SIXTH FIVE-YEAR REVIEW REPORT FOR
SKINNER LANDFILL SUPERFUND SITE
BUTLER COUNTY, OHIO
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Prepared by
U.S. Environmental Protection Agency
Region 5
Chicago, Illinois
3/22/2024
X Douglas Ballotti
Douglas Ballotti, Director
Superfund & Emergency Management Division
Signed by: DOUGLAS BALLOTTI
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Table of Contents
LIST OF ABBREVIATIONS & ACRONYMS 2
I. INTRODUCTION 3
FIVE-YEAR REVIEW SUMMARY FORM 4
II. RESPONSE ACTION SUMMARY 4
Basis for Taking Action 4
Response Actions 5
Status of Implementation 6
Institutional Controls 7
Systems Operations/Operation & Maintenance 9
III. PROGRESS SINCE THE LAST REVIEW 11
Community Notification, Involvement & Site Interviews 13
Data Review 13
Site Inspection 16
V. TECHNICAL ASSESSMENT 16
QUESTION A: Is the remedy functioning as intended by the decision documents? Yes 16
QUESTION B: Are the exposure assumptions, toxicity data, cleanup levels, and remedial action
objectives (RAOs) used at the time of the remedy selection still valid? Yes 17
VI. ISSUES/RECOMMENDATIONS 18
OTHER FINDINGS 19
VII. PROTECTIVE NESS STATEMENT 19
VIII. NEXT REVIEW 20
APPENDIX A - REFERENCE LIST 21
Figures and Tables
Table 1 Summary of Planned and/or Implemented ICs
Table 2 Protectiveness Determinations/Statements from the 2019 FYR
Table 3 Status of Recommendations from the 2019 FYR
Attachments
Attachment 1 Skinner Site Maps
Attachment 2 Trigger Levels
Attachment 3 Copy of Environmental Covenant
Attachment 4 Site Inspection Checklist
Attachments Newspaper Ad
Attachment 6 Mann-Kendall Concentration Trend Summary
Attachment 7 Comparison of Pilot Test to Pre-Pilot Test Dissolved Metal Concentrations
Attachment 8 Groundwater Elevation and Gradient Data (2014 - 2022)
Attachment 9 Groundwater Potentiometric Surface Maps
Attachment 10 Monitoring Well and Piezometer Hydrographs (2014 - 2022)
Attachment 11 Analytical Data Summary Tables (2016 - 2022)
Attachment 12 Statistical Analysis Output (2016 - 2022)
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LIST OF ABBREVIATIONS & ACRONYMS
ARARs Applicable or Relevant and Appropriate Requirements
BCDES Butler County Department of Environmental Services
bgs below ground surface
CD Consent Decree
CERCLA Comprehensive Environmental Response, Compensation, and Liability Act
CFR Code of Federal Regulations
CQA Construction Quality Assurance
DNAPL Dense Non-Aqueous Phase Liquid
EPA United States Environmental Protection Agency
FML Flexible Geomembrane Liner
FS Feasibility Study
FYR Five-Year Review
GCL Geosynthetic Clay Liner
GIS Groundwater Interception System
ICs Institutional Controls
LTPP Long Term Performance Plan
MCL Maximum Contaminant Level
NCP National Contingency Plan
NPL National Priorities List
O&M Operation and Maintenance
Ohio EPA Ohio Environmental Protection Agency
OU Operable Unit
PCBs Polychlorinated Biphenyls
PCOR Preliminary Close Out Report
PFAS perfluoroalkyl and polyfluoroalkyl substances
ppm parts per million
PRPs Potentially Responsible Parties
PTP Pilot Test Plan
RA Remedial Action
RAOs Remedial Action Objectives
RD Remedial Design
ROD Record of Decision
RPM Remedial Project Manager
Site Skinner Landfill Superfund Site
SVE Soil Vapor Extraction
SVOCs Semi-Volatile Organic Compounds
SWRAU Site Wide Ready for Anticipated Use
UAO Unilateral Administrative Order
UECA Uniform Environmental Covenants Act
VOCs Volatile Organic Compounds
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I. INTRODUCTION
The purpose of a Five-Year Review (FYR) is to evaluate the implementation and performance of a
remedy in order to determine whether the remedy is and will continue to be protective of human
health and the environment. The methods, findings, and conclusions of reviews are documented in FYR
reports such as this one. In addition, FYR reports identify issues found during the review, if any, and
document recommendations to address them.
The United States Environmental Protection Agency (EPA) is preparing this FYR pursuant to the
Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) Section 121,
consistent with the National Contingency Plan (NCP)(40 CFR Section 300.430(f)(4)(ii)), and considering
EPA policy.
This is the sixth FYR for the Skinner Landfill Superfund Site (Site). The triggering action for this statutory
review is the completion date of the previous FYR on March 27, 2019. The FYR has been prepared due
to the fact that hazardous substances, pollutants, or contaminants remain at the Site above levels that
allow for unlimited use and unrestricted exposure (UU/UE).
The Site consists of two Operable Units (OUs), both of which will be addressed in this FYR. OU1 was an
interim action to protect human health from any immediate potential risks. OU1 included Site fencing,
connections to the Butler County public water system for potentially affected local users of
groundwater, and groundwater monitoring. OU2 addressed potential future migration of Site
contaminants into groundwater and limited direct exposure to Site contaminants to humans through
source control measures (landfill cap and groundwater interception system).
The Skinner Landfill FYR was led by Scott Hansen, EPA Remedial Project Manager (RPM) for the Site.
Participants included Leslie Williams, State Project Manager with the Ohio Environmental Protection
Agency (Ohio EPA). The Potentially Responsible Parties (PRPs) were notified of the initiation of the FYR.
The review began on 4/4/2023.
Site Background
The Site is located approximately 15 miles north of Cincinnati, Ohio, near West Chester, Butler County,
Ohio, in Township 3, Section 22, Range 2. The entire Skinner property is comprised of approximately 78
acres of hilly terrain (Attachment 1). The Site (approximately 10.5-acre landfill) was used in the past for
the mining of sand and gravel and was operated for the landfilling of a wide variety of materials from
approximately 1934 through 1990. Materials deposited at the Site include demolition debris,
household refuse, and a variety of chemical wastes. The Site is bordered on the east by a Norfolk
Southern Railway Company right-of-way, on the south by the East Fork of Mill Creek, on the north by
wooded and agricultural land, and on the west by a gravel driveway and Cincinnati-Dayton Road.
The Site, which is part of the 78 acres, is fenced on all sides with locked access gates on the south and
west sides of the landfill site. The only structures on the landfill site are the metal electrical box located
near the south entrance gate and the gas vents. A gravel access road is located inside the fence on the
south and west sides of the landfill.
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In 1982, EPA conducted a limited Site investigation for the purpose of scoring the Site for inclusion on
the National Priorities List (NPL). The investigation showed that groundwater southeast of the buried
waste lagoon was contaminated with volatile organic compounds (VOCs). The Site was proposed for
the NPL in December 1982 and finalized in September 1983.
FIVE-YEAR REVIEW SUMMARY FORM
SITE IDENTIFICATION
Site Name: Skinner Landfill
EPA ID: OHD063963714
Region: 5
State: OH
City/County: West Chester/Butler County
NPL Status: Final
Multiple OUs?
Yes
Has the site achieved construction completion?
Yes
Lead agency: EPA
[If "Other Federal Agency", enter Agency name]:
Author name (Federal or State Project Manager): Scott Hansen
Author affiliation: EPA
Review period: 4/4/2023 - 10/30/2023
Date of site inspection: 10/4/2023
Type of review: Statutory
Review number: 6
Triggering action date: 3/27/2019
Due date (five years after triggering action date): 3/27/2024
II. RESPONSE ACTION SUMMARY
Basis for Taking Action
Contaminants of Concern (COCs)
The contaminants in soil, sediment, groundwater, surface water and leachate contributing the most
significantly to current and future site risks included: VOCs, such as carbon tetrachloride, vinyl chloride,
benzene, chloroform, dichloroethene and bis(2-chloroethyl)ether; pesticides, such as heptachlor,
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aldrin, dieldrin, chlordane, and hexachlorobenzene; polychlorinated biphenyls (PCBs), specifically
Arochlor 1254; and inorganic compounds, such as arsenic and cobalt.
Risk Characterization
Because the Site accepted a variety of wastes, numerous chemicals are present at the Site. Following
the remedial investigation, EPA conducted an evaluation to estimate the potential health or
environmental problems that could result if the Site was not remediated. EPA evaluated the health
risks associated with 114 different contaminants.
Human Health
The risk assessment (Rust, Inc., 1992) concluded that the potential routes of current and future
exposure above a Hazard Index (HI) of 1 and cancer risk above 1 x 10~4 included: ingestion of and direct
contact with contaminated soils; ingestion of affected groundwater; dermal contact with groundwater;
inhalation of chemicals that volatilize from groundwater to air during showering; and ingestion of and
direct contact with surface water and sediments during recreational activities. Inhalation of fugitive
dust and volatile chemicals was also evaluated qualitatively as a potential exposure route but did not
warrant a quantitative assessment because emissions from surface soil would likely be low. This is
because the most contaminated portion of the Site, the buried waste lagoon, is covered by up to 40
feet of demolition debris and is not considered a source of inhalation risk under the current conditions.
Ecological Risks
For ecological risks, it was also projected that, under the "no action" scenario, surface water standards
may be exceeded in the future in the East Fork of Mill Creek for the following compounds: benzene,
carbon tetrachloride, chloroform, 1,1,2,2-tetrachloroethane, toluene, 1,1,1- trichloroethane, 1,1,2-
trichloroethane, trichloroethene, bis(2-chloroethyl)ether, phenol, aldrin, dieldrin, and Aroclor 1254.
Response Actions
Past Response Actions
EPA organized the remedial action (RA) at the Site into two phases, by area of concern or OUs. The first
phase was for an interim action at OU1 to protect human health from any immediate potential risks.
EPA's Record of Decision (ROD) for the first OU interim action was signed on September 30, 1992 (EPA,
1992). The remedy selected in the ROD included Site fencing, connections to the Butler County public
water system for potentially affected local users of groundwater, and groundwater monitoring.
EPA signed the ROD for the second and final OU2 on June 4, 1993 (EPA, 1993). The 1992 interim
remedy was ultimately incorporated and finalized as part of the OU2 ROD. The major components of
the selected remedy included:
• Construction of a hazardous waste landfill cap over the waste-materials,
• Construction of a Groundwater Interception System (GIS),
• Diversion of upgradient groundwater flow,
• Monitoring,
• Institutional controls (ICs), and
• Soil vapor extraction (SVE).
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In September 2012, EPA issued an Explanation of Significant Differences (ESD) for the Site that
eliminated the need for the Skinner PRP work group to incorporate the upgradient groundwater
control remedy, a provision that was included in the 1993 ROD (EPA, 2012). The ESD concluded that
groundwater in contact with waste materials beneath the landfill cap has not resulted in
contamination of the groundwater above the site-specific Trigger Levels (Attachment 2) and does not
affect the protectiveness of the selected remedy.
Remedial Action Objectives (RAOs)
The remedial objective for OU1 is protection of human health only. Protection of the environment will
be achieved by future OUs that address contaminated groundwater and on-site sources of
contamination. The RAOs for the second and final OU2 addressed potential future migration of Site
contaminants into groundwater and limited direct exposure to Site contaminants to humans through
source control measures. The RA addressed the source of the contamination by intercepting and
treating on-Site groundwater. The function of this action was to control the landfill Site as a source of
groundwater contamination; to reduce the risks associated with the Site and reduce exposure to
contaminated materials; and to prevent untreated leachate from running off Site. The groundwater
response action includes long-term monitoring with Site-specific groundwater Trigger Levels. The site-
specific Trigger Levels were drawn from the risk assessment. If the site-specific groundwater Trigger
Levels are exceeded in downgradient groundwater monitoring wells, EPA will consider whether
additional RAs are necessary to address groundwater conditions. The ROD also required an
investigation to determine the feasibility for SVE in the granular soil adjacent to the buried lagoon.
Status of Implementation
EPA issued a Unilateral Administrative Order (UAO) (EPA, 1992) to the PRPs to implement the remedy
selected in the 1992 ROD (EPA, 1992). Several PRPs complied with the UAO and installed a fence
around the Site, completed connections to the Butler County public water system for potentially
affected local users of groundwater, and implemented groundwater monitoring from 1992 to 1994.
A Remedial Design (RD) Investigation was performed in 1994 to collect data required to assess the
feasibility of the SVE and to design the multi-media cap and the groundwater extraction/treatment
system (Rust, Inc., 1996). Based on the RD investigation, EPA determined that the installation of a SVE
system was not feasible.
Judge Weber of the Federal District Court in Cincinnati, Ohio, signed the Remedial Action Consent
Decree (CD) for implementation of the final OU remedy on April 2, 2001 (EPA, 2001). The PRP group
constructed the landfill cap and the GIS under the requirements of the CD. Construction began in April
2001 and was completed in September 2001.
The profile of the installed landfill cap from top down includes vegetative cover materials,
geocomposite drainage layer, flexible geomembrane liner (FML) primary barrier layer, geosynthetic
clay liner (GCL) secondary barrier layer, geocomposite gas venting layer and the prepared subgrade.
The GIS was installed to intercept and capture groundwater migrating from the landfill to the East Fork
of Mill Creek. Soils from two contaminated areas located outside the landfill area, but within the limits
of the Site, were excavated and moved to the on-Site landfill and incorporated under the landfill cap.
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Monitoring wells and piezometers were installed in and around the landfill to: 1) monitor the
groundwater elevation under the cap to determine contact with buried waste, and 2) assess the long-
term performance of the groundwater interception system (interception trench and cut-off wall) in
accordance with the Long-Term Performance Plan (LTPP) (see Systems Operations/Operation &
Maintenance) (Earth Tech, 2003).
The remedy also restricts physical access to the Site with a six-foot high fence with barbed wire at the
top, around the entire Site landfill perimeter. The fence is sufficient to prevent the public from easily
entering the Site landfill. The fence is posted with numerous visible warning signs to inform the public
of potential Site hazards. As stated earlier, nearby residences located southwest of the Site were
connected to a public water supply in order to prevent these residents from potential exposure to
contaminated groundwater.
The RA construction was completed at the Site in September 2001. A Preliminary Close Out Report
(PCOR), documenting sitewide construction completion was completed on September 27, 2001 (EPA,
2001).
In August 2007, Ohio EPA was notified via a complaint that assorted electronic waste (e-waste) was
being stored in open containers along the southwestern portion of the fence surrounding the Skinner
Landfill. Ohio EPA investigated the complaint and identified 78 one-cubic-yard cardboard containers of
crushed computer glass and a roll-off container of assorted computer parts, including intact monitors
and hard drives. The waste was being stored in an uncovered location and the weather was causing the
containers to deteriorate rapidly.
Ohio EPA sampled the waste material and determined it to be hazardous waste based on its high lead
content. In February 2008, Ohio EPA issued Notices of Violation to the waste generator and to Skinner
Demolition, requiring abatement of the illegal storage of hazardous waste. Neither party submitted a
compliance plan to Ohio EPA. In March 2008, Ohio EPA requested assistance from EPA with the
assessment, removal, and disposal of the hazardous waste.
EPA confirmed that the waste exceeded hazardous waste regulatory limits for lead. After both parties
failed to submit a response to EPA's Notice of Liability, EPA initiated a time-critical removal of the
hazardous waste. EPA and its contractors began the cleanup on June 9, 2008. Approximately 131 tons
of hazardous waste, including crushed cathode ray tubes, e-waste, and contaminated soil were
disposed of at the Michigan Disposal Waste Treatment Plant in Belleville, Michigan. EPA completed this
removal action on June 11, 2008.
Institutional Controls
ICs are non-engineered instruments, such as administrative and legal controls, that help to minimize
the potential for exposure to contamination and that protect the integrity of the remedy. ICs are
required to assure long-term protectiveness for any areas which do not allow for UU/UE. ICs are also
required to maintain the integrity of the remedy.
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The ICs currently in place for the Site are listed in Table 1 below. A map showing the area in which the
ICs apply is included in Appendix B, Attachment 3 to this FYR.
Table 1: Summary of Planned and/or Implemented ICs
Media, engineered
controls, and areas
that do not support
UU/UE based on
current conditions
ICs
Needed
ICs Called
for in the
Decision
Documents
Impacted
Parcel(s)
IC
Objective
Title of IC
Instrument
Implemented and
Date (or planned)
RA components such
as wells, and GIS
Yes
Yes
See
Attachment
3
Prohibits use
of land
underlying the
Site, and
assures the
integrity of
remedy
components
Environmental
Covenant
pursuant to Ohio
Uniform
Environmental
Covenants Act
(UECA), recorded
at Butler County,
Feb. 14, 2006
Landfill Cap
Yes
Yes
See
Attachment
3
Prohibits use
of land
underlying the
Site, and
assures the
integrity of the
landfill cap
Environmental
Covenant
pursuant to Ohio
Uniform
Environmental
Covenants Act
(UECA), recorded
at Butler County,
Feb. 14, 2006
Groundwater - area
that exceeds cleanup
levels
Yes
Yes
See
Attachment
3
Prohibits use
of
Groundwater
Environmental
Covenant
pursuant to Ohio
Uniform
Environmental
Covenants Act
(UECA), recorded
at Butler County,
Feb. 14, 2006
Status of Access Restrictions and ICs
Current compliance
The PRPs updated the title commitment and survey for the ICs in July 2009. Based on Site inspections
and interviews, EPA finds there is no evidence of a cap breach, and the existing use is consistent with
the objectives of the landfill cap and land use restrictions. EPA confirmed during the FYR Site
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inspection, the ICs remain in place and the objectives of the ICs are being met. In addition, the fence
and warning signs are in place.
Long-Term Stewardship
Long-term protectiveness at the Site requires compliance with use restrictions to assure the remedy
continues to function as intended. The original LTPP was approved in 2003 and EPA approved
reductions in the frequency and sampling parameters of the groundwater and surface water
monitoring program in 2009. It also includes procedures to ensure long-term IC stewardship including
regular inspections of the engineering controls and access controls at the Site, reviews of the ICs, and
semi-annual reports with results of the inspection and review and certification to EPA that ICs remain
in-place and are effective. The regular inspections are provided for in the LTPP and constitute long-
term stewardship at the Site.
Systems Operations/Operation & Maintenance
Operation and maintenance (O&M) activities are currently performed by Brown and Caldwell, a
contractor for the PRP group per the LTPP. The O&M activities include maintenance of the landfill cap,
the GIS and any other remedy components, whenever it is needed. In addition, monitoring wells and
surface water sampling events are conducted on a semi-annual basis. Inspections of all the remedial
components at the Site are conducted on a semi-annual basis.
In 2008, the Skinner PRP work group petitioned for a reduction in monitoring based on the lack of
confirmed exceedances of the Trigger Levels (Attachment 2) and general lack of detections in Site
groundwater and surface water above the quantitation limits for monitoring events. EPA approved the
petition on November 24, 2009, which included the following reductions in the monitoring program:
• Monitoring frequency reduced from quarterly to semi-annual.
• Sampling for VOCs and semi-volatile organic compounds (SVOCs), pesticides and PCBs reduced
to annual during the spring event.
• Monitoring well sample locations reduced from 11 to 7.
• Surface water sample locations reduced from 6 to 4.
• Data package deliverable from lab reduced number of compounds from Level II to Level III (data
validation).
• A contingency to further reduce the monitoring frequency from semi-annual to annual if data
trends remain consistent.
The revised monitoring program reductions went into effect in 2010.
In 2015, the Skinner PRP work group submitted a Pilot Test Plan (PTP) for idling the GIS. EPA verbally
approved the PTP in March 2016 and formally approved the PTP on December 16, 2016 (Brown and
Caldwell, 2016). The GIS was idled on March 31, 2016.
Pilot test monitoring during the first six years was performed in accordance with the approved PTP.
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The monitoring program employed during this FYR period of the pilot test is described below. The first
three years of monitoring were discussed in the previous FYR.
Year 4 (April 2019 through March 2020):
In accordance with recommendations in the PTP's Year 3 Summary Report (Brown and Caldwell, 2020),
the fourth year of monitoring was an annual event which was completed at the same monitoring well
and surface water locations as Years 1, 2, and 3. The samples were collected during the March 2020
annual event and analyzed for total and dissolved metals. The annual monitoring event was also used
for a semi-annual Site inspection that included visual observations made from the creek bed between
surface water sampling locations SW-50 and SW-52. These inspections were performed coincident with
the landfill and creek bank stabilization inspections that also includes collecting a complete round of
water levels from Site monitoring wells, piezometers, and accessible vapor probes for use in
preparation of a groundwater potentiometric surface map. An additional semi-annual Site inspection
was conducted in October 2019.
A small area of localized seepage from near the base of the creek bank was observed near the south
end of the northern gabion wall (see Figure 2 in Attachment 1) during both the Year 2 and Year 3 semi-
annual Site inspections that were not noticed during Year 1 quarterly Site inspections. In response to
EPA's recommendation in the Fifth FYR Report (EPA, 2019), the seep was to be sampled during the
semi-annual Site inspection in October 2019. However, no visible flow was observed at the seep at the
time of the October 2019 Site inspection. Therefore, the seep was sampled during the next sampling
event (i.e., the annual monitoring event in March 2020) when the seep was flowing.
Year 5 (April 2020 through March 2021):
In accordance with recommendations in the PTP Year 4 Summary Report (Brown and Caldwell, 2021),
the fifth year of monitoring was an annual event which was completed at the same monitoring well
and surface water locations as Years 1 through 4. The samples were collected during the March 2021
annual event and analyzed for total and dissolved metals, VOCs, SVOCs, pesticides, and PCBs. The
annual monitoring event was also used for a semi-annual Site inspection that included visual
observations made from the creek bed between surface water sampling locations SW-50 and SW-52.
These inspections were performed coincident with the landfill and creek bank stabilization inspections
and included a complete round of water levels from additional Site monitoring wells, piezometers, and
accessible vapor probes for use in preparation of a groundwater potentiometric surface map. An
additional semi-annual Site inspection was conducted in October 2020.
A small area of localized seepage from near the base of the creek bank was observed near the south
end of the northern gabion wall (see Figure 2 in Attachment 1) during the Year 2, Year 3, and Year 4
semi-annual Site inspections that was not noticed during Year 1 quarterly Site inspections. The seep
was first sampled during the annual monitoring event in March 2020, when the seep was flowing, and
again during the annual monitoring event in March 2021.
Year 6 (April 2021 through March 2022):
In accordance with recommendations in the PTP Year 5 Summary Report (Brown and Caldwell, 2022),
the sixth year of monitoring consisted of an annual monitoring event which was completed at the same
monitoring well and surface water locations as Years 1 through 5. The samples were collected in March
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2022 and analyzed for total and dissolved metals. The annual monitoring event was also used for a
semi-annual Site inspection that included visual observations made from the creek bed between
surface water sampling locations SW-50 and SW-52. These inspections were performed coincident with
the landfill and creek bank stabilization inspections that also includes collecting a complete round of
water levels from all Site monitoring wells, piezometers, and accessible vapor probes for use in
preparation of a groundwater potentiometric surface map. An additional semi-annual Site inspection
was conducted in November 2021.
A small area of localized seepage from near the base of the creek bank was observed near the south
end of the northern gabion wall (see Figure 2 in Attachment 1) during the Year 2 through Year 5 semi-
annual Site inspections that was not noticed during the Year 1 quarterly Site inspections. The seep was
first sampled during the annual monitoring event in March 2020, when the seep was flowing, and again
during the annual monitoring events in March 2021 and March 2022. The location has been identified
as S-01 and has been added as regular part of O&M activities at the Site.
On March 1, 2023, the PRP notified EPA that there was trespassing and vandalism on the Site in
October/November 2022. During the inspection, the PRP contractor noticed the fence was damaged in
a couple places and two gas vents and two piezometers on the landfill cap were also damaged. The Site
fence and the two piezometers have since been repaired but the two gas vents will need to be
repaired.
III. PROGRESS SINCE THE LAST REVIEW
This section includes the protectiveness determinations and statements from the last FYR as well as
the recommendations from the last FYR and the current status of those recommendations.
Table 2:
3rotectiveness Determinations/Statements from the 2019 FYR
OU#
Protectiveness
Determination
Protectiveness Statement
1
Protective
The OU1 interim remedy at the Site is protective of
human health and the environment. There are no
current exposure pathways and the remedy appears
to be functioning as designed. The connection of
nearby residents to the public water supply
eliminates the potential exposure to the source of
contamination. In addition, site fencing remains in
place and groundwater monitoring has been
conducted at the required frequency. This interim
remedy was ultimately incorporated and finalized as
part of OU2.
2
Short-term Protective
The OU2 remedy at the Site is currently protective
of human health and the environment. There are no
current exposure pathways and the remedy appears
to be functioning as designed. The landfill cap, the
GIS and the connection of nearby residents to the
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public water supply eliminate the source of
contamination and have achieved the remedial
objectives to minimize the migration of
contaminants to groundwater and surface water
and to prevent direct contact with, or ingestion of,
contaminants in soils and sediments. ICs, in the form
of an environmental covenant, have been
implemented to protect the remedy components,
and to protect against improper use of Site land and
groundwater resources. Compliance with effective
ICs will be ensured through long-term stewardship
by implementing, maintaining, monitoring and
enforcing effective ICs as well as maintaining the
Site remedy components. However, in order for the
remedy to be protective in the long-term, the
following action needs to be taken to ensure
protectiveness: sample the seep to make sure it is
not contaminated material or related to the recent
idling of the treatment system.
Sitewide
Short-term Protective
The Sitewide remedy at the Skinner Landfill
Superfund site currently protects human health and
the environment. There are no current exposure
pathways and the remedy appears to be functioning
as designed. The landfill cap, the GIS and the
connection of nearby residents to the public water
supply eliminate the source of contamination and
have achieved the remedial objectives to minimize
the migration of contaminants to groundwater and
surface water and to prevent direct contact with, or
ingestion of, contaminants in soils, groundwater and
sediments. ICs, in the form of an environmental
covenant, have been implemented to protect the
remedy components, and to protect against
improper use of Site land and groundwater
resources. Compliance with effective ICs is being
ensured through long-term stewardship by
implementing, maintaining, monitoring and
enforcing effective ICs as well as maintaining the
Site remedy components. However, in order for the
remedy to be protective in the long-term, the
following action needs to be taken to ensure
protectiveness: sample the seep to make sure it is
not contaminated material or related to the recent
idling of the treatment system.
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Table 3: Status of Recommendations from the 2019 FYR
ou#
Issue
Recommendations
Current Status
Current
Implementation
Status
Description
Completion
Date (if
applicable)
1
There is a
seep adjacent
to the gabion
wall on the
bank of the
East Fork of
Mill Creek.
Sample the seep to
make sure it is not
contaminated
material or related
to the recent idling
of the treatment
system.
Completed
The PRP sampled
the seep in 2020
- 2022. Results
are discussed in
Data Review
section below.
March 31,
2020
OTHER FINDINGS
In addition, the following recommendation was identified during the 2019 FYR and may improve
performance of the remedy and management of O&M but does not affect current nor future
protectiveness: clear out the overgrown areas around the fence and repair the fence, if necessary.
Status update: Overgrown areas around the fence have been cleared out and the fence has been
repaired when needed. This will be a continued task during the O&M activities.
IV. FIVE-YEAR REVIEW PROCESS
Community Notification. Involvement & Site Interviews
A public notice was made available by newspaper posting in the Journal News on March 17, 2024,
stating that there was a FYR and inviting the public to submit any comments to EPA (Attachment 5).
The results of the review and the report will be made available at the Site information repositories
located at MidPointe Library West Chester, West Chester Township Halland at:
www.epa.gov/superfund/skinnerlandfill. EPA will also place a public notice in the newspaper regarding
the completion of the FYR after the report is issued. No public comments were received.
Data Review
Groundwater monitoring has been occurring at this Site since August 2003. The Semi-Annual and
Annual PTP reports, March 2019 to March 2022, were reviewed by EPA as part of this FYR. The results
are discussed below.
Site inspections were performed semi-annually by Brown and Caldwell (PRP contractor) during the
third through the sixth year (March 2019 - March 2022) of the pilot test. During the Site inspections,
no adverse conditions were observed related to idling the GIS, nor were observations inconsistent with
those made prior to initiating the pilot test. For example, no additional ponded water or overland flow
toward the creek was observed in the vicinity of the slurry wall.
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A small area of seepage from the creek bank was observed near the south end of the northern gabion
wall (see Figure 2 in Attachment 1) during the Year 2 semi-annual Site inspections that was not noticed
during Year 1 quarterly Site inspections. Because the creek bank was not routinely inspected for seeps
prior to the pilot test it is unclear if this seep may have been present sporadically prior to idling the GIS.
The observed seep area was to first be sampled during the semiannual inspection conducted in
October 2019; however, the seep was dry at the time of the event. Therefore, it was sampled
(identified as location S-01) for the first time during the annual monitoring event conducted in March
2020, and again in March 2021 and March 2022 (identified as location SWX). No Trigger Level
exceedances for the seeps were noted for the detected parameters. The analytical results are
summarized in Attachment 9. The sampling of seep S-01 has been added to O&M monitoring activities
for the Site.
In addition, during an inspection in Fall 2022, it was noticed by the PRP contractor that the fence had
been breached (taken down) on the east and west side of the site. And some of vapor probes and
piezometers were damaged. The fence was repaired in Spring 2023. However, not all the piezometers
and vapor probes have been repaired yet.
Groundwater Elevations
Groundwater levels collected during the semi-annual inspections from Site monitoring wells,
piezometers and vapor probes during the years of the pilot test are summarized in Table 2 of
Attachment 8. Data included in Table 2 consists of the six years of the PTP plus the previous two years
of data for comparison. A representative groundwater potentiometric surface map for year 6 of the
PTP, as well as the map from the March 2016 monitoring event, just prior to initiating the PTP,
included for comparison, are provided in Attachment 9, while hydrographs for the monitoring wells
and piezometers for data collected from March 2014 through March 2022 are included in Attachment
10. A review of the groundwater level and elevation data for the six years of the PTP indicates the
following:
• Groundwater elevations during the six years of the PTP generally fall within the range observed
for the two years leading up to the PTP, with no apparent increasing trend at the monitored
locations since idling the GIS to begin the PTP, confirming that groundwater is not mounding
behind the slurry wall as a result of idling the GIS.
• The groundwater flow patterns and gradient(s) across the Site during the six years of the PTP
remain generally consistent with those from the two years preceding the PTP.
Groundwater, Surface Water and Seep Analytical Results
Data summary tables of the groundwater and surface water analytical results are included in
Attachment 11. The tabulated data includes data from the first six years of the pilot test monitoring in
addition to data collected in March 2016, just prior to idling the GIS and initiating the pilot test.
Review of the data summary tables associated with the first six years of the pilot test yield the
following results:
• No Trigger Levels were exceeded or approached during the six years of the PTP monitoring for
the analyzed parameters in the groundwater, surface water or seep samples. Confirmation
sampling of the low-level Trigger Level exceedances initially reported for chromium and lead
14
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from monitoring well GW-65 during the September 2017 sampling event, as well as subsequent
routine sampling, has confirmed that these exceedances were anomalous and the Trigger
Levels for those two metals have not been approached since. In fact, chromium concentrations
appear to be stable and lead concentrations show a decreasing trend.
• The PTP data are generally consistent with those obtained during the years leading up to the
PTP (prior to idling the GIS). Table 3 in Attachment 7 indicates the minimum and maximum
reported dissolved metals results for the five years preceding the PTP (2011 through March
2016) as well as for the six years of the PTP (April 2016 through March 2022). In many instances
some higher reported concentrations are sporadic and associated with a single event. These
types of detections are in data from both the pre-PTP and during the PTP. In addition, where
sporadic higher concentrations were reported during the PTP, they often remain within historic
concentration ranges and well below the associated Trigger Levels.
• A seep area periodically flows near the base of the creek bank just downstream of the northern
gabion structure. This seep area was not flowing during the October 2019 semi-annual
inspection but was successfully sampled for the first time during the March 2020 event. During
the March 2021 and 2022 semi-annual inspections and sampling events, the seep area was
flowing at a total flow rate of approximately three gallons per minute. Analytical data from the
seep area composite sample are well below the Trigger Levels and are generally consistent with
groundwater and surface water data at the Site, indicating that the seep does not pose a threat
to adversely impact water quality in the East Fork of Mill Creek.
Statistical Trend Analysis
The Mann-Kendall statistical test was used to assess the groundwater and surface water data trends
since the GIS was idled in March 2016. The statistical test was applied to those dissolved metals with
established Trigger Levels. This evaluation included assessing the trends of 15 parameters for 11 data
points from June 2016 through March 2022 for the eight monitoring wells and two surface water/creek
locations monitored, for a total of 150 statistical tests. The data were evaluated in terms of increasing,
stable, or decreasing trends with a 95% confidence level and the results are summarized in Table 4 of
Attachment 6. The statistical analysis output is provided in Attachment 12. Based on the analysis of the
six years of monitoring data since idling the GIS, the data showed the following trends:
• Ten statistically significant decreasing trends were identified, with data well below the
associated Trigger Levels.
• Four statistically significant increasing trends were identified for just three parameters and
three monitoring wells. These trends were for monitoring wells GW-7R (antimony and nickel),
GW-59 (nickel), and GW-61 (barium). In each case the reported concentrations are well below
the associated Trigger Levels, ranging from 7X to more than 30X lower than the corresponding
Trigger Level. Additional rounds of data are needed to further evaluate these trends and
whether they are significant and sustained over time.
• 75 stable trends where concentration trends were neither statistically increasing nor decreasing
but the data were well below the associated Trigger Levels. For these data sets the slope of the
trend line was zero.
15
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• 24 data sets where the data were non-detect and therefore concentrations are considered
stable.
• 37 data sets were identified where no trend was apparent, but the data were well below the
associated Trigger Levels. For these data sets, the slope of the trend line was not zero;
however, no statistically significant trend was identified.
The Site inspections and monitoring results confirm that the remedy has been and continues to be
effective at protecting human health and the environment with no exceedances of applicable Trigger
Levels.
Site Inspection
The inspection at the Site as part of this FYR was conducted on October 4, 2023. In attendance were
Scott Hansen, EPA; Leslie Williams, Ohio EPA; two staff members from Brown and Caldwell and three
members of the Skinner PRP work group. In addition, local law enforcement (West Chester Police)
attended so that we had an escort while onsite. The purpose of the inspection was to assess the
protectiveness of the remedy, including the presence of fencing to restrict access, the integrity of the
landfill cap, and general conditions of the Site.
A drive was taken around the landfill. Site access is available through a locked gate which encloses the
Site landfill. The Site Inspection Checklist was completed by EPA and is included as Attachment 4.
The landfill cap over the Site appeared to be in good condition and well vegetated. However, some
areas around the fence were overgrown with smaller trees and bushes. Two gas vents and two
piezometers were damaged. The landfill cap needs to be mowed.
V. TECHNICAL ASSESSMENT
QUESTION A: Is the remedy functioning as intended by the decision documents? Yes
Question A Summary:
Remedial Action Performance: The remedies selected in the 1992 ROD for the first OU interim
action and the 1993 final ROD have been implemented and remain functional, operational and
effective. As long as the Site hazardous waste cap continues to be maintained and monitored,
and the security perimeter fence is maintained, the source area remedies will ensure that the
Site remains protective. As mentioned above, in 2015, the Skinner PRP workgroup submitted a
PTP for idling the GIS. EPA verbally approved the PTP in March 2016 and formally approved the
PTP on December 16, 2016 (Brown and Caldwell, 2016). The GIS was idled on March 31, 2016.
Idling the GIS system has not impacted the protectiveness of the remedy.
System Operations/O&M: O&M is performed by the PRP in accordance with the LTPP. No
early indicators of potential remedy failure were noted during the review. Maintenance
activities have been fairly consistent although the Site inspection identified some areas around
the fence were overgrown with smaller trees and bushes, some vapor probes and piezometers
16
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were damaged, and the landfill cap needs to be mowed. As mentioned above, on March 1,
2023, the PRP notified EPA that there was trespassing and vandalism on the Site in
October/November 2022. During the inspection, the PRP contractor noticed the fence was
damaged in a couple places and gas vents and piezometers on the landfill cap were also
damaged. The Site fence and two piezometers have since been repaired but the two gas vents
will need to be repaired. An updated O&M plan was submitted to the Agencies for review in
May 2023. EPA and Ohio EPA will review and comment on the updated plan in 2024.
Implementation of Institutional Controls and Other Measures: Access controls (e.g., fencing
and warning signs) are in place and effective. The 1993 ROD remedy included the
implementation of proprietary controls and other ICs to prevent future development of the
Site, assure the integrity of the RA, and prohibit the use of Site groundwater as a drinking water
source. These controls were required to protect the integrity of the landfill cap, the GIS, and all
other components of the RA. On February 14, 2006, an environmental covenant, (Attachment
3) under the Ohio version of the UECA, was recorded in the land records for the Site. The
environmental covenant implements the ROD requirements. Compliance with the ICs will be
ensured through long-term stewardship by implementing, maintaining, monitoring, and
enforcing effective ICs as well as maintaining the Site remedy components per the procedures
in the LTPP.
QUESTION B: Are the exposure assumptions, toxicity data, cleanup levels, and remedial action
objectives (RAOs) used at the time of the remedy selection still valid? Yes
Question B Summary:
Changes in Standards and To Be Considered: All standards outlined in the September 1992
and June 4, 1993, RODs and the 2012 ESD are still valid at the Site.
Changes in Exposure Pathways: No changes in the Site conditions that affect exposure
pathways were identified as part of the FYR. However, based on the types of wastes disposed at
the Site, there is potential for emerging contaminants perfluoroalkyl and polyfluoroalkyl
substances (PFAS) and 1,4-dioxane to be present; therefore, an issue and recommendation are
included in this FYR. If emerging contaminants are present, a complete human exposure
pathway via groundwater is not expected because as part of remedy implementation nearby
residences located southwest of the Site were connected to a public water supply in order to
prevent these residents from potential exposure to contaminated groundwater. In addition,
effective ICs are in place to prevent use of the groundwater.
Changes in Risk Assessment Methodologies: No changes in risk assessment methodologies
were identified.
QUESTION C : Has any other information come to light that could call into question the protectiveness
of the remedy? No
No other information has come to light that calls into question the protectiveness of the
remedy. In addition, there are currently no impacts from climate change or natural disasters.
17
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18
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VI. ISSUES/RECOMMENDATIONS
Issues/Recommendations
OU(s) without Issues/Recommendations Identified in the Five-Year Review:
OU1
Issues and Recommendations Identified in the Five-Year Review:
OU(s): OU2
Issue Category: Monitoring
Issue: Determine if 1,4-Dioxane and PFAS are impacting the Site.
Recommendation: Conduct groundwater sampling for 1,4-dioxane and
PFAS at the Site to check if they are present.
Affect Current
Protectiveness
Affect Future
Protectiveness
Party
Responsible
Oversight Party
Milestone Date
No
Yes
PRP
EPA/State
12/31/2024
OU(s): OU2
Issue Category: Operations and Maintenance
Issue: Smaller trees and bushes have overgrown around the fence. Landfill
cap needs to be mowed.
Recommendation: Clear out the overgrown areas around the fence, and
repair the fence, and mow the cap.
Affect Current
Protectiveness
Affect Future
Protectiveness
Party
Responsible
Oversight Party
Milestone Date
No
Yes
PRP
EPA/State
9/30/2024
OU(s): OU2
Issue Category: Operations and Maintenance
Issue: Gas vents are damaged on the landfill cap.
Recommendation: Repair all damaged gas vents.
19
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Affect Current
Protectiveness
Affect Future
Protectiveness
Party
Responsible
Oversight Party
Milestone Date
No
Yes
PRP
EPA/State
12/31/2024
OTHER FINDINGS
In addition, the following are recommendations that were identified during the FYR and may improve
performance of the remedy, reduce costs, improve management of O&M, accelerate site close out,
conserve energy, promote sustainability, but do not affect current nor future protectiveness:
• An updated O&M plan was submitted to the Agencies for review in May 2023, which included
proposed monitoring and inspection changes (frequency) and GIS equipment removal. EPA and
Ohio EPA will review and comment on the updated plan in 2024.
VII. PROTECTIVENESS STATEMENT
Protectiveness Statement(s)
Operable Unit: 1 Protectiveness Determination:
Protective
Protectiveness Statement: The OU1 interim remedy at the Site is protective of human health
and the environment. There are no current exposure pathways, and the remedy appears to be
functioning as designed. The connection of nearby residents to the public water supply
eliminates the potential exposure to the source of contamination. In addition, site fencing
remains in place and groundwater monitoring has been conducted at the required frequency.
This interim remedy was ultimately incorporated and finalized as part of OU2.
Protectiveness Statement(s)
Operable Unit: 2 Protectiveness Determination:
Short-term Protective
Protectiveness Statement: The OU2 remedy at the Site is currently protective of human health
and the environment. There are no current exposure pathways, and the remedy appears to be
functioning as designed. The landfill cap, the GIS and the connection of nearby residents to
the public water supply eliminate the source of contamination and have achieved the remedial
objectives to minimize the migration of contaminants to groundwater and surface water and
to prevent direct contact with, or ingestion of, contaminants in soils and sediments. ICs, in the
form of an environmental covenant, have been implemented to protect the remedy
20
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components, and to protect against improper use of Site land and groundwater resources.
Compliance with effective ICs will be ensured through long-term stewardship by
implementing, maintaining, monitoring, and enforcing effective ICs as well as maintaining the
Site remedy components. However, in order for the remedy to be protective in the long-term
the following actions need to be taken to ensure protectiveness: conduct sampling of 1,4-
Dioxane and PFAS to determine if they are present at the Site, maintain the cap area and repair
damage to perimeter fencing, and repair damaged gas vents to ensure all monitoring locations
are functioning appropriately.
Sitewide Protectiveness Statement
Protectiveness Determination:
Short-term Protective
Protectiveness Statement: The Sitewide remedy at the Skinner Landfill Superfund site currently
protects human health and the environment. There are no current exposure pathways, and
the remedy appears to be functioning as designed. The landfill cap, the GIS and the connection
of nearby residents to the public water supply eliminate the source of contamination and have
achieved the remedial objectives to minimize the migration of contaminants to groundwater
and surface water and to prevent direct contact with, or ingestion of, contaminants in soils,
groundwater and sediments. ICs, in the form of an environmental covenant, have been
implemented to protect the remedy components, and to protect against improper use of Site
land and groundwater resources. Compliance with effective ICs is being ensured through long-
term stewardship by implementing, maintaining, monitoring, and enforcing effective ICs as
well as maintaining the Site remedy components. However, in order for the remedy to be
protective in the long-term the following actions need to be taken to ensure protectiveness:
conduct sampling of 1,4-Dioxane and PFAS to determine if they are present at the Site,
maintain the cap area and repair damage to perimeter fencing, and repair damaged gas vents
to ensure all monitoring locations are functioning appropriately.
VIII. NEXT REVIEW
The next FYR report for the Skinner Landfill Superfund Site is required five years from the completion
date of this review.
21
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APPENDIX A - REFERENCE LIST
• Fifth Five-Year Review Report, EPA, March 2019
• Explanation of Significant Differences, EPA, September 2012
• RA Consent Decree, EPA, April 2001
• Record of Decision, EPA, September 1992
• Record of Decision, EPA, June 1993
• Summary reports from the PTP, Brown and Caldwell, 2019 - 2022
• Remedial Design, Rust, 1996
• Baseline Risk Assessment and Feasibility Study (FS), Rust, 1992.
• Phase II Rl, Rust, May 1991
• Pilot Test Plan, Brown and Caldwell, 2016
• Long-Term Performance Plan (Systems Operations/Operation & Maintenance), Earth Tech,
2003
• Preliminary Close Out Report, EPA, 2001
22
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Attachment 1
Skinner Site Maps
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N
I
Source: Google Earth
NOT TO SCALE
1
Brown and
Caldwell i
i
Figure 1
Site Vicinity Map
Skinner Landfill
Butler County, Ohio
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GAS VENT
GAS PROBE
GROUND WATER MONITORING WELL
PIEZOMETER
-f- OUTFALL SURFACE WATER RUN OFF SAMPLE LOCATION
CREEK SURFACE WATER SAMPLE LOCATION
OBSERVATION WELL
GROUNDWATER INTERCEPTION TRENCH AND SUMP
SLURRY WALL
EAST FORK OF MILL CREEK
ORIGINAL SAMPLE LOCATION ELIMINATED FROM MONITORING PROGRAM IN 2009
CURRENT MONITORING PROGRAM SAMPLE LOCATION
FENCELINE
23
GW-650
GW-65g
¦ x
SKINNER LANDFILL
SITE MAP AND MONITORING PROGRAM
FIGURE
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Attachment 2
Trigger Levels
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Skinner Landfill
Operation & Maintenance-Long Tern Performance Plan
TABLE 9
REVISED MODIFIED TRIGGER LEVELS
Compound
Units
Modified
Trigger Limit
Volatile Organic Compounds
1,1,1-Trichloroethaiie
ug/l
88
1, S ,2,2-1 etracMoraethane
ug/l
107
1,1,2- I'ricliioroethane
ug/1
418
1,2-DicMoroethane
ug/i
5
1,2-DicHoroetbane(total)**
ug/l
70
1,2-DicMoropropan.e
Bg/1
5
2-Butanone
ug/1
71
Benzene
Ug/l
5
Carbon Tetrachloride
ug/1
5
Chlorobenzeiie
ug/l
26
CMoroform
ug/l
79
Ethylbeiizeiie
ug/l
62
Styrene
ug/l
56
Tetrachloroethene
ug/l
5
Toluene
Ug/l
1000
Trichloroethene
ug/l
5
Vinyl Chloride
ug/l
2
Xylene (total)
ug/l
10000
Semi-V olatile Organics
1,2,4-TricMorobenzene
ug/l
77
1,2-DicMorobenzene
ug/l
11
1,3 -Diehlorobenzene
Ug/l
600
1,4-Dichlorobenzene
ug/l
75
2,2'-oxybis-(l -Chloropropane)#
Ug/l
4360
2.4-DimethvlDhenol
asfl
2120
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Skinner Landfill
Operation & Maintenance-Long Term Performance Plan
TABLE 9 .
REVISED MODIFIED TRIGGER LEVELS
Compound
Units
Modified
Trigger Limit
4-Nitroph.enol
ug/1
150
Acenaphthene
ug/1
520
Benzo(a)antliraceiie
ug/1
10
Benzo(a)pyrene
Ug/1
10
Benzo(b)fluoranthene ¦
• ug/1
10
Benzo(g,h,i)perylene
ug/1
10
B enzo(k)fluor3fltiiene
ug/1
10
bis(2-CHoroethyl)Etiier
¦Ug/1
• 13.6
bis(2-Ethylliexyl)pMhalate
ug/1
49
Butylbenzylphthalate
Ug/1
10
Chiysene
Ug/1
10
Di-n-butylphtfaalate
ug/1
190
D i b enzo{ a ,h)an thrac cnc
ug/1
,10
Dimethylphthalate
ug/1
73
Fluoranthene
Ug/1
. • 10
Hexachloroefhaiie
Ug/1
10
Indeno(l,2,3-cd)pyrene
Ug/1'
10
Isophorone
ug/1 - •
900
Naphthalene
ug/1
44
Nitrobenzene
Ug/1
27000
Phenantiirene
Ug/1
10
Phenol
Ug/1
370
Inurgaiilcs
Antimony
ug/1
60
Arsenic
ug/1
10
Barium
ug/1
1000
Beryllium
ug/1
5
Cadmium
ug/1
5
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Skinner Landfill
Operation & Maintenance-Long Term Performance Plan
TABLE 9
REVISED MODIFIED TRIGGER LEVELS
Compound
Units
Modified
Trigger Limit
Chromium'
ug/1
11
Copper
ug/1
25
Iron
ug/1
5000
Lead-
ug/1
4,2
Mercury
ug/1
0.2
Nickel
ug/l
96
Selenium
ug/1
5
Silver
ug/1
10
Thallium
ug/l
40
Zinc
ug/1
86
Cyanide
ug/1
10
Only parameters with existing Table 1 trigger levels were evaluated.
# Previously known by the name bis(2-Chloroisopropyl)efiier.
** Existing trigger for cis isomer is 70 ug/1, trans isomer is 100 ug/1.
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Attachment 3
Copy of Environmental Covenant
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ENVIRONMENTAL COVENANT
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