable water is obtained from the City of Cincinnati municipal system. There are no active
potable wells downgradient of the site groundwater is currently not used for drinking water at the
Facility. The risk associated with construction worker exposure to groundwater is insignificant due to
the depth to groundwater and low levels of metals in groundwater. The depth to groundwater at the
Site is approximately 50 feet or greater below ground surface and below the depth of the deepest
utilities, which precludes potential exposures to maintenance workers. The following table 4 shows the
statistical evaluation of the groundwater monitoring data collected from eight quarterly samples
collected in 2017 and 2018. The groundwater analytical data for all monitoring wells are shown in
Figure 7 in Attachment 1.
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Table 4: On-site Groundwater Data Evaluation
On Site
Groundwater
Well ID
coc
Maximum
level
of Total
Metals
Maximum
level
of Dissolved
Metals
Mean and Trend Analysis
of Eight
Quarterly Samples
Drinking
Water
Criteria
(MCL or Risk
Based)
95% UCL
of the
Mean
Dissolved
Metals
Trend
Analysis of
Dissolved
Metals
OW-6D
Arsenic
21
7.4
6.4
No Trend
10
OW-3
Iron
15000
1800
1220
No Trend
14,000
OW-3
Manganese
850
550
367
No Trend
430
All levels are in ng/L.
The Ohio EPA Technical Guidance Manual for Groundwater Investigations indicates that if the
concentration of a chemical is much greater in unfiltered samples it would be likely that most of the
chemical would adsorb onto particulate matter or would be a naturally occurring element within the
soil particle and not dissolved in the groundwater samples. As the samples showed a high level of
turbidity, EPA considered the dissolved metals for analysis for clean up standard attainment evaluation.
Following the groundwater statistics tool user's guide (2018), the consecutive quarterly monitoring
data for eight sampling periods was evaluated by applying both the Upper Confidence Limit (UCL) on
the mean and the trend test. In general, the 95% UCL is used as the recommended confidence limit.
Statistics are used to determine the slope of the trend line to conclude future groundwater remedial
conditions.
The 95% upper confidence of the mean for dissolved arsenic, manganese, and total iron in groundwater
in the selected monitoring wells does not exceed the drinking water criteria or risk-based standards.
The trend analysis indicates no trend and is not predicted to exceed the drinking water standards.
Figures 8 through 10 in Attachment 1 provides the statistical analysis output for this attainment
evaluation.
Soil to Groundwater Migration Pathway Evaluation
Table 5 shows the refined evaluation for this pathway screening the shallow and deep soil samples
against the migration to groundwater screening criteria (MTGW). If an exceedance was observed in a
deep soil sample or if there were no deeper soil sampling data in the same boring, an additional
evaluation was conducted to assess if the chemical in soil was detected at concentrations above the
MCL in a nearby or downgradient groundwater monitoring well. The results from these evaluations
indicate that there are no exceedances of the MCL at the downgradient groundwater monitoring well
locations. Therefore, for all the chemicals that exceeded the initial screening criteria, the soil migration
to groundwater pathway is found to be insignificant and expected to remain so due to the presence of
the paved surface in most of the impacted areas.
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Table 5: Evaluation of Soil to Groundwater Migration Pathway
Area
Contaminant of
Concern
Soil
Maximum
Concentration
Background
Concentration
(MTGW) Soil
Criteria Based
on Drinking
Water
Pathway
Constituent
Exceeded MCL in
Ground water
downgradient of
this location
AOC A
Bis (2-Ethylhexyl)
phthalate
260
N/A
29
No
AOI D
Manganese
825
459
570
No
AOI E
Manganese
849
459
570
No
AOI G
Manganese
694
459
570
No
SWMU 10
Bis (2-Ethylhexyl)
phthalate
240
N/A
29
No
SWMU 10
Manganese
880
459
570
No
SWMU 10
Iron
18500
18400
7000
No
SWMU 11
Bis (2-Ethylhexyl)
phthalate
630
N/A
29
No
SWMU 11
Manganese
598
459
570
No
SWMU 11
Iron
20100
18400
7000
No
SWMU 11
PCE
0.8
N/A
0.046
No
SWMU 11
TCE
0.04
N/A
0.036
No
SWMU 12
Iron
19900
18400
7000
No
SWMU 12
Manganese
864
459
570
No
SWMU 13
Iron
24900
18400
7000
No
SWMU 15
Bis (2-Ethylhexyl)
phthalate
630
N/A
29
No
SWMU 15
Manganese
988
459
570
No
SWMU 15
Iron
25600
18400
7000
No
SWMU 23
Manganese
1009
459
570
No
SWMU 23
Iron
30100
18400
7000
No
SWMU 23
Arsenic
14.2
12.9
5.8
No
All levels are in mg/Kg.
-------
15
Surface Water and Sediment
The on-Site surface water and sediment locations consist of the historical debris area (AOI C) and the
wastewater storage pond (within SWMU 22); the off-Site location consists of the quarry pond (AOI B).
Potential exposures to workers in the on-Site locations are not reasonably expected due to the remote
location of the historical debris area and the absence of worker contact with the wastewater storage
pond. Consumption of fish is not of significance as these water bodies are not used for recreational
swimming or sport fishing. There are no current industrial activities within the off-Site quarry pond and
recreational use of the pond is prohibited. Therefore, potential exposure to on-Site and off-Site surface
water and sediment locations is limited to trespassers.
Table 6: Site- specific risk evaluation for surface water and sediment contact
Adolescent T respasser Contact
Adult Trespasser Contact
Area
Excess Cancer Risk
HI
Excess Cancer Risk
HI
AOI B
1E-06
1E-01
3E-06
1E-01
AOI C
3E-07
1E-02
1E-06
1E-02
SWMU 22
3E-07
8E-02
6E-07
8E-02
HI - Hazard Index.
For assessing the Site-specific risk associated with trespasser exposure to surface water and sediment,
the highest concentration of each chemical detected at each area was conservatively used in the risk
calculations. The cumulative cancer risk and non-cancer HI estimates for a trespasser based on exposure
to both sediment and surface water are provided in Table 6. The cumulative cancer risk and HI estimates
for each area are well below EPA's limits of 10E-4 and 1, respectively. Based on these estimates, no
unacceptable exposure of trespassers to surface water or sediment is expected in on-site or off-site
areas.
Based on the evaluations of all the media of concern at the identified SWMUs and AOIs, EPA concludes
that potential releases of hazardous constituents from Bway do not pose a significant risk to on-Site or
off-Site human exposures.
Ecological Risk Assessment Summary
Benthic invertebrate community structure and function
The only constituent, or class of constituents, that potentially pose a risk to the benthic community is
PAHs, and this potential risk is only in isolated portions of the closed quarry pond (AOI B). Specifically,
the analyses of additive impacts to benthic invertebrates were performed using EPA's equilibrium
partitioning approach, and those results showed that PAHs could pose a potential impact on benthic
diversity in very isolated locations within AOI B. Fluoranthene and Pyrene are the only constituents that
exceed the HQ threshold for benthic invertebrates. However, it does not appear that the PAHs identified
in the quarry pond sediment is from Site-related releases due to the low detection frequency and the
low levels of these constituents in the analyzed surface soil or porewater samples. In addition, the
owner of the quarry pond (Martin Marietta) obtained a permit from the Anderson Township Board of
Zoning to resume operations of the quarry pond. These operations are expected to diminish the
ecological diversity and value of the pond, and therefore, the potential for adverse effects associated
with detected PAH concentrations in sediments is considered insignificant by comparison.
-------
16
Fish community structure and function
Adverse impacts are not likely to occur due to Site-related constituents. The toxicity units for all surface
water sampling locations do not exceed the screening benchmark of 1.
Survival and reproduction of aquatic- and terrestrial-feeding wildlife populations
Adverse impacts are not likely to occur due to Site-related constituents. The HQ for any of the receptors
at the impacted area (SWMU 22, AOI B, and AOI C) did not exceed a target HQ threshold of 1.
Based on these findings, EPA concludes that potential releases of hazardous constituents from Bway do
not pose ecologically significant impacts to populations, communities, or ecosystems.
SI 1ECT1WE ACTION OBJECTIVES
Based on the RFI and subsequent investigations, in 2016 Bway achieved a "yes" determination for both
the Human Health and Groundwater El Reports (Also referred to as the CA725 and CA725 status codes
in RCRA Info, respectively). The El reports are used by the RCRA Corrective Action Program to indicate
the quality of the environment concerning current human exposures contamination and the migration
of contaminated groundwater and are considered short-term goals. The Site achieved a "yes"
determination for the human health El indicating that there are no unacceptable human exposures to
contamination that can reasonably be expected under current land and groundwater use conditions at
the Site. In addition, the Site achieved a "yes" determination for the migration of contaminated
groundwater El. Quarterly groundwater monitoring continued at the Bway facility during 2017 and 2018
for the monitoring wells located side gradient and downgradient to the spray field area. This evaluation
showed the attainment of drinking water criteria for all the dissolved metals in groundwater.
EPA's long-term goals for the remedy being proposed for final remedy selection are:
- Protecting human health and the environment
- Controlling the sources of the releases to the extent practicable
As described in Section IV, the investigation and evaluation identified insignificant human health risk or
ecological risk due to the low levels of contaminants identified in soil, groundwater, surface water, and
sediments. Ohio EPA's permit to install the drip irrigation system for sanitary wastewater management
includes the semi-annual monitoring of the groundwater at the spray area for TCE and other water
quality indicators. The potential for the remaining chemicals in the soil to migrate to groundwater is
greatly minimized due to the paved surface at the applicable areas. Groundwater monitoring data from
the shallow aquifer show no impacts in all the downgradient locations of the paved areas. Based on this
evaluation, EPA has determined that no remedial action is required for soil or groundwater.
The areas of contamination impacting the soil-to-groundwater migration pathway at the Facility are
deeper in the subsurface and not readily accessible. Institutional controls for the Facility will include a
non-residential deed restriction and an on-Site prohibition against potable uses of groundwater.
SECTION VI: PROPOSED FINAL REMEDY AND EVALUATION
EPA is proposing a Corrective Action Complete with Controls determination as a final remedy for the
Facility. EPA believes that no further actions to remediate soil or groundwater be required at the Facility
because levels of contamination in soils and groundwater are protective of human health and the
-------
17
environment under the current land use and are below the cleanup criteria. To ensure that protection of
human health is maintained at the Facility, EPA is proposing to require Bway to implement and maintain
institutional controls as discussed below.
Institutional Controls
Institutional controls are non-engineered enforceable instruments such as administrative or legal
controls that minimize the potential for human exposure to contamination and/or protect the
integrity of the remedy by limiting land or resource use. Performance standards by which the proposed
corrective measure will be assessed are through documentation that include:
-Deed restriction to commercial/industrial land use is filed through an Environmental
Covenant prepared under Ohio's Uniform Environmental Covenants Act (ORC 5301.80 5301.92)
(UECA). Paved areas will be identified in the deed.
- Deed restriction prohibiting groundwater use is filed through an Environmental
Covenant prepared under Ohio's UECA (ORC 5301.80 5301.92).
- Visual inspection of the Site is conducted annually to confirm that the paved areas are maintained and
that land use inconsistent with these controls has not occurred.
Should the Facility cease operations and be demolished, or cease to maintain the buildings and
pavement, or if the use of the property for other than nonresidential purposes is contemplated, it will
be necessary for EPA to revisit all exposure scenarios to evaluate the potential need for additional
corrective measures at the Facility.
Evaluation of the Proposed Remedy
This section describes the criteria EPA used to evaluate the proposed remedy consistent with EPA
guidance. The criteria are applied in two phases. In the first phase, EPA evaluates three decision
threshold criteria as general goals. In the second phase, for those remedies which meet the threshold
criteria, EPA evaluates six balancing criteria.
Threshold Criteria
Evaluation
1) Protect human
health and the
Environment
EPA's proposed remedy protects human health and the environment by eliminating,
reducing, or controlling potentially unacceptable risks through the implementation and
maintenance of ICs. For Facility soils, EPA is proposing ICs to restrict land use to
commercial or industrial purposes at the Facility. For groundwater, the proposed remedy
requires groundwater use restrictions to minimize the potential for human exposure to
contamination due to the continued operation of the drip irrigation system at the land
application area. This IC will complement the Ohio EPA permit that requires semi-annual
monitoring for water quality criteria and TCE.
-------
18
Threshold Criteria Evaluation
2) Achieve Media
Cleanup Objectives
EPA's proposed remedy meets the media cleanup objectives based on assumptions
regarding current and reasonably anticipated land and water use(s). The remedy proposed
in this SB is based on the current and future anticipated land use at the Facility as
commercial or industrial. As such, industrial media cleanup objectives were selected, and
the Facility soils contain contaminant concentrations that are below EPA's industrial soil
RSLs. EPA's statistical evaluation of the eight quarterly samples collected from 2017 to
2018 shows the attainment of drinking water standards for the dissolved metals in
groundwater. The Facility meets EPA risk guidelines for human health and the
environment. EPA's proposed remedy requires the maintenance of paved areas and the
implementation and maintenance of institutional controls to ensure that groundwater
beneath Facility property is not used for any purpose. This control is necessary to prevent
human exposure to further contamination in groundwater due to the potential for the drip
irrigation system to migrate the residual contaminants in deep soil to groundwater.
3) Remediating the
Source of Releases
In all proposed remedies, EPA seeks to eliminate or reduce further releases of hazardous
wastes and hazardous constituents that may pose a threat to human health and the
environment. Controlling the sources of contamination relates to the ability of the
proposed remedy to eliminate or reduce, to the maximum extent practicable, further
releases. By modifying its manufacturing and waste collection process Bway significantly
reduced further releases to on-Site soils as well as the source of the groundwater
contamination. Most solvents have been taken out of service or have been converted to
water-based cleaning solutions. The paved surface in the deepest soil impacted areas and
natural attenuation processes are preventing the migration of COCs in concentrations that
would pose an unacceptable risk.
Balancing Criteria
Evaluation
4) Long-term
effectiveness
The long-term effectiveness of the proposed remedy for the Facility will be maintained by
the implementation of land and groundwater use restrictions through ICs.
5) Reduction of
toxicity, mobility, or
volume of the
Hazardous
Constituents
The reduction of toxicity, mobility and volume of hazardous constituents will be achieved
through the maintenance of the paved areas. The paved areas, acting as an impermeable
barrier, will continue to reduce the mobility or volume of any remaining metals and VOCs
in subsurface soil impacting the groundwater.
6) Short-term
Effectiveness
EPA's proposed remedy does not involve any activities, such as construction or excavation,
which would pose short-term risks to workers, residents, and the environment. EPA
anticipates that the land and groundwater use restrictions will be fully implemented
shortly after the issuance of the Final Decision and Response to Comments.
7) Implementability
EPA's proposed decision is readily implementable. The groundwater monitoring is already
in place as part of the drip irrigation system. EPA does not anticipate any regulatory
-------
19
I Threshold Criteria Evaluation
constraints in implementing its proposed remedy. EPA proposes to implement the ICs
through an enforceable mechanism such as an Environmental Covenant.
8) Cost
EPA's proposed decision is cost-effective. The costs associated with this proposed remedy
and the continuation of groundwater monitoring have already been incurred and the
remaining costs are minimal. The costs to record an environmental covenant in the chain
of title to the Facility property are minimal. The costs associated with issuing an order are
also minimal.
9) Community
Acceptance
EPA will evaluate community acceptance of the proposed remedy during the public
comment period, and it will be described in the Final Decision and Response to Comments.
SECTION VII: FINANCIAL ASSURANCE
EPA has evaluated whether financial assurance for corrective action is necessary to implement
EPA's proposed remedy at the Facility. Given that EPA's proposed remedy does not require any
further actions to remediate soil or groundwater contamination at this time and given that the costs of
implementing institutional controls at the Facility will be de minimis, EPA is proposing that no financial
assurance be required.
SECTION VIII: PUBLIC PARTICIPATION AND INFORMATION REPOSITORY
EPA requests feedback from the community on the proposal to select the Alternatives described
above as the final remedy for the Bway Facility. The public comment period will last thirty (30) calendar
days from the date of the public notification in the local newspaper, from March 9, 2022, to April 8,
2022. We encourage community members to submit any comments regarding the proposed remedy in
writing by April 8, 2022. If requested during the public comment period, EPA will also host a public
meeting in to receive feedback directly. Due to restriction related to the COVID-19 pandemic, a public
meeting may be virtual. The Public should send comments to EPA in writing at the EPA mailing address
or the email address listed below. To submit comments or to request a public meeting, contact EPA
Project Manager Bhooma Sundar (see contact information below).
Following the 30-day public comment period, EPA will prepare a Final Decision and Response
to Comments document that will identify the selected remedy for the Facility. The document will
address all significant written comments and any significant oral comments generated at a public
meeting if a meeting is held. EPA will make the Final Decision and Response to Comments
document available to the public. If such comments or other relevant information would cause
EPA to propose significant changes to the currently proposed remedy, EPA will seek additional
public comments on any proposed revised remedy.
At the conclusion of the comment period, EPA will summarize public comments and prepare the
Final Decision and Response to Comments document, which will become part of the EPA Site
Record. To send written comments or obtain further information, contact:
-------
20
Bhooma Sundar
Project Manager
U.S. EPA Region 5
77 W. Jackson Blvd. (M/C LR-16J)
Chicago, IL 60604
Ph: (312)-886-1660
Email: sundar.bhoomagepa.gov
The Site Records (documents about the Site) may be reviewed at these locations:
Cincinnati Public Library
Anderson Branch
7450 State Road, Cincinnati, OH
Mon -Sat, 10 am-6 pm.
Electronic Document Repository
EPA Site Webpage Link: https://www.epa.eov/hwcorrectiveactionsites/epa-rcra4d-ohd004253225
U.S. EPA, Region 5
Land, Chemicals and Redevelopment Division Records Center
77 West Jackson Boulevard, 7th Floor
Chicago, Illinois 60604
(312) 353-5821
Mon-Fri, 8:30 a.m. - 5:00 p.m.
IX: REFERENCES
1. United States Environmental Protection Agency, 1994. RCRA Corrective Action Plan; OSWER
Directive 9902.3-2A; Office of Waste Programs Enforcement, Office of Solid Waste.
2. United States Environmental Protection Agency, 1996. Advance Notice of Proposed Rulemaking
3. (61 FR 19432, May 1). Available http://www.epa.gov/docs/fedrgstr/EPA-WASTE/1996/
May/Day-01/pr-547.pdf.
4. United States Environmental Protection Agency, 1996. Soil Screening Guidance: User's Guide.
EPA/540/R-96/018. Office of Emergency and Remedial Response, Washington, DC. NTIS
PB96.9634501
5. USEPA, 2006. National Recommended Water Quality Criteria. U.S. Environmental Protection
Agency, Office of Water and Office of Science and Technology.
6. United States Environmental Protection Agency (USEPA). 1989b. Risk Assessment Guidance for
Superfund. Volume I, Human Health Evaluation Manual. Office of Emergency and Remedial
Response, Washington, DC. EPA/540-1-89-002. OSWER Directive 9285.7-01a. December.
U. S. Environmental Protection Agency (USEPA). 1991. Role of the baseline risk assessment in
Superfund remedy selection decisions. Memorandum from Don R. Clay to Regional Directors.
OSWER Directive 9355.0-30. April 22.
7. U. S. Environmental Protection Agency (USEPA), Region 9. 2004. Users' Guide and Background
Technical Document for USEPA Region 9's Preliminary Remediation Goals (PRG) Table.
8. United States Environmental Protection Agency (USEPA). 2018. Groundwater Statistics Tool
Users guide updated version 2. Office of solid Waste and Emergency Response, Office of
Superfund Remediation and Technology Innovation.
-------
21
9. U.S. Environmental Protection Agency (USEPA). 2015. Regional Screening Levels (RSLs).
https://www.epa.gov/risk/regional-screening-levels-rsls-generic-tables-november-2015.
November.
10. USEPA. National Recommended Aquatic Life Criteria. 2015. https://www.epa.gov/wqc/national-
recommended-water-quality-criteria-aquatic-life-criteria-table
11. USEPA. 1993b. Wildlife Exposure Factors Handbook. Volumes I and II. EPA/600/R-
93/187. Office of Research and Development, Washington DC.
12. USEPA. 2000b. Equilibrium-Partitioning Sediment Guidelines (ESGs) for the Protection of
Benthic Organisms: Polycyclic Aromatic Hydrocarbon (PAH) Mixtures (Draft). U.S.
Environmental Protection Agency, Office of Science and Technology and Office of
Research and Development.
13. USEPA. 2001. ECO Update: The Role of Screening-Level Risk Assessments and Refining
Contaminants of Concern in Baseline Ecological Risk Assessments. U.S. Environmental
Protection Agency, Office of Solid Waste and Emergency Response. Publication 9345.0-
EPA 540/F-01/014.
14. Ohio EPA. 2003a. Guidance for Conducting RCRA Ecological Risk Assessments. Ohio
Environmental Protection Agency, Division of Hazardous Waste Management, Columbus,
Ohio.
15. USEPA. 2003b. Ecological Screening Levels. United States Environmental Protection
Agency, Region 5, Resource Conservation and Recovery Act Corrective Action and Permit
programs. August 22. http://www.epa.gov/RCRIS-Region-5/ca/edql.htm.
16. USEPA. 2004. Generic Ecological Assessment Endpoints. (EPA/630/P-02-004F).
http://cfpub.epa.gov/ncea/raf/recordisplay.cfm?deid=55131.
17. USEPA, 2006. National Recommended Water Quality Criteria. U.S. Environmental Protection
Agency, Office of Water and Office of Science and Technology.
18. Ohio Environmental Protection Agency (OEPA). 2017. Closure Plan Review Guidance for RCRA
Facilities. Division of Environmental Response and Revitalization. July. (OEPA CPRG 2017).
19. United States Environmental Protection Agency, 1999. Interim Final Guidance for RCRA
Corrective Action Environmental Indicators.
20. United States Environmental Protection Agency, 2000. U.S. EPA Fact Sheet "Institutional
Controls: A Site Manager's Guide to Identifying, Evaluating and Selecting Institutional Controls at
Superfund and RCRA Corrective Action Cleanups.
21. United States Environmental Protection Agency, 1995. Final Policy Toward Owners of Property
Containing Contaminated Aquifers; Office of Enforcement and Compliance Assurance, Waste
Programs Enforcement, Office of Solid Waste.
22. United States Environmental Protection Agency, 2003; Final Guidance on Completion of
Corrective Action Activities at RCRA Facilities (68 FR 8757, February 25). Available at
http://www.epa.gov/correctiveaction/complete.pdf.
23. United States Environmental Protection Agency, 2004. Handbook of Ground Water Protection
and Cleanup Policies for RCRA Corrective Action/EPA530-R-04-030.
24. United States Environmental Protection Agency, 2007. U.S. EPA Memo "Ensuring Effective and
Reliable Institutional Controls at RCRA Facilities."
25. Industrial Compliance Solutions. 2020. Bway Corporation Groundwater Management Plan.
March 2020.
-------
22
Attachment 1
Figures and Tables
-------
Figure 1: Bway Facility Location
PROJECT HWA }, _ RCjtt ClH.m.ljn, Artiou
FKit'RE So. j
"aTC 10/15/07
TITLE
BWAY Facility Location
i>RA" \ ur ylDB
REQl EST LI) H J ^ jiyfi
"3 1 he Payne Finn, Inc.
Cincinnati/Cleveland / Chicago
rmutn+a 654.13.02
REFEHE.M E ^.njtCij (jcitftn'ic .Wivr i LSGS) 7 5 Mi aide Otnhfronak' Man fur MaJcria. Ohio am! Wifltumsvilfc. ()hio (what.
I'JW),
-------
Figure 2: Facility Layout and Features
OW"3
(OW-2
land-application sprayfield
sanitary biological
treatment plant .
treated sanitary
wastewater."
storage pond
grayeh-
rt'pondl
a Wf* > - sn .
w twogravel,;!^ ¦
1 3&E§gm-, i
||§#iy
closed: historical
debris area
> ANDERSON TWP.
FIRE DEPARTMENT
closed construction
demolition debris landfill
MARTIN MARIETTA
LEGEND
& Monitoring Well
S> Abandoned Production Well
O Unlocated Former Production Well
® Unidentified 1" PVC Pipes
- • — BWAY Property Boundary
BWAY Facility Building Additions
~ A - D&l Addition
EJ B - D&l Office
~J C - D&l Coil Storage
~ D - D&l Building
~ E - Warehouse
~ F - Warehouse Addition
~ G - Original Manufacturing Bidg.
Q H - Plate Storage Building
~ I - Flammable Liquid Storage "B"
O J - Pallet Storage
O K - Coil Storage
~ L - Lithographing Building
~ M - Flammable Liquid Storage "A"
N - Truck & R.R. Shipping Bldg.
0 125 250
1" = 250'
MARTIN MARIETTA
-------
0W;3
IMMRIINPWIE®
MARTIN MMliliTTA
OW-1
Locations of SWMUs and AOC identified in 1989 PA/VSI
Locations of additional SWMUs and AOIs identified in 2007 CCR
BWAY property boundary
Sprayfield monitoring wells
, /
.#
SENCO
-------
Figure 4
Geologic Cross
Section
E
ro
$
LAJ
—I
UJ
600
J=FM/I
J=RUM
j=Rnvi
J=RSM
550
J=RCM
wWRPM
J=RCM
J=RNVI
500
J=Q/M
J=OJM
J=GTM
J=CSM
450
J=QPVI
J=€PM
J=CQVI
J=CNVI
400
s
Verticle Exaggeration ~ 50 ft.
~MESTONE:BEDROCIC(ARRROXIMATE)
£ £ £ £ L. . tl £. £ . c JL
z:
z:
modified from 1983 Burgess and Niple Hydrogeologic Investigation Report
'c a
t <8
# .5
>«!
©S
1 7
« 2>
© 55
<25
-------
Martin Marietta
Materials, Inc.
[GI osed [Quarrvl p o n d
SW/SED-01
SW/SED/PW-04
SW/SED/PW-OS
SW/SED-02
Martin Marietta
Materials, Inc.
SW/SED-03
Closed Quarry Pond
Site of planned
commercial/industrial
SW/SED/PW-06
,6w/d~ B-70
SENCO
PRODUCTS
INC.
- SW/SED-09
|SW/SED-07i
JW/SED
SENCO PRODUCTS INC.
FORMER DISCHARGE POND FOR
SANITARY WASTE WATER AND
UNTREATED INDUSTRIAL PROCESS
WASTEWATER INCLUDING OILS, J
METALS AND SPENT HALOGENATED AND
NONtHALOGENATED SOLVENTS USED IN
DEGREASING (F001, 002, 003, 005).
(Source: Ohio EPA Files;
EDR Database Radius Report)
- ^
Data Copyright © 2009, The Payne Firm, Inc^f ^ .
Additional public information data Copyright;© 2006
Orthophoto Courtesy CAGIS (http: cagi.s./'familtonzco^rg/). '
This map does not represent a legal document.¦
fltn^antended to serve as an aid in graphical representation only.
Monitoring well
—BWAY property boundary
GW contours (1' interval) based upon
field collected data 3/09/2015
SWMU, AOC, or AOI investigated area
RFI Sampling Locations
® Geoprobe Soil Sample Location
o Pore Water Sample Location
Collocated Surface Water and
Sediment Sample Location
Collocated Surface Water, Sediment,
and Pore Water Sample Location
n Shallow Wetland Soil Sample Location
TITLE
RFI SAMPLING LOCATIONS AND
GROUNDWATER FLOW
SW/SED-15
SW/SED-11
SW/SED-1A PROJECT
BWAY - RCRA Corrective Action
DATE
FIGURE
PROJECT NUMBER
DRAWN BY
TRC Environmental Corporation
CLOSED RUMPKE LANDFILL
(south across Broadwell Road)
SW/SED-12^
-¦*"
-------
Es
53
Figure 6: Regional Groundwater Elevations and Flow
SENCO PRODUCTS INC.
FORMER DISCHARGE POND FOR SANITARY WASTE WATER
AND UNTREATED INDUSTRIAL PROCESS
WASTEWATER INCLUDING OILS, METALS AND SPENT
HALOGENATED AND NON-HALOGENATED SOLVENTS
USED IN DEGREASING (F001, 002, 003, 005).
(Source: Ohio EPA Files; EDR Database Radius Report)
O Q_
CD E
.. X
E ^
-------
Figure 7: Groundwater Sampling Locations and Results
OW-6
DATE
T/D
AS
CR
FE
PB
MN
TL
PCE
TCE
VC
9/17/2014
T
1.4 J
18
1100
0.91 JB
44
0.12 JB
1.2
<1U
<1U
9/17/2014
D
0.84 J B
< 2 U
< 50 U
<1U
8
<1U
N/A
N/A
N/A
12/16/2014
T
1J
15 Bj
310 Bu
0.27 JBj
13
< 1 U
1.8
0.15 J
< 1 U
12/16/2014
D
0.91 JB
1.3 JB
< 50 Uu
< 1 Uj
6 B
< 1 U
N/A
N/A
N/A
3/9/2015
T
< 1.4 JBu
13 B
1000
0.84 JBu
34
<1U
1.8
<1U
<1U
3/9/2015
D
0.69 J
<1.4 JBu
< 50 U
<1U
5.1
<1U
N/A
N/A
N/A
5/19/2015
2.4 JB
19 B
2100
1.8
64
<1U
2
<1U
<1U
5/19/2015
D
1.2 JB
1.5 JB
< 50 U
0.17 JB
2 J
<1U
N/A
N/A
N/A
LEGEND
©
o
E
E
E
Groundwater Observation Well
Geoprobe Soil Sample Location
Pore Water Sample Location
Collocated Surface Water and
Sediment Sample Location
Collocated Surface Water, Sediment and
Pore Water Sample Location
Shallow Wetland Soil Sample Location
Pre-RFI soil samples
Groundwater Contours (11/5/2018)
Storm Sewer
~ Catch Basin or Storm Grate
BWAY Property Boundary
17771 SWMU, AOC, or AOI investigated area
Senco Discharge Lines
(sanitary and process wastewater)
¦iiiBinwiia Senco Parcels
OW-6D
DATE
T/D
AS
CR
FE
PB
MN
TL
TCE
VC
9/17/2014
T
13
35
3500
0.55 JB
240
0.12JB
<1U
<1U
9/17/2014
D
7.2 B
30
2200
0.32 J
240
< 1 U
N/A
N/A
12/16/2014
T
9.1
44 B
2900 B
<0.33 JBu
240
< 1 U
< 1 U
< 1 U
12/16/2014
D
5.1 B
1.3 JBj
< 50 U
<1U
230 B
<1U
N/A
N/A
3/9/2015
T
13 B
45 B
4000
< 1 Bu
300
<1U
<1U
<1U
3/9/2015
D
6.4
< 1.2 JBu
< 50 U
<1U
250
<1U
N/A
N/A
5/19/2015
T
8.1 B
2 B
1900
0.13 J
230
<1U
<1U
<1U
5/19/2015
D
5 B
2.6 B
MOB
0.17 JB
230
< 1 U
N/A
N/A
1/19/2017
T
21
19
6500 B
N/A
320
N/A
< 1 U
N/A
1/19/2017
D
4.9 J
< 2 U
<6.9 JBu
N/A
240
N/A
N/A
N/A
4/7/2017
T
10
<0.7 JBu
2000 B
N/A
260 B
N/A
<1U
N/A
4/7/2017
D
7.7
<0.32 JBu
< 100 Bu
N/A
260 B
N/A
N/A
N/A
7/13/2017
T
12 j
430
4900
N/A
270
N/A
< 1 U
N/A
7/13/2017
D
5.4
< 2 U
< 50 U
N/A
190
N/A
N/A
N/A
10/18/2017
T
11
6.2
2200
N/A
270
N/A
<1U
N/A
10/18/2017
D
6.6
< 2 U
< 50 U
N/A
260
N/A
N/A
N/A
3/28/2018
T
22 j
390
7300 j
N/A
370
N/A
< 1 U
N/A
3/28/2018
D
5.4
< 2 U
< 50 U
N/A
280
N/A
N/A
N/A
6/1/2018
T
5.6
3.4
2000
N/A
270
N/A
<1U
N/A
6/1/2018
D
3.5 J
< 2 U
< 50 U j
N/A
260 j
N/A
N/A
N/A
8/6/2018
T
9.6
< 2.1 B u
2400
N/A
240
N/A
< 1 U
N/A
8/6/2018
D
5.6
< 1.8 J B u
< 50 U uj
N/A
230
N/A
N/A
N/A
11/5/2018
T
7.3
< 2 U
1900
N/A
150
N/A
<1U
N/A
11/5/2018
D
5.5
< 2 U
< 50 U
N/A
170
N/A
N/A
N/A
OW-7
DATE
T/D
AS
CR
FE
PB
MN
TL
TCE
VC
9/17/2014
T
0.63 J
2.1
290
0.19 JB
47
0.11 JB
<1U
<1U
9/17/2014
D
0.57 JB
< 2 U
< 50 U
< 1 U
37
< 1 U
N/A
N/A
12/16/2014
T
1J
9.1 Bj
320 Bu
0.27 JBj
24
< 1 U
< 1 U
< 1 U
12/16/2014
D
0.85 JBj
2 Bj
< 50 U
< 1 U
11 Bj
< 1 U
N/A
N/A
3/9/2015
T
< 2.2 JBu
33 B
2200
1.4 B
120
< 1 U
< 1 U
< 1 U
3/9/2015
D
0.88 J
< 3.2 Bu
< 50 U
<1U
6.2
<1U
N/A
N/A
5/19/2015
T
2.3 JB
41 B
2100
1.2
96
<1U
<1U
<1U
5/19/2015
D
1.1 JB
1.4 JB
< 50 U
0.16 JB
6.5
<1U
N/A
N/A
OW-7D
DATE
T/D
AS
CR
FE
PB
MN
TL
TCE
VC
9/17/2014
T
4.8 J
13
6600
0.19 JB
53
0.077 JB
< 1 U
<1U
9/17/2014
D
1.9 JB
< 2 U
380
<1U
46
< 1 U
N/A
N/A
12/16/2014
T
6.4
50 B
7200 B
0.83 JBj
71
< 1 U
< 1 U
< 1U
12/16/2014
D
2.2 JBj
1.2 JBj
62 Bu
< 1 U
40 B
< 1 U
N/A
N/A
3/9/2015
T
7.7 B
26 B
7200
<0.33 JBu
57
< 1 U
< 1 U
<1U
3/9/2015
D
3.2 J
<1.3 JBu
270
< 1 U
46
< 1 U
N/A
N/A
5/19/2015
T
8.5 B
2.9 B
7200
0.63 J
71
< 1 U
< 1 U
< 1 U
5/19/2015
D
2.9 JB
1.6 JB
< 50 U
0.13 JB
44
< 1 U
N/A
N/A
OW-2
DATE
T/D
AS
CR
FE
PB
MN
TL
TCE
VC
9/17/2014
T
2.3 J
2.7
1500
2.8 B
72
1.5 B
<1U
<1U
9/17/2014
D
0.57 JB
< 2 U
< 50 U
< 1 U
< 5 U
< 1 U
N/A
N/A
12/16/2014
T
2.3 J
5.2 Bj
3200 B
5.6 B
160
0.28 J
< 1 U
< 1 U
12/16/2014
D
0.65 JBj
1.2 J Bj
< 50 U
<1U
< 5 U
<1U
N/A
N/A
3/9/2015
T
4.2 JB
< 6.2 Bu
7100
6.1 B
390
0.088 J
< 1 U
< 1 U
3/9/2015
D
0.76 J
<1.4 JBu
< 50 U
0.26 J
1.3 J
0.3 J
N/A
N/A
5/19/2015
T
1.8 JB
2.6 B
2000 j
1.7
61
<1U
<1U
<1U
5/19/2015
D
1.9 JB
1.6 JB
17 JB
0.42 JB
< 5 U
0.35 JB
N/A
N/A
12/5/2019
N
N/A
N/A
N/A
N/A
N/A
N/A
DRY
N/A
2/7/2020
N
N/A
N/A
N/A
N/A
N/A
N/A
<1U
N/A
6/30/2021
N
N/A
N/A
N/A
N/A
N/A
N/A
<1U
N/A
MW-4
DATE
T/D
TCE
12/5/2019
N
< 1 U
2/7/2020
N
< 1 U
6/30/2021
N
< 1 U
1
fc. ' '
f
C
W-3
DATE
T/D
AS
CR
FE
PB
MN
TL
TCE
VC
9/17/2014
T
7.6
7.3
20000
11 B
1200
0.44 JB
29
<1U
9/17/2014
D
0.5 JB
< 2 U
< 50 U
<1U
320
< 1 U
N/A
N/A
12/16/2014
T
4.7 J
6.1 Bj
12000 B
6 B j
1400
0.12 J
11
< 1 U
12/16/2014
D
0.61 JBj
1.1 JBj
< 50 U
< 1U
510 B
<1U
N/A
N/A
3/9/2015
T
4.5 JB
< 5.6 Bu
12000
6.5 B
890
0.096 J
11
< 1 U
3/9/2015
D
0.62 J
< 1.3 JBu
< 50 U
0.13 J
550
0.11 J
N/A
N/A
1
i
5/19/2015
T
3.3 JB
4.7 B
8400
4.6
820
<1U
20
<1U
5/19/2015
D
1.1 JB
1.4 JB
< 50 U
0.25 JB
220
0.15 JB
N/A
N/A
1/19/2017
T
1.7 J
0.99 J
3800 B
N/A
490
N/A
11
N/A
1/19/2017
D
0.39 J
< 2 U
< 50 U
N/A
270
N/A
N/A
N/A
4/7/2017
T
1.2 J
<1.2 JBu
2400 B
N/A
440 B
N/A
5.8
N/A
4/7/2017
D
0.45 J
< 2 U
< 50 U
N/A
440 B
N/A
N/A
N/A
7/13/2017
T
1.5 J
< 2 U
3400
N/A
490
N/A
22
N/A
7/13/2017
D
1J
< 2 U
1800
N/A
360
N/A
N/A
N/A
10/18/2017
T
< 5 U
< 2 U
1100
N/A
240
N/A
16
N/A
10/18/2017
D
< 5 U
< 2 U
< 50 U
N/A
260
N/A
N/A
N/A
3/28/2018
T
< 5 U
< 2 U
1600
N/A
370
N/A
13
N/A
3/28/2018
D
< 5 U
< 2 U
< 50 U
N/A
300
N/A
N/A
N/A
6/1/2018
T
0.96 J
< 2 U
2100
N/A
600
N/A
6.8
N/A
6/1/2018
D
< 5 U
< 2 U
< 50 U
N/A
140
N/A
N/A
N/A (
8/6/2018
T
< 5 U
< 2.1 B u
730
N/A
330
N/A
3.2
N/A
8/6/2018
D
< 5 U
< 1.8 J B u
< 50 U
N/A
250
N/A
N/A
N/A
11/5/2018
T
5.2
6.9
15000
N/A
850
N/A
12
N/A
11/5/2018
D
< 5 U
< 2 U
< 50 U
N/A
400
N/A
N/A
N/A
12/5/2019
N
N/A
N/A
N/A
N/A
N/A
N/A
DRY
N/A
2/17/2020
N
N/A
N/A
N/A
N/A
N/A
N/A
<1U
N/A
6/30/2021
N
N/A
N/A
N/A
N/A
N/A
N/A
< 1 U
N/A
OW-5
DATE
T/D
AS
CR
FE
PB
MN
TL
TCE
VC
9/17/2014
T
3.2 J
35
3000
1.8 B
270
0.26 JB
< 1U
0.43 J
9/17/2014
D
1.3 JB
< 2 U
< 50 U
< 1 U
220
<1U
N/A
N/A
12/16/2014
T
1.5 J
2.5 B
550 B
0.33 JB
33
0.087 J
< 1 U
< 1U
12/16/2014
D
0.94 JBj
1.1 JBj
< 50 U
< 1 U
15 Bj
< 1U
N/A
N/A
3/9/2015
T
9.2 B
22 B
9900
4.9 B
370
0.2 J
< 1U
<1U
3/9/2015
D
1J
< 1.2 JBu
< 50 U
< 1 U
20
<1U
N/A
N/A
5/19/2015
T
1.9 JB
3 B
940
0.6 J
23
< 1U
< 1 U
< 1U
5/19/2015
D
1.4 JB
1.4 JB
< 50 U
0.22 JB
1.2 J
0.14 JB
N/A
N/A
Notes
AN samples reported in UG/L (micrograms per liter); QA/QC Duplicate samples not shown on figure.
AS = Arsenic; CR = Chromium; FE = lron; PB = Lead; MN = Manganese; TL = Thallium;TCE = Trichloroethene; VC = Vinyl Chloride; PCE = Tetrachlorethene
RSL: USEPA Regional Screening Levels, November 2015 (Iron RSL= 15,000) (Manganese RSL = 480)
MCL: Maximum Contaminant Level enforceable standard of National Primary Drinking Water Regulations underSafe Drinking Water Act
(Arsenic MCL = 10) (Chromium MCL = 100) (Lead MCL = 15) (Thallium MCL = 2) (TCE MCL = 5) (Vinyl Chloride MCL = 2)
T/D: measured basis (metals only); T = total, D = dissolved
N/A: Not Analyzed
U: Test America Lab Qualifier. Nondetect.
J: Test America Lab Qualifier. Method blank contamination. The associated method blank contains the target analyte at a reportable level.
•: Test America Lab Qualifier. Estimated result. Result is less than the reporting limit.
TRC Qualifier. The analyte was not detected above the reporting sample quantitation limit. However, the reported quantitation limit is approx. and
may or may not represent the actual limit of quantitation necessary to accurately and precisely measure the analyte in the sample.
u: TRC Qualifier. The analyte was analyzed for, but was not detected above the level of the reported sample quantitation limit.
Note: 12/15/2019, 2/7/2020 and 6/30/2021 samples were collected for Mauser Packaging Solutions-BWay Corporation's Groundwater Management Plan
(DSWPTI#1216660).
SENCO PRODUCTS INC.
FORMER DISCHARGE POND FOR SANITARY WASTE WATER AND UNTREATED
INDUSTRIAL PROCESS
WASTEWATER INCLUDING OILS, METALS AND SPENT HALOGENATED AND NON-
HALOGENATED SOLVENTS
USED IN DECREASING (F001, 002, 003, 005).
(Source: Ohio EPAiFiles; EPR Database Radius Report)
;ent a legal document It is intended to serve as an aid
Data Copyright © 2021, TRC Environmental Corp. This map does not repi
in graphical representation only,; Information shown on this map is not warrartfe^for accuracy or fitness for any particular purpose.
Background Image: Google | '"•*
Groundwater Sample
Locations & Results
Since September 2014
OW-4
DATE
T/D
AS
CR
FE
PB
MN
TL
TCE
VC
9/17/2014
T
2 J
2.7
630
0.47 JB
64
0.29 JB
< 1 U
< 1 U
9/17/2014
D
1.5 JB
< 2 U
< 50 U
< 1 U
21
< 1 U
N/A
N/A
12/16/2014
T
2.3 J
61 B
1200 B
0.9 JBj
98
0.085 J
<1U
< 1U
12/16/2014
D
1.6 JBj
1.1 JBj
< 50 U
<1U
10 Bj
<1U
N/A
N/A
3/9/2015
T
< 1.8 JBu
< 2.7 Bu
160
<0.19 JBu
15
< 1 U
< 1 U
< 1 U
3/9/2015
D
1.6 J
< 1.2 JBu
< 50 U
< 1 U
3.3 J
0.092 J
N/A
N/A
5/19/2015
T
3.9 JB
HOB
3800
2.3
320
0.09 J
<1U
< 1U
5/19/2015
D
1.5 JB
1.5 JB
< 50 U
0.21 JB
31
0.13 JB
N/A
N/A
1/19/2017
T
1.6 J
0.63 J
430 B
N/A
49
N/A
< 1 U
N/A
1/19/2017
D
1.3 J
< 2 U
< 50 U
N/A
12
N/A
N/A
N/A
4/7/2017
T
1.2 J
0.63 JB
< 110 Bu
N/A
20 B
N/A
<1U
N/A
4/7/2017
D
1.2 J
< 2 U
<5.4 JBu
N/A
6.6 B
N/A
N/A
N/A
7/13/2017
T
1.3 J
1J
61
N/A
9.1
N/A
< 1 U
N/A
7/13/2017
D
1.4 J
< 2 U
< 50 U
N/A
4.3 J
N/A
N/A
N/A
10/18/2017
T
2.2 J
44 j
520 j
N/A
58
N/A
<1U
N/A
10/18/2017
D
1.1 J
< 2 U
<50 Uj
N/A
10
N/A
N/A
N/A
3/28/2018
T
1.5 J
6.3
380
N/A
27
N/A
< 1 U
N/A
3/28/2018
D
0.93 J
< 2 U
< 50 U
N/A
5.3
N/A
N/A
N/A
6/1/2018
T
1.1 J
< 2 U
< 50 U
N/A
7.4
N/A
<1U
N/A
6/1/2018
D
1.2 J
< 2 U
< 50 U
N/A
6.1
N/A
N/A
N/A
8/6/2018
T
1.3 J
< 7.4 B u
200
N/A
17
N/A
< 1 U
N/A
8/6/2018
D
0.92 J
< 2.4 B u
< 50 U uj
N/A
2-1J j
N/A
N/A
N/A
11/5/2018
T
2.9 J
16
2200
N/A
170
N/A
< 1 U
N/A
11/5/2018
D
1.2 J
< 2 U
< 50 U
N/A
19
N/A
N/A
N/A
OW-1
DATE
T/D
AS
CR
FE
PB
MN
TL
TCE
VC
9/17/2014
T
2.7 J
16
260
0.73 JB
9.2
0.99 JB
<1U
< 1U
9/17/2014
D
2.1 JB
0.4 J
< 50 U
0.12 J
3.6 J
0.11 J
N/A
N/A
12/16/2014
T
2.4 J
1.5 JBj
180 Bu
0.29 JBj
8.1
< 1 U
< 1 U
< 1 U
12/16/2014
D
2.3 J
1.4 JBj
< 50 U
0.17 J
<5 U
0.23 J
N/A
N/A
3/9/2015
T
2.6 JB
< 2.2 Bu
240
<0.44 JBu
10
0.19 J
<1U
< 1U
3/9/2015
D
2.2 J
< 1.4 JBu
< 50 U
0.16 J
< 5 U
0.21 J
N/A
N/A
5/19/2015
T
2.6 JB
9.4 B
170
0.28 J
10
0.091 J
< 1 U
< 1 U
5/19/2015
D
3.1 JB
1.6 JB
22 JB
0.34 JB
< 5 U
0.23 JB
N/A
N/A
12/5/2019
N
N/A
N/A
N/A
N/A
N/A
N/A
< 1 U
N/A
2/7/2020
N
N/A
N/A
N/A
N/A
N/A
N/A
<1U
N/A
6/30/2021
N
N/A
N/A
N/A
N/A
N/A
N/A
<1U
N/A
BWAY RCRA CORRECTIVE ACTION (RCRA-05-2007-0011)
FIGURE
August 2021
214114.0000
2
GIS
A
"A
TRC
11231 Cornell Park Drive
Cincinnati, Ohio 45242
513-489-2255 http://www.trcsolutions.com/
-------
Groundwater Statistics Tool
Site & Summary Statistics for Normal Data Sets with Normal Residuals
General Information
Analyst
BS
Date of Evaluation
1/7/2022
Site Name
Bway
Operable Unit
SWMU 11
Type of Evaluation
Attainment
Well Name/Number
OW-6D
Chemical of Concern
Dissolved Arsenic
Concentration Units
ug/L
Cleanup Level
10
Source of Cleanup Level
MCL
Confidence Level
95%
Risk of False Outlier Rejection
5%
Number of Results
8
Outliers present?
No
Number of Non-Detects
0
Trend Line
~ Detected Data
Cleanup Level
O Nondetected Data
¦ Upper Confidence Band
• Ordinary Least Squares
12
10
8
6
4 -
2 -
' *
1/19/2017
8/25/2017 3/31/2018
Date
11/4/2018
Trend Analysis
Trend Type
Normal
Method
Ordinary Least Squares
Is the Upper Confidence Band above the cleanup level?
NA
Slope
-0.00183
Intercept
84.5
R2
0.1286
Test Result
No trend
When concentration is predicted to achieve the cleanup
level
NA
When concentration is predicted to exceed the cleanup
level
NA
UCL Analysis
Distribution Type
Normal
Test
Student's t UCL
Mean
5.58
95% UCL
6.4
Is the 95% UCL greater than the cleanup level?
No
UCLfor Normal Data Set
Cleanup Level
~
UCL
Mean
~
~
Previous Step: Trend Screen
Previous Step: UCL Screen
Restart: Data Input Screen
-------
Groundwater Statistics Tool
Site & Summary Statistics for Nonparametric Data Sets with
Nonparametric Residuals
General Information
Analyst
BS
Date of Evaluation
1/7/2022
Site Name
Bway
Operable Unit
SWMU 23
Type of Evaluation
Attainment
Well Name/Number
OW-3
Chemical of Concern
Dissolved Iron
Concentration Units
ug/L
Cleanup Level
14000
Source of Cleanup Level
Risk Based PRG
Confidence Level
95%
Risk of False Outlier Rejection
5%
Number of Results
8
Outliers present?
Yes
Number of Non-Detects
0
~ Detected Data
Cleanup Level
16000
14000 -I-
12000 -
10000 -
8000 -
6000 -
4000
2000
Trend Line
O Nondetected Data
— — Upper Confidence Band
-Theil-Sen
1/19/2017
8/25/2017
3/31/2018
11/4/2018
Trend Analysis
Trend Type
Nonparametric
Method
Theil-Sen Line, Mann-Kendall Test
Is the Upper Confidence Band above the cleanup
level?
NA
Slope
0
Intercept
50
Test Result
No trend
When concentration is predicted to achieve the
cleanup level
NA
When concentration is predicted to exceed the
cleanup level
NA
UCL Analysis
Distribution Type
Nonparametric
Test
Chebyshev UCL
Mean
269
95% UCL
1220
Is the 95% UCL greater than the cleanup level?
No
UCL for Nonparametric Data Set
14000 -
SJ 12000 ¦
3
"§ 10000 -
I 8000 -
u
§ 6000 ¦
u
4000 ¦
2000 -
—Gleanup Level ^—
~
UCL
0 -
Previous Step: Trend Screen
Previous Step: UCL Screen
Restart: Data Input Screen
-------
Groundwater Statistics Tool
Site & Summary Statistics for Normal Data Sets with Normal Residuals
General Information
Analyst
BS
Date of Evaluation
1/7/2022
Site Name
Bway
Operable Unit
SWMU 23
Type of Evaluation
Attainment
Well Name/Number
OW-3
Chemical of Concern
Dissolved Manaanese
Concentration Units
ug/L
Cleanup Level
430
Source of Cleanup Level
Risk Based Concentration
Confidence Level
95%
Risk of False Outlier Rejection
5%
Number of Results
8
Outliers present?
No
Number of Non-Detects
0
Trend Line
~ Detected Data
Cleanup Level
O Nondetected Data Ordinary Least Squares
¦ Upper Confidence Band
600
500
400
300
200
100
1/19/2017
8/25/2017 3/31/2018
Date
11/4/2018
Trend Analysis
Trend Type
Normal
Method
Ordinary Least Squares
Is the Upper Confidence Band above the cleanup level?
NA
Slope
-0.0966
Intercept
4460
R2
0.0584
Test Result
No trend
When concentration is predicted to achieve the cleanup
level
NA
When concentration is predicted to exceed the cleanup
level
NA
UCL Analysis
Distribution Type
Normal
Test
Student's t UCL
Mean
303
95% UCL
367
Is the 95% UCL greater than the cleanup level?
No
UCLfor Normal Data Set
500
450
400
350
300
250
200
150
100
50
0
Previous Step: Trend Screen
Previous Step: UCL Screen
Restart: Data Input Screen
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Table 1: List of SWMUs, AOCs, and AOIs at the Bway Site
SWMU,
AOC or
AOI
Name
Description
RCRA Facility
Investigation
Recommended
per the CCR
Report
SWMU 1
Vapor Collection
System
Indoor system currently in operation and in
compliance with air emission standards.
None
SWMU 2
Volatile Vapor
Incinerators
The units incinerate vapors collected from the
vapor collection system. Emissions are permitted
as part of the facility's Title V air permit.
None
SWMU 3
Scraper Coating
Buckets
Units stored on concrete flooring inside the
building. No documented releases from the
indoor operations.
None
SWMU 4
Waste Coating
Buckets
Units stored on concrete flooring inside the
building. No documented releases from the
indoor operations.
None
SWMU 5
Satellite waste
accumulation
collection areas
Totes collect the spent solvents from operational
lines and bucket cleaning operations. Units are
closed-topped and stored on concrete flooring
inside the building. No documented releases
from the indoor operations.
None
SWMU 6
Satellite Scrap
Metal Collect
Area
The collection bins are stored on concrete
flooring inside the building. No documented
releases from the indoor operations.
None
SWMU 7
Scrap metal
bailers
Bailers were stored on concrete flooring inside
the building. No documented releases from the
indoor operations.
None
SWMU 8
Scrap metal
storage area
20-square foot storage area on concrete flooring
inside the building. No documented releases
from the indoor operations.
None
SWMU 9
Safety-Kleen
units (3)
Self contained solvent units are on concrete
flooring inside the building. No documented
releases from the indoor operations.
None
SWMU 10
#1 empty
product drum
storage area
Former outdoor empty drum storage area on an
unbermed concrete pad. Previous disposal
practices were not documented.
Yes
SWMU 11
#1 drummed
hazardous
waste storage
area
Former outdoor drum storage area for hazardous
wastes from two-piece can operations. Previous
disposal practices were not documented.
Yes
-------
SWMU 12
#2 empty
product drum
storage area
Former outdoor empty drum storage area on a
concrete pad. no investigation or closure reports
exist for this area. Past storage and handling
processes are not documented.
Yes
SWMU 13
#2 drummed
hazardous
waste storage
area
Former outdoor hazardous waste storage area
with an evidence of spills and releases. A 40 foot
by 120-foot storage pad was excavated in 1995.
No closure report exists for this area.
Yes
SWMU 14
Scrap yard
Former storage yard on an unbermed concrete
base used for the storage of metal piping and
equipment.
None
SWMU 15
Former
drummed
chrome-sludge
storage area
Former Outdoor area that stored drums of
chromium sludge on an unbermed concrete pad.
The area is currently used as a parking lot for
tractor trailers. No investigation or closure
reports exist for this area.
Yes
SWMU 16
Acid bath sump
Former stainless-steel sump located in an
enclosed concrete area with concrete flooring.
No documented releases from the indoor
operations. This area is now a warehouse for
storing cans.
None
SWMU 17
Acid waste
storage tanks
Former fiber glass above ground storage tanks
were stored on concrete flooring inside the
building. No documented releases from the
indoor operations.
None
SWMU 18
Neutralization
bath
Neutralized effluent was reportedly discharged
via a sewer line to an off-site gravel pit located
north of the Facility until 1987. No documented
releases from this area.
None
SWMU 19
Former chrome-
waste storage
tank
Former above ground holding tank for chromic
acid waste stored on a concrete floor inside the
building. No documented releases from the
indoor operations.
None
SWMU 20
Biological
treatment plant
This unit stored treated process wastewater
between 1987 and 1989. It is currently used for
treating sanitary wastes at the facility. The facility
has a permit with the Ohio EPA to treat and land
apply its sanitary wastewater.
None
SWMU 21
Wet well
5000- gallon concrete sump that collects the
treated sanitary effluent from the biological
treatment plan. The facility is required to test its
treated effluent on a semi-annual basis.
None
SWMU 22
Storage pond
The fenced half-acre storage pond currently
stores wastewater pumped from the
Yes
-------
wet-well until it is discharged through the land
application system.
SWMU 23
Land application
treatment area
The 4.5acre spray field received the discharged
treated process water through a slow rate spray
application system for two years from 1987 to
1989. TCE and metals were initially detected in
one of the monitoring wells. At present, the
treated sanitary water effluent is discharged in
this area through the drip irrigation system.
Yes
AOC A
Drummed
product storage
area
The former product drum storage existed as a
concrete pad near SWMUs #10 and 11. Leakage
was observed on to the pad from two drums
during the PA/VSI.
Yes
AOI B
Former process
wastewater
discharge line
Prior to the construction of the land application
treatment system, the treated effluent from the
acid wastewater treatment was discharged
through the inlet pipe in a 15-inch sewer line
running from the former process wastewater
treatment area to the off-site gravel pit lake.
Yes
AOI C
Historical debris
area
Two small ponds are present at a portion of the
bottom of the former gravel pit. Soil investigation
in 2002, did not detect any chemicals of concern
above the direct contact soil standard for
industrial use. In 2003, with the consent of Ohio
EPA and the Hamilton County this area was
cleared of the debris and resurfaced with
vegetative cover.
None
AOI D
Former Plant 9
underground
storage tanks
(5)
Five 4000-gallon chemical product USTs were
located on the northern portion of the facility.
Prior to the closure in 1989, two of the tanks may
have experienced collapsed vent lines.
Yes
AOI E
Former
underground
storage tanks
(5)
Of the five tanks that existed north of the D&l
building, three tanks were known to have
contained virgin product and materials and two
were waste storage tanks. The closure was
achieved in 1991 through the excavation and
post confirmation sampling. Xylene was detected
in a floor sample.
Yes
AOI F
Former gasoline
underground
storage tank
A 1000- gallon gasoline UST was excavated in
1991 and received the NFA letter from Ohio
BUSTR.
None
AOI G
Former fuel oil
underground
storage tank
A 10,000-gallon fuel oil (#2 heating oil) UST was
located west of the boiler house. The tank was
constructed of carbon steel and was excavated in
Yes
-------
1991. There is no documentation as to how long
this tank was in operation prior to closure.
AOI H
Former
compound
room
underground
storage tanks
Two 170-gallon tanks with non-petroleum mixers
with n-Hexane were removed in 1998. A closure
report was accepted by the Anderson Township
Fire department in 1999.
None
AOI 1
Former scrap
building
underground
storage tank
According to a 2002 phase 1 environmental site
assessment, this BUSTR-regulated UST was
cleaned, disconnected, and closed.
None
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U.S. ENVIRONMENTAL PROTECTION AGENCY
PENDING ADMINISTRATIVE RECORD
FOR THE
BWAY PACKAGING SITE
CINCINNATI, HAMILTON COUNTY, OHIO
ORIGINAL
STATEMENT OF BASIS
MARCH 1, 2022
SEMS ID: 972815
NO.
SEMS ID DATE
AUTHOR
RECIPIENT
TITLE/DESCRIPTION
PAGES
2004108
11/13/03
Hamilton County
General Health
District
Norman, M.,
Vorys, Sater,
Seymour and Pease
LLP
Historic Conditions Compiled
Report - 1977-2003
1140
2003990 9/13/07 Cisneros, J., U.S.
EPA
O'Connell, J., Administrative Order on Consent
Bway Corporation
19
2003991
1/14/08
The Payne Firm,
Inc.and Bway
Corporation
U.S. EPA Fourth Quarter 2007 Progress
Report
1831
2003992
4/14/08
The Payne Firm,
Inc.and Bway
Corporation
U.S. EPA First Quarter 2008 Progress
Report
1099
2004039
6/11/08
The Payne Firm,
Inc.and Bway
Corporation
U.S. EPA Statement of Work #1 - AOIB
and AOI I Integrity Test
2004040
6/16/08
The Payne Firm,
Inc.and Bway
Corporation
U.S. EPA Sampling and Analysis Plan #2 -
Direct Push Soil Investigation
2003993
7/14/08
The Payne Firm,
Inc.and Bway
Corporation
U.S. EPA Second Quarter 2008 Progress
Report
1627
2004041 8/11/08 The Payne Firm, U.S. EPA Sampling and Analysis Plan #3-
Inc.and Bway Surface Water, Sediment,
Corporation Sediment Pore Water and Shallow
Soil Investigation
13
2004107
10/8/08
The Payne Firm,
Inc.and Bway
Corporation
U.S. EPA
Quality Assurance Project Plan
172
-------
NO,
10
11
12
13
14
15
16
17
18
19
SEMS ID DATE AUTHOR RECIPIENT TITLE/DESCRIPTION PAGES
2003994
1/14/09
The Payne Firm,
Inc.and Bway
Corporation
U.S. EPA Fourth Quarter 2008 Progress
Report
751
2004002
4/14/09
The Payne Firm,
Inc.and Bway
Corporation
U.S. EPA First Quarter 2009 Progress
Report
1009
2004004
10/14/09
The Payne Firm,
Inc.and Bway
Corporation
U.S. EPA Third Quarter 2009 Progress
Report
1159
2004005
1/14/10
The Payne Firm,
Inc.and Bway
Corporation
U.S. EPA Fourth Quarter 2009 Progress
Report
1084
2004006
4/14/10
The Payne Firm,
Inc.and Bway
Corporation
U.S. EPA First Quarter 2010 Progress
Report
867
2004007 4/4/14 TRC
Environmental
Corporation and
Bway Corporation
U.S. EPA First Quarter 2014 Progress
Report - Tables and Figures
19
2004042 6/19/14 TRC U.S. EPA
Environmental
Corporation and
Bway Corporation
Memo re: Supplemental RFI - 6
Sampling and Analysis Plan No. 4
2004008 7/31/14 TRC U.S. EPA
Environmental
Corporation and
Bway Corporation
Second Quarter 2014 Progress
Report
233
2004009 10/28/14 TRC U.S. EPA
Environmental
Corporation and
Bway Corporation
Third Quarter 2014 Progress
Report
234
2004010 1/15/15 TRC U.S. EPA
Environmental
Corporation and
Bway Corporation
Fourth Quarter 2014 Progress 185
Report
-------
NO. SEMS ID DATE
20 2004011 4/14/15
AUTHOR RECIPIENT
TRC U.S. EPA
Environmental
Corporation and
Bway Corporation
TITLE/DESCRIPTION
First Quarter 2015 Progress
Report
21 2004012 7/14/15
TRC U.S. EPA
Environmental
Corporation and
Bway Corporation
Second Quarter 2015 Progress
Report
22 2004013 10/14/15
TRC U.S. EPA
Environmental
Corporation and
Bway Corporation
Third Quarter 2015 Progress
Report
23 2004038 3/4/16 Nielsen, M.,
Ramboll Environ
and Bway
Corporation
Thomas, J., U.S.
EPA
Response to Comments and
Revised Ecological Risk
Assessment
24 2003217 3/25/16
Kallini, K., TRC Thomas, J., U.S.
Environmental EPA
Corporation and
Bway Corporation
Memo re: Environmental
Indicator Documentation - CA750
Update
25 2003216 3/25/16
Kallini, K., TRC Thomas, J., U.S.
Environmental EPA
Corporation and
Bway Corporation
Documentation of Environmental
Indicator Determination - CA725
Update
26 2004014 4/15/16
TRC U.S. EPA
Environmental
Corporation and
Bway Corporation
First Quarter 2016 Progress
Report (Redacted)
27 2004036 10/6/16
28 2004035 10/6/16
U.S. EPA Public
U.S. EPA Public
Environmental Indicator - CA725
Current Human Exposures under
Control
Environmental Indicator - CA750
Migration of Contaminated
Groundwater under Control
PAGES
174
173
10
132
489
120
157
20
-------
NO. SEMS ID DATE
29 2004053 12/18/16
30 2004016 1/3/17
31 2004017 4/15/17
32 2004018 7/15/17
33 2004019 10/15/17
34 2004020 2/15/18
35 2004021 4/15/18
36 2004024 7/15/18
37 2004025 3/1/19
AUTHOR RECIPIENT TITLE/DESCRIPTION PAGES
TRC U.S. EPA Corrective Measures Proposal 221
Environmental (Redacted)
Corporation &
Ramboll Environ
US Corporation
and Bway
Cornoration
TRC
Environmental
Corporation and
Bway Corporation
U.S. EPA Data Quality Assessment and
Validation for the Fourth Quarter
2016 Groundwater Sampling
Event
37
TRC U.S. EPA First Quarter 2017 Progress 550
Environmental Report
Corporation and
Bway Corporation
TRC U.S. EPA Second Quarter 2017 Progress 49
Environmental Report
Corporation and
Bway Corporation
TRC U.S. EPA Third Quarter 2017 Progress 51
Environmental Report
Corporation and
Bway Corporation
TRC U.S. EPA Fourth Quarter 2017 Progress 51
Environmental Report
Corporation
TRC U.S. EPA First Quarter 2018 Progress 44
Environmental Report
Corporation
TRC U.S. EPA Second Quarter 2018 Progress 52
Environmental Report
Corporation and
Bway Corporation
TRC U.S. EPA Fourth Quarter 2018 Progress 1365
Environmental Report
Corporation and
Bway Corporation
-------
NO. SEMS ID DATE
AUTHOR
RECIPIENT TITLE/DESCRIPTION PAGES
38 2004034 3/1/19 TRC U.S. EPA Response to U.S. EPA Comments 12
Environmental (Redacted)
Corporation and
Bway Corporation
39
2003220 9/15/20
TRC
Environmental
Corporation and
Bway Corporation
U.S. EPA Bway Response to U.S. EPA
Comments - Draft Corrective
Measures Proposal
1071
40 972810 3/1/22 U.S. EPA
Public
Fact Sheet - EPA Announces
Proposed Cleanup and Final
Remedy
41 972811 3/1/22 U.S. EPA
Slide Presentation of Statement of
Basis - Proposed Remedy
12
42 972812 3/1/22 U.S. EPA
Bway Corporation Statement of Basis
36
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