43
1 1 United States United States Environmental Protection Agency Environmental Protection Agency (U.S. EPA) Presentation of the (U.S. EPA) Presentation of the Tremont City Barrel Fill Site Tremont City Barrel Fill Site Proposed Plan Proposed Plan Ron Murawski Ron Murawski June 22, 2010 June 22, 2010

United States Environmental Protection Agency (U.S. … · United States Environmental Protection Agency (U.S. EPA) ... “Polyol” 19 ... Bulk Sludge & Still Bottoms 0.7 Latex Glue

  • Upload
    ngolien

  • View
    220

  • Download
    0

Embed Size (px)

Citation preview

Page 1: United States Environmental Protection Agency (U.S. … · United States Environmental Protection Agency (U.S. EPA) ... “Polyol” 19 ... Bulk Sludge & Still Bottoms 0.7 Latex Glue

11

United States United States

Environmental Protection AgencyEnvironmental Protection Agency

(U.S. EPA) Presentation of the(U.S. EPA) Presentation of the

Tremont City Barrel Fill SiteTremont City Barrel Fill Site

Proposed Plan Proposed Plan

Ron MurawskiRon Murawski

June 22, 2010June 22, 2010

Page 2: United States Environmental Protection Agency (U.S. … · United States Environmental Protection Agency (U.S. EPA) ... “Polyol” 19 ... Bulk Sludge & Still Bottoms 0.7 Latex Glue

22

Topics of the PresentationTopics of the Presentation

�� Introduction of the Regulatory TeamIntroduction of the Regulatory Team

�� What is the Proposed Plan?What is the Proposed Plan?

�� Tremont City Barrel Fill Site BackgroundTremont City Barrel Fill Site Background

�� Progress Toward Cleaning Up the SiteProgress Toward Cleaning Up the Site

�� Remedial Investigation (RI) Report SummaryRemedial Investigation (RI) Report Summary

�� Description and Comparison of Cleanup AlternativesDescription and Comparison of Cleanup Alternatives

�� U.S. EPAU.S. EPA’’s Preferred Cleanup Alternatives Preferred Cleanup Alternative

�� Public Comment PeriodPublic Comment Period

�� Record of Decision (ROD) and PostRecord of Decision (ROD) and Post--ROD ActivitiesROD Activities

�� Contact and Resource InformationContact and Resource Information

�� Question and Answer PeriodQuestion and Answer Period

Page 3: United States Environmental Protection Agency (U.S. … · United States Environmental Protection Agency (U.S. EPA) ... “Polyol” 19 ... Bulk Sludge & Still Bottoms 0.7 Latex Glue

33

Introduction of the Regulatory TeamIntroduction of the Regulatory Team

�� Ron Murawski, U.S. EPA Remedial Project ManagerRon Murawski, U.S. EPA Remedial Project Manager

�� Patricia Krause, U.S. EPA Community Involvement Patricia Krause, U.S. EPA Community Involvement CoordinatorCoordinator

�� Diana Embil, U.S. EPA Site AttorneyDiana Embil, U.S. EPA Site Attorney

�� Bob Kay, U.S. Geological Survey HydrogeologistBob Kay, U.S. Geological Survey Hydrogeologist

�� Jewelle Keiser, U.S. EPA oversight contractor (CH2M Hill) Jewelle Keiser, U.S. EPA oversight contractor (CH2M Hill) Site ManagerSite Manager

�� Other U.S. EPA and CH2M Hill specialists (not present)Other U.S. EPA and CH2M Hill specialists (not present)

�� Kelly Kaletsky, Ohio EPA Site CoordinatorKelly Kaletsky, Ohio EPA Site Coordinator

�� Mark Allen, Ohio EPA SupervisorMark Allen, Ohio EPA Supervisor

�� Matt Justice, Ohio EPA Hydrogeologist (not present)Matt Justice, Ohio EPA Hydrogeologist (not present)

Page 4: United States Environmental Protection Agency (U.S. … · United States Environmental Protection Agency (U.S. EPA) ... “Polyol” 19 ... Bulk Sludge & Still Bottoms 0.7 Latex Glue

44

What is the Proposed Plan?What is the Proposed Plan?

�� The U.S. EPA document that describes The U.S. EPA document that describes

U.S. EPAU.S. EPA’’s preferred cleanup alternative s preferred cleanup alternative

for the Sitefor the Site

�� Summarizes the steps that were taken to Summarizes the steps that were taken to

arrive at the preferred cleanup alternativearrive at the preferred cleanup alternative

�� Invites public comment on U.S. EPAInvites public comment on U.S. EPA’’s s

preferred cleanup alternativepreferred cleanup alternative

�� Identifies the public comment periodIdentifies the public comment period

Page 5: United States Environmental Protection Agency (U.S. … · United States Environmental Protection Agency (U.S. EPA) ... “Polyol” 19 ... Bulk Sludge & Still Bottoms 0.7 Latex Glue

55

Tremont City Barrel Fill Site Tremont City Barrel Fill Site

LocationLocation

�� Barrel Fill is in Clark County in southwest Barrel Fill is in Clark County in southwest

Ohio, about 1.5 miles west of Tremont Ohio, about 1.5 miles west of Tremont

CityCity

�� Barrel Fill is about 4.5 miles northwest of Barrel Fill is about 4.5 miles northwest of

SpringfieldSpringfield

�� Barrel Fill is next to the former Tremont Barrel Fill is next to the former Tremont

City Waste Transfer Facility and just north City Waste Transfer Facility and just north

of the Tremont City Landfill Siteof the Tremont City Landfill Site

Page 6: United States Environmental Protection Agency (U.S. … · United States Environmental Protection Agency (U.S. EPA) ... “Polyol” 19 ... Bulk Sludge & Still Bottoms 0.7 Latex Glue

66

Barrel Fill is 1.5 miles west of Tremont CityBarrel Fill is 1.5 miles west of Tremont City

Barrel FillBarrel FillBarrel Fill

Page 7: United States Environmental Protection Agency (U.S. … · United States Environmental Protection Agency (U.S. EPA) ... “Polyol” 19 ... Bulk Sludge & Still Bottoms 0.7 Latex Glue

77

8.58.5--Acre Barrel Fill (crosshatch area)Acre Barrel Fill (crosshatch area)

Page 8: United States Environmental Protection Agency (U.S. … · United States Environmental Protection Agency (U.S. EPA) ... “Polyol” 19 ... Bulk Sludge & Still Bottoms 0.7 Latex Glue

88

Operational History and Nature Operational History and Nature

of the Wasteof the Waste

�� In 1976, Ohio EPA granted a permit to the In 1976, Ohio EPA granted a permit to the owner (Danis) to dispose of industrial sludges owner (Danis) to dispose of industrial sludges and solidsand solids

�� From 1976From 1976--1979, 51,500 barrels and some 1979, 51,500 barrels and some uncontainerized waste disposed of in 50 unlined uncontainerized waste disposed of in 50 unlined cells in the 8.5cells in the 8.5--acre Barrel Fill acre Barrel Fill

�� 3.1M gallons of total waste (15,500 yds3.1M gallons of total waste (15,500 yds33))

�� 1.8M gallons of industrial sludges1.8M gallons of industrial sludges

�� 1.5M gallons of hazardous waste1.5M gallons of hazardous waste

Page 9: United States Environmental Protection Agency (U.S. … · United States Environmental Protection Agency (U.S. EPA) ... “Polyol” 19 ... Bulk Sludge & Still Bottoms 0.7 Latex Glue

99

Operational History and Nature Operational History and Nature

of the Waste, cont.of the Waste, cont.

22Still BottomsStill Bottoms

0.80.8Asbestos or Asbestos SlurryAsbestos or Asbestos Slurry

55Resins Resins

1010Soap, Shampoo, Detergent, ToothpasteSoap, Shampoo, Detergent, Toothpaste

1515Glues, Adhesives, Rubber CementGlues, Adhesives, Rubber Cement

1515““Latex or Latex SludgeLatex or Latex Sludge””

1919““PolyolPolyol””

3131““Paint SludgePaint Sludge””

% of Barrels% of BarrelsWaste DescriptionWaste Description

Page 10: United States Environmental Protection Agency (U.S. … · United States Environmental Protection Agency (U.S. EPA) ... “Polyol” 19 ... Bulk Sludge & Still Bottoms 0.7 Latex Glue

1010

Operational History and Nature Operational History and Nature

of the Waste, cont.of the Waste, cont.

0.70.7Bulk Sludge & Still BottomsBulk Sludge & Still Bottoms

11Latex GlueLatex Glue

88Still BottomsStill Bottoms

2020Latex Glue, Asbestos & WaterLatex Glue, Asbestos & Water

6969Bulk SludgeBulk Sludge

% of Volume% of VolumeBulk Waste DescriptionBulk Waste Description

Page 11: United States Environmental Protection Agency (U.S. … · United States Environmental Protection Agency (U.S. EPA) ... “Polyol” 19 ... Bulk Sludge & Still Bottoms 0.7 Latex Glue

1111

Operational History and Nature Operational History and Nature

of the Waste, cont.of the Waste, cont.

�� In 1980, after all operations ceased, a soil cover In 1980, after all operations ceased, a soil cover

was placed over the Barrel Fillwas placed over the Barrel Fill

�� Additional cover added in the midAdditional cover added in the mid--1980s, 1980s,

following removal of an underground storage following removal of an underground storage

tank tank

�� 1010--17 foot soil cover currently exists over the 17 foot soil cover currently exists over the

waste cellswaste cells

�� Buried drums are generally in good conditionBuried drums are generally in good condition

Page 12: United States Environmental Protection Agency (U.S. … · United States Environmental Protection Agency (U.S. EPA) ... “Polyol” 19 ... Bulk Sludge & Still Bottoms 0.7 Latex Glue

1212

Page 13: United States Environmental Protection Agency (U.S. … · United States Environmental Protection Agency (U.S. EPA) ... “Polyol” 19 ... Bulk Sludge & Still Bottoms 0.7 Latex Glue

1313

Page 14: United States Environmental Protection Agency (U.S. … · United States Environmental Protection Agency (U.S. EPA) ... “Polyol” 19 ... Bulk Sludge & Still Bottoms 0.7 Latex Glue

1414

Page 15: United States Environmental Protection Agency (U.S. … · United States Environmental Protection Agency (U.S. EPA) ... “Polyol” 19 ... Bulk Sludge & Still Bottoms 0.7 Latex Glue

1515

Progress Toward Progress Toward

Cleaning Up the SiteCleaning Up the Site

�� Enforcement order in October 2002 for the Enforcement order in October 2002 for the ““Performing RespondentsPerforming Respondents”” (The Responsible (The Responsible Environmental Solutions Alliance (Environmental Solutions Alliance (““RESARESA””); ); including GM, Delphi, and Procter & Gamble) to including GM, Delphi, and Procter & Gamble) to conduct the RI and Feasibility Study (FS)conduct the RI and Feasibility Study (FS)

�� RI field work conducted from 2003RI field work conducted from 2003--20052005

�� U.S. EPA approved the RI Report in 2006, the FS U.S. EPA approved the RI Report in 2006, the FS with modifications in 2008, and the FS with modifications in 2008, and the FS Addendum with modifications in 2010Addendum with modifications in 2010

�� U.S. EPA issued the Proposed Plan in June 2010U.S. EPA issued the Proposed Plan in June 2010

Page 16: United States Environmental Protection Agency (U.S. … · United States Environmental Protection Agency (U.S. EPA) ... “Polyol” 19 ... Bulk Sludge & Still Bottoms 0.7 Latex Glue

1616

RI Report Site Characterization RI Report Site Characterization

Summary: HydrogeologySummary: Hydrogeology

�� Waste cells are partially submerged in a Water TableWaste cells are partially submerged in a Water Table

�� A series of lowA series of low--permeability tills (clay, mostly) and permeability tills (clay, mostly) and intertills of fine sand exist beneath the waste cellsintertills of fine sand exist beneath the waste cells

�� Groundwater flow from the intertills is mostly horizontal Groundwater flow from the intertills is mostly horizontal

�� Groundwater flow from the Water Table and 1075 Groundwater flow from the Water Table and 1075 Intertill is mostly to the unnamed tributary east of the Intertill is mostly to the unnamed tributary east of the Barrel Fill Barrel Fill

�� The deep sand and gravel aquifer, which is about 100 The deep sand and gravel aquifer, which is about 100 feet below the bottom of the waste cells, is used for feet below the bottom of the waste cells, is used for drinking water drinking water

�� Groundwater flow in the deep sand and gravel aquifer is Groundwater flow in the deep sand and gravel aquifer is generally to the north and northeastgenerally to the north and northeast

Page 17: United States Environmental Protection Agency (U.S. … · United States Environmental Protection Agency (U.S. EPA) ... “Polyol” 19 ... Bulk Sludge & Still Bottoms 0.7 Latex Glue

1717

Waste Cells in Relation to the HydrogeologyWaste Cells in Relation to the Hydrogeology

Page 18: United States Environmental Protection Agency (U.S. … · United States Environmental Protection Agency (U.S. EPA) ... “Polyol” 19 ... Bulk Sludge & Still Bottoms 0.7 Latex Glue

1818

U.S. EPA and Ohio EPA PostU.S. EPA and Ohio EPA Post--RI Report RI Report

Evaluation of the HydrogeologyEvaluation of the Hydrogeology

�� U.S. EPA and Ohio EPA determined that the RI Report U.S. EPA and Ohio EPA determined that the RI Report estimate of vertical hydraulic conductivity beneath the estimate of vertical hydraulic conductivity beneath the Barrel Fill was unreasonably lowBarrel Fill was unreasonably low

�� ReRe--evaluation of the RI Report data showed that tills and evaluation of the RI Report data showed that tills and intertills were not as uniform as depicted in the RI intertills were not as uniform as depicted in the RI ReportReport

�� U.S. EPA and Ohio EPA now believe that the vertical U.S. EPA and Ohio EPA now believe that the vertical hydraulic conductivity is substantially greater, but still hydraulic conductivity is substantially greater, but still considered lowconsidered low

�� Therefore, the drinking water exposure pathway from Therefore, the drinking water exposure pathway from the deep sand and gravel aquifer must be considered the deep sand and gravel aquifer must be considered when selecting the final remedywhen selecting the final remedy

Page 19: United States Environmental Protection Agency (U.S. … · United States Environmental Protection Agency (U.S. EPA) ... “Polyol” 19 ... Bulk Sludge & Still Bottoms 0.7 Latex Glue

1919

RI Report Contaminant SummaryRI Report Contaminant Summary

�� High levels of metals, organic chemicals, and High levels of metals, organic chemicals, and pesticides in the barrels and uncontainerized pesticides in the barrels and uncontainerized wastewaste

�� Soil cover: no contaminants above screening Soil cover: no contaminants above screening levels except for arsenic, which is naturally levels except for arsenic, which is naturally occurringoccurring

�� Surface water (the unnamed tributary): no Surface water (the unnamed tributary): no contaminants above screening levelscontaminants above screening levels

�� Sediment: a few organic chemicals and metals Sediment: a few organic chemicals and metals above ecological screening levels, but not above ecological screening levels, but not enough to pose an unacceptable risk enough to pose an unacceptable risk

Page 20: United States Environmental Protection Agency (U.S. … · United States Environmental Protection Agency (U.S. EPA) ... “Polyol” 19 ... Bulk Sludge & Still Bottoms 0.7 Latex Glue

2020

RI Report Contaminant Summary, RI Report Contaminant Summary,

cont.cont.

�� Groundwater:Groundwater:

�� Waste cell water and water adjacent to the Waste cell water and water adjacent to the

waste cells are highly contaminated waste cells are highly contaminated

�� Water Table contaminant levels 90 feet Water Table contaminant levels 90 feet

downgradient of waste cells were below downgradient of waste cells were below

screening levelsscreening levels

�� Generally, contamination in lower Generally, contamination in lower

groundwater zones was less than in upper groundwater zones was less than in upper

zones and difficult to trace to the Barrel Fill zones and difficult to trace to the Barrel Fill

Page 21: United States Environmental Protection Agency (U.S. … · United States Environmental Protection Agency (U.S. EPA) ... “Polyol” 19 ... Bulk Sludge & Still Bottoms 0.7 Latex Glue

2121

Risk SummaryRisk Summary

�� Future risk to maintenance workers digging in Future risk to maintenance workers digging in Barrel FillBarrel Fill

�� Unacceptable risk to maintenance workers and Unacceptable risk to maintenance workers and trespassers in the event of a potential, future trespassers in the event of a potential, future release of contaminated groundwater to surface release of contaminated groundwater to surface waterwater

�� Unacceptable risk, in the event of a potential, Unacceptable risk, in the event of a potential, future release, to receptors of the deep sand future release, to receptors of the deep sand and gravel aquifer and gravel aquifer -- not quantified in the risk not quantified in the risk assessmentassessment

�� Unacceptable eco risk in the event of a potential, Unacceptable eco risk in the event of a potential, future release of Barrel Fill contaminants to future release of Barrel Fill contaminants to surface watersurface water

Page 22: United States Environmental Protection Agency (U.S. … · United States Environmental Protection Agency (U.S. EPA) ... “Polyol” 19 ... Bulk Sludge & Still Bottoms 0.7 Latex Glue

2222

Description of Cleanup AlternativesDescription of Cleanup Alternatives

�� Remedial Alternative (RA)Remedial Alternative (RA)--1: the No1: the No--Action Action AlternativeAlternative

�� RARA--2: containment with a downgradient 2: containment with a downgradient groundwater collection trench and ongroundwater collection trench and on--site site treatment or offtreatment or off--site disposal and treatment at a site disposal and treatment at a wastewater treatment plantwastewater treatment plant

�� RARA--3: RA3: RA--2 with an upgradient groundwater 2 with an upgradient groundwater diversion structurediversion structure

�� RARA--7: RA7: RA--3 with the addition of liquid waste 3 with the addition of liquid waste removal sumps and portable pumps, and offremoval sumps and portable pumps, and off--site site liquid waste disposal and treatmentliquid waste disposal and treatment

Page 23: United States Environmental Protection Agency (U.S. … · United States Environmental Protection Agency (U.S. EPA) ... “Polyol” 19 ... Bulk Sludge & Still Bottoms 0.7 Latex Glue

2323

Description of Cleanup Alternatives, cont.Description of Cleanup Alternatives, cont.

�� RARA--4: total waste removal and transport to a 4: total waste removal and transport to a hazardous waste treatment/disposal facility or hazardous waste treatment/disposal facility or solid waste facility, as appropriatesolid waste facility, as appropriate

�� RARA--4a: RA4a: RA--4 except solid, non4 except solid, non--hazardous hazardous drummed waste and nondrummed waste and non--hazardous soils would hazardous soils would be placed in an engineered waste cell in the be placed in an engineered waste cell in the Barrel Fill Barrel Fill

�� RARA--4b: RA4b: RA--4a except the waste cell would 4a except the waste cell would include a plastic linerinclude a plastic liner

Page 24: United States Environmental Protection Agency (U.S. … · United States Environmental Protection Agency (U.S. EPA) ... “Polyol” 19 ... Bulk Sludge & Still Bottoms 0.7 Latex Glue

2424

Description of Cleanup Alternatives, cont.Description of Cleanup Alternatives, cont.

�� RARA--5:5: waste removal; offwaste removal; off--site disposal and treatment of site disposal and treatment of drummed waste, uncontainerized waste, cell water, and drummed waste, uncontainerized waste, cell water, and light nonlight non--aqueous phase liquids (such as oil); onaqueous phase liquids (such as oil); on--site site treatment via high temperature thermal desorption treatment via high temperature thermal desorption (HTTD) and stabilization of hazardous soils and (HTTD) and stabilization of hazardous soils and residuals; replacement of treated soils and residuals in a residuals; replacement of treated soils and residuals in a waste cell in the Barrel Fillwaste cell in the Barrel Fill

�� RARA--5a: RA5a: RA--5 except solid, non5 except solid, non--hazardous drummed hazardous drummed waste and nonwaste and non--hazardous soils would be placed in an hazardous soils would be placed in an engineered waste cell in the Barrel Fill engineered waste cell in the Barrel Fill

�� RARA--5b: RA5b: RA--5a except the waste cell would include a 5a except the waste cell would include a plastic liner plastic liner

�� RARA--6: RA6: RA--5 except HTTD5 except HTTD--treated soil would be treated soil would be transported offtransported off--site to a solid waste landfillsite to a solid waste landfill

Page 25: United States Environmental Protection Agency (U.S. … · United States Environmental Protection Agency (U.S. EPA) ... “Polyol” 19 ... Bulk Sludge & Still Bottoms 0.7 Latex Glue

2525

Nine Superfund Remedy Selection Nine Superfund Remedy Selection

CriteriaCriteria

�� Overall protection of human health and the environment Overall protection of human health and the environment

�� Compliance with applicable or relevant and appropriate Compliance with applicable or relevant and appropriate requirements (ARARs)requirements (ARARs)

�� LongLong--term effectiveness and permanenceterm effectiveness and permanence

�� Reduction of toxicity, mobility, or volume through Reduction of toxicity, mobility, or volume through treatmenttreatment

�� ShortShort--term effectivenessterm effectiveness

�� ImplementabilityImplementability

�� CostCost

�� State AcceptanceState Acceptance

�� Community AcceptanceCommunity Acceptance

Page 26: United States Environmental Protection Agency (U.S. … · United States Environmental Protection Agency (U.S. EPA) ... “Polyol” 19 ... Bulk Sludge & Still Bottoms 0.7 Latex Glue

2626

Comparison of Alternatives:Comparison of Alternatives:Protection of Human Health and the Protection of Human Health and the

EnvironmentEnvironment

�� All cleanup alternatives, except for the NoAll cleanup alternatives, except for the No--

Action Alternative, protect human health Action Alternative, protect human health

and the environment and the environment

Page 27: United States Environmental Protection Agency (U.S. … · United States Environmental Protection Agency (U.S. EPA) ... “Polyol” 19 ... Bulk Sludge & Still Bottoms 0.7 Latex Glue

2727

Comparison of Alternatives:Comparison of Alternatives:Compliance with ARARsCompliance with ARARs

�� All alternatives, except for the NoAll alternatives, except for the No--Action Action

Alternative, would comply with ARARsAlternative, would comply with ARARs

�� Alternative 5a would require a waiver of Alternative 5a would require a waiver of

OhioOhio’’s solid waste construction s solid waste construction

requirementsrequirements

Page 28: United States Environmental Protection Agency (U.S. … · United States Environmental Protection Agency (U.S. EPA) ... “Polyol” 19 ... Bulk Sludge & Still Bottoms 0.7 Latex Glue

2828

Comparison of Alternatives:Comparison of Alternatives:LongLong--term effectiveness and permanenceterm effectiveness and permanence

�� The excavation alternatives are longThe excavation alternatives are long--term term effective and permanent (LTEP) because there effective and permanent (LTEP) because there will be little or no risk after all principal threat will be little or no risk after all principal threat waste is removed and treatedwaste is removed and treated

�� Containment alternatives RAContainment alternatives RA--2 and RA2 and RA--3 are not 3 are not LTEP because contamination could reach the LTEP because contamination could reach the deep sand and gravel aquiferdeep sand and gravel aquifer

�� Containment/treatment alternative RAContainment/treatment alternative RA--7 falls 7 falls between the containment and excavation between the containment and excavation alternatives in terms of being LTEP alternatives in terms of being LTEP

Page 29: United States Environmental Protection Agency (U.S. … · United States Environmental Protection Agency (U.S. EPA) ... “Polyol” 19 ... Bulk Sludge & Still Bottoms 0.7 Latex Glue

2929

Comparison of Alternatives:Comparison of Alternatives:Reduction of Toxicity, Mobility, or Volume Reduction of Toxicity, Mobility, or Volume

through Treatmentthrough Treatment

�� The excavation alternatives fully reduce toxicity, The excavation alternatives fully reduce toxicity, mobility, or volume because all principal threat waste is mobility, or volume because all principal threat waste is removed and treatedremoved and treated

�� Containment alternatives RAContainment alternatives RA--2 and RA2 and RA--3 do not 3 do not significantly reduce the toxicity, mobility, or volume of significantly reduce the toxicity, mobility, or volume of hazardous waste because the principal threat waste hazardous waste because the principal threat waste would remain in placewould remain in place

�� Containment/treatment alternative RAContainment/treatment alternative RA--7 falls between 7 falls between the excavation and containment alternatives in its ability the excavation and containment alternatives in its ability to reduce the toxicity, mobility, or volume of hazardous to reduce the toxicity, mobility, or volume of hazardous waste by capturing and treating some of the liquid waste by capturing and treating some of the liquid hazardous waste hazardous waste

Page 30: United States Environmental Protection Agency (U.S. … · United States Environmental Protection Agency (U.S. EPA) ... “Polyol” 19 ... Bulk Sludge & Still Bottoms 0.7 Latex Glue

3030

Comparison of Alternatives:Comparison of Alternatives:ShortShort--term Effectiveness term Effectiveness

for Excavation Alternativesfor Excavation Alternatives

�� Excavation alternatives present some shortExcavation alternatives present some short--term risk to term risk to workers due to unstable conditions and material workers due to unstable conditions and material handlinghandling

�� Some risk would exist from trucking hazardous waste Some risk would exist from trucking hazardous waste offoff--sitesite

�� For alternatives 5, 5a, 5b, and 6, airborne risk exists For alternatives 5, 5a, 5b, and 6, airborne risk exists from operating an HTTD systemfrom operating an HTTD system

�� Risk from potentially contaminating the 1075 IntertillRisk from potentially contaminating the 1075 Intertill

�� Health and safety planning, engineering controls, and Health and safety planning, engineering controls, and other mitigative measures taken during construction other mitigative measures taken during construction would minimize human health and environmental risks would minimize human health and environmental risks noted abovenoted above

Page 31: United States Environmental Protection Agency (U.S. … · United States Environmental Protection Agency (U.S. EPA) ... “Polyol” 19 ... Bulk Sludge & Still Bottoms 0.7 Latex Glue

3131

Comparison of Alternatives:Comparison of Alternatives:ShortShort--term Effectiveness term Effectiveness

for Alternatives RAfor Alternatives RA--2, 3, and 72, 3, and 7

�� Containment alternatives RAContainment alternatives RA--2 and RA2 and RA--3 present minimal 3 present minimal shortshort--term risk to the workers and communityterm risk to the workers and community

�� Containment/treatment alternative RAContainment/treatment alternative RA--7 presents short7 presents short--term risk to workers because sumps will be installed term risk to workers because sumps will be installed through hazardous waste, and effective placement of the through hazardous waste, and effective placement of the sumps will be difficultsumps will be difficult

�� For RAFor RA--7, risk to the community will exist from 7, risk to the community will exist from transporting hazardous liquid waste offtransporting hazardous liquid waste off--sitesite

�� Health and safety planning, engineering controls, and Health and safety planning, engineering controls, and other mitigative measures taken during construction other mitigative measures taken during construction would minimize human health and environmental risks would minimize human health and environmental risks noted abovenoted above

Page 32: United States Environmental Protection Agency (U.S. … · United States Environmental Protection Agency (U.S. EPA) ... “Polyol” 19 ... Bulk Sludge & Still Bottoms 0.7 Latex Glue

3232

Comparison of Alternatives:Comparison of Alternatives:Implementability of Excavation AlternativesImplementability of Excavation Alternatives

�� Implementation of excavation alternatives would Implementation of excavation alternatives would be difficult; concern about excavating a large be difficult; concern about excavating a large volume of waste in an unstable setting and volume of waste in an unstable setting and handling the materialshandling the materials

�� Much coordination needed among different Much coordination needed among different entitiesentities

�� Many drum removals have occurred in the Many drum removals have occurred in the countrycountry

�� Few vendors may be available for an HTTD Few vendors may be available for an HTTD system (alternatives 5, 5a, 5b, and 6)system (alternatives 5, 5a, 5b, and 6)

Page 33: United States Environmental Protection Agency (U.S. … · United States Environmental Protection Agency (U.S. EPA) ... “Polyol” 19 ... Bulk Sludge & Still Bottoms 0.7 Latex Glue

3333

Comparison of Alternatives:Comparison of Alternatives:Implementability Implementability

of Alternatives RAof Alternatives RA--2, 3, and 72, 3, and 7

�� Containment alternatives RAContainment alternatives RA--2 and RA2 and RA--3 are readily 3 are readily

implementableimplementable

�� Containment/treatment alternative RAContainment/treatment alternative RA--7 will be more 7 will be more

difficult to implement:difficult to implement:

�� Optimal placement and depth of sump needed at Optimal placement and depth of sump needed at

each waste celleach waste cell

�� No way to accurately determine the percentage of No way to accurately determine the percentage of

liquid collectedliquid collected

�� Screens in the sumps may become clogged and Screens in the sumps may become clogged and

require maintenance or replacementrequire maintenance or replacement

Page 34: United States Environmental Protection Agency (U.S. … · United States Environmental Protection Agency (U.S. EPA) ... “Polyol” 19 ... Bulk Sludge & Still Bottoms 0.7 Latex Glue

3434

Comparison of Alternatives:Comparison of Alternatives:CostCost

�� Excavation alternatives are the most expensive Excavation alternatives are the most expensive ($56.9M ($56.9M -- $61.2M)$61.2M)

�� Containment alternatives RAContainment alternatives RA--2 ($7.3M) and RA2 ($7.3M) and RA--3 3 ($13.8M) are the least expensive (not including ($13.8M) are the least expensive (not including the Nothe No--Action Alternative)Action Alternative)

�� Containment/treatment alternative RAContainment/treatment alternative RA--7 7 ($22.5M) is less than half the cost of the ($22.5M) is less than half the cost of the excavation alternativesexcavation alternatives

�� RARA--2, RA2, RA--3, and RA3, and RA--7 operation and 7 operation and maintenance would need to occur indefinitelymaintenance would need to occur indefinitely

Page 35: United States Environmental Protection Agency (U.S. … · United States Environmental Protection Agency (U.S. EPA) ... “Polyol” 19 ... Bulk Sludge & Still Bottoms 0.7 Latex Glue

3535

Comparison of Alternatives:Comparison of Alternatives:State AcceptanceState Acceptance

�� Ohio EPA supports any of the excavation Ohio EPA supports any of the excavation alternativesalternatives

�� Ohio EPA does not support a containment Ohio EPA does not support a containment or containment/treatment alternativeor containment/treatment alternative

Page 36: United States Environmental Protection Agency (U.S. … · United States Environmental Protection Agency (U.S. EPA) ... “Polyol” 19 ... Bulk Sludge & Still Bottoms 0.7 Latex Glue

3636

Comparison of Alternatives:Comparison of Alternatives:Community AcceptanceCommunity Acceptance

�� Community input will be received during the Community input will be received during the public comment periodpublic comment period

�� The community advisory group (Citizens for The community advisory group (Citizens for Wise Approaches Toward Environmental Wise Approaches Toward Environmental Resources (Resources (““CF/WATERCF/WATER””)) and the Clark County )) and the Clark County Combined Health District support an excavation Combined Health District support an excavation alternativealternative

�� RESA has stated that either of the containment RESA has stated that either of the containment alternatives is adequate; however, RESA also alternatives is adequate; however, RESA also supports the containment/treatment alternativesupports the containment/treatment alternative

Page 37: United States Environmental Protection Agency (U.S. … · United States Environmental Protection Agency (U.S. EPA) ... “Polyol” 19 ... Bulk Sludge & Still Bottoms 0.7 Latex Glue

3737

U.S. EPAU.S. EPA’’s s

Preferred Cleanup AlternativePreferred Cleanup Alternative

�� U.S. EPA recommends Alternative RAU.S. EPA recommends Alternative RA--4a: 4a: excavation and offexcavation and off--site disposal and treatment of site disposal and treatment of hazardous and liquid waste; placement of solid, hazardous and liquid waste; placement of solid, nonnon--hazardous drummed waste and nonhazardous drummed waste and non--hazardous soils in an engineered waste cell in hazardous soils in an engineered waste cell in the Barrel Fill area; longthe Barrel Fill area; long--term operation and term operation and maintenance to include cap maintenance, maintenance to include cap maintenance, leachate collection and disposal, and leachate collection and disposal, and groundwater monitoring groundwater monitoring

�� U.S. EPA believes that Alternative RAU.S. EPA believes that Alternative RA--4a 4a presents the best balance of the nine criteria.presents the best balance of the nine criteria.

Page 38: United States Environmental Protection Agency (U.S. … · United States Environmental Protection Agency (U.S. EPA) ... “Polyol” 19 ... Bulk Sludge & Still Bottoms 0.7 Latex Glue

3838

will be fully evaluated after the public comment periodwill be fully evaluated after the public comment periodCommunity AcceptanceCommunity Acceptance

Ohio EPA has indicated support for the preferred alternative.Ohio EPA has indicated support for the preferred alternative.State AcceptanceState Acceptance

$22.5M$22.5M$61.2M$61.2M$57.4/$57.4/

60.6M60.6M$60.5M$60.5M$56.9/$56.9/

59.1M59.1M$60.6M$60.6M$13.8M$13.8M$7.3M$7.3M$0$0Cost Cost

����������������N/AN/AImplementabilityImplementability

����������������N/AN/AShortShort--term Effectivenessterm Effectiveness

������������������Reduction of Toxicity, Mobility, or Reduction of Toxicity, Mobility, or

Volume through TreatmentVolume through Treatment

������������������LongLong--term Effectiveness and term Effectiveness and

PermanencePermanence

������������������Compliance with ARARsCompliance with ARARs

������������������Overall Protection of Human Health and Overall Protection of Human Health and

the Environmentthe Environment

Evaluation CriterionEvaluation Criterion

Alt.7Alt.7Alt. 6Alt. 6Alt. Alt.

5a/5b5a/5bAlt. 5Alt. 5Alt. Alt.

4a/4b4a/4bAlt. 4Alt. 4Alt.3Alt.3Alt. 2Alt. 2Alt. 1Alt. 1

� Fully meets criterion � Partially meets criterion � Does not meet criterion

Page 39: United States Environmental Protection Agency (U.S. … · United States Environmental Protection Agency (U.S. EPA) ... “Polyol” 19 ... Bulk Sludge & Still Bottoms 0.7 Latex Glue

3939

Public Comment PeriodPublic Comment Period

�� Public comment period is from June 10Public comment period is from June 10thth

through July 12through July 12thth

�� Public comment period may be extended if Public comment period may be extended if

neededneeded

�� Comments may be faxed, eComments may be faxed, e--mailed, hardmailed, hard--

copy mailed; or submitted orally or in copy mailed; or submitted orally or in

writing at this meetingwriting at this meeting

Page 40: United States Environmental Protection Agency (U.S. … · United States Environmental Protection Agency (U.S. EPA) ... “Polyol” 19 ... Bulk Sludge & Still Bottoms 0.7 Latex Glue

4040

Record of Decision (ROD)Record of Decision (ROD)

�� Includes U.S. EPAIncludes U.S. EPA’’s selected remedys selected remedy

�� Includes the Responsiveness Summary, which Includes the Responsiveness Summary, which

contains significant comments from the public contains significant comments from the public

and U.S. EPA responsesand U.S. EPA responses

�� Selected remedy is normally the preferred Selected remedy is normally the preferred

cleanup alternative in the Proposed Plan, but cleanup alternative in the Proposed Plan, but

U.S. EPA may choose a different alternative U.S. EPA may choose a different alternative

based on public comment or other, new based on public comment or other, new

information that may become available information that may become available

Page 41: United States Environmental Protection Agency (U.S. … · United States Environmental Protection Agency (U.S. EPA) ... “Polyol” 19 ... Bulk Sludge & Still Bottoms 0.7 Latex Glue

4141

PostPost--ROD ActivitiesROD Activities

�� Remedial Design and Remedial Action (RD/RA) Remedial Design and Remedial Action (RD/RA) NegotiationsNegotiations

�� Enforcement order for RD/RAEnforcement order for RD/RA

�� Remedial Design: design the selected remedy Remedial Design: design the selected remedy as described in the RODas described in the ROD

�� Remedial construction: build the remedy as Remedial construction: build the remedy as detailed in the Remedial Designdetailed in the Remedial Design

�� Operation and maintenance: longOperation and maintenance: long--term term activities; e.g., groundwater monitoring, waste activities; e.g., groundwater monitoring, waste cap maintenance, leachate collection and cap maintenance, leachate collection and haulinghauling

Page 42: United States Environmental Protection Agency (U.S. … · United States Environmental Protection Agency (U.S. EPA) ... “Polyol” 19 ... Bulk Sludge & Still Bottoms 0.7 Latex Glue

4242

Contact and Resource InformationContact and Resource Information

�� Site information on the Internet: Site information on the Internet: www.epa.gov/region5/sites/tremontwww.epa.gov/region5/sites/tremont

�� Ron Murawski, Remedial Project Manager; Ron Murawski, Remedial Project Manager; 312312--886886--2940; 2940; [email protected]@epa.gov

�� Patricia Krause, Community Involvement Patricia Krause, Community Involvement Coordinator; 312Coordinator; 312--886886--9506; 9506; [email protected]@epa.gov

�� U.S. EPA tollU.S. EPA toll--free number: 800free number: 800--621621--84318431

�� Local Site repositoriesLocal Site repositories

�� Clark County Public Library, SpringfieldClark County Public Library, Springfield

�� Tremont City Municipal Building, Tremont CityTremont City Municipal Building, Tremont City

Page 43: United States Environmental Protection Agency (U.S. … · United States Environmental Protection Agency (U.S. EPA) ... “Polyol” 19 ... Bulk Sludge & Still Bottoms 0.7 Latex Glue

4343

Question and Answer PeriodQuestion and Answer Period