John F. Bushelman Construction, Inc. 11980 Runyan Drive ... · EPA Region 5 Records Ctr. Karl S. Bourdeau (202)789-6019 [email protected] LAW OFFICES BEVERIDGE & DIAMOND, P. C

EPA Region 5 Records Ctr.

Karl S. Bourdeau(202)[email protected]

LAW OFFICES

BEVERIDGE & DIAMOND, P. C.SUITE 7OO

I35O I STREET, N.W.WASHINGTON, D. C. 2OOO5-33II

(2OZ) 789-6OOO

TELECOPIER (202)789-61 SO

February 28, 1997

275718

4OTH FLOOR

437 MADISON AVENUflNEW YORK, N. Y. IOO22-7;i8O

(2I2J7O2-54OO

BEVERIDGE & DIAMONDSUITE 4OO

ONE BRIDGE PLAZAFORT LEE, N. J. O7O24-71JO2

(200SSS-8I62

BEVERIDGE & DIAMONDSUITE 34OO

ONE SANSOME STREETSAN FRANCISCO, CA 94IO4-4438

(4I5)397-OIOO

John F. Bushelman Construction, Inc.11980 Runyan DriveCincinnati, OH 45241

SKINNER LANDFILL SUPERFUND SITE

Dear Sir or Madame:

This firm represents a group of companies, including The Dow Chemical Company, Ford MotorCompany, GE Aircraft Engines, Morton International, PPG Industries, Inc., and VelsicolChemical Corporation (hereinafter "the Group"), in an action to be filed on their behalf in March1997 in the United States District Court for the Southern District of Ohio. The Group consists ofcompanies that have incurred response costs associated with the Skinner Landfill in WestChester, Ohio ("the Site") and are parties to a Unilateral Administrative Order and Consent Orderv/ith the United States Environmental Protection Agency ("EPA") regarding certain activities atthe Site. The Complaint will seek from you and a number of other defendants recovery of costsincurred and to be incurred by the Group.

Most of the defendants have already received some background information about the SkinnerLandfill from EPA. Upon information and belief, the Site was used for waste disposal from the1930s until the late 1980s. The Site was operated as a family-owned business from the time theSkinners purchased the property (in or around 1947). All members of the Skinner family thatworked at the Site have been deposed or interviewed regarding operations of the landfill andidentification of PRPs. In addition, Elsa Skinner, who maintained the accounting records for theSkinner business for the entire time it was in operation, provided an accounting ledger spanningthe period 1955 to 1987.

Many parties have already received nexus data that describe the evidence allegedly tying them 1othe Site. Enclosed with this letter is an additional package referencing your alleged nexus to theSite. This information was obtained through the efforts of EPA and the Group. EPA conducted aResponsible Party Search, took several administrative depositions and conducted several witnessinterviews, and obtained responses to Section 104(e) requests for information from a number ofPRPs. The Group hired an investigator to identify additional PRPs and to interview individuals

BEVERIDGE & DIAMOND, P. C.

with knowledge of the Site and its customers during the years of operation.-

As we mentioned above, the Group intends to file its Complaint in March, but will temporarilyrefrain from serving the Complaint on you in the hope that the parties can reach consensus on artAlternative Dispute Resolution ("ADR") process to be conducted in lieu of traditional litigation.We believe that this approach is more equitable and cost effective for all the parties concerned.As you know, EPA has already endorsed such an approach in this case to bring about anallocation that is fair, reasonable, and acceptable to the parties.

As you know, there is a meeting scheduled for March 11, 1997 in Cincinnati to discuss these andother issues. We will provide to you shortly before or at that meeting a model ADR protocol thatwe would like to use as a starting point for developing a consensual ADR process. The Groupwants to stress that you and your client will have input on the type of allocation process that willbe most effective for this particular Site. We anticipate using the next month to entertaincomments on the ADR procedure and to develop an acceptable ADR process.

We encourage you to attend the March 11th meeting. If you have any questions before then,please feel free to call me at (202) 789-6019, Fred Wagner of my office at (202) 789-6041, orMichael Kay at (517) 636-7872.

Sincerely yours,

Karl S. Bourdeau

On Behalf of: The Dow Chemical Company,Ford Motor Company, GE Aircraft EnginesMorton International, PPG Industries, Inc.Velsicol Chemical Corporation

Enclosures

J/ At the request of EPA, the nexus materials have been redacted in an initial effort to protect the privacy ofnon-Skinner family member witnesses. We anticipate that full, unredacted versions of the nexus materials will beprovided to cooperating PRPs during the course of the ADR proceedings.

Skinner AccountingLog Entry Summaries

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SKINNER UNDF1LL PRPS

HAMILTON WEST APTS. (He. ji »O,.HO» -c- UOO-IUWM cu n, onllo. 4I51Z| Jn.rcavUl., OH 43241

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HOWARD COSSACE

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JAMES etuis, coNTtACTORIOHN F. BUSHELHAM CONST

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HAMILTON WEST AFTS. (He. J» »u

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Skinner Site ContractWorker Sworn

Statement Excerpts

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IN RE: SKINNER LANDFILL SUPERFUND SITE.

SWORN STATEMENT OF

Taken by John Breslin, Esq., at

the Stewart Potter United States Courthouse, 100

Main Street, Room 248, Cincinnati, Ohio at 9:30

a.m. on November 8, 1994 before Lisa Conley, RPR, a

notary public within and for the State of Ohio.

RECEIVED

DEC 0 2 1994Legal Department

SPANGLER REPORTING SERVICES

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APPEARANCES:

John Breslin, Esq.

Charles H. Tisdale, Jr., Esq.

Mr. Joseph Kawecki

Ms. Karen Lauzon

Lisa Conley, RPR, Court Reporter-Notary Public

I N D E X

WITNESS EXAM FURTHER EXAM

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MR. BRESLIN: My name is John

Breslin. I'm an attorney with the Environmental

Protection Agency. To my right is Joe Kawecki, who

is a civil investigator with the EPA. At the end

of the table is Chet Tisdale, who is an attorney.

I'd like to thank you for coming for this

deposition under Superfund Law/ which is also

called CERCLA, C E R C L A.

of lawful age, a witness herein, being first duly

sworn as hereinafter certified was examined and

testified as follows:

EXAMINATION

BY MR. BRESLIN:

Q. Would you please state your name.

A. I'm

Q. What's your address,

A. Present address is18

19

20 Q. Are you currently employed?

21 A. Yes, I'm working for Jerry's Truck

22 and Diesel Repair, Harrison, Ohio.

23 (Witness affirmed.)

24 Q. could you tell us a

25 little about your background, how long you've lived


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in the Cincinnati area?

A. Basically all of my life. Maybe

eight or ten years when I was a small child I was

throughout Southern Indiana/ and then perhaps

around '84 to '90 I was in Indiana again, you know,

but other than that, I've always been around

Cincinnati.

Q. Is all of your schooling, education

in the Cincinnati area?

A. Outside of my grade school was in

Indiana.

Q. Okay. Has your employment history

all been in the Cincinnati area?

14 A. Basically.

15 Q. Could you trace that briefly for us,

16 just in a general sense.

17 A. General from my first job to my

18 current job/ is that where we want to go?

19 Q. Yes, that would be fine.

20 A. Let's see, how ridiculous could it

21 be. I sold papers as a child. Then I worked in a

22 greenhouse. Would you like to know when I -- what

23 to do with the Skinner Landfill/ what about those

24 jobs?

25 Q. Yeah, or your jobs as an adult. What


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would you say your trade is or has been?

A. Well/ my trade is, I'm a diesel

mechanic/ heavy equipment mechanic, also heavy

trucks/ class A trucks. I worked from around '67

to '70 basically in that area for a company/ A Okay

Leasing, that was on 6256 Wiley Road, and that was

when I first learned about Skinner's landfill

because Keenan Oil -- This has never been said to

anybody. Keenan Oil used to dump a lot of their

residue oil at the lagoon there at Skinner's

landfill.

Q. Do you know how to spell Keenan Oil?

13 A. K E E N A N , ! presume.

14 Q. Was that a Cincinnati --

15 A. They're by Cincinnati Gardens.

16 Anchor-Hocking I believe bought the company.

17 Q. And how do you know that they dumped

18 materials there?

19 A. Because I took care of the trucks,

20 and the trailers, and tankers/ and everything for A

21 Okay Leasing, which called for Keenan Oil.

22 Q. When you say took care of them --

23 A. I was a mechanic.

24 Q. -- you repaired them?

25 A. Yes.


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Q. Did you actually --

A. No, I didn't drive it.

Q. So how did you know directly what was

being hauled by the --

A. I don't know what was being hauled

exactly as far as the chemical makeup. I know

mostly it was creosote and other by-products that I

guess Keenan bought from other manufacturers or was

given to them or something that they couldn't use.

,Q. How did you become aware that Keenan

was using the Skinner Landfill site?

A. Well/ later on when I worked with

John Skinner, I knew about the lagoon. He cut one

lagoon out of rock, and the gentlemen at Keenan Oil

told him it wouldn't work, and this old man

Skinner, this was Albert, didn't take much heed to

what they said, and it did leak. It leaked through

the cracks of the stone.

That's the one down below. It's not

up in the dumper where the lagoon was up by the

smoke stack. In other words, the first lagoon that

the EPA looked for, that's the one that was covered

up the weekend prior to the EPA coming on the

landfill. That's when John Bushelman had every

piece of equipment he owned there.


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Q. Okay, we'll cover that in a little

while. When you were at A Okay, did you talk to

drivers; is that how you knew what was going on?

A. Well, James Hurley was one of the .—

he worked for Harley Hale, which originally owned

or I presume started A Okay Leasing. Ken Riley

owned the business when I worked for A Okay or he

owned the business when I worked for A Okay

Leasing, and he told me later that he had hauled a

lot of that stuff there, and, of course, the lagoon

smelled like creosote, but that was years before

the Skinner thing came up. That was back in the

late '60's.

Q. So did you know the Skinners at that

point?

A. Not really. I didn't really meet

John until around '73, although, I knew of him, you

know, but I never -- John and I were very good

friends. I worked with John for a long time.

Q. Where did you work after you worked

at A Okay Leasing through 1970?

A. Oh, God, many places, Gallenstein

Construction, Continental Plastics. You know, I

probably worked a hundred different places in my

life.


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Q. Were all of those jobs as a truck

mechanic?

A. Yeah/ sometimes, you know, usually,

whatever pays, you know what I mean. I drove

trucks and repaired them. I designed furniture and

things, tools to cut plastics and so on.

Q. Where did you work at the time you

first came in contact with John Skinner or any of

the other Skinners; do you recall?

,A. I believe the first time I personally

met John I was up at Mason at a friend of mine's

garage, Junior Robinson's, and that's when I first

met John. In fact, John and I went and looked at a

truck that he wanted to -- somebody to assemble

it. It had been bought without an engine in it,

and that's the first time that I met John. It was

in '73. I remember that because I bought a new

Chevrolet pickup truck in '73, and the thing was

brand new and it quit on us.

Q. Pardon me?

A. It quit on us, a new car, and I'm a

mechanic, and the stupid thing quit running.

Q. Oh, okay. So did John get in contact

with you for you to repair this truck?

A. Right. Well, I never worked on that


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particular truck. That truck was sold to someone

else, but I started working with John probably in

the latter part of '74.

Q. Did you have any contractual

employment relationship with him or was it a

job-by-job thing?

A. Yeah, it was just a job-by-job thing,

you know. In other words, we did a lot of work

together, in other words, we worked about 7 days a

week, 20 hours a day, which is about as steady asi

you can work, you know, but we never had an

agreement that we were going to do this 6 months

from now or whatever. We just, whatever was being

worked on or the work to be done, it would be done.

Q. Did you work at the Skinner property?

A. Yeah.

Q. On Cincinnati-Dayton Road there?

A. Yeah.

Q. Was there some kind of garage?

A. No. I mean, that was doing whatever,

you know, a lot of demolition work and moving of

heavy equipment and objects and so forth.

Q. Were you involved while you were

working with John Skinner with the waste disposal

operations out there at all?


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A. Yeah, right.

Q. How would you characterize your

involvement in those types of operations?

A. Well, let's.see. I personally don't

remember driving or hauling anything from Chem-Dyne

in Hamilton to the Skinner landfill. Ray did that

basically every night, you know, a lot of stuff at

night was hauled in there. I unloaded a lot of

trailers, you know, box trailers, freight type

trailers, John and I did that.

Q. When you say Ray, for the record who

do you mean?

Ray Scarra, that's John's half

brother. Well, since John's dead, I guess it's not

his half brother, but John would have been his half

brother.

Who was running the Skinner

operations in those days?

A. Well, I presume, of course, ownership

would have been Albert and Elsa's, but, you know,

they didn't really know what John was doing. I

remember when the problem first came around, it was

something illegally done, I didn't know that. You

know, I just took for granted it had always been a

dump or a landfill, you know, and I didn't know


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anything was wrong about it, quite frankly.

You know, here's a company in

Hamilton, and this is the landfill, you know. And

I believe John only told them like 100 or 150 per

trailer load or something, and John was probably

getting a thousand. When I knew about this was

prior to the EPA coming in there, I think Kovacs is

his name from Chem-Dyne.

Q. Kovacs?

.A. Kovacs. This has been 20 years ago,

you know, and it was something I overheard the old

man saying something about 25,000, and he says that

guys crazy, it's only 2,500, and you have to make

some money out of that.

So I mean, Albert was talking to

John, so Albert had in his mind John had only got

$2,500 this last time or something or the other,

and it was actually $25,000 owed John Skinner. So

John made an immense lot of money. I mean, maybe

not millions, but hundreds of thousands, you know,

couple hundred thousand dollars. I'm just

guessing, you know.

Q. This is around the time when you

started out there, you say it was '74?

A. Around, yeah.


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Q. At first/ then/ were your

responsibilities mostly taking care of equipment or

repairing equipment at some point or were you

immediately involved in every aspect of the

operation?

A. Yeah/ basically everything that was

being done/ you know. In '74, '75 John and I

8 worked a little over a year seven days a week every

day wrecking a real large building in St. Bernard/

10 the Armor. Fertilizer building.

11 Q. You wrecked it/ you say?

12 A. Yeah/ wrecked it. It was a

13 tremendous job. That's how John showed -- I mean,

14 John basically bought the job to show Elsa, and I

15 presume to show Elsa and Albert/ how he got all

16 this money. The job didn't really pay all that

17 much money/ but that's when John bought a new

18 Cadillac and a lot of equipment. Ray/ of course/

19 whatever John bought/ Ray had to have, so Ray got a

20 new Lincoln out of the deal.

21 Q. How does this relate to you? You

22 said you wrecked -- What's the name of the building

23 you wrecked?

24 A. We demolished a great big 800 feet

25 long/ 200 feet wide, 100 foot high -- I did all the


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heavy work on it.

Q. What was that company called?

A. The Armor Fertilizer building. It's

still owned by the same people, Bill Schmit, and I

can't think of Bill Schmit's partner's name. I

just gave them some pieces for an old truck. I

can't think. The two guys are partners.

Q. What was done with the debris and the

wreckage from there?

.A. Well, the wood was, of course, hauled

to the dump, the landfill, and the materials was

either -- of course, the steel materials that was

damaged was recycled or sold to scrap metal

14 dealers, you know. The steel that was usable, was

15 sold or shipped to people that needed it, you know,

16 wanted it, and other materials were sold. There

17 was, you know, not a lot of debris on it. It was a

18 steel building.

19 Q. In those days, the first part of the

20 '70's, what were you typically doing in the course

21 of a day or a week regarding disposal of wastes at

22 the Skinner landfill?

23 A. Well, okay. When I was up at the

24 dump or landfill, it was in a trailer. John would

25 excavate a hole, and John and I would get up in the


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trailer and literally hand throw the material into

a hole and cover it up.

Q.

talking about?

Is this waste material you were

A. Waste material.

Q. Would trucks be driving onto the site

with other drivers?

A. No, not in the daytime. Like I say,

most of all of those trailers, I presume that Ray

hauled them in there at night to keep people from

noticing so much traffic. There wasn't a lot of

activity in the daytime.

Q. There were not waste trucks coming in

and dumping waste during the day time?

A. No, no.

Q. So at night would you notice that

there were trailers there all of a sudden?

A. Well, this is a large area. I mean,

we was demolishing this large building, so what

happened there through the day I didn't see because

John and I were both on this job, and then in the

evenings when we got in, we would unload or empty

out any trailers.

Q. And these all had some sort of waste

materials on them?


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A. Well, I probably personally only

unloaded maybe a dozen trailers with John. I

personally only went and got/ that I remember, one

load of material, and that was I believe Borden

Chemical up by Newark, Ohio someplace. I got that

on a drop deck truck, you know, low boy, low

platform truck.

Q. Okay. When you mention the dozen

trailers or so that you unloaded with John, what

was the waste in on these trailers?i

A. Okay. The trailers I most -- You

know, this has been 20 years ago. We almost got

killed on this one trailer, and that was a deep pit

14 that he dug and it was muddy, and we had the

15 trailer, we backed it up to this pit, and it was

16 too far back in the pit. We couldn't get out of

17 the trailer hardly, and it was muddy, and the old

18 man took a bull dozer and helped pull the truck up

19 so we could get in and out of the trailer easier.

20 About 5 minutes, maybe 20 minutes into the middle

21 of this trailer, this pit explodes, and we

22 literally would have got burned up in the trailer.

23 This was material that was in the

24 large, I'm going to say, 50 paper barrels that had

25 like speedy dry or sawdust around it to cushion it,


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A. Yeah.

Q. Where would that go, that rinse

water?

A. You know, I should remember, but I•

presume they was took up to the dump, I guess the

dump or lagoon, because there wouldn't be but a

hundred or some gallons.

Q. That would be collected, that water?

A. Yeah, wouldn't be too much.

Q. Was there names on those tankers*

trucks like Chem-Dyne?

A. No. I presume them to have been

Chem-Dyne's trailers, and I presume the chemical

was hauled in by tank railroad cars. You know, I'm

15 just presuming this because Chem-Dyne at that time

16 didn't have -- didn't seem like these trailers were

17 good enough to run over the road or whatever. I

18 mean, that's what I remember about them.

19 Q. Okay. Would you tell us about the

20 incident that occurred in April, '76 when EPA came

21 out —

22 A. Was that the lagoon?

23 Q. — to the site? Yes.

24 A. Was that the day that a dozen police

25 cars were there? Then I remember it.


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Q. It was in April of '76, and the EPA

and I believe the Ohio EPA came out to the site and

various --

A. I was in some of the newspaper

clippings because people showed my picture in it,

so I was there, yeah.

Q. Can you briefly explain what happened

at that time from your perspective?

A. They came in and looked over the

place.

Q. Do you know why they came?

A. I presume they had a reason to be

there.

Q. You're not sure what it was, though?

A. No.

Q. Okay.

A. I mean, I don't know what they

claimed to be a reason for them to be there, you

know. It was my job to keep most of the people out

of there, which I did; but when they came, I think

there was 9 or 10 or 11 police cars, and I don't

know if this guy's name is around, somebody said

that I was a professional instigator. I'm not.

I'm just large/ and I'm very good at

doing what I do. If you hire me to keep people out


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of this room, they'll probably be out of this

room. I don't have to physically do it. I can

intimidate people or I can aggravate them so bad

they'll leave, you know.

Q. Whose directions were you following?

A. Well, John, you know.

Q. He said -- What did he say to you

when the police and everyone came?

A. Well, I don't know what he was doing,

but he said don't let anybody in here. So I was

there, this was probably the night before, prior to

that, I don't know who it was, one of the major

network's news people came down in a large car and

started asking questions, and I said, you know,

this is not the time or place, you people have to

leave. And a man started to get out, and I put my

hand on the door, and I said don't do this, you'll

have to leave, and at that time they left, you

know. I don't know who it was.

Q. Okay. Did the Skinners know that the

EPA was -- or the EPA people and the police are you

saying?

A. Yeah, they wouldn't have came in

there by themselves for fear of their lives.

Q. The EPA people, you mean?


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A. Anybody that was not invited by the

Skinners did not come on that property. That's why

all of the police were there for escort.

Q. It's* my understanding there was an

initial trip out to the site by some EPA people.

A. Well, they probably got thrown out/

you know. I'm saying that's why they came back,

you know.

Q. In the interim before you said all

the police cars and all these people came back out,

what activities took place at the site?

A. Well, they walked around, and there

was like a few trailers that had -- I remember one

instance there was a trailer with a license plate

on it. They was looking one way, and I just walked

around and took the license plate off the trailer.

17 I just pulled bolts and all. I just gave it a

18 pull, and I folded the license plate up and put it

19 in my pocket. So seemed like at that time nobody

20 wanted anybody to have any evidence as to who owned

21 the trailer. Whatever this, I presume Brown --

22 this is the name that I remember, that really,

23 really upset him, and in fact --

24 Q. Was this an EPA person?

25 A. This is one of the EPA major people,


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1 whoever was in charge. He hit me on my shoulder

2 like you would, well, if you're a friend of

3 someone, you might have the habit of touching

4 someone's shoulder; if you would want to hurt them,

5 you might want to hit them a little bit harder, and

6 if you would like to hurt them but afraid to hurt

7 them, this is the way the man hit me.

8 And I just grinned because at that

9 time I realized I had him. He was shot. Whatever

10 he was Iqoking at, he was so mad at me for -- he's

11 the one that said that I was a professional

12 instigator, and I was merely doing my job, you

13 know. Of course, I went down and filed a police

14 report, and, of course, that was lost, that was

15 never came up with.

16 Q. Did you and the Skinners around that

17 time do anything to cover up the lagoon?

18 A. I just said we did everything, we

19 covered up the lagoon.

20 Q. Can you explain that part of it to

21 me?

22 A. I think I did. I think I said there

23 was about 50 cars put in the lagoon, and barrels

24 with holes in them that I personally put holes in

25 the barrels, and John Bushelman's entire


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construction fleet. There was 15 to 20

bulldozers. I don't know what that cost the old

man, but this is Saturday and Sunday, if you hire a

construction company's entire, I mea'n everything.

Q. So the cars were thrown in at that

time, then?

A. Right.

Q. Okay, I didn't follow that. Is this

after the EPA people had come to the site?

•A. No, this was before. When they came

on the site, there was no lagoon. The only way

they knew there was a lagoon, they had an aerial

photograph of the incinerator. And there was a log

over top of that little creek, and here was a

lagoon. And at that time I said, well, there's no

lagoon there, you guys must have been someplace

else.

Q. But you guys had all covered it up?

A. Right.

Q. Why was Bushelman there?

A. He's the only body that had 15 to 20

bulldozers. This was a large undertaking, and it

was done in 2 days.

Q. What was Bushelman, what kind of

outfit?


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A. Well, construction, and the old man

hired his company, you know, come here, clean this

lagoon off for me, bulldoze this dirt for me, and

that's what they did.

Q. Did Bushelman's people do the whole

job or were you personally involved in it as well?

A. I just repaired the one big

bulldozer, and I think John was running the big

one, and Ray was running the little one, and that's

how I was involved.

11 Q. Was John Bushelman himself out there;

do you recall?

A. Well, considering, probably, yeah. I

didn't talk to John out there, but this was an

immense undertaking, you know. I'm going to say

again, when you hire every piece of equipment a man

has, yeah, he was there. His fuel trucks were

18 there and everything.

19 Q. Did Bushelman or his company have any

20 other involvement with the site?

21 A. No.

22 Q. It was just that one time?

23 A. Right. He was just a contractor that

24 they hired to push dirt.

25 Q. Okay. I'm going to ask you about a


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that weighed hundreds of tons, and taking things

into or out of places where normal people couldn't

do that. We had the cranes and so forth.

Q. So there wasn't always waste

involved?

A. No. Also there was demolition work

and everything/ just a lot of different things we

did.

Q. AT&T?

•A. NO.

Q. City of Blue Ash?

A. No.

Q. BP Oil?

A. No.

Q. Bushelman?

A. Well, Bushelman done the excavation,

some bulldozing up there at the lagoon.

Q. When you say excavation, did they --

A. Well, they didn't dig. They

bulldozed dirt into an area.

Q. Okay. Cincinnati Drum Service?

A. No.

Q. Continental Mineral Processing?

A. No.

Q. Gene Crow Equipment?


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Skinner Site WorkerInterview Excerpts

CONFIDENTIAL INVESTIGATIVEMEMORANDUM

Interview, .

On April 1, 1993, > ., was contacted and advised that Orion Management

International (OMI) had been retained to reconstruct the eventsand use of an area known as the Skinner Landfill.

The name of •. : . was provided by "_ - '_ -, and anadditional source, as an individual who would have informationregarding Chem-Dyne'8 dealings at the Skinner Landfill. ••- •. did not feel that •. _ .. / would agree to be interviewed.[NOTE: This individual was later identified as " • . ~ ].

', currently employed with . - -...- -. - • _ -~ •,advised that he initially met Otis Skinner while stripping coalin 1974. Otis Skinner hooked him up with John Skinner when

returned to the West Chester area in late 1974.

To the best of his knowledge, Otis Skinner currently resides in asuburb directly outside of Birmingham, Alabama. He started as adriver and mechanic for John Skinner, and they became bestfriends up until the day John died in 1981 or 1982.

The two of them worked side-by-side during this period of time.Between the years 1975 and 1976, Chem-Dyne barrels were hauledinto the Skinner Landfill "around the clock". He personallyhauled approximately one dozen times from Chem-Dyne, as did JohnSkinner. But Ray Skinner hauled the majority of the loads intothe Skinner site.

He and John Skinner were working a demolition project forapproximately one and a half years during this period of time.Re.y Skinner would go to Chem-Dyne at night and bring in severaltruck loads, approximately 80 barrels a truck. The three of themwould unload the trucks, and he and John Skinner would pour thecontents of the barrels into the lagoon or other holes dug at thesite. Ray Skinner would then return to Chem-Dyne to pick up morebarrels.

•This report prepared at the direction of counsel in anticipation of litigation.90

"This report prepared at the direction of counsel in anticipation of litigation.


Interview, . _ . - • •_ _ (cont) :

stated that this was done virtually every night for twoyears. John Skinner's instructions were to "pick" the barrels,meaning taking a pick-axe and destroy the barrels as much aspossible, to not only allow the fluid to leak out, but to destroyany name or labels on the barrels.

He; stated the barrels were then either disposed of directly atthe site, or within the lagoon located on the site. To hisknowledge, a great deal of the barrels contained anti-freeze, buthe: was not sure where the anti-freeze came from.

He: advised that the railroad (was not certain of the name) whichrein behind Chem-Dyne in Hamilton, Ohio, also brought in barrelsto the Chem-Dyne storage facility, as well as in tankers whichcarried liquid. Ray Skinner would unload the liquid from therailroad cars into their own trucks, which was then driven to thesite and emptied into the lagoon.

related that 1975 and 1976 were good financial years forboth he and John Skinner, stating that John Skinner madeapproximately $100,000 that year hauling for Chem-Dyne.

He stated that the lagoon had a significant amount of oildeposited from Kennan Oil. He believed Kennan Oil was sold to aglass company, located near Cincinnati Gardens.

He recalled a great deal of creosote, a substance used topreserve railroad ties. He stated a good deal of old barrels thathe had placed pick holes in, contained this substance, which wasdeposited not only in the lagoon, but in holes at the landfill.He stated that he personally put thousands of empty barrels intothe lagoon.

Ludwick stated he was personally concerned with the substanceplaced just outside the perimeter of the landfill, which were two40-50 ton tanks containing phenol, described as "thick, gooeystuff".

"This report prepared at the direction of counsel in anticipation of litigation."91

"This report prepared at the direction of counsel in anticipation of litigation."


Interview, - _^--.--_. (cont) :

: . explained an occurrence which was outlined in the Stateof Ohio Attorney General's suit against the Skinners in 1977. Theincident occurred approximately April, 1976, when the EPAtraveled to the site and attempted to examine the lagoon, as itwas believed Chem-Dyne was utilizing the lagoon as a dumpingground.

The EPA was not permitted on the site, and was told to come backin a matter of days. •>. o • stated that that weekend, prior tothe EPA's arrival, he, Ray Skinner, John Skinner, Albert Skinnerand approximately twenty-five of John Bushelman's men, operatedheavy machinery in an attempt to completely clean the landfill ofbarrels and completely bury the lagoon. He stated the lagoon tookapproximately three acres of dirt to cover. [NOTE: John Bushelmanoperates a construction firm and has been identified as a PRP].

Just prior to the EPA's arrival, when they were not permitted toinspect the landfill, John Skinner had placed a TD ThirtyInternational Bulldozer in front of the entrance to the dump,blocking any vehicles from entering it. He stated that all ofthis was done to avoid the EPA from identifying substances andbarrels in the lagoon and on the grounds itself.

. advised that John Skinner also worked with Frank Adams &Company, believed to now be out of business. He stated FrankAdams and John Skinner hauled liquid oxygen storage tanks fromthe Lindy Company in Chicago, Illinois. He also believed theyhauled for the National Cylinder and Gas Company in the Chicagoarea. These storage tanks were disposed of within the SkinnerLandfill.

The only three additional PRP's he could identify were O'RourkeWrecking, Dave Estes and John Bushelman, all of whom hauleddemolition debris rather extensively into the Skinner site.

-• • •• stated that Ellis Smith hauled Chem-Dyne's materials intothe Clairmont County Landfill and a landfill in North Vernon,

"This report prepared at the direction of counsel in anticipation of litigation.93


Skinner Site WorkerInterview Excerpts


Interview. :

On March 10, 1993,was contacted and advised that Orion Management

International (OMI) had been retained to reconstruct the eventsarid use of an area known as the Skinner Landfill.

During interviews with Ray Skinner, the name of • . : wasmentioned as an individual who may have information regardingPRPs utilizing the Skinner Landfill. [NOTE: Although Skinnerstated in his interview that he did not know wherelived, . ' trailer is located approximately 100 to 200 yardsfrom the entrance to the Skinner Landfill].

• ' stated that he had been storing salvaged material andliving on the site since 1978, and pays Elsa Skinner-Morgan $300per month for the use of their area.

He advised that John and Ray Skinner were Albert' s son from hisfirst marriage, and Ray and Maria are Elsa Skinner's children.

According to , Albert Skinner went into retirement in thelate 1970's, was moved into a rest home where he died in theearly to mid-1980's. John Skinner was killed prior to Albert'sdeath, and Albert was never advised of John's demise.

He stated that all money, contracts and decisions regarding thesite were made by Elsa Skinner, and John and Albert Skinnerprimarily worked the dump.

Miller advised that on numerous occasions, he observed tractortrailers with 30 yard "unmarked" containers on the Skinner site.He also recalled several "midnight runs" during the time JohnSkinner operated the site. He explained that John Skinner was avery intimidating man and : . . did not interfere.




Interview, :

: • • •• stated that Albert Skinner did business with Queen CityRailroad in Sharonville, Ohio, and this entity utilized the site.He was not certain what they placed at the dump.

N&wberry Railroad was a frequent user of the Skinner dump,depositing "thousands" of railroad ties into the site with theirown vehicles, he recalled were red in color.

John F. Bushelman Construction, located on Haulk Road,Sharonville, Ohio, dumped industrial brick, stone and wood intothe site for numerous years, as John Bushelman was a friend ofAlbert Skinner.

stated that Bushelman Construction worked in conjunctionwith MVM Sales and Service, who installed service stations. MVM,which is located next to John Bushelman Construction, hauledseveral gasoline storage tanks into the dump, but according toMiller, Ray Skinner hauled the storage tanks away from the dump.

MVM Sales and Service, located on Haulk Road, Sharonville, Ohio,builds, tears down and remodels gas stations, and works inconjunction with John Bushelman. He believed MVM Sales andService had done work for Shell Oil Company and Sunoco, andhauled their debris into the Skinner site. He was not certain howthey disposed of underground gasoline storage tanks. MVM Salesand Service hauled into the Skinner site at least once per week,since 1978 or 1979.Ed Batey was an individual hauler located on Western Row Road andRoute 42, Mason, Ohio. ' - . ' • • stated that Ray and/or John Skinnerha.uled demolition material for Batey into the site. Ed Batey andJohn Skinner were very good friends. He suggested that Ed Bateymay have additional information regarding the site.

There was a military base located in, what now is called, MicroCenter Mall in the Sharonville area. According to Miller, thisbcLse was torn down and the debris was hauled by Jim Gillis intothe Skinner dump.




Interview,

Dave Estes Construction Company contracted with Ray Skinner tohaul brush and construction debris into the site. He also statedthat Estes had his own dump trucks which also frequented thesite. Dave Estes is believed to be retired and the operation isnow run by his son.

Thomas/Sysco Foods in Evendale, Ohio, was renovated in the mid-1980's, and ' ' believed John Bushelman Company hauled therenovation/construction debris, including everything frominsulation to concrete blocks, into the Skinner site.

He: stated that Ray Skinner hauled the debris from the old postoffice, and new building, in West Chester, near the entrance tothe Skinner dump, into the landfill.

Acme Wrecking Company in Cincinnati, Ohio, hauled demolitiondebris in 30 to 40 yard dump trucks, on an average of once permonth into the site. He stated Acme Wrecking- would not be in thesite for six months at a time, and then would show up four tofive times in one day over the next six months.

Coca-Cola in either Cincinnati or Hamilton, Ohio, utilized theSkinner site, depositing wood pallets and wood boxes that held 24bottles. They used their own tractor trailer trucks, which wouldhold approximately 60 yards. He recalled Coca-Cola in the dumpthe last three or four years that it was open, and estimated theyutilized it once every two months.

1 stated the City of Deer Park, City of Silverton and theCity of Maderia hauled into the site during the 1950's and1960's. He identified a Mrs. Spalding as the owner of a haulingcompany that hauled for these cities, and believed Mr. Spaldingwas deceased.



Maria Skinner RoyInterview Excerpts


Interview, Maria Skinner Rov:

On April 2, 1993, Maria Skinner Roy (daughter of John and ElsaSkinner), P.O. Box 247, West Chester, Ohio 45071, was contactedand advised that Orion Management International (OMI) had beenretained to reconstruct the events and use of an area known asthe Skinner Landfill. Her physical location is near the entranceof the dump, located at 8740 Dayton-Cincinnati Road, WestChester, Ohio 45069 (513)777-9454.

Roy, who is 45 years of age, stated that she spent the majorityof her life on the Skinner property that surrounds the dump. Sherecalled her father first utilizing the site as a dump, when shewas a little girl during the 1950's.

During that time, Rumpke hauled a considerable amount of generalrefuse, boxes of clothes and sets of silverware into the site,with the refuse being the primarily debris.

She stated a paint company in Redding, Ohio, whose name she couldnot recall, hauled a great deal of empty barrels containing paintresidue, which were disposed of at the site.

She was under the impression that the U.S. Army had ', and possibly Kings Mill, making gun powder for the

military. As a child, she often recalled "someone important" fromthe Army at the site, dealing with her father on an extensivebasis. She was not certain what they dumped at the site, butstated there were numerous green cans, the size of gasolinecontainers full of oil, which were constantly at the site.

She stated that the Army utilized this site as a dump prior toher father conducting business there.


"This report prepared at the direction of cou

Documents

John F. Bushelman Construction, Inc. 11980 Runyan Drive ... · EPA Region 5 Records Ctr. Karl S. Bourdeau (202)789-6019 [email protected] LAW OFFICES BEVERIDGE & DIAMOND, P. C