feasibility study addendum tremont city barrel …identification and description of modified or new...

FEASIBILITY STUDY ADDENDUM TREMONT CITY BARREL FILL SITE CLARK COUNTY GERMAN TOWNSHIP, OHIO by Haley & Aldrich, Inc. Cleveland, Ohio for Responsible Environmental Solutions Alliance (RESA)* File No. 28703-031 April 2009 *RESA is comprised of eight companies: Delphi Corporation; Franklin International, Inc.; General Motors Corporation; International Paper Company; The Procter & Gamble Company; PPG Industries, Inc.; Strebor/Roberts; and Worthington Cylinder Corporation

TABLE OF CONTENTS

Page

LIST OF TABLES iv LIST OF FIGURES iv LIST OF APPENDICES iv

1. INTRODUCTION 1

2. IDENTIFICATION AND DESCRIPTION OF MODIFIED OR NEW REMEDIAL ALTERNATIVES 2

2.1 Alternative 4a: Waste Removal with Off-Site Disposal of Hazardous Waste and On-Site Disposal of Solid Non-Hazardous Drummed Waste and Residuals in a Constructed Non-Lined Landfill 2

2.2 Alternative 4b: Waste Removal with Off-Site Disposal of Hazardous Waste and On-Site Disposal of Solid Non-Hazardous Drummed Waste and Residuals in a Constructed Lined Landfill 3

2.3 Alternative 5a: Waste Removal with Off-Site Disposal of Hazardous Waste, On-Site Treatment of Contaminated/Hazardous Residuals and Placement of Solid Non-Hazardous Drummed Wastes and Residuals into an On-Site Non-Lined Landfill 4

2.4 Alternative 5b: Waste Removal with Off-Site Disposal of Hazardous Waste, On-Site Treatment of Contaminated/Hazardous Residuals and Placement of Solid Non-Hazardous Drummed Wastes and Residuals into an On-Site Lined Landfill 5

2.5 Alternative 7: Liquid Waste Removal, Down Gradient Groundwater Collection Trench, Up Gradient Groundwater Diversion, Cap/Cover Regrading, Institutional Controls, Contingency Planning and Groundwater Monitoring 6

3. PROCESS FOR DETAILED ANALYSIS AND COMPARATIVE ANALYSIS OF REMEDIAL ALTERNATIVES 9

4. DETAILED ANALYSIS OF MODIFIED OR NEW REMEDIAL ALTERNATIVES 10

4.1 General 10 4.2 Remedial Alternative RA-4a (Waste Treatment): Waste Removal with Off-

Site Disposal of Hazardous Waste and Hazardous Soils, Placement of Non-Hazardous Drummed Waste and Non-hazardous Soils in a Non-Lined On-Site Landfill, Relocate Unnamed Tributary, Institutional Controls, Contingency Planning (During Construction) and Groundwater Monitoring 10

4.3 Remedial Alternative RA-4b (Waste Treatment): Waste Removal with Off-Site Disposal of Hazardous Waste and Hazardous Residuals, Placement of Non-Hazardous Drummed Waste and Non-Hazardous Soils in a Lined On-Site Landfill, Relocate Unnamed Tributary, Institutional Controls, Contingency Planning (During Construction) and Groundwater Monitoring 14

4.4 Remedial Alternative RA-5a (Waste Treatment): Waste Removal with Off-Site Disposal of Hazardous Waste, On-Site Treatment of Contaminated/Hazardous Residuals and Placement of Non-Hazardous Drummed Waste and Residuals into an On-Site Non-Lined Landfill,

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Relocate Unnamed Tributary, Institutional Controls Contingency Planning (During Construction) and Groundwater Monitoring 18

4.5 Remedial Alternative RA-5b (Waste Treatment): Waste Removal with Off-Site Disposal of Hazardous Waste, On-Site Treatment of Contaminated/Hazardous Residuals and Placement of Non-Hazardous Drummed Wastes and Residuals into an On-Site Lined Landfill, Relocate Unnamed Tributary, Institutional Controls Contingency Planning (During Construction) and Groundwater Monitoring 21

4.6 Remedial Alternative RA-7 (Waste Containment and Liquid Removal): Liquid Waste Removal, Down Gradient Groundwater Collection Trench, Up Gradient Groundwater Diversion, Cap/Cover Regrading, Relocate Unnamed Tributary, Institutional Controls, Contingency Planning and Groundwater Monitoring 25

5. COMPARATIVE ANALYSIS OF REMEDIAL ALTERNATIVES 29

5.1 Comparison of Overall Protection of Human Health and the Environment 29 5.2 Comparison of Compliance with ARARs 29 5.3 Comparison of Long-Term Effectiveness and Permanence 30 5.4 Comparison of Reduction in the Toxicity, Mobility, or Volume Through

Treatment 30 5.5 Comparison of Short-Term Effectiveness 30 5.6 Comparison of Implementability 32 5.7 Comparison of Cost 32 5.8 Summary of Comparisons 32 5.9 Summary 33

REFERENCES 35 TABLES FIGURES APPENDICES

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LIST OF TABLES Table No. Title 1 Detailed Analysis of Remedial Alternative RA-4a 2 Detailed Analysis of Remedial Alternative RA-4b 3 Detailed Analysis of Remedial Alternative RA-5a 4 Detailed Analysis of Remedial Alternative RA-5b 5 Detailed Analysis of Remedial Alternative RA-7 6 Summary of Potential ARAR and TBC Guidance 7 Net Present Worth – Summary of Remedial Alternatives 8 Comparative Analysis of Remedial Alternatives LIST OF FIGURES Figure No. Title 1 Layout Remedial Alternative RA-4a 2 Layout Remedial Alternative RA-5a 3 Layout Remedial Alternative RA-7 4 Remedial Alternative RA-7 Sump Locations 5 Remedial Alternative RA-7 Sump Detail LIST OF APPENDICES Appendix Title A Economic Evaluation of Remedial Alternatives

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LIST OF ACRONYMS AND ABBREVIATIONS AAD Alternatives Array Document AMSL Above Mean Sea Level AOC Administrative Order by Consent ARARs Applicable or Relevant and Appropriate Requirements ASTM American Society for Testing and Materials ATSDR Agency for Toxic Substances and Disease Registry BDL Below Detection Limits BFOU Barrel Fill Operable Unit (Tremont City Barrel Fill Site) bgs Below Ground Surface BNA Base/Neutral- and Acid-Extractable SVOCs BRA Baseline Risk Assessment CERCLA Comprehensive Environmental Response Compensation and

Liability Act CLP Contract Laboratory Program cm/sec Centimeters per Second COC Constituents of Concern COPC Constituents of Potential Concern COEC Constituents of Ecological Concern CPT Cone Penetration Test CSM Conceptual Site Model CSEM Conceptual Site Exposure Model CSF Cancer Slope Factor CVS Calibration Verification Sample CWM Chemical Waste Management, Inc. CFR Code of Federal Regulations DAF Dilution Attenuation Factor Danis Danis Industries, Inc. DFR Daily Field Report DO Dissolved Oxygen DOH Department of Health DOT Department of Transportation DPT Direct Push Technology DSP/WPA Data Summary Package/Work Plan Addendum Eagon Eagon & Associates, Inc. ECO-SSLs Ecological Soil Screening Levels ERA Ecological Risk Assessment FID Flame Ionization Detector FS Feasibility Study FSP Field Sampling Plan ft/day Feet per Day

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LIST OF ACRONYMS AND ABBREVIATIONS (continued)

GRA General Response Action gpm Gallons per Minute Haley & Aldrich Haley & Aldrich, Inc. HASP Health and Safety Plan HEAST Health Effects Assessment Summary Tables HHE Human Health Evaluation HHRA Human Health Risk Assessment I.D. Inner Diameter ID Identification IRIS Integrated Risk Information System IWD Industrial Waste Disposal, Inc. IC Institutional Control Kp Dermal permeability K Hydraulic Conductivity KVA Kilovolt LNAPL Light Non-Aqueous Phase Liquid LDR Land Disposal Restriction HTTD High Temperature Thermal Desorption mg/L Milligrams per Liter ug/L Micrograms per Liter mg/kg Milligrams per Kilogram ug/kg Micrograms per Kilogram MCL Maximum Contaminant Level MDL Method Detection Limit MS Matrix Spike MSD Matrix Spike Duplicate MRBVA Mad River Buried Valley Aquifer MW Monitoring Well MNA Monitored Natural Attenuation NA Not Analyzed NAPL Non-Aqueous Phase Liquid NCEA National Center for Environmental Assessment NCP National Contingency Plan ND Not Detected NTU Nephelometric Turbidity Unit NPDES National Pollutant Discharge Elimination System O.D. Outer Diameter ODNR Ohio Department of Natural Resources ODH Ohio Department of Health Ohio EPA Ohio Environmental Protection Agency

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ORP Oxidation Reduction Potential OVA Organic Vapor Analyzer OSHA Occupational Safety and Health Administration OAC Ohio Administrative Code ORC Ohio Revised Code O&M Operations and Maintenance PAHs Polycyclic Aromatic Hydrocarbons PCB Polychlorinated Biphenyls PCG s Preliminary Cleanup Goals PID Photo-Ionization Detector ppb Parts per Billion ppbv Parts per Billion - volume ppm Parts per Million PRG s Region 9 Preliminary Remediation Goals PTI Permit to Install POTW Publicly-Owned Treatment Works

QAPP Quality Assurance Project Plan QA/QC Quality Assurance/Quality Control QMP Quality Management Plan RAO Remedial Action Objective RBC Risk Based Concentration, U.S. EPA Region III RCRA Resource Conservation and Recovery Act RESA Responsible Environmental Solutions Alliance RfD Reference Dose RI Remedial Investigation RG Remediation Goal RD/RA Remedial Design/Remedial Action SAP Sampling & Analysis Plan SARA Superfund Amendments and Reauthorization Act SDWA Safe Drinking Water Act SIS Site Investigation Summary

Site Tremont City Barrel Fill Site SLERA Screening-Level Ecological Risk Assessment

SOP Standard Operating Procedures SOW Scope of Work SSL Soil Screening Level SSP Support Sampling Plan SVOC Semi-Volatile Organic Compound TBC To Be Considered TSCA Toxic Substance Control Act TAL Target Analyte List TCL Tremont City Landfill (Tremont City Landfill Site)

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TN&A T N & Associates, Inc. TSDF Treatment, Storage and Disposal Facility UCL Upper Confidence Limit (of the mean) USACE United States Army Corps of Engineers USCS Unified Soil Classification System U.S. EPA United States Environmental Protection Agency USGS United States Geological Survey UST Underground Storage Tank UTL Upper Tolerance Limit (population) VAP Voluntary Action Program (Ohio) VOC Volatile Organic Compound WTF Waste Transfer Facility (Tremont City Waste Transfer Facility

Site)

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1. INTRODUCTION This document is an addendum to the July 2008 Feasibility Study (FS) as modified and approved by U.S. EPA1 for the Tremont City Barrel Fill Site (Barrel Fill Site), formerly the Barrel Fill Operable Unit (BFOU) of the Tremont City Landfill, located at 3108 Snyder-Domer Road, Tremont City, German Township, Ohio. This addendum is in response to the U.S. EPA’s request to evaluate modifications to Remedial Alternatives RA-4 and RA-5 and RESA’s request to provide a new Remedial Alternative, RA-7. Note that this addendum focuses on the description and analysis of the modified or new Remedial Alternatives and references information contained in the July 2008 FS as modified and approved by U.S. EPA on background, site description, history, nature and extent of contamination, areas and volumes for media for which general response actions may be applied, and risks used to develop the alternatives and cost assumptions. This addendum to the FS is organized in sections as follows:

Section 1 - Introduction Section 2 - Identification and Description of Modified or New Remedial Alternatives Section 3 – Process for Detailed Analysis and Comparative Analysis of Alternatives Section 4 - Detailed Analysis of the Modified or New Remedial Alternatives Section 5 - Comparative Analysis of Remedial Alternatives References

1 RESA invoked dispute resolution pursuant to the Administrative Order on Consent.

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2. IDENTIFICATION AND DESCRIPTION OF MODIFIED OR NEW REMEDIAL ALTERNATIVES

Figures depicting the modified or new conceptual remedial alternatives are provided in Figures 1 through 5. Each modified or new remedial alternative is described in the following sections. 2.1 Alternative 4a: Waste Removal with Off-Site Disposal of Hazardous Waste and

On-Site Disposal of Solid Non-Hazardous Drummed Waste and Residuals in a Constructed Non-Lined Landfill

Alternative 4a is a variation of Alternative 4 (described in the July 2008 FS as modified and approved by U.S. EPA) that includes waste removal with off-site treatment, recycling, and disposal of hazardous waste. The difference in this alternative is that the drummed wastes and contaminated soil that are non-hazardous would be placed into a newly constructed waste cell on-site instead of being disposed off-site (see Figure 1).The new cell would be built consistent with requirements for a solid waste landfill as described for Remedial Alternative RA-5 in the July 2008 FS, but without a landfill liner.. The landfill bottom would be constructed with low permeability clay and sloped to facilitate the collection and removal of leachate. Alternative 4a also includes groundwater monitoring and post-closure care, consistent with RA-5 to protect against residual contamination. Hazardous wastes would be transported off-site and treated at commercial treatment, storage, and disposal facilities (TSDFs) or solid waste facilities, as appropriate. The solid non-hazardous waste and non-hazardous soils would be placed into a newly constructed waste cell on-site. Key components of the removal/treatment alternative include removal and staging of the existing cover soil; removal and handling of the waste cell contents (drums, water, uncontainerized waste and contaminated soil); personnel and perimeter air monitoring; waste characterization, off-site waste transportation and treatment, recycling, and disposal; water management; replacement of solid non-hazardous wastes and non-hazardous soils into a newly constructed solid waste cell; Site grading/restoration; and closure/post-closure care consistent with requirements for a solid waste landfill. Removal of drums, uncontainerized waste, cell water and soil between cells would require the same extensive excavation and waste handling as described in alternative RA-4. This alternative would achieve RAOs for groundwater by the following:

Removal of hazardous and liquid waste would eliminate the possibility of release of these materials to groundwater. On-site containment of non-hazardous solid waste in a newly constructed solid waste cell with post-closure care would lessen the likelihood of future releases of these materials to groundwater. Enforceable institutional controls would restrict the use of on-site groundwater as needed to control human exposure.

Removal of the waste and contaminated soil, and proper containment of treated/contaminated soils would lessen the likelihood of future migration of Site contaminants above risk-based levels to the Site land surface, the unnamed tributary, the deep sand and gravel groundwater unit, and to future indoor air.

This alternative would achieve RAOs for soil vapor and wastes at the Barrel Fill Site by the following:

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Waste removal would eliminate the source and therefore eliminate human exposures to hazardous substances in indoor air.

Removal of hazardous and liquid waste and on-site containment of non-hazardous solid waste in a newly constructed solid waste cell with post-closure care would reliably control the human direct contact exposure pathway. Fencing would discourage trespassing on the Site.

Removal of hazardous and liquid waste from the Site would eliminate hazardous substances in drums, barrels, tanks, or other bulk storage containers that may pose a threat of release.

This remedial alternative would achieve the RAOs directed by the U.S. EPA by the following:

Removal of waste and contaminated soil will protect groundwater from future degradation.

Removal of the hazardous waste eliminates the possibility of a future catastrophic release of contamination from the Barrel Fill.

Removal of the hazardous waste and soil will prevent migration of Site contaminants above risk-based levels to the Site land surface, the unnamed tributary, the deep sand and gravel groundwater unit, and future indoor air.

The estimated time for remedial design, procurement, and development of project plans and construction submittals would be 12 to 18 months; and for remedial construction would be 14 to 21 months. Monitoring would start after remedy construction and for the purpose of the FS, is assumed to continue for 30 years. However, the monitoring would be required for as long as necessary to protect human health and the environment. Post-closure care of the on-site solid waste landfill containing the solid non-hazardous wastes and residuals would be implemented following closure and continue for a minimum period of 30 years. Post-closure care would include quarterly inspections and the following activities:

Operation, maintenance, monitoring and repair of the leachate management system Cleaning and repair of the surface water management features Groundwater monitoring, and repair of the monitoring system Maintenance and repair of the cap system to correct settling or subsidence, ponding,

erosion, pest holes; and regular mowing to discourage deep-rooted vegetation. Written certification that the necessary work had been completed will need to occur within the context of CERCLA, and as treated soils remain on-site in a solid waste cell, Five-Year Reviews will be required as long as hazardous substances above health-based limits remain on-site. 2.2 Alternative 4b: Waste Removal with Off-Site Disposal of Hazardous Waste and

On-Site Disposal of Solid Non-Hazardous Drummed Waste and Residuals in a Constructed Lined Landfill

Alternative 4b includes all elements of Alternative 4a plus the installation of a liner in the constructed on-site landfill. The liner would be installed as described in Alternative 5 of the July 2008 FS as modified and approved by U.S. EPA. This alternative would achieve RAOs for groundwater by the following:

Removal of hazardous and liquid waste would eliminate the possibility of release of these materials to groundwater. On-site containment of non-hazardous solid waste in a newly constructed solid waste cell with post-closure care would lessen the likelihood of

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future releases of these materials to groundwater. Enforceable institutional controls would restrict the use of on-site groundwater as needed to control human exposure.




Removal of hazardous and liquid waste, and on-site containment of non-hazardous solid waste in a newly constructed solid waste cell with post-closure care would reliably control the human direct contact exposure pathway. Fencing would discourage trespassing on the Site.






The estimated time for remedial design, procurement, and development of project plans and construction submittals would be 12 to 18 months; and for remedial construction would be 14 to 23 months. Monitoring would start after remedy construction and for the purpose of the FS, is assumed to continue for 30 years. However, the monitoring would be required for as long as necessary to protect human health and the environment. 2.3 Alternative 5a: Waste Removal with Off-Site Disposal of Hazardous Waste, On-

Site Treatment of Contaminated/Hazardous Residuals and Placement of Solid Non-Hazardous Drummed Wastes and Residuals into an On-Site Non-Lined Landfill

Alternative 5a is a variation of Alternative 5 (described in the July 2008 FS as modified and approved by U.S. EPA). The difference in this alternative is that the drummed wastes and contaminated soil that are non-hazardous would be placed into a newly constructed waste cell on-site instead of being disposed off-site. The structure would be built consistent with requirements for a solid waste landfill without a liner as shown on Figure 2. The bottom of the landfill would be constructed as described above for Remedial Alternative RA-4a. This alternative would achieve RAOs for groundwater by the following:

Removal of hazardous and liquid waste would eliminate the possibility of release of these materials to groundwater. On-site containment of non-hazardous solid waste in a newly constructed solid waste cell with post-closure care would lessen the likelihood of

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future releases of these materials to groundwater. Enforceable institutional controls would restrict the use of on-site groundwater as needed to control human exposure.










The estimated time for remedial design, procurement, and development of project plans and construction submittals would be 12 to 18 months; and for remedial construction would be 14 to 23 months. Groundwater monitoring would start after remedy construction and for the purpose of the FS, is assumed to continue for 30 years. However, monitoring would be required for as long as necessary to protect human health and the environment. 2.4 Alternative 5b: Waste Removal with Off-Site Disposal of Hazardous Waste, On-

Site Treatment of Contaminated/Hazardous Residuals and Placement of Solid Non-Hazardous Drummed Wastes and Residuals into an On-Site Lined Landfill

Alternative 5b includes all elements of Alternative 5a plus the installation of a liner in the constructed on-site landfill. The liner would be constructed as described in alternative RA-5 of the July 2008 FS as modified and approved by U.S. EPA. This alternative would achieve RAOs for groundwater by the following:

Removal of hazardous and liquid waste would eliminate the possibility of release of these materials to groundwater. On-site containment of non-hazardous solid waste in a newly constructed solid waste cell with post-closure care would lessen the likelihood of future releases of these materials to groundwater. Enforceable institutional controls would restrict the use of on-site groundwater as needed to control human exposure.

Removal of the waste and contaminated soil, and proper containment of treated/contaminated soils would lessen the likelihood of future migration of Site

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contaminants above risk-based levels to the Site land surface, the unnamed tributary, the deep sand and gravel groundwater unit, and to future indoor air.









The estimated time for remedial design, procurement, and development of project plans and construction submittals would be 12 to 18 months; and for remedial construction would be 14 to 25 months. Groundwater monitoring would start after remedy construction and for the purpose of the FS, is assumed to continue for 30 years. However, monitoring would be required for as long as necessary to protect human health and the environment. 2.5 Alternative 7: Liquid Waste Removal, Down Gradient Groundwater Collection

Trench, Up Gradient Groundwater Diversion, Cap/Cover Regrading, Institutional Controls, Contingency Planning and Groundwater Monitoring

Alternative 7 includes all elements of the previously described Remedial Alternative RA-3 (July 2008 FS as modified and approved by U.S. EPA) with the additional installation of liquid waste removal sumps at all waste cell locations. The purpose of the sumps would be to remove cell water, uncontainerized liquid wastes, infiltration from precipitation, and any liquids that could be released by the drums in the future. The sumps would alleviate build-up of hydraulic head in the waste cells, reducing vertical groundwater flow. The proposed sump locations are shown on Figures 3 and 4. As shown on Figures 3 and 4, the sumps are currently proposed to be installed on the southern edges of the waste cells as this is the likely topographic low of the waste cell bottoms based on the construction of cells from the south. The assumption is that the waste cells would have been constructed with a slight slope to the south to drain the cells of accumulated water during construction. To assist in defining the topographic lows of waste cell bottoms, borings would be installed prior to sump installation activities to identify the topographic low side of the waste cells. Waste cell edges will be determined through review of existing plans and surface geophysical surveys. The borings would then be advanced at waste cell edges. One boring will be installed per waste cell side.

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The sumps would be installed via large diameter (approximately 2.0 to 1.5 ft.) drilling methods such as dual rotary or percussion drilling techniques to just below the bottom of the waste cells, but above the 1075 Intertill. A drilling mud such as a polymer additive would be used to keep the sump bore stable during installation activities. Down-hole geophysics would be used during installation activities to confirm that the sumps would be installed beneath the base of the drums. Geophysical methods would include electromagnetic techniques that would identify the metal drums contained in the waste cells. The response profiles of the top of the waste cells could be used to confirm response profiles for the bottom of waste cells. In addition, the geophysical profile of the top of drums could be confirmed with known top elevations of drums as measured during RI test pit activities. After placement of a five foot section of 12-inch diameter stainless steel screen, a 12-inch stainless steel riser would be extended to ground surface. The annular space would be filled with granular material to a height above the screen, a bentonite seal would be installed, and the remaining annular space would be filled with cement\bentonite grout. A flush mount protective cover and traffic bollards would be installed to protect the sump as shown on Figure 5. A rotation of approximately ten frac tanks and off-site transportation and disposal of liquids would be used to collect an estimated 910,000 gallons of waste cell water pumped during initial sump installation and development activities. Portable “trash” pumps that are moved from sump to sump and also removed between pumping events would be used to collect the liquids. These portable “trash” pumps would remove fines and sediment from the sumps, and because they would be removed from the waste cell environment when not in use, would also reduce the number of pumps required over the life of the project The liquid wastes removed from the sumps would be stored, properly characterized and properly disposed, as approved by U.S. EPA. Any excess non-hazardous drilling soils\solid wastes would be collected and placed under the cover\cap as part of the already described Remedial Alternative RA-3. Sumps would be equipped with level sensors connected to a central control panel. After initial start-up, the control panel would alert off-site operations and maintenance personnel that liquid levels had risen above a pre-determined level in a particular sump or sumps. Once alerted, operations and maintenance personnel would respond and pump out the liquid from that particular sump(s) within one to two days. In addition to removing liquids from sumps (two trips per month), routine operation and maintenance activities would include measuring liquid levels in each sump, and cleaning sumps and pumps as required. Routine removal of liquids from the sumps will vary depending on precipitation frequency and intensity, long term performance of the cut off wall and cap\cover, and the frequency and duration of liquid drummed waste release in the cells.

Even though the upgradient cut off wall and low permeability cap\cover would reduce water infiltration and leachate production, an estimated 83,000 gallons of liquids would be removed from the sumps each year. This estimate is based on rainfall infiltration of approximately 0.5 inch per year over the waste cell area of approximately 4 acres, and 850,000 gallons of liquid drummed waste being released over thirty years. The sumps would remove a significant portion of infiltration due to precipitation and liquids released by the drums in the future. This alternative would achieve RAOs for groundwater by the following:

Liquid waste removal would remove a significant portion of the liquid principal threat

waste and reduce the source of future groundwater contamination, thereby lessening the likelihood for future releases of Barrel Fill waste to groundwater.

Enforceable institutional controls prohibiting the on-site of groundwater would reduce the likelihood of human potable use exposure to groundwater COCs.

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The sumps, down gradient collection trench and up gradient groundwater diversion would also further minimize the already extremely low rate of vertical groundwater flow by reducing the hydraulic head differential between the liquid level in the cells and the 1075 Intertill.


Enforceable institutional controls prohibiting residential, commercial, or recreational use on the Site would reduce the likelihood of human exposure to hazardous substances in indoor air.

The cap and cover would prevent direct contact human exposures to hazardous substances in the wastes.

The liquid waste removal along with the groundwater cut-off/collection trench would manage releases of hazardous substances from drums, barrels, tanks or other bulk storage containers by reducing the spread of contamination.


This remedial alternative will remove liquid wastes and thereby reduce the possibility of future degradation of groundwater.

The removal of liquid wastes using the sumps will reduce the possibility of a future catastrophic release of contamination from the Barrel Fill.

The removal of liquid wastes from the sumps will reduce the possibility of migration of Site contaminants above risk-based levels to the Site land surface, the unnamed tributary, the deep sand and gravel groundwater unit, and future indoor air.

The estimated time for remedial design, procurement, and development of project plans and construction submittals would be 8 to 12 months; and for remedial construction would be 10 to 16 months. Monitoring and contingency planning would start after remedy construction and continue for 30 years. However, the monitoring and contingency plan would be required for as long as necessary to protect human health and the environment.

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3. PROCESS FOR DETAILED ANALYSIS AND COMPARATIVE ANALYSIS OF REMEDIAL ALTERNATIVES

Please refer to Section 3 of the July 2008 Feasibility Study as modified and approved by U.S. EPA for description of the nine criteria.

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4. DETAILED ANALYSIS OF MODIFIED OR NEW REMEDIAL

ALTERNATIVES

In this section, each of the five modified or new remedial alternatives that were described in Section 2 undergoes a detailed analysis or assessment against each of the first seven of nine evaluation criteria (as described in Section 3 of the July 2008 FS as modified and approved by U.S. EPA). 4.1 General

The selection of a Barrel Fill Site remedy is based upon a qualitative evaluation of the alternatives using the following criteria:

Overall Protection of Human Health and the Environment; Compliance with ARARs; Long-Term Effectiveness and Permanence; Reduction in the Toxicity, Mobility, or Volume through Treatment; Short-term Effectiveness; Implementability; and Cost.

The text in this Section provides an overview of the detailed evaluation. More specific and detailed evaluations with regard to each of the criteria are presented in Tables 1 through 5.

A relative estimate of occupational and transportation risk of remedial alternatives as compared to the risks of the alternatives previously described in the July 2008 FS as modified and approved by U.S. EPA are presented below. The basis for the costs of each new or modified remedial alternative is presented in Appendix A. A breakdown of the modified unit quantities for each unit process along with costs associated with each unit for the addendum is provided in Appendix A. Table 7 summarizes the capital and annual O&M costs for each modified or new remedial alternative based upon the component costs developed in the previous subsection. For the economic evaluation of alternatives, the total cost (e.g., capital and annual O&M costs) for an alternative is converted to its present worth based upon the performance period of the alternative or technologies and a seven percent interest rate. The net present value of each remedial alternative is also presented in Table 7.

4.2 Remedial Alternative RA-4a (Waste Treatment): Waste Removal with Off-Site

Disposal of Hazardous Waste and Hazardous Soils, Placement of Non-Hazardous Drummed Waste and Non-hazardous Soils in a Non-Lined On-Site Landfill, Relocate Unnamed Tributary, Institutional Controls, Contingency Planning (During Construction) and Groundwater Monitoring

4.2.1 Overall Protection of Human Health and the Environment

Remedial Alternative RA-4a protects human health and the environment through removal of the principal threat waste, liquid waste, and hazardous soils with off-site treatment, recycling and disposal. Non-hazardous solid waste would be disposed of on-site in a newly constructed non-lined solid waste cell. Groundwater monitoring will be conducted to verify that the removal of the principal threat waste and containment of the low-level threat waste has been protective of groundwater and surface water. Containment of the low-level threat waste and post-closure care under OAC 3745-27 would prevent exposure to these wastes. Institutional controls would restrict future use of the Site and on-site groundwater. This controls exposure to hazardous substances in

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groundwater. There are occupational and transportation risks associated with the removal, handling and transportation of waste and contaminated residuals. The relative occupational and transportation risks of this alternative are generally consistent with those described in Remedial Alternative RA-5 of the July 2008 FS as modified and approved by U.S. EPA, with the exception that Remedial Alternative RA-4a does not include the treatment of hazardous residuals or the installation of a liner. The relative magnitude of the occupational risks are lower than Remedial Alternative RA-5 because there is no on-site treatment of hazardous waste and the on-site landfill would be non-lined and incrementally smaller in size. The relative magnitude of the transportation risks would be slightly higher than Remedial Alternative RA-5 because of the off-site disposal of the hazardous residuals. The relocation of the unnamed tributary provides overall protection of human health and the environment by reducing and controlling impacts to surface water This alternative provides long-term effectiveness and permanence, short-term effectiveness, and compliance with ARARs (see below for further discussion). In summary RA-4a provides the following with respect to overall protection of human health and the environment:

All of the principal threat waste is removed and/or treated. Water table groundwater contaminated above acceptable levels is removed and

treated/disposed of off-site. The treatment processes employed are irreversible. The remedial action has a high degree of reliability and permanence; possibility

of future exposure to contamination in excess of risk-based criteria is minimal. Containment of the non-hazardous solid waste in a new solid waste cell is

reliable and readily monitored. The magnitude of residual risk associated with the non-hazardous solid waste is

minimal. Short-term risks to Site workers are significant but manageable, and short-term

risks to the community are of lesser magnitude than to on-site workers and are also manageable. Due to increased materials handling and transportation, short-term risks to Site workers and the community are greater than the short-term risks for RA-2, RA-3 and RA-7.

Enforceable institutional and access controls consistent with solid waste closure requirements will restrict future use of the Site and limit use of on-site groundwater.

Time until all RAOs are achieved for the excavation alternative is approximately three years.

4.2.2 Compliance with ARARs

As provided in Table 6, chemical-specific, action-specific and location-specific ARARs would be met through proper design, planning and implementation of the remedy. Select ARARs associated with this alternative and how the alternative complies with them are as follows:

40 CFR Part 262 - Standards Applicable to Generators of RCRA Hazardous Wastes – Wastes handled during removal would be managed on-site in accordance with substantive RCRA requirements; off-site in accordance with substantive and administrative requirements.

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OAC 3745-39 - Storm Water Management Program - Would meet substantive requirements for on-site storm water management; substantive and administrative requirements for off-site storm water management.

OAC 3745-51 Identification & Listing of RCRA Hazardous Waste - Would meet substantive requirements if RCRA hazardous waste is generated or managed on-site; substantive and administrative requirements if managed off-site.

49 CFR Part 171 - US DOT Placarding and Handling Hazardous Material Regulations - DOT Hazardous Materials handled during waste removal would meet substantive and administrative requirements for off-site transportation.

OAC 3745-27 - Solid Waste Regulations - Would meet substantive requirements by design, operation and maintenance of Solid Waste Landfill on-site for non-hazardous wastes and treated residuals. The construction of a solid waste landfill without a liner may require a waiver.

4.2.3 Long-Term Effectiveness and Permanence

This alternative is an effective, permanent remedy. The source hazardous wastes, hazardous soils and cell water would be removed and treated, recycled, and disposed of off-site, thus preventing the potential for future exposure. Non-hazardous cell materials and non-hazardous soils would be disposed of on-site in a newly constructed solid waste cell. Enforceable institutional controls, and post-closure care and monitoring under OAC 3745-27 would contribute to long-term effectiveness by significantly reducing the possibility of exposure to the contaminated materials, groundwater, and surface water until monitoring has demonstrated that removal of the hazardous wastes and liquids, and containment of the non-hazardous cell contents and soils have been protective of groundwater and surface water. In addition the following applies to this criterion:

All principal threat waste, liquid waste, and hazardous contaminated soils are removed and/or treated. The treatment processes employed are irreversible.

Water table groundwater contaminated above acceptable levels is removed and treated/disposed of off-site.

The remedial action has a high degree of reliability and permanence; the probability of future exposure to contamination in excess of risk-based criteria is very low.

Enforceable institutional and access controls consistent with solid waste closure requirements will restrict future use of the Site and use of on-site groundwater.

Containment of the non-hazardous solid waste in a new on-site solid waste cell is reliable and readily monitored.

Replacement of the remedial action is not likely; therefore, the threat or risk of replacement is minimal. Maintenance of the solid waste cell and leachate collection system will be needed.

The magnitude of residual risk associated with the non-hazardous solid waste is minimal.

The remaining risks are minimal and include the possibility that residual hazardous substances remaining in groundwater may migrate. Remaining concentrations of hazardous substances in groundwater are expected to be low and to decrease with time. Groundwater monitoring will be conducted to verify that principal threat waste removal and low-level threat waste containment has effectively protected groundwater and that residual groundwater contamination is not migrating to points of potential exposure at concentrations posing risk to human health and the environment.

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4.2.4 Reduction of Toxicity, Mobility, or Volume through Treatment

All principal threat waste, liquid waste and hazardous contaminated soils would be transported off-site for treatment, recycling, or disposal at appropriately permitted facilities. This component of Alternative 4a irreversibly reduces the toxicity, mobility, or volume of these wastes through ex-situ treatment. Low-level threat non-hazardous solid waste would be disposed of on-site in a newly constructed solid waste cell.

4.2.5 Short-Term Effectiveness

Worker health and safety measures such as personal protective equipment, monitoring, and health and safety plans will be required to mitigate exposure of Site workers to hazardous substances. Careful control of the removal work will minimize emissions during excavation, sampling, consolidation, and transportation. Air monitoring will be performed for fugitive dust, metals, and volatile emissions during source removal to ensure that Site activities do no present an unacceptable airborne risk to on-site workers or off-site receptors. Exceedance of action levels during construction may require shut-down of activities while further mitigative measures are implemented. Mitigative measures such as dust suppression and temporary covers for waste piles will be employed to reduce emissions if perimeter monitoring indicates any potential for off-site risk due to airborne contamination. In addition, this remedial action will expose the community to significant risks due to the heavy truck traffic and movement of hazardous waste through the community. The community must be prepared in advance for this activity. Due to the proximity of the top of the 1075 Intertill to the bottom of the excavation, excavation below the cells may expose the 1075 Intertill. Mitigation measures (safeguards) including construction dewatering and vacuum trucks will be employed to reduce the risk of contaminating the 1075 Intertill during construction. The relative occupational and transportation risks of this alternative are generally consistent in type with those described in Remedial Alternative RA-5 of the July 2008 FS as modified and approved by U.S. EPA, with the exception of the treatment of hazardous wastes and residuals. The relative magnitude of the occupational risks are lower than Remedial Alternative RA-5 because there is no on-site treatment of hazardous waste and the on-site landfill would be incrementally smaller in size. The relative magnitude of the transportation risks would be slightly higher than Remedial Alternative RA-5 because of the off-site disposal of the hazardous residuals. The magnitude of green house gas emissions compared to Alternative RA-5 are likely lower due to no on-site treatment of wastes, and vehicle emissions are likely higher due to additional off-site disposal of hazardous waste. The timeframe to reach the RAOs is less than 30 years because the waste would be removed from the Barrel Fill Site.

4.2.6 Implementability

This alternative is technically and administratively feasible. RA-4a will require coordination among numerous parties including local governmental agencies, traffic control, contractors, and disposal facilities to address the complex issues associated with handling and transporting significant quantities of hazardous waste through a community. The limited environmental covenant and groundwater monitoring portions of the remedy are readily implementable.

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No additional remedial action is anticipated. The effectiveness of the remedy is readily monitored by post-excavation verification sampling prior to backfilling the excavation with clean soil, , and groundwater monitoring.

The logistical requirements of moving approximately more than 3,500 trucks through the local community (two lane road) may cause delays;

There are inherent uncertainties in performing an excavation and removal of this magnitude (subsurface conditions, weather, etc.) that may cause delays;

Coordination of disposal facilities will be challenging and may cause delays. None of the proposed activities are likely to preclude additional remedial

actions if necessary. Construction of an on-site permanent landfill will be readily implementable.

4.2.7 Cost The total capital costs for Alternative RA-4a are estimated to be $55,670,000. The annual O&M costs are estimated to be $158,000 for the first five years, $90,000 for years 5 through 10 and $56,000 for years 11 through 30. The total net present value of the costs for this alternative, with 30 years of operation and maintenance, is estimated at $56,883,000.

4.3 Remedial Alternative RA-4b (Waste Treatment): Waste Removal with Off-Site

Disposal of Hazardous Waste and Hazardous Residuals, Placement of Non-Hazardous Drummed Waste and Non-Hazardous Soils in a Lined On-Site Landfill, Relocate Unnamed Tributary, Institutional Controls, Contingency Planning (During Construction) and Groundwater Monitoring


Remedial Alternative RA-4b protects human health and the environment through removal of the principal threat waste, liquid waste, and hazardous soils with off-site treatment, recycling and disposal. Non-hazardous solid waste would be disposed of on-site in a newly constructed non-lined solid waste cell. Groundwater monitoring will be conducted to verify that the removal of the principal threat waste and containment of the low-level threat waste has been protective of groundwater and surface water. Containment of the low-level threat waste and post-closure care under OAC 3745-27 would prevent exposure to these wastes. Institutional controls would restrict future use of the Site and on-site groundwater. This controls exposure to hazardous substances in groundwater. There are occupational and transportation risks associated with the removal, handling and transportation of waste and contaminated residuals. The relative occupational and transportation risks of this alternative are generally consistent with those described in Remedial Alternative RA-5 of the July 2008 FS as modified and approved by U.S. EPA, with the exception that Remedial Alternative RA-4b does not include the treatment of hazardous residuals. The relative magnitude of the occupational risks are lower than Remedial Alternative RA-5 because there is no on-site treatment of hazardous waste and the on-site landfill would be incrementally smaller in size. The relative magnitude of the transportation risks would be slightly higher than Remedial Alternative RA-5 because of the off-site disposal of the hazardous residuals. The relocation of the unnamed tributary provides overall protection of human health and the environment by reducing and controlling impacts to surface water. This alternative provides long-term effectiveness and permanence, short-term effectiveness, and compliance with ARARs (see below for further discussion).

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In summary RA-4b provides the following with respect to overall protection of human health and the environment:

All of the principal threat waste is removed and/or treated. Water table groundwater contaminated above acceptable levels is removed and



reliable and readily monitored. The magnitude of residual risk associated with the non-hazardous solid waste is

minimal. Short-term risks to Site workers are significant but manageable, and short-term

risks to the community are of lesser magnitude than to on-site workers and are also manageable. Due to increased materials handling and transportation, short-term risks to Site workers and the community are greater than the short-term risks for RA-2, RA-3 and RA-7.









OAC 3745-27 - Solid Waste Regulations - Would meet substantive requirements by design, operation and maintenance of Solid Waste Landfill on-site for treated residual waste.


This alternative is an effective, permanent remedy. The source hazardous wastes, hazardous soils and cell water would be removed and treated, recycled, and disposed of off-site, thus preventing the potential for future exposure. Non-hazardous cell materials

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and non-hazardous soils would be disposed of on-site in a newly constructed solid waste cell. Enforceable institutional controls, and post-closure care and monitoring under OAC 3745-27 would contribute to long-term effectiveness by significantly reducing the possibility of exposure to the contaminated materials, groundwater, and surface water until monitoring has demonstrated that removal of the hazardous wastes and liquids, and containment of the non-hazardous cell contents and soils have been protective of groundwater and surface water. In addition the following applies to this criterion:

All principal threat waste, liquid waste, and hazardous contaminated soils are removed and/or treated. The treatment processes employed are irreversible.




Containment of the non-hazardous solid waste in a new on-site solid waste cell is reliable and readily monitored.


The magnitude of residual risk associated with the non-hazardous solid waste is minimal.



Principal threat waste, liquid waste and hazardous contaminated soils would be transported off-site for treatment, recycling, or disposal at appropriately permitted facilities. This component of Alternative 4b irreversibly reduces the toxicity, mobility, or volume of these wastes through ex-situ treatment. Low-level threat non-hazardous solid waste would be disposed of on-site in a newly constructed solid waste cell.


Worker health and safety measures such as personal protective equipment, monitoring, and health and safety plans will be required to mitigate exposure of Site workers to hazardous substances. Careful control of the removal work will minimize emissions during excavation, sampling, consolidation, and transportation. Air monitoring will be performed for fugitive dust, metals, and volatile emissions during source removal to ensure that Site activities do no present an unacceptable airborne risk to on-site workers or off-site receptors. Exceedance of action levels during construction may require shut-down of activities while further mitigative measures are implemented. Mitigative measures such as dust suppression and temporary covers for waste piles will be

17

employed to reduce emissions if perimeter monitoring indicates any potential for off-site risk due to airborne contamination. In addition, this remedial action will expose the community to significant risks due to the heavy truck traffic and movement of hazardous waste through the community. The community must be prepared in advance for this activity. Due to the proximity of the top of the 1075 Intertill to the bottom of the excavation, excavation below the cells may expose the 1075 Intertill. Mitigation measures (safeguards) including construction dewatering and vacuum trucks will be employed to reduce the risk of contaminating the 1075 Intertill during construction. The relative occupational and transportation risks of this alternative are generally consistent in type with those described in Remedial Alternative RA-5 of the July 2008 FS as modified and approved by U.S. EPA, with the exception of the treatment of hazardous wastes and residuals. The relative magnitude of the occupational risks are lower than Remedial Alternative RA-5 because there is no on-site treatment of hazardous waste and the on-site landfill would be incrementally smaller in size. The relative magnitude of the transportation risks would be slightly higher than Remedial Alternative RA-5 because of the off-site disposal of the hazardous residuals. The vehicle emissions compared to Alternative RA-5 are likely higher due to additional off-site disposal of hazardous waste.

4.3.6 Implementability

This alternative is technically and administratively feasible. RA-4b will require coordination among numerous parties including local governmental agencies, traffic control, contractors, and disposal facilities to address the complex issues associated with handling and transporting significant quantities of hazardous waste through a community. The limited environmental covenant and groundwater monitoring portions of the remedy are readily implementable. No additional remedial action is anticipated. The effectiveness of the remedy is readily monitored by post-excavation verification sampling prior to backfilling the excavation with clean soil, and groundwater monitoring.

The logistical requirements of moving approximately more than 3,500 trucks through the local community (two lane road) may cause delays;



actions if necessary. Construction of an on-site permanent landfill will be readily implementable.

4.3.7 Cost The total capital costs for Alternative RA-4b are estimated to be $57,910,000. The annual O&M costs are estimated to be $158,000 for the first five years, $90,000 for years 5 through 10 and $56,000 for years 11 through 30. The total net present value of the costs for this alternative, with 30 years of operation and maintenance, is estimated at $59,123,000.

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4.4 Remedial Alternative RA-5a (Waste Treatment): Waste Removal with Off-Site Disposal of Hazardous Waste, On-Site Treatment of Contaminated/Hazardous Residuals and Placement of Non-Hazardous Drummed Waste and Residuals into an On-Site Non-Lined Landfill, Relocate Unnamed Tributary, Institutional Controls Contingency Planning (During Construction) and Groundwater Monitoring


Remedial Alternative RA-5a protects human health and the environment through removal of the principal threat waste and liquid waste with off-site treatment, recycling and disposal. Hazardous soils would be treated on-site to render them non-hazardous. Treated soils and non-hazardous solid waste would be disposed of on-site in a newly constructed unlined solid waste cell. Groundwater monitoring will be conducted to verify that the removal of the principal threat waste and containment of the low-level threat waste has been protective of groundwater and surface water. Containment of the low-level threat waste and post-closure care under OAC 3745-27 would prevent exposure to these wastes. Institutional controls would restrict future use of the Site and on-site groundwater. This controls exposure to hazardous substances in groundwater. There are occupational and transportation risks associated with the removal, handling and transportation of waste and contaminated residuals The relative occupational and transportation risks of this alternative are generally consistent with those described in Remedial Alternative RA-5 of the July 2008 FS as modified and approved by U.S. EPA, with the exception that Remedial Alternative RA-5a does not include the installation of a liner. The relative magnitude of the occupational risks are about the same as Remedial Alternative RA-5 because the on-site waste landfill in remedial Alternative 5a would be non-lined, but incrementally larger in size. The relative magnitude of the transportation risks would be slightly lower than Remedial Alternative RA-5 because of the on-site disposal of non-hazardous drummed wastes. The relocation of the unnamed tributary provides overall protection of human health and the environment by reducing and controlling impacts to surface water This alternative provides long-term effectiveness and permanence, short-term effectiveness, and compliance with ARARs (see below for further discussion). RA-5a provides the following with respect to overall protection of human health and the environment:

Principal threat waste is removed and/or treated. Water table groundwater contaminated above acceptable levels is removed and



reliable and readily monitored. The magnitude of residual risk associated with the non-hazardous solid waste

and treated soils in minimal. Short-term risks to Site workers and the community are manageable, and short-

term risks to the community are of lesser magnitude than to on-site workers and are also manageable. Due to increased materials handling and transportation, short-term risks to Site workers and the community are greater than the short-term risks for RA-2, RA-3 and RA-7.

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Enforceable Institutional and access controls consistent with solid waste closure requirements will restrict future use of the Site and limit use of on-site groundwater.








OAC 3745-15 - General Provisions for Air Pollution Control - On-site actions would meet substantive requirements by monitoring and controls.

OAC 3745-27 - Solid Waste Regulations - Would meet substantive requirements by design, operation and maintenance of Solid Waste Landfill on-site for treated residual waste. The construction of a solid waste landfill without a liner may require a waiver.


This alternative is an effective, permanent remedy. The principal threat waste and liquid waste would be removed and treated, recycled, and disposed of off-site, thus preventing the potential for future exposure. Hazardous soils would be treated on-site to render them non-hazardous. Treated soils and low level threat solid waste would be disposed of on-site in a newly constructed solid waste cell. Enforceable institutional controls, and post-closure care and monitoring under OAC 3745-27 would contribute to long-term effectiveness by reducing the likelihood of exposure to the solid waste soils and to on-site groundwater until monitoring has demonstrated that removal and treatment of the principal threat waste wand containment of low-level threat waste has been protective of groundwater and surface water. In addition the following applies to this criterion:

Principal threat waste, liquid waste, and hazardous contaminated soils are removed and/or treated. The treatment processes employed are irreversible.


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Containment of the non-hazardous solid waste and treated soils in a new on-site solid waste cell is reliable and readily monitored.


The magnitude of residual risk associated with the non-hazardous solid waste and treated soils is minimal.



Principal threat waste and liquid waste would be transported off-site for treatment, recycling, or disposal at appropriately permitted facilities. Hazardous soils will be treated on-site to render them non-hazardous. This component of Alternative 5a irreversibly reduces the toxicity, mobility, and volume of these wastes through ex-situ treatment. Low-level threat non-hazardous solid waste would be disposed of on-site in a newly constructed solid waste cell.


Worker health and safety measures such as personal protective equipment, monitoring, and health and safety plans will be required to mitigate exposure of Site workers to hazardous substances. Careful control of the removal work will minimize emissions during excavation, sampling, consolidation, and transportation. Air monitoring will be performed for fugitive dust, metals, and volatile emissions during source removal to ensure that Site activities do no present an unacceptable airborne risk to on-site workers or off-site receptors. Exceedance of action levels during construction may require shut-down of activities while further mitigative measures are implemented. Mitigative measures such as dust suppression and temporary covers for waste piles will be employed to reduce emissions if perimeter monitoring indicates any potential for off-site risk due to airborne contamination. In addition, this remedial action will expose the community to significant risks due to the heavy truck traffic and movement of hazardous waste through the community. The community must be prepared in advance for this activity. Due to the proximity of the top of the 1075 Intertill to the bottom of the excavation, excavation below the cells may expose the 1075 Intertill. Mitigation measures (safeguards) including construction dewatering and vacuum trucks will be employed to reduce the risk of contaminating the 1075 Intertill during construction. The relative occupational and transportation risks of this alternative are generally consistent with those described in Remedial Alternative RA-5 of the July 2008 FS as

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modified and approved by U.S. EPA. The relative magnitude of the occupational risks are about the same as Remedial Alternative RA-5 because the on-site waste landfill in remedial Alternative 5a would be non-lined, but incrementally larger in size. The relative magnitude of the transportation risks would be slightly lower than Remedial Alternative RA-5 because of the on-site disposal of non-hazardous drummed wastes. 4.4.6 Implementability

This alternative is technically and administratively feasible. RA-5a will require coordination among numerous parties including local governmental agencies, traffic control, contractors, and disposal facilities to address the complex issues associated with handling and transporting significant quantities of hazardous waste through a community. The limited environmental covenant and groundwater monitoring portions of the remedy are readily implementable. No additional remedial action is anticipated. The effectiveness of the remedy is readily monitored by post-excavation verification sampling prior to backfilling the excavation with clean soil, post-treatment verification sampling, and groundwater monitoring.

The logistical requirements of moving approximately 3,500 trucks through the local community (two lane road) may cause delays;


Delays due to the complexity of installation, and operation of the on-site thermal desorption unit are possible/likely including the need to address community concerns regarding incineration;

Based on discussions with remediation vendors, on-site thermal desorption may not be available from multiple vendors and may prevent implementation;


actions if necessary. Additional infrastructure to provide the necessary energy to operate the high

temperature thermal desorption (approximately 800° F) unit would need to be installed.

Construction of an on-site permanent landfill will be readily implementable. 4.4.7 Cost

The total capital costs for Alternative RA-5a are estimated to be $56,088,000. The annual O&M costs are estimated to be $162,000 for the first five years, $94,000 for years 5 through 10 and $60,000 for years 11 through 30. The total net present value of the costs for this alternative, with 30 years of operation and maintenance, is estimated at $57,351,000.

4.5 Remedial Alternative RA-5b (Waste Treatment): Waste Removal with Off-Site

Disposal of Hazardous Waste, On-Site Treatment of Contaminated/Hazardous Residuals and Placement of Non-Hazardous Drummed Wastes and Residuals into an On-Site Lined Landfill, Relocate Unnamed Tributary, Institutional Controls Contingency Planning (During Construction) and Groundwater Monitoring 4.5.1 Overall Protection of Human Health and the Environment

Remedial Alternative RA-5b protects human health and the environment through removal of the principal threat waste and liquid waste with off-site treatment, recycling

22

and disposal. Hazardous soils would be treated on-site to render them non-hazardous. Treated soils and non-hazardous solid waste would be disposed of on-site in a newly constructed lined solid waste cell. Groundwater monitoring will be conducted to verify that the removal of the principal threat waste and containment of the low-level threat waste has been protective of groundwater and surface water. Containment of the low-level threat waste and post-closure care under OAC 3745-27 would prevent exposure to these wastes. Institutional controls would restrict future use of the Site and on-site groundwater. This controls exposure to hazardous substances in groundwater. There are occupational and transportation risks associated with the removal, handling and transportation of waste and contaminated residuals The relative occupational and transportation risks of this alternative are generally consistent with those described in Remedial Alternative RA-5 of the July 2008 FS as modified and approved by U.S. EPA. The relative magnitude of the occupational risks may be slightly higher as compared to Remedial Alternative RA-5 because the on-site waste landfill in remedial Alternative 5b would be incrementally larger in size. The relative magnitude of the transportation risks would be slightly lower than Remedial Alternative RA-5 because of the on-site disposal of non-hazardous drummed wastes. The relocation of the unnamed tributary provides overall protection of human health and the environment by reducing and controlling impacts to surface water. This alternative provides long-term effectiveness and permanence, short-term effectiveness, and compliance with ARARs (see below for further discussion). RA-5b provides the following with respect to overall protection of human health and the environment:

Principal threat waste is removed and/or treated. Water table groundwater contaminated above acceptable levels is removed and



reliable and readily monitored. The magnitude of residual risk associated with the non-hazardous solid waste

and treated soils in minimal. Short-term risks to Site workers and the community are manageable, and short-

term risks to the community are of lesser magnitude than to on-site workers and are also manageable. Due to increased materials handling and transportation, short-term risks to Site workers and the community are greater than the short-term risks for RA-2, RA-3 and RA-7.





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OAC 3745-15 - General Provisions for Air Pollution Control - On-site actions would meet substantive requirements by monitoring and controls.

OAC 3745-27 - Solid Waste Regulations - Would meet substantive requirements by design, operation and maintenance of Solid Waste Landfill on-site for treated residual waste.


This alternative is an effective, permanent remedy. The principal threat waste and liquid waste would be removed and treated, recycled, and disposed of off-site, thus preventing the potential for future exposure. Hazardous soils would be treated on-site to render them non-hazardous. Treated soils and low level threat solid waste would be disposed of on-site in a newly constructed solid waste cell. Enforceable nstitutional controls, and post-closure care and monitoring under OAC 3745-27 would contribute to long-term effectiveness by reducing the likelihood of exposure to the solid waste soils and to on-site groundwater until monitoring has demonstrated that removal and treatment of the principal threat waste wand containment of low-level threat waste has been protective of groundwater and surface water. In addition the following applies to this criterion:

Principal threat waste, liquid waste, and hazardous contaminated soils are removed and/or treated. The treatment processes employed are irreversible.



Enforceable Institutional and access controls consistent with solid waste closure requirements will restrict future use of the Site and use of on-site groundwater.

Containment of the non-hazardous solid waste and treated soils in a new on-site solid waste cell is reliable and readily monitored.


The magnitude of residual risk associated with the non-hazardous solid waste and treated soils is minimal.

The remaining risks are minimal and include the possibility that residual hazardous substances remaining in groundwater may migrate. Remaining concentrations of hazardous substances in groundwater are expected to be low

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and to decrease with time. Groundwater monitoring will be conducted to verify that principal threat waste removal and low-level threat waste containment has effectively protected groundwater and that residual groundwater contamination is not migrating to points of potential exposure at concentrations posing risk to human health and the environment.


Principal threat waste and liquid waste would be transported off-site for treatment, recycling, or disposal at appropriately permitted facilities. Hazardous soils will be treated on-site to render them non-hazardous. This component of Alternative 5b irreversibly reduces the toxicity, mobility, and volume of these wastes through ex-situ treatment. Low-level threat non-hazardous solid waste would be disposed of on-site in a newly constructed solid waste cell.


Worker health and safety measures such as personal protective equipment, monitoring, and health and safety plans will be required to mitigate exposure of Site workers to hazardous substances. Careful control of the removal work will minimize emissions during excavation, sampling, consolidation, and transportation. Air monitoring will be performed for fugitive dust, metals, and volatile emissions during source removal to ensure that Site activities do no present an unacceptable airborne risk to on-site workers or off-site receptors. Exceedance of action levels during construction may require shut-down of activities while further mitigative measures are implemented. Mitigative measures such as dust suppression and temporary covers for waste piles will be employed to reduce emissions if perimeter monitoring indicates any potential for off-site risk due to airborne contamination. In addition, this remedial action will expose the community to significant risks due to the heavy truck traffic and movement of hazardous waste through the community. The community must be prepared in advance for this activity. Due to the proximity of the top of the 1075 Intertill to the bottom of the excavation, excavation below the cells may expose the 1075 Intertill. Mitigation measures (safeguards) including construction dewatering and vacuum trucks will be employed to reduce the risk of contaminating the 1075 Intertill during construction. The relative occupational and transportation risks of this alternative are generally consistent with those described in Remedial Alternative RA-5 of the July 2008 FS as modified and approved by U.S. EPA. The relative magnitude of the occupational risks may be slightly higher as compared to Remedial Alternative RA-5 because the on-site waste landfill in remedial Alternative RA-5b would be incrementally larger in size. The relative magnitude of the transportation risks would be slightly lower than Remedial Alternative RA-5 because of the on-site disposal of non-hazardous drummed wastes. 4.5.6 Implementability

This alternative is technically and administratively feasible. RA-5b will require coordination among numerous parties including local governmental agencies, traffic control, contractors, and disposal facilities to address the complex issues associated with handling and transporting significant quantities of hazardous waste through a

25

community. The limited environmental covenant and groundwater monitoring portions of the remedy are readily implementable. No additional remedial action is anticipated. The effectiveness of the remedy is readily monitored by post-excavation verification sampling prior to backfilling the excavation with clean soil, post-treatment verification sampling, and groundwater monitoring.

The logistical requirements of moving approximately 3,500 trucks through the local community (two lane road) may cause delays;


Delays due to the complexity of installation, and operation of the on-site thermal desorption unit are possible/likely including the need to address community concerns regarding incineration;

Based on discussions with remediation vendors, on-site thermal desorption may not be available from multiple vendors and may prevent implementation;


actions if necessary. Additional infrastructure to provide the necessary energy to operate the high

temperature thermal desorption (approximately 800° F) unit would need to be installed.

Construction of an on-site permanent landfill will be readily implementable.

4.5.7 Cost

The total capital costs for Alternative RA-5b are estimated to be $59,293,000. The annual O&M costs are estimated to be $162,000 for the first five years, $94,000 for years 5 through 10 and $60,000 for years 11 through 30. The total net present value of the costs for this alternative, with 30 years of operation and maintenance, is estimated at $60,556,000.

4.6 Remedial Alternative RA-7 (Waste Containment and Liquid Removal): Liquid

Waste Removal, Down Gradient Groundwater Collection Trench, Up Gradient Groundwater Diversion, Cap/Cover Regrading, Relocate Unnamed Tributary, Institutional Controls, Contingency Planning and Groundwater Monitoring


Remedial Alternative RA-7 protects human health and the environment over both the short and long term through engineering and institutional controls. Liquid waste removal from waste cells and the collection and treatment of Water Table and 1075 Intertill groundwater protects human health and the environment by redundantly controlling potential future risks that would result from hazardous substance migration to the unnamed tributary. Liquid waste removal from the waste cells via sumps is expected to remove a significant portion of the liquid principal threat waste. The diversion of up gradient groundwater reduces flow through the site. The sumps, collection trench and diversion structure would also further minimize the already extremely low rate of vertical groundwater flow by reducing the hydraulic head in the 1075 Intertill. Groundwater monitoring allows for the identification of hazardous substances in groundwater. The associated contingency plan provides for a range of potential actions necessary to respond to future changes in site conditions and controls exposure. Enforceable institutional controls prohibiting the on-site use of groundwater would reduce the likelihood of human potable use exposure to groundwater COCs.

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Regrading the cap increases the level of protection by further reducing infiltration to groundwater, further reducing the potential for direct contact to waste and reducing the potential for constituent migration. The relocation of the unnamed tributary provides overall protection of human health and the environment by allowing construction of the alternative and thereby reducing and controlling impacts to surface water This alternative provides long-term effectiveness and permanence, short-term effectiveness, and compliance with ARARs (see below for further discussion).



40 CFR Part 136 - Guidelines for Establishing Test Procedures for Analyses of Pollutants (NPDES) - NPDES Analysis would meet substantive requirements by using established test procedures.

40 CFR Part 262 - Standards Applicable to Generators of RCRA Hazardous Wastes - Wastes handled during groundwater collection/treatment would be managed on-site in accordance with substantive requirements; off-site in accordance with substantive and administrative requirements.

OAC 3745-1 - Water Quality Standards - Would meet substantive requirements for on-site surface water discharges; substantive and administrative requirements for off-site surface water discharges. Monitoring, controls and treatment.

OAC 3745-27-09 (F) (effective 7/29/76) - Landfill Closure Standards - Substantive requirements would be met by cap regrading and improvements.


Remedial Alternative RA-7 provides a reliable and long-term effective means for protecting human health2. During the time until the remedial action objectives are achieved, human health is protected via liquid waste removal from waste cells, groundwater collection and treatment, and institutional controls including OAC 3745-27-13 and site-specific environmental covenants. Liquid waste removal from the waste cells via sumps removes principal threat wastes, thereby reducing the potential for exposure to impacted groundwater or waste. In addition, the environmental covenants provide redundant long-term effectiveness and permanence, in preventing exposure to impacted groundwater or waste by restricting future use of the Barrel Fill Site. Liquid waste removal along with a regraded cap and up gradient groundwater diversion reduces and controls infiltration, and the cap eliminates direct contact with waste. Liquid waste removal along with groundwater diversion, collection and treatment provides long-term effectiveness, with a high degree of certainty, by preventing Water Table and 1075 Intertill groundwater from discharging to the unnamed tributary. In effect, the 1075 Intertill will act as an underdrain resulting in lateral flow of all groundwater reaching this unit into the collection trench. The liquid waste removal sumps, diversion structure and collection trench will also reduce the hydraulic head in the 1075 Intertill. A reduced hydraulic head and the low permeability of the till beneath the 1075 Intertill will reduce the potential for vertical groundwater flow from the 1075 Intertill. All of the groundwater units beneath the waste will be monitored so that

2 As with any remediation that leaves waste in place the potential for contaminant migration may require management through contingency plans.

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additional contingent remedial actions can be taken to prevent potential adverse impacts on the Deep Sand and Gravel, in the event that such actions are necessary. Further, select monitoring wells installed in the 1050 Intertill would be used for extraction in the improbable event that contaminants from the Barrel Fill wastes reach this unit. This alternative addresses the elements identified in Section 6.2.3.3 of the “Guidance for Conducting Remedial Investigations and Feasibility Studies Under CERCLA,” Interim Final, OSWER Directive 9355.3-01, October 1988. However, there is some additional uncertainty with this alternative compared to the excavation alternatives, especially related to the first and sixth bullets below.

The remaining risks are minimal and are controlled through principal threat waste removal, containment and monitoring.

Five year reviews will be required as long as wastes with COPCs remain on-site.

The technologies for this alternative will meet required process efficiencies. Long term operations, maintenance and monitoring will be required as

described herein. These activities are easily implemented with little uncertainty.

Additional technical components are not likely. Replacement of the remedial action is not likely, therefore the threat or risk of

replacement is minimal. There is a high degree of confidence that the controls (for example, contingency

planning) can adequately handle potential problems.

4.6.4 Reduction of Toxicity, Mobility or Volume through Treatment

Barrel Fill Site liquid wastes (including liquid waste in drums, uncontainerized liquid waste, and cell water) would be treated or destroyed in this alternative. These liquid wastes would be removed, characterized, and transported off-site for treatment/disposal. This remedy is irreversible and reduces the toxicity, mobility, and volume of hazardous substances through ex-situ treatment of liquids. This alternative treats a significant portion of the principal threat waste in the form of liquid waste in the Barrel Fill. Hazardous and non-hazardous solid waste, and any liquid waste not collected by the sumps and/or downgradient trench would remain on-site. 4.6.5 Short-Term Effectiveness

Alternative RA-7 involves potential exposure to hazardous substances during sump installation and operation and maintenance activities, and will require the implementation of engineering and worker health and safety measures. These measures may include specialized drilling equipment, non-sparking\intrinsically safe tools and equipment, and personal protective equipment. Other health and safety measures will likely include explosive gas monitoring, perimeter air monitoring, and dedicated on-site health and safety personnel.

There are risks associated with the removal, sampling and transportation of hazardous wastes in the community.

The relative magnitude of the occupational risks will be higher as compared to Remedial Alternative RA-3 because the liquid waste sump installation and pumping.

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The relative magnitude of the transportation risks would be higher than Remedial Alternative RA-3 because of the off-site disposal of liquid wastes from the sumps. The magnitude of green house gas emissions will be higher as compared to Remedial Alternative 3, due to liquid waste sump installation and additional vehicle emissions due to off-site disposal of liquid wastes but will be less than for RAs 4 through 6. The timeframe to reach the RAOs is greater than 30 years because some waste will remain in place. 4.6.6 Implementability The alternative is technically and administratively feasible, and the technologies are readily available. Coordination with regulatory agencies would be required (e.g. Sections 401 and 404 of the Clean Water Act). Delays due to technical problems, lack of equipment or specialists, or disposal capacity would likely be minimal. None of the proposed activities are likely to preclude additional remedial actions if necessary. Environmental covenants are readily implementable. Currently deed restrictions are in place prohibiting the development of wells or use of groundwater from the site for anything other than remediation investigation and work, and also prohibiting the construction of residences on the Site. Additional institutional controls such as statutory environmental covenants could be used to enhance those already in place and would be easily implemented once a final remedy decision is in place. Such restrictions will require the participation of governmental environmental and land use agencies and the Site property owner. Monitoring groundwater through a well network and installing additional monitoring wells is readily implementable using standard technologies. Installation of liquid waste sumps, and collection and off-site disposal of liquid wastes are readily implementable using standard, proven technologies. However, there are some inherent difficulties in installing the liquid waste removal sumps at each waste cell. The difficulties will be addressed through the use of geophysics to locate the waste cells and down-hole geophysical techniques to locate the bottom of each waste cell.

Collection, treatment, and discharge of groundwater are readily implementable using standard, proven technologies. Regrading and vegetation of the cap are readily implementable using standard, proven technology. Construction of the up gradient groundwater diversion is readily implementable using standard, proven technology. Pre-design investigation will be required to determine topographic lows of each waste cell utilizing established drilling techniques and geophysics. These technologies are reliable and readily implementable.

4.6.7 Cost The total capital costs for Alternative RA-7 are estimated to be $15,655,000. The annual O&M costs are estimated to be $659,000 for the first five years, $535,000 for years 5 through 10 and $473,000 for years 11 through 30. The total net present value of the costs for this alternative, with 30 years of operation and maintenance, is estimated at $22,468,000.

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5. COMPARATIVE ANALYSIS OF REMEDIAL ALTERNATIVES This section presents a comparative analysis of the remedial alternatives against each other in consideration of the two threshold and five balancing criteria. A summary of the comparative analysis is presented in Table 8. The following analysis includes the Remedial Alternatives described in the July 2008 FS as modified and approved by U.S. EPA. 5.1 Comparison of Overall Protection of Human Health and the Environment Alternative RA-1 is considered to be ineffective in protecting human health and the environment because the hazardous substances and their associated risks would remain unchanged following the implementation of the alternative. Waste containment alternatives RA-2 and RA-3 provide comparable and superior protection to human health and the environment in both the short- and long-term through engineering and institutional controls, and the associated contingency plan by controlling the exposures to levels established during the development of the remediation goals. Treatment alternatives RA-4, RA-4a, RA-4b, RA-5, RA-5a, RA-5b, and RA-6 provide comparable protection among the removal/treatment alternatives, but compared to RA-2 and RA-3, have a lower overall protection to human health due to increased occupational and transportation (including the community) risks in the short-term. The treatment alternatives (RA-4, RA-4a, RA-4b, RA-5, RA-5a, RA-5b, and RA-6) have a higher overall protection in the long-term than RA-2 and RA-3. The treatment alternatives eliminate exposures to levels established during development of remediation goals. Alternative RA-7, a combination of containment and liquid removal, provides protection to human health and the environment by removing a significant portion of principal threat liquid wastes and providing additional safeguards in the form of redundant down gradient liquid collection as well as the other engineering and enforceable institutional controls common to the all other alternatives. In addition, RA-7 carries lower occupational and transportation risks as compared to the treatment alternatives in RAs 4 through 6 but higher than RA-2 and RA-3. Treatment alternatives RA-4a, RA-4b, RA-5a and RA-5b would dispose of non-hazardous waste drums at the site that would reduce transportation risks as compared to RA-4, RA-5 and RA-6. The above assessment also considered other criteria, especially long term effectiveness and permanence, short term effectiveness, and compliance with ARARs. These are described below. 5.2 Comparison of Compliance with ARARs Chemical-specific ARARs for groundwater and surface water may be met over time for Alternative RA-1; however, confirmation of this would not be possible without monitoring. There are no location- or action-specific ARARs associated with this alternative. Each of the remaining alternatives, Remedial Alternatives RA-2, RA-3, RA-4, RA-4a, RA-4b RA-5, RA-5a, RA-5b, RA-6 and RA-7, would meet site ARARs, and each includes a monitoring program to verify compliance. No waivers are anticipated for of the alternatives, with the exception of a need for a waiver for Remedial Alternatives RA-4a and RA-5a regarding the need for a landfill liner.

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5.3 Comparison of Long-Term Effectiveness and Permanence Alternative RA-1 has the lowest degree of long-term effectiveness and no permanence. Waste containment alternatives RA-2 and RA-3 are comparably effective as long-term remedies with comparable permanence. Treatment alternatives RA-4, RA-4a, RA-4b, RA-5, RA-5a, RA-5b, and RA-6 provide comparable, high levels of permanent long-term effectiveness. On-site disposal of non-hazardous drummed solid wastes in RA-4a and RA-4b, treated residuals in Alternative RA-5, and on-site disposal of treated residuals and non-hazardous drummed solid wastes in RA-5a and RA-5b would be comparable in effectiveness and permanence to off-site disposal in Alternatives RA-4 and RA-6. In addition, the groundwater units beneath the waste, to the Deep Sand and Gravel will be monitored in all alternatives except RA-1. Alternative RA-7, a combination of liquid waste removal and containment, provides high levels of long term effectiveness and permanence by combining the elements of principal threat waste removal and containment with the addition of:

Removing liquids that are currently in waste cells, which would occur during construction;

Removing liquids that are within drums as they release their contents, which may occur in the future, and;

Providing backup liquid recovery systems in the form of the down gradient collection system.

Based on the above and considering the magnitude of residual risk and the adequacy and reliability of controls, all alternative with the exception of RA-1 provide a comparable high degree of certainty that the alternatives will have long-term effectiveness. RA-7 provides a high level of permanence, with RA-4 through RA-6 providing the highest levels. 5.4 Comparison of Reduction in the Toxicity, Mobility, or Volume Through

Treatment Alternative RA-1 does not reduce the toxicity, mobility or volume of hazardous wastes. The toxicity, mobility and volume of hazardous substances in the Water Table and 1075 Intertill groundwater are reduced in waste containment alternatives RA-2 and RA-3. Although there is no direct reduction in principal threat wastes. Treatment alternatives RA-4, RA-4a, RA-4b, RA-5, RA-5a, RA-5b and RA-6 provide comparable, high levels of reduction in toxicity, mobility and volume through removal and ex-situ treatment of waste and residuals Alternatives RA-4, RA-4a, RA-4b, RA-5, RA-5a, RA-5b and RA-6 reduce toxicity, mobility and volume through treatment to a greater degree than RA-2 and RA-3. Alternative RA-7 reduces mobility by extracting liquids (principal threat wastes) during construction and removing liquids (principal threat wastes) that are released from drums over time through operation of the sump system. Removal and off-site treatment of the liquid waste would reduce the toxicity and volume of waste. This alternative provides greater reduction in toxicity, mobility and volume through treatment than RA-2 and RA-3, and less than the RA-4 through RA-6 series of alternatives. 5.5 Comparison of Short-Term Effectiveness

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There is no construction required for implementation of Alternative RA-1; therefore, short-term effectiveness is not relevant to RA-1. Waste containment alternatives RA-2 and RA-3 are similar to each other with respect to short-term effectiveness. However, Remedial Alternative RA-3 has greater remedy implementation risks and impacts to the community compared to RA-2. Treatment alternatives RA-4, RA-4a, RA-4b, RA-5, RA-5a, RA-5b and RA-6 provide comparable short-term effectiveness to each other and to waste containment alternatives RA-2 and RA-3; however, short-term impacts and risks to site workers and the community are much greater for RA-4, RA-4a, RA-4b, RA-5, RA-5a, RA-5b and RA-6 than for other alternatives. Remedial alternative RA-7 would have remedy implementation risks and impacts to the community that lie between RA-2 and RA-3, and the RA-4 through RA-6 series of alternatives. Not considering RA-1 (no action), Remedial Alternatives RA-2 and RA-3 have the lowest occupational and transportation risks. The estimated risk of occurrence of an occupational fatality associated with the groundwater collection/containment remedies is approximately 5 times higher than the excess lifetime cancer risk associated with exposures to the modeled future surface water conditions (i.e., the no-action alternative). There is a risk of general transportation related injuries to workers and others in the community associated with the construction of Remedial Alternatives RA-2 and RA-3. The estimated risk of a general transportation (including the community) related injury during construction and operation and maintenance of Remedial Alternative RA-3 is slightly higher than Remedial Alternative RA-2. Treatment remedial Alternatives RA-4 and RA-6 have the highest occupational and transportation (including the community) risk because of the added volume of wastes and residuals that are transported off site. Remedial Alternatives RA-4a, RA-4b, RA-5, RA-5a and RA-5b have less occupational and transportation (including the community) risks than RA-4 and RA-6 because a large volume of soil would remain on-site in a solid waste landfill constructed at the Barrel Fill. However, the occupational and transportation (including the community) risks associated with RA-4a, RA-4b, RA-5, RA-5a and RA-5b are still greater than containment alternatives RA-2 and RA-3. Remedial alternative RA-7 would have occupational and transportation risks that would lie between RA2 and RA-3, and the RA-4 through RA-6 series of alternatives. Containment Remedial Alternatives RA-2 and RA-3 will result in green house gas emissions associated with the construction of the groundwater collection/containment/treatment system. However, the estimated greenhouse gas emissions for RA-2 and RA-3 are significantly less than the removal/treatment alternatives. Due to the on-site treatment of soil in alternatives RA-5, RA-5a, RA-5b and RA-6, these remedies will generates additional green house gas emissions compared to RA-3. Remedial Alternative RA-4, RA-4a, RA-4b, RA-5a, RA-5b would generate less green house gas emissions than RA-5 and RA-6, but due to the added transportation will generates additional green house gas emissions compared to RA-3. The estimates of green house gas emissions associated with treatment Alternatives RA-4, RA-4a, RA-4b, RA-5, RA-5a, RA-5b and RA-6 do not consider the greenhouse gas emissions that would be associated with the required treatment, handling and storage of the wastes upon reaching the new disposal facilities. It is expected that RA-7 would have greenhouse gas emissions slightly greater than RA-2 and RA-3 due to the extraction and transportation off site of liquid wastes over a number of years. With the exception of RA-1, the remedial alternatives will generate increased vehicle emissions (CO, NOx, SOx, VOCs, and particulates) in Clark County. Containment Remedial Alternatives RA-2 and RA-3 have similar estimated vehicle emissions but are approximately half the amount estimated for the treatment Remedial Alternatives RA-4 through RA-6. It is estimated that Remedial Alternatives RA-2 and RA-3 will increase vehicular particulate material emissions in Clark County. Due to the added volume of wastes and residuals that are transported off site

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under the removal/treatment alternatives (RA-4, through RA-6), the vehicular particulate material emissions in Clark County is estimated to increase. It is expected that RA-7 would have vehicle emissions similar to and slightly greater than RA-2 and RA-3 but less than RA-4 through RA-6. The timeframe to reach the RAOs is more than 30 years for RA-2, RA-3 and RA-7. The timeframe to reach the RAOs is less than 30 years for RA-4 through RA-6 series of alternatives. The risk to human health (occupational and transportation risks) and the environment (carbon loading and other toxic gas emissions) are significantly greater with the removal/treatment alternatives compared to groundwater collection/containment/treatment. Remedial alternative RA-7 would have risk to human health and the environment that would lie between the containment alternatives (RA2 and RA-3) and the RA-4 through RA-6 series of alternatives. 5.6 Comparison of Implementability Alternative RA-1 has nothing to implement. Containment Alternatives RA-2 and RA-3 are the least difficult to construct, with RA-3 somewhat more difficult; the construction techniques are well-proven, contact with hazardous substances would likely be minimal, and no extraordinary health and safety precautions would be necessary. Treatment Alternatives RA-5 and RA-6 pose difficulties in their implementation because, based on discussions with potential vendors, the availability of a high temperature thermal desorption unit, considered in Alternatives RA-5 and RA-6, is questionable because only a couple of North American vendors could be located. The implementability of remedial alternative RA-7 would lie between the containment alternatives (RA2 and RA-3), and the RA-4 through RA-6 series of alternatives. Excluding RA-1 and based on the above, RA-2 and RA-3 are easier to implement than the RA-4 through RA-6 series, considering technical and administrative feasibility, and the availability of services and materials. The implementability of remedial alternative RA-7 would lie between the containment alternatives (RA-2 and RA-3), and the RA-4 through RA-6 series of alternatives. 5.7 Comparison of Cost An examination of the present worth values of the preliminary capital, and operations and maintenance costs for the eleven alternatives reveals that the range of costs is from no cost for Alternative RA-1 to $61,197,000 for treatment Alternative RA-6. Containment alternatives RA-2 and RA-3 provide significant increases in protection over the no action alternative, with costs of $7,291,000 and $13,821,000, respectively. Costs for treatment Alternatives RA-4, RA-4a, RA-4b, RA-5, RA-5a, RA-5b and RA-6 are comparable, and substantially higher than Alternatives RA-2 and RA-3. The cost for remedial alternative RA-7 is estimated to be $22,468,000 and lies between the containment alternatives (RA-2 and RA-3) and the RA-4 through RA-6 series of remedial alternatives. 5.8 Summary of Comparisons Alternative RA-1 is considered to be ineffective because the hazardous substances and their associated risks would remain unchanged following the implementation of the alternative. It is noted that current health risks associated with the Barrel Fill Site are within acceptable levels. However, without a monitoring program in place, it would be unknown if and when the modeled surface water conditions and associated future risk predicted in the RI had occurred. Containment alternatives RA-2 and RA-3 eliminate or minimize the conditions that may cause changes to Barrel Fill Site risks: eliminating land and groundwater use risk through institutional

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controls, minimizing erosion of surficial soils through proper grading and vegetation, relocating the unnamed tributary, minimizing mobility of the on-site hazardous substances through groundwater collection and treatment, and monitoring potential changes in site conditions through a groundwater monitoring program and contingency plan. The combination of groundwater collection and treatment combined with a monitoring program and contingency plan provides substantial safeguards to prevent unacceptable exposures of hazardous substances over time. The treatment alternatives (RA-4, RA-4a, RA-4b, RA-5, RA-5b, RA-6 and RA-7 for liquid treatment) significantly reduce the toxicity, mobility or volume of hazardous substances through treatment. Containment Alternatives RA-2 and RA-3 are expected to reduce the hydraulic head in the Water Table and 1075 Intertill. A reduction in hydraulic head would further minimize the downward driving force for contaminants in shallow groundwater to reach the lower groundwater units. Alternative RA-7 also reduces the hydraulic head within the waste cells by removing liquids currently present in the cells and future liquids that may be released from drums. In addition, the underlying 1075 Intertill is essentially continuous beneath the Barrel Fill Site and will continue to act as a natural underdrain. This underdrain will capture the limited vertical groundwater and contaminant migration beneath the waste cells. In addition, select monitoring wells installed into the 1050 Intertill would be converted to extraction wells and would collect contaminants in the unlikely event they reach this unit. This series of tills and Intertills (1075 Intertill and 1050 Intertill) combined with the installation of the down gradient collection and up gradient diversion (RA-3 and RA-7) structures create a continuous and robust collection and containment system that would provide long-term effectiveness. Treatment Alternatives RA-4 through RA-6 are comparable and result in greater short-term risks to workers, the community and the environment than RA-2, RA-3 and RA-7. The excavation of soil (alternatives RA-4 through RA-6) and drilling (alternative RA-7) beneath the waste cells may result in excavations into the 1075 Intertill. If this were to occur, it would likely result in spreading contamination into the 1075 Intertill groundwater. This condition would require further excavation and possibly longer term groundwater extraction. At a minimum, a contingency planning process would be required to prevent contaminated 1075 Intertill groundwater from discharging to the unnamed tributary during construction for alternatives RA-4 through RA-6. Alternative RA-7 includes installation of the down gradient collection trench prior to the installation of the sumps. Accordingly, the trench could be used to collect liquids that inadvertently enter the 1075 Intertill during the drilling of the sumps. Inadvertent breachs of the 1075 Intertill during drilling of the sumps for RA-7 would be “repaired” as part of the sump installation. The availability of a high temperature thermal desorption unit considered in Alternatives RA-5 and RA-6 from multiple venders is questionable/doubtful. RA-4a, RA-4b, RA-5, RA-5a and RA-5b have lower occupational and transportation (including the community) risks than RA-4 and RA-6 because there is less off-site transportation. RA-5, RA-5a and RA-5b generate more greenhouse gas emissions (along with RA-6) than RA-4, RA-4a and RA-4b due to the use of a high temperature thermal desorption unit. The risk to human health (occupational and transportation risks) and the environment (carbon loading and other toxic gas emissions) are significantly greater for RA-4, RA-4a, RA-4b, RA-5, RA-5a, RA-5b and RA-6 compared to RA-2, RA-3 and RA-7. 5.9 Summary Containment alternatives RA-2 and RA-3 exhibit long-term and reliable protection to human health and environment and offer similar levels of protection through groundwater collection and treatment and long-term monitoring. RA-7 exhibits long-term and reliable protection to

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human health and environment similar to RA-2 and RA-3 while providing treatment of principal threat waste. Treatment Alternatives RA-4, RA-4a, RA-4b, RA-5, RA5a, RA-5b and RA-6 carry a substantial increase in short-term risks, difficulty in implementation and significant cost. Containment alternatives RA-2 and RA-3 offer similar levels of protection through groundwater collection and treatment and long term monitoring. Alternative RA-3 has the added benefit of greater reduction in the hydraulic head in the essentially continuous 1075 Intertill, thereby further reducing or eliminating the driving force for vertical contaminant migration. In addition, these alternatives offer additional protection by extracting groundwater from the 1050 Intertill if necessary. RA-7 has the further benefit of an immediate reduction in hydraulic head within the waste cells (as part of construction) and long-term head relief via liquid collection and disposal through its sump system. The difference in cost from RA-2 to RA-3 is related to the up gradient groundwater diversion. RA-7 has additional cost associated with sump installation (including disposal of liquids within the cells) and long term operations and maintenance of the liquid extraction system. The risk to human health (occupational and transportation risks) and the environment (carbon loading and other toxic gas emissions) are greater with removal/treatment alternatives compared to groundwater collection/containment/treatment.

Containment Alternatives RA‐2 and RA‐3 do not treat the principal threat waste. Containment and treatment Alternative RA‐7 irreversibly treats a significant portion of the liquid principal threat waste. Treatment Alternatives RA‐4, RA‐4a, RA‐4b, RA‐5, RA‐5a, and RA‐6 irreversibly treat all of the principal threat waste.

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G:\28703\031 - FS\FS_April_2009\Final April FS Addendum\FINAL Feasibility Study Addendum_042409 Single Sided.doc

TABLES

Table 1 Detailed Analysis of Remedial Alternative RA-4a

RA-4a(Waste Treatment): Waste Removal with Off-Site Disposal of Hazardous Waste and Hazardous Residuals, Placement of Non-Hazardous Waste and Residuals in a Non-Lined On-Site Landfill, Relocate Unnamed Tributary, Institutional Controls, Contingency Planning (During Construction), and Groundwater

Monitoring Tremont City Barrel Fill Site, Clark County, German Township, Ohio

RA-4a: Waste Removal with Off-Site Treatment/Disposal of Hazardous Waste and On-Site Placement of Non-Hazardous Waste and Residuals • Hazardous waste removal with transportation off-site for commercial waste treatment/disposal • Non-hazardous waste and residuals removal with replacement into a newly constructed on-site waste cell • After removal, place enforceable institutional controls through environmental covenants • After removal, implement long-term post-removal groundwater monitoring consistent with OAC 3745-27

Notes: ARARs – applicable, or relevant and appropriate requirements O&M – operation and maintenance, includes groundwater monitoring RA – remedial alternative RAOs – remedial action objectives Air pollutant emissions were not recalculated from the November 2007 draft FS

Threshold Criterion Overall Protection of Human Health and the Environment

• Protective of human health and the environment both short and long term. Eliminates, reduces and controls exposure through treatment of waste and residuals, relocation of surface water, engineering controls and institutional controls.

• After waste removal, environmental covenants would protect human health by restricting groundwater use and reducing the likelihood of exposure to residuals (if present).

• After waste removal, groundwater monitoring would reliably identify future risks from hazardous substance migration. • Waste removal would provide a high level of long-term effectiveness and permanence at the Barrel Fill Site, but with a high level of short-

term risks. • Contingency plan allows for further remedies to control exposures and to protect human health and the environment if needed.

Threshold Criterion Compliance with ARARs

• Chemical-specific ARARs for groundwater will be met sometime after waste removal. • Chemical-specific ARARs for off-site waste disposal (LDR), air and surface water will be met through proper design, planning and

implementation of the remedy. • Action-specific ARARs would be substantial, and could be met through proper design, planning and implementation. Replacement of

untreated non-hazardous solid waste and residuals into a newly constructed on-site waste cell would require construction of a solid waste disposal facility.

• The construction of a solid waste landfill without a liner may require a waiver. • Location-specific ARARs would be substantial and could be met through proper design, planning and implementation.

Balancing Criterion Long-Term Effectiveness and Permanence

• After waste removal which is a permanent remedy environmental covenants are reliable, and provide long-term effectiveness and permanence in restricting groundwater use and exposure on the Barrel Fill Site property (if required). Land use restrictions would protect the solid waste disposed at the site.

• Need for long-term site monitoring, management and control because untreated non-hazardous solid waste is replaced into a new on-site waste cell.

• After waste removal, groundwater monitoring is a proven and reliable means for determining the trend of hazardous substance migration; long-term O&M is required and is reliable.

• After non-hazardous wastes and residuals are replaced into a new on-site waste cell, long-term groundwater monitoring will be required similar to post-closure care of a solid waste disposal facility.

• Hazardous waste removal and off-site disposal would be effective and permanent at the site; however replacement of non-hazardous waste and residuals into a new on-site waste cell would be less effective and permanent than off-site disposal.

• Waste removal provides reduction in residual risk and permanence. Balancing Criterion Reduction of Toxicity, Mobility, or Volume through Treatment

• The volume of residual impacted groundwater would decrease over time. • All principal threat waste, liquid waste and hazardous contaminated soils would be transported off-site for treatment, recycling or disposal

and on-site replacement of non-hazardous waste and residuals would accomplish reduction of toxicity, mobility and volume through treatment.

Balancing Criterion Short-Term Effectiveness

• Sampling the existing monitoring well network and construction of additional monitoring wells will require personal protective equipment; occupational risks are readily controlled.

• Implementation time, two construction seasons. • Significant impact on the community during remedial action due to waste removal, on-site waste handling and transportation. Remedy

introduces short-term risks from exhuming/exposing waste and transportation of waste through the community. Risks can be controlled but not eliminated.

• Significant occupational risk to site workers during remedial action due to excavation, waste exposure, and waste handling and transportation. Risks can be controlled, but not eliminated.

• Significant environmental impacts are possible and unavoidable during waste exposure, waste handling and transportation, and on-site replacement of non-hazardous waste and residuals.

• Potential to excavate into the 1075 Intertill may introduce contamination into the 1075 groundwater and require additional excavation or extraction.

• The relative magnitude of the occupational risks are lower than Remedial Alternative RA-5 because there is no on-site treatment of hazardous waste and the on-site waste landfill would be non-lined and incrementally smaller in size.

• The relative magnitude of the transportation risks would be slightly higher than Remedial Alternative RA-5 because of the off-site disposal of the hazardous residuals.

• The magnitude of green house gas emissions compared to Remedial Alternative RA-5 are likely lower due to no on-site treatment of wastes, and vehicle emissions are likely higher due to additional off-site disposal of hazardous waste.

Balancing Criterion Implementability

• After waste removal and replacement of non-hazardous waste and residuals, environmental covenants are readily implementable and require the participation of government environmental and land use agencies.

• After waste removal and replacement non-hazardous waste and residuals, monitoring groundwater through a well network and installing additional monitoring wells is readily implementable using standard, proven technology.

• Technical feasibility of waste removal is somewhat difficult due to stacked drums in deep cells with water and uncontainerized waste. Significant unknown conditions include soil stability, stacked drum stability, wet clayey soils, etc.

• Administrative feasibility of waste transportation would require substantial coordination with local, regional and state safety/health/transportation/emergency agencies.

• Adequate TSDF services and capacity are available for the large volume of waste. • Potential to excavate into the 1075 Intertill may introduce contamination into the 1075 groundwater and require additional excavation or

extraction. • None of the proposed activities are likely to preclude additional remedial actions if necessary.

Balancing Criterion Cost

• Capital Costs: $55,670,000 • Annual O&M Costs (Years 1 to 5): $158,000 • Annual O&M Costs (Years 5 to 10): $90,000 • Annual O&M Costs (Years 11 to 30): $56,000 • Net Present Value (30 years, 7%): $56,883,000

Table 2 Detailed Analysis of Remedial Alternative RA-4b

RA-4b(Waste Treatment): Waste Removal with Off-Site Disposal of Hazardous Waste and Hazardous Residuals, Placement of Non-Hazardous Waste and Residuals in a Lined On-Site Landfill, Relocate Unnamed Tributary, Institutional Controls, Contingency Planning (During Construction), and Groundwater Monitoring

Tremont City Barrel Fill Site, Clark County, German Township, Ohio

RA-4b: Waste Removal with Off-Site Treatment/Disposal of Hazardous Waste and On-Site Placement of Non-Hazardous Waste and Residuals • Hazardous waste removal with transportation off-site for commercial waste treatment/disposal • Non-hazardous waste and residuals removal with replacement into a newly constructed on-site waste cell • After removal, place enforceable institutional controls through environmental covenants • After removal, implement long-term post-removal groundwater monitoring consistent with OAC 3745-27





• After waste removal, groundwater monitoring would reliably identify future risks from hazardous substance migration. • Waste removal would provide a high level of long-term effectiveness and permanence at the Barrel Fill Site, but with a high level of

increased short-term risks. • Contingency plan allows for further remedies to control exposures and to protect human health and the environment if needed.



implementation of the remedy. • Action-specific ARARs would be substantial, and could be met through proper design, planning and implementation. Replacement of

untreated non-hazardous solid waste and residuals into a newly constructed on-site waste cell would require construction of a solid waste disposal facility.

• Location-specific ARARs would be substantial and could be met through proper design, planning and implementation. Balancing Criterion Long-Term Effectiveness and Permanence


• Need for long-term site monitoring, management and control because untreated non-hazardous solid waste is replaced into a newly constructed on-site waste cell.


• After non-hazardous wastes and residuals are replaced into a newly constructed on-site waste cell, long-term groundwater monitoring will be required similar to post-closure care of a solid waste disposal facility.

• Hazardous waste removal and off-site disposal would be effective and permanent at the site; however replacement of non-hazardous waste and residuals into the site would be less effective and permanent than off-site disposal.


• The volume of residual impacted groundwater would decrease over time. • All principal threat waste, liquid waste and hazardous contaminated soils would be transported off-site for treatment, recycling or disposal




• Implementation time, two construction seasons. • Significant impact on the community during remedial action due to waste removal, on-site waste handling and transportation. Remedy

introduces short-term risks from exhuming/exposing waste and transportation of waste through the community. Risks can be controlled but not eliminated.

• Significant occupational risk to site workers during remedial action due to excavation, waste exposure, and waste handling and transportation. Risks can be controlled, but not eliminated.

• Significant environmental impacts are possible and unavoidable during waste exposure, waste handling and transportation, and on-site replacement of non-hazardous waste and residuals.

• Potential to excavate into the 1075 Intertill may introduce contamination into the 1075 groundwater and require additional excavation or extraction.

• The relative magnitude of the occupational risks are lower than Remedial Alternative RA-5 because there is no on-site treatment of hazardous waste and the on-site waste landfill would be lined and incrementally smaller in size.

• The relative magnitude of the transportation risks would be slightly higher than Remedial Alternative RA-5 because of the off-site disposal of the hazardous residuals.

• The magnitude of green house gas emissions compared to Remedial Alternative RA-5 are likely lower due to no on-site treatment of wastes, and vehicle emissions are likely higher due to additional off-site disposal of hazardous waste.


• After waste removal and replacement of non-hazardous waste and residuals, environmental covenants are readily implementable and require the participation of government environmental and land use agencies.

• After waste removal and replacement non-hazardous waste and residuals, monitoring groundwater through a well network and installing additional monitoring wells is readily implementable using standard, proven technology.

• Technical feasibility of waste removal is somewhat difficult due to stacked drums in deep cells with water and uncontainerized waste. Significant unknown conditions include soil stability, stacked drum stability, wet clayey soils, etc.

• Administrative feasibility of waste transportation would require substantial coordination with local, regional and state safety/health/transportation/emergency agencies.


extraction. • None of the proposed activities are likely to preclude additional remedial actions if necessary.



Table 3

Detailed Analysis of Remedial Alternative RA-5a RA-5a(Waste Treatment): Waste Removal with Off-Site Disposal of Hazardous Waste, On-Site Treatment of Contaminated Residuals and Placement of Non-

Hazardous Waste and Residuals into an On-Site Non-Lined Landfill, Relocate Unnamed Tributary, Institutional Controls, Contingency Planning (During Construction), and Groundwater Monitoring

Tremont City Barrel Fill Site, Clark County, German Township, Ohio

RA-5a: Waste Removal with Off-Site Treatment/Disposal of Waste and On-Site Treatment and Replacement of Contaminated Residuals • Waste removal with transportation off-site for commercial waste treatment/disposal • Contaminated residuals removal with on-site treatment and replacement into a newly constructed on-site waste cell • Waste removal with replacement of non-hazardous solid drum waste and residuals into a newly constructed on-site waste cell • After removal, place enforceable institutional controls through environmental covenants • After removal, implement long-term post-removal groundwater monitoring consistent with OAC 3745-27






term risks. • On-site treatment of contaminated residuals and replacement of non-hazardous solid drum waste and treated residuals into a newly

constructed on-site waste cell introduces additional occupational, community and environmental risks. • Contingency plan allows for further remedies to control exposures and to protect human health and the environment if needed.



implementation of the remedy. • Action-specific ARARs would be substantial, and could be met through proper design, planning and implementation. Replacement of non-

hazardous solid drummed waste and treated residuals, and untreated solid waste into a newly constructed on-site waste cell would require construction of a solid waste disposal facility.

• The construction of a solid waste landfill without a liner may require a waiver. • Location-specific ARARs would be substantial and could be met through proper design, planning and implementation.



• Need for long-term site monitoring, management and control because non-hazardous solid drum waste, treated residuals and untreated solid waste are replaced into a newly constructed on-site waste cell.


• After non-hazardous solid drum waste, treated residuals, and untreated solid waste are replaced into the a newly constructed on-site waste cell, long-term groundwater monitoring will be required similar to post-closure care of a solid waste disposal facility.

• Waste removal and off-site disposal would be effective and permanent at the site; however replacement of non-hazardous solid drum waste, treated residuals, and untreated solid waste into the site would be less effective and permanent than off-site disposal.


• Residuals are treated on-site and replaced into a newly constructed on-site waste cell. • The volume of residual impacted groundwater would decrease over time. • All principal threat waste, liquid waste and hazardous contaminated soils would be transported off-site for treatment, recycling or disposal




• Implementation time, two construction seasons. • Significant impact on the community during remedial action due to waste removal, on-site waste handling and transportation, and on-site

treatment of contaminated residuals. Remedy introduces short-term risks from exhuming/exposing waste and transportation of waste through the community. Risks will can be controlled but not eliminated.

• Significant occupational risk to site workers during remedial action due to excavation, waste exposure, waste handling and transportation, and on-site treatment of residuals. Risks can be controlled, but not eliminated.

• Significant environmental impacts are possible and unavoidable during waste exposure, waste handling and transportation, on-site treatment of hazardous residuals, and on-site replacement of non-hazardous solid drum waste treated residuals, and untreated solid waste.

• Potential to excavate into the 1075 Intertill may introduce contamination into the 1075 groundwater and require additional excavation or extraction. The relative magnitude of the occupational risks are about the same as Remedial Alternative RA-5 because the on-site waste landfill in Remedial Alternative RA-5a would be non-lined, but incrementally larger in size.

• The relative magnitude of the transportation risks would be slightly lower than Remedial Alternative RA-5 because of the on-site disposal of non-hazardous drummed wastes.

• The magnitude of green house gas emissions is comparable to Remedial Alternative RA-5. Vehicle emissions are likely lower due to additional on-site disposal of non-hazardous drummed waste.


• After waste removal and replacement of non-hazardous drum wastes, treated residuals, and untreated solid waste, environmental covenants are readily implementable and require the participation of government environmental and land use agencies.

• After waste removal and replacement of non-hazardous drum waste, treated residuals and untreated solid waste, monitoring groundwater through a well network and installing additional monitoring wells is readily implementable using standard, proven technology.

• Technical feasibility of waste removal is somewhat difficult due to stacked drums in deep cells with water and uncontainerized waste. Significant unknown conditions include soil stability, stacked drum stability, wet clayey soils, etc. Technical feasibility of on-site treatment of contaminated residuals has some difficulties due to the need for much material handling equipment, the specialized thermal desorption equipment, additional air monitoring, etc. and would be less efficient compared to higher volume off-site commercial treatment.

• Administrative feasibility of waste transportation would require substantial coordination with local, regional and state safety/health/transportation/emergency agencies. Administrative feasibility of on-site treatment and disposal is difficult and would require significant coordination with local and state health and regulatory environmental agencies.


extraction. • Availability of high temperature thermal desorption unit is questionable.



Table 4 Detailed Analysis of Remedial Alternative RA-5b

RA-5b(Waste Treatment): Waste Removal with Off-Site Disposal of Hazardous Waste, On-Site Treatment of Contaminated Residuals and Placement of Non-Hazardous Waste and Residuals into an On-Site Lined Landfill, Relocate Unnamed Tributary, Institutional Controls, Contingency Planning (During Construction),

and Groundwater Monitoring Tremont City Barrel Fill Site, Clark County, German Township, Ohio

RA-5b: Waste Removal with Off-Site Treatment/Disposal of Waste and On-Site Treatment and Replacement of Contaminated Residuals • Waste removal with transportation off-site for commercial waste treatment/disposal • Contaminated residuals removal with on-site treatment and replacement into a newly constructed on-site waste cell • Waste removal with replacement of non-hazardous solid drum waste and residuals into a newly constructed on-site waste cell • After removal, place enforceable institutional controls through environmental covenants • After removal, implement long-term post-removal groundwater monitoring consistent with OAC 3745-27






term risks. • On-site treatment of contaminated residuals and replacement of non-hazardous solid drum waste and treated residuals into a newly

constructed on-site waste cell introduces additional occupational, community and environmental risks. • Contingency plan allows for further remedies to control exposures and to protect human health and the environment if needed.



implementation of the remedy. • Action-specific ARARs would be substantial, and could be met through proper design, planning and implementation. Replacement of non-

hazardous solid drummed waste and treated residuals, and untreated solid waste into a newly constructed on-site waste cell would require construction of a solid waste disposal facility.

• Location-specific ARARs would be substantial and could be met through proper design, planning and implementation. Balancing Criterion Long-Term Effectiveness and Permanence


• Need for long-term site monitoring, management and control because non-hazardous solid drum waste, treated residuals and untreated solid waste are replaced into a newly constructed on-site waste cell; however, there is no treatment equipment that would require eventual replacement.


• After non-hazardous solid drum waste, treated residuals, and untreated solid waste are replaced into the a newly constructed on-site waste cell, long-term groundwater monitoring will be required similar to post-closure care of a solid waste disposal facility.

• Waste removal and off-site disposal would be effective and permanent at the site; however replacement of non-hazardous solid drum waste, treated residuals, and untreated solid waste into the site would be less effective and permanent than off-site disposal.


• Residuals are treated on-site and replaced into a newly constructed on-site waste cell. • The volume of residual impacted groundwater would decrease over time. • All principal threat waste, liquid waste and hazardous contaminated soils would be transported off-site for treatment, recycling or disposal


• . Balancing Criterion Short-Term Effectiveness


• Implementation time, two construction seasons. • Significant impact on the community during remedial action due to waste removal, on-site waste handling and transportation, and on-site

treatment of contaminated residuals. Remedy introduces short-term risks from exhuming/exposing waste and transportation of waste through the community. Risks will can be controlled but not eliminated.

• Significant occupational risk to site workers during remedial action due to excavation, waste exposure, waste handling and transportation, and on-site treatment of residuals. Risks can be controlled, but not eliminated.

• Significant environmental impacts are possible and unavoidable during waste exposure, waste handling and transportation, on-site treatment of hazardous residuals, and on-site replacement of non-hazardous solid drum waste treated residuals, and untreated solid waste.

• Potential to excavate into the 1075 Intertill may introduce contamination into the 1075 groundwater and require additional excavation or extraction. The relative magnitude of the occupational risks are about the same as Remedial Alternative RA-5. However, the on-site waste landfill in Remedial Alternative RA-5b would be incrementally larger in size.

• The relative magnitude of the transportation risks would be slightly lower than Remedial Alternative RA-5 because of the on-site disposal of non-hazardous drummed wastes.

• The magnitude of green house gas emissions is comparable to Remedial Alternative RA-5. Vehicle emissions are likely lower due to additional on-site disposal of non-hazardous drummed waste.


• After waste removal and replacement of non-hazardous drum wastes, treated residuals, and untreated solid waste, environmental covenants are readily implementable and require the participation of government environmental and land use agencies.

• After waste removal and replacement of non-hazardous drum waste, treated residuals and untreated solid waste, monitoring groundwater through a well network and installing additional monitoring wells is readily implementable using standard, proven technology.

• Technical feasibility of waste removal is somewhat difficult due to stacked drums in deep cells with water and uncontainerized waste. Significant unknown conditions include soil stability, stacked drum stability, wet clayey soils, etc. Technical feasibility of on-site treatment of contaminated residuals has some difficulties due to the need for much material handling equipment, the specialized thermal desorption equipment, additional air monitoring, etc. and would be less efficient compared to higher volume off-site commercial treatment.

• Administrative feasibility of waste transportation would require substantial coordination with local, regional and state safety/health/transportation/emergency agencies. Administrative feasibility of on-site treatment and disposal is difficult and would require significant coordination with local and state health and regulatory environmental agencies.


extraction. • Availability of high temperature thermal desorption unit is questionable.



Table 5 Detailed Analysis of Remedial Alternative RA- 7

RA-7(Waste Containment and Liquid Removal): Liquid Waste Removal, Downgradient Groundwater Collection Trench, Up gradient Groundwater Diversion, Cap/Cover Regrading, Relocate Unnamed Tributary, Institutional Controls, Contingency Planning and Groundwater Monitoring

Tremont City Barrel Fill Site, Clark County, German Township, Ohio RA-7: Liquid Waste Removal with Redundant Groundwater Collection/Treatment/Discharge with Upgradient Groundwater Diversion • Installation of sumps in the waste cells removes a significant portion of liquid principal threat wastes • Enforceable institutional controls through environmental covenants • Regraded and vegetated soil cover prevent contact, promote drainage and reduce infiltration • Long-term groundwater monitoring consistent with OAC 3745-27 with contingency planning • Groundwater collection through downgradient trench and ex-situ treatment • Discharge to surface water in relocated unnamed tributary (alternatively, POTW discharge to be evaluated) • Upgradient groundwater diversion to reduce infiltration



• Protective of human health and the environment both short and long term. Reduces and controls exposure through removal of a significant portion of liquid principal threat waste, groundwater treatment, capping, relocation of surface water, upgradient diversion and institutional controls.

• Environmental covenants (institutional controls) protect human health by reducing the likelihood of use of groundwater and exposure to the waste and residuals.

• Regraded and vegetated existing cover prevents contact with waste and residuals. • Groundwater monitoring would allow the identification of future risks from hazardous substance migration. • Removal of a significant portion of liquid principal threat waste and groundwater collection/treatment/discharge would effectively and

reliably control exposure that would result from hazardous substance migration to surface water. • Engineered groundwater diversion would limit infiltration. • Contingency plan allows for further remedies to control exposure and protect human health and the environment if needed.


• Chemical-specific ARARs for groundwater will be met over time. • Chemical-specific ARARs for air and surface water will be met through proper design, planning and implementation of remedy. • Action-specific ARARs will be met through proper design, planning and implementation. • Location-specific ARARs will be met through proper design, planning and implementation.


• Environmental covenants are reliable, and provide redundant long-term effectiveness and permanence in reducing the likelihood of groundwater use and exposure to the waste constituents on the Barrel Fill Site property.

• Groundwater monitoring is a proven and reliable means for determining the trend of hazardous substance migration; reasonable O&M is required and is reliable.

• Removal of a significant portion of liquid principal threat waste and groundwater collection/treatment/discharge (including the 1050 Intertill if necessary) is an effective, proven and reliable means of hazardous substance migration control; reasonable O&M is required and is reliable.

• Re-graded existing cover is reliable and proven means to prevent contact with waste, and promote drainage and reduce infiltration; reasonable O&M is required and is reliable.

• Removal of a significant portion of liquid principal threat waste, groundwater diversion, collection and treatment provides long-term effectiveness, with a high degree of certainty, by reducing hydraulic head and reducing the likelihood of waste, Water Table and 1075 Intertill groundwater from discharging to the unnamed tributary.

• Upgradient groundwater diversion is reliable and proven means to reduce lateral infiltration; little O&M is required and is reliable. • Contingency plan allows for further remedies to control exposures and protect human health and the environment if needed.

Balancing Criterion Reduction of Toxicity, Mobility, or Volume through Treatment

• Removal of a significant portion of liquid principal threat waste with off-site disposal would accomplish reduction of toxicity, mobility and volume through treatment.

• The volume of impacted groundwater derived from Barrel Fill waste would decrease as impacted groundwater is collected, treated, and discharged; and as infiltration is reduced by regrading of the cap and groundwater underflow and hydraulic head is reduced/eliminated by liquid principal threat waste removal, placement of the upgradient diversion wall and downgradient collection trench.

• Mobility of impacted groundwater derived from Barrel Fill waste is reduced and controlled via groundwater collection, treatment and discharge, and reduced infiltration, lateral groundwater underflow, vertical hydraulic head are reduced/eliminated due to removal of a significant portion of liquid principal threat waste, the cap and upgradient diversion wall.

• Residuals from groundwater treatment will require proper characterization, treatment, and disposal. Balancing Criterion Short-Term Effectiveness

• Liquid waste removal, sampling the existing monitoring well network, construction of additional monitoring wells, construction of the liquid waste removal sumps and groundwater collection/treatment/disposal system and upgradient diversion, and regarding of existing cover will require personal protective equipment; occupational risks are readily controlled.

• Minimal impact on the community from implementation of the remedy. However, there are risks associated with the removal, sampling and transportation of hazardous wastes in the community.

• Risks to community are readily controlled during remedial construction. • Minimal impact to environment from implementation of remedy. • Short implementation time, 10 to 16 months. The relative magnitude of the occupational risks will be higher as compared to Remedial

Alternative RA-3 because the liquid waste sump installation and pumping. The relative magnitude of the transportation risks would be higher than Remedial Alternative RA-3 because of the off-site disposal of liquid wastes from the sumps.

• The magnitude of green house gas emissions will be higher as compared to Remedial Alternative RA-3, due to liquid waste sump installation and additional vehicle emissions due to off-site disposal of liquid wastes, but will be less than for Remedial Alternatives 4 through 6.


• Environmental covenants are readily implementable and require the participation of government environmental and land use agencies. • Installation of liquid waste sumps, and collection and off-site disposal of liquid wastes are readily implementable using standard, proven

technologies. However, there are some inherent difficulties in installing the liquid waste removal sumps and identification of topographic low at each waste cell. The difficulties will be mitigated through the use of established drilling techniques and geophysics to locate the waste cells and down hole inspection techniques to locate the bottom and topographic low of each waste cell.

• Monitoring groundwater through a well network and installing additional monitoring wells is readily implementable using standard, proven technology.

• Administrative feasibility of permitting would require coordination with local and state agencies. • Collection, treatment, and discharge of groundwater are readily implementable using standard, proven technologies. • Regrading and vegetation of the cap are readily implementable using standard, proven technology. • Construction of the upgradient groundwater diversion is readily implementable using standard, proven technology. • Proposed activities are not likely to preclude additional remedial actions if necessary.



Table 6Summary of Potential ARAR and TBC Guidance

Feasibility Study Tremont City Barrel Fill Site, Clark County, German Township, Ohio

CERCLIS ID# OHD980612188

Potential Requirement "Applicable," "TBC," or "Relevant and Appropriate" Chemical, Action, or Location Specific Requirement Synopsis Applies to

Alternatives:

Federal

33 CFR Parts 320-330, and 40 CFR § 6.302 - Fish and Wildlife Coordination Act

Relevant and appropriate if the unnamed tributary were diverted, channeled, or otherwise impacted by the remedial actions.

Location These Corps of Engineers provisions would require permits (including nationwide general permits) to protect fish or wildlife from dams, dikes, diversion, channeling, discharge of dredged fill, or other actions that would modify navigable waters. 2,3

Guidance on Remedial Action for Superfund Sites with PCB Contamination; OSWER Directive 9355.4-01; EPA 540/G-90/007; August 1990

TBC Action, Chemical, Location This guidance is for remedial actions at Superfund landfill sites with PCB contamination. Applies for engineering and institutional controls for material that is managed in place. 2,3,5

40 CFR Part 6.302 and Executive Order No. 11990 - Protection of Wetlands

Applicable to any wetlands that would be impacted by remedial actions. Location Any action involving construction of facilities or management of property in wetlands would avoid adverse effects on the wetlands, minimize potential harm, and preserve and enhance the

wetlands to the extent possible. 2,3,4,5,6

40 CFR 60 - Standards of Performance for New Stationary Sources

Applicable (default to federal rules if state regulations are not as stringent) to equipment used in remedial actions with potential air emissions

Action These regulations establish air emissions performance criteria for select equipment installations (tanks for volatile organic liquid storage), which could be used for remedial technologies. 2,3,4,5,6

40 CFR 61 & 63 - National Emissions Standards for Hazardous Air Pollutants and for Source Categories

Applicable (default to federal rules if state regulations are not as stringent) for actions with potential hazardous air emissions

Action These regulations establish air emissions performance criteria for specific compounds (benzene and vinyl chloride) and select source categories (manufacturing/operating practices) that emit Hazardous Air Pollutants, including remediation activities, pumping/piping leaks, and other specific equipment-oriented standards. 2,3,4,5,6

40 CFR Part 81 - Non-Attainment Provisions for Ozone - Clark County, Ohio Applicable Action, Location These provisions provide additional regulation of stationary sources in non-attainment areas. Metropolitan Dayton Intrastate Air Quality Control Region includes Clark County (40 CFR 81.34). 2,3,4,5,6

40 CFR Part 141 - National Primary Drinking Water Regulations

Relevant and Appropriate (default to federal rules if state regulations are not as stringent) for groundwater that is potentially a source of public water supply.

Chemical These regulations establish maximum contaminant levels (MCLs) for public water systems. 2,3,4,5,6

40 CFR Part 143 - National Secondary Drinking Water Regulations

TBC Chemical These regulations establish secondary maximum contaminant levels (SMCLs) for public water systems. SMCLs are non-enforceable guidelines for public water supplies. 2,3,4,5,6

40 CFR Parts 122 and 125 - National Pollutant Discharge Elimination System (NPDES) Permits, criteria and standards

Applicable (default to federal rules if state regulations are not as stringent) for off-site discharges of treated water to surface water; substantive requirements are applicable for on-site discharges.

Chemical These regulations set chemical-specific standards to discharge any pollutant from a point source to the waters of the United States. 2,3

40 CFR Part 136 - Guidelines for Establishing Test Procedures for analyses of pollutants Applicable Chemical These regulations establish procedures for the analysis of pollutants in water. 2,3

40 CFR 165 - Pesticide Management and Disposal (FIFRA)

Relevant and appropriate Action These regulations recommend pesticide incineration and treatment processes, and performance. 2,3,5

40 CFR Part 261 - Identification and Listing of Hazardous Wastes (RCRA)

Applicable (default to federal rules if state regulations are not as stringent) to identify hazardous wastes that may be generated during remedial actions at the Site.

Chemical These regulations define hazardous wastes by list and by criteria. 2,3,4,5,6

40 CFR Part 262 - Standards Applicable to Generators of Hazardous Wastes (RCRA)

Applicable (default to federal rules if state regulations are not as stringent) if listed or characteristic wastes are generated at the Site.

Action These regulations establish standards of operation and management for hazardous wastes that may be generated at the Site. 2,3,4,5,6

Notes:1. ARAR - Applicable, or relevant and appropriate requirement2. TBC - To be considered

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Alternatives:

40 CFR Part 263 - Standard Applicable to Transporters of Hazardous Wastes

Applicable (default to federal rules if state regulations are not as stringent) if listed or characteristic wastes are generated at the Site.

Action These regulations establish requirements for the transport of hazardous waste off-site, including DOT regulations, manifesting, record keeping, and discharge cleanup. 4,5,6

40 CFR Part 267 - Standards for Hazardous Waste Facilities

Relevant and Appropriate (default to federal rules if state regulations are not as stringent) for any containment remedial action where wastes that meet criteria as hazardous are generated and landfilled on-site.

Action These regulations establish minimum national standards for design, construction, and operation of hazardous waste landfills and would be considered as part of any remedial actions that include generating what would be defined as hazardous waste and landfilling hazardous waste on-site. 2,3

40 CFR Part 268 - Land Disposal RestrictionsApplicable: Substantive requirements apply to remedial options involving land disposal.

Action, Chemical These regulations establish standards for treatment and disposal of certain hazardous wastes. 2,3,4,5,6

40 CFR Part 403 - General Pretreatment Regulations

Applicable (default to federal rules if state regulations are not as stringent) for any discharge of process water to a POTW or hauling wastewater to a POTW.

Chemical These regulations establish standards for discharge to publicly-owned treatment works (POTWs) to control pollutants which pass through or interfere with treatment processes in POTWs. 2,3,4,5,6

40 CFR Part 761 - Regulation of PCB-Containing Materials

Applicable if any PCB-containing materials are removed or handled.

Chemical These regulations establish requirements for storage, handling, and disposal of materials containing PCBs greater than 50 ppm that may be generated during remedial actions. 2,3,4,5,6

42 USC §§ 6901 et seq. - Solid Waste Disposal Act as amended by the Resource Conservation and Recovery Act

Applicable (default to federal rules if state regulations are not as stringent) for hazardous waste storage and treatment; relevant and appropriate for waste disposal facility construction, operation and maintenance.

Action This act details various design, operation, and maintenance requirements for solid waste disposal facilities. 2,3,5,6

49 CFR Part 100-185 - Transportation of Hazardous Materials

Applicable for off-site transportation of waste.

Action These regulations establish specific federal requirements for transport of hazardous waste including labeling, packaging, shipping papers, and transport by rail and highway. 4,5,6

49 CFR Part 171 - US DOT Placarding and Handling Hazardous Material Regulations

Applicable for off-site transportation of waste. Action These regulations establish federal transportation and handling requirements for hazardous materials that are shipped by common carrier. 2,3,4,5,6

Implementing Presumptive Remedies (EPA 540-R-97-029) October 1997

TBC Action Guidance 2,3

Use of Monitored Natural Attenuation at Superfund, RCRA Corrective Action, and Underground Storage Tank Sites (OSWER Directive 9200.4-17P) April 1999

TBC Chemical Guidance 2,3

Presumptive Remedies: Site Characterization and Technology Selection for CERCLA Sites with VOCs in Soils (EPA 540-F-93-048) September 1993

TBC Action, Chemical Guidance for VOCs in soil. 2,3

User's Guide to the VOCs in Soils Presumptive Remedy

TBC Action, Chemical Guidance for VOCs in soil. 2,3

Presumptive Remedy: Multi-Phase Extraction Technology for VOCs in Soil and Groundwater (EPA 540-F-97-004) April 1997

TBC Action, Chemical Guidance for VOCs in Soil and Groundwater. 2,3

Presumptive Response Strategy and Ex-Situ Treatment Technologies for Contaminated Groundwater at CERCLA Sites

TBC Action, Chemical Guidance for ex-situ treatment of groundwater. 2,3


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Alternatives:

Presumptive Remedy for CERCLA Municipal Landfill Sites (EPA 540-F-93-035), September 1993

TBC Action Provides criteria for identifying "hot spots" that cannot be reliably contained. 2,3,4,5,6

A Guide to Principal Threat and Low Level Threat Wastes (OSWER Directive 9380.3-06FS), November 1991

TBC Chemical Considerations for categorizing waste for treatment or containment. 2,3,4,5,6

Massachusetts v. Environmental Protection Agency, 549 U.S. 497 (2007). 74 Fed. Reg. 16448 (April 10, 2009)

40 CFR Parts 86, 87, 89 et al., FR Vol. 74, No. 68, April 10, 2009, p. 16448. Id at 16449-50.

TBC Chemical, Action, Location Comparison of GHG effects of the several alternatives is appropriate under US EPA policy and federal law. The US Supreme Court has ruled that the US EPA has authority under the CAA to regulate such gases. 40 CFR Parts 86, 87, 89 et al., FR Vol. 74, No. 68, April 10, 2009, p. 16448. Under those proposed rules, landfills and mobile sources are regulated source categories. Id at 16449-50.

2,3,4,4a,4b,5,5a,5b,6,7

Ohio Requirements

ORC 1518.02 - Injuring or removing endangered or threatened plants.

Applicable to remedial options that displace endangered or threatened plant species (only if species are present).

Action, Location Prohibits removal or destruction of endangered plant species. 2,3,4,5,6

ORC 1531.25 - Endangered Animal Species

Applies to remediation sites where chemicals may harm endangered species (only if species are present). Clearly establishes that receptor animal species must be considered in risk assessments. This act may require consideration of endangered species in remediations that involve movement or displacement of large volumes of surface soil.

Action, Location Prohibits removal or destruction of endangered animal species. 2,3,4,5,6

OAC 1501-18-1-03, (A) - List of Endangered Plant Species

Applicable to remedial options where activities may disrupt habitats of listed species (only if species are present).

Action, Location Plant species considered endangered in Ohio. 2,3,4,5,6

ORC 3734 - Solid and Hazardous Wastes

Requirements are applicable for new solid waste facilities and for hazardous wastes treated, stored or disposed on-site; relevant and appropriate for on-site hazardous waste caps.

Action This statute governs solid and hazardous waste disposal facilities. Hazardous waste capping requirements are relevant and appropriate for alternatives 2 and 3; new solid waste facility requirements are applicable for alternative 5; hazardous waste storage and treatment rules are applicable for alternatives 5 and 6. 2,3,5,6

ORC 3734.02 (H) - "Digging" Where Hazardous or Solid Waste Facility was Operated

Substantive requirements are applicable for remedial alternatives that include excavations on-site.

Action, Location Prohibits filling, grading, excavating, building, drilling, or mining without authorization from the Director on land where a hazardous waste or solid waste facility was operated. 2,3,4,5,6

ORC 3734.02 (I) - Air Emissions from Hazardous Waste Facilities

Requirements are applicable to any remedial action that includes a stationary source of regulated air emissions.

Action Stationary sources at hazardous waste facilities must comply with this statute. Hazardous waste facility shall not cause, permit, or allow nuisance emission of particulates, dust fumes, gas, mist, smoke, vapor, or odorous substance. 2,3,4,5,6

ORC 3734.03 - Prohibits Open Dumping or Open Burning of Solid Waste

Requirements are relevant and appropriate for site.

Action, Location No additional solid waste would be placed at the site during remediation; however, surface materials at the site would be re-graded within the area of contamination to allow for the construction of the remedy. No open burning of solid waste would take place at the site for any remedial alternatives.

1,2,3,4,5,6

OAC 1501:31-23-01, (A) (B) - List of Endangered Animal Species

Applicable where listed species are threatened by chemical releases. Applicable where remedial activities could disturb existing habitats. (Applicable if species are present.)

List of Ohio animal species considered endangered 2,3,4,5,6


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Alternatives:

ORC 5301.80 to 5301.92 - Uniform Environmental Covenants Act

Applicable to remedial options that rely on institutional controls using Ohio's Environmental Covenants Act.

Location Regulations for the restriction of activity and use at contaminated properties by maintaining institutional controls. 2,3,4,5,6

ORC 6101.19 - Acts of Pollution ProhibitedApplicable to any site that may affect a construction within a conservancy district (if one is in place).

Board of Directors of a conservancy district may make and enforce rules and regulations pertaining to channels, ditches, pipes, sewers, etc. 2,3,4,5,6

ORC 6111.04 - Acts of Pollution of State Waters Prohibited

Applicable Action This statute prohibits polluting the waters of the state. No point source discharges of untreated leachate to surface water would exist for any of the remedial alternatives. 2,3,4,5,6

ORC 6111.04.2 - Rules Requiring Compliance with National Effluent Standards consistent with Federal CWA Sect. 301, 306, 307 and 405

Applicable Action, Chemical This statute requires point source discharges to comply with national effluent standards for any remedial action that includes a point source discharge. Remedial alternatives that have point source discharges of stormwater from the surface of the site would be monitored to ensure that they meet substantive stormwater regulations. 2,3,4,5,6

ORC 6111.30 - Section 401 Water Quality Standards

Applicable Action, Chemical This statute requires evaluation of the impacts to wetlands/waterways and sets standards to prevent degradation of water quality. 2,3,4,5,6

ORC 6111.07 A, C - Water Pollution Control Requirements - Duty to Comply

Applicable Action This statute prohibits violations of Chapter 6111. 2,3,4,5,6

Ohio Water Requirements

OAC 3745-1 - Water Quality Standards

Applicable for off-site discharges of treated water to surface water; substantive requirements are applicable for on-site discharges.

Action, Location This regulation governs surface water quality criteria with qualitative rules for specific Ohio water bodies/rivers and water body types. These rules establish minimum water quality requirements for all surface waters of the state. 2,3,4,5,6

OAC 3745-2 - Surface Water Quality Standards, Attainment, and Protection

Applicable for off-site discharges of treated water to surface water; substantive requirements are applicable for on-site discharges.

ActionThis regulation governs attainment and protection of standards (WQS) for surface water quality. This chapter sets forth the rules for developing water quality-based effluent limitations for point sources and total maximum daily loads (TMDLs) for discharges of any pollutant requiring control, including toxic, carcinogenic, and/or organoleptic pollutants. Obtaining permits is an administrative requirement.

2,3,4,5,6

OAC 3745-3 Pretreatment RulesApplicable if any wastewater is discharged to a POTW as part of remedial actions.

Action These regulations govern pretreatment of wastewater that is discharged to a POTW, to be used as an alternative to surface water NPDES-permitted discharge. 2,3,4,5,6

OAC 3745-9 - Water Well Standards Applicable Action This regulation applies to drilling, operation, maintenance, and abandonment of a well or monitoring well and is applicable only if a well is installed. 2,3,4,5,6OAC 3745-32 - Federal CWA Section 401 Water Quality Certifications

Applicable Action This statute requires point source discharges to comply with national effluent standards for any remedial action that includes a point source discharge. Remedial alternatives that have point source discharges of stormwater from the surface of the site would be monitored to ensure that they meet substantive stormwater regulations.

2,3,4,5,6

OAC 3745-36 - Non-domestic Wastewater Discharges into a Publicly Owned Treatment Works; Permit Program

Applicable if any wastewater is discharged to a POTW as part of remedial actions.

Action These regulations govern the discharge of non-domestic wastewaters to a POTW, to be used as an alternative to surface water NPDES-permitted discharge. 2,3,4,5,6

OAC 3745-39 - Stormwater Management Program

Applicable requirements for alternatives that increase surface water runoff. Action These regulations define requirements for stormwater discharges to surface waters of the state. 2,3,4,5,6

OAC 3745-81 & 82 - Primary and Secondary Drinking Water Rules for Public Water Systems

Applicable - Chapter 81 MCLs; TBC - Chapter 82 MCLGs. Action, Chemical These regulations provide to public water systems the chemical specific regulatory (primary) and guidance (secondary) concentrations (MCLs, MCLGs) for drinking water standards and BATs for

treatment. 2,3,4,5,6

OAC 3745-1-03 - Analytical and Collection Procedures

Substantive requirements applicable to discharges to surface waters as a result of remediation and any on-site surface waters affected by site conditions.

Action, Chemical Specifies analytical methods and collection procedures for surface water discharges. 2,3,4,5,6

OAC 3745-1-04 (A-E) - The "Five Freedoms" For Surface Water

Applicable to discharges to surface waters as a result of remediation and any on-site surface waters affected by site conditions.

Action, Chemical All surface waters of the State shall be free from: A) Objectionable suspended solids, B) Floating debris, C) Materials that create a nuisance, D) Toxic, harmful or lethal substances, and E) Nutrients that create nuisance growth. 2,3,4,5,6


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Alternatives:

OAC 3745-1-05 - Antidegradation Policy for Surface Water

Applicable: requires that Best Available Technology (BAT) be used to treat surface water discharges. The Division of Water Quality Planning and Assessment uses this rule to set standards when existing water quality is better than the designated use.

Action, Chemical, Location Prevents degradation of surface water quality below designated use or existing water quality. Existing stream uses shall be maintained and protected. The most stringent controls for treatment shall be required by the director to be employed for all new and existing point source discharges. Prevents any degrading of State resource waters. 2,3,4,5,6

OAC 3745-1-21 - Water Use Designation for the Great Miami River

Applicable if stream or stream segment is either affected by site conditions or if remedy includes direct discharge. Used by the Division of Surface Water to establish waste load allocations.

Chemical, Location Establishes water use designations for stream segments within the Great Miami River Basin. 2,3,4,5,6

OAC 3745-1-34 - Water Quality for the Ohio River Drainage Basin

Applicable to discharges to the Ohio River Basin.

Chemical, Location Establishes chemical criteria for streams in the Ohio River Drainage Basin. 2,3,4,5,6

OAC 3745-1-34 (A-D) - Water Quality Criteria for the Ohio River Drainage Basin

Applicable for discharges to the Ohio River Basin. Chemical, Location Applies to discharges to streams within the Ohio River Basin. This ARAR is used by the Division of Surface Water to determine discharge limits. 2,3,4,5,6

Ohio Air Requirements

OAC 3745-17 - General Provisions For Particulate Matter Emissions from Air Pollution Sources

Substantive requirements are applicable for on-site waste treatment operations that may generate regulated particulate emissions.

Action, Chemical This regulation governs and places limits on the particulate matter emissions from air pollution sources. 4,5,6

OAC 3745-21 - Carbon Monoxide, Ozone, and Hydrocarbon Air Quality Standards and Related Emissions Requirements

Substantive requirements are applicable for on-site waste treatment operations that may generate regulated hydrocarbon air emissions.

Action, Chemical This regulation establishes ambient air quality standards and best available technology for the emissions of CO, ozone, and hydrocarbons. 2,3,4,5,6

Ohio Waste Requirements

OAC 3745-256-101 - Design and Operating Standards for Containment Buildings

Applicable for sites with buildings for treatment, storage or disposal. Action, Chemical Standards for design and operation of containment buildings. Replaces OAC 3745-248-011, which has been rescinded. 5,6

OAC 3745-256-102 - Post-Closure Care of Containment Buildings

Applicable for sites with buildings for treatment, storage or disposal.

Action, Chemical Standards for closure and post closure care of containment buildings. Replaces OAC 3745-248-02, which has been rescinded. 5,6

OAC 3745-270 Hazardous Wastes Restricted From Land Disposal, including but not limited to the 3745-270 restrictions

Substantive requirements are applicable to remedial options involving land disposal.

Action, Chemical Chapter 3745-270 of the Administrative Code identifies hazardous wastes that are restricted from land disposal and defines those limited circumstances under which an otherwise prohibited waste may continue to be land disposed. 5

OAC 3745-270 -03 (A-D) - Dilution Prohibited as a Substitute for Treatment

Applicable to remedial options including treatment for disposal.

Action, Chemical Forbids dilution as a means of achieving land disposal restrictions levels. 2,3,4,5,6

OAC 3745-270-07 (A-E) - Testing, Tracking and Recordkeeping Requirements

Substantive requirements applicable to remedial options in which wastes are generated, stored, disposed, or treated.

Action, Chemical Testing, tracking, and recordkeeping requirements for generators, treaters, and disposal facilities. 2,3,4,5,6

OAC 3745-270-09 (A-D) - Special Rules Regarding Characteristic Wastes

Applicable to remedial options that generate characteristic wastes.

Action, Chemical Rules applicable for land disposal of characteristic wastes. 2,3,4,5,6

OAC 3745-270-40 (A-J) - Applicability of Treatment Standards

Applicable for sites that generate wastes or with wastes disposed on site. Action, Chemical Detailed listing of chemical specific treatment standards or required treatment technologies. 2,3,4,5,6

OAC 3745-270-42 (A-D) - Treatment Standards Expressed as Specified Technologies

Applicable at all sites generating wastes or with on-site disposal. Action, Chemical Lists specific treatment technologies required for specific wastes. 2,3,4,5,6

OAC 3745-270-45 (A-D) - Treatment Standards for Hazardous Debris

Applicable for sites with contamination by debris.

Action, Chemical Specifies treatment technologies and performance standards for various debris. 2,3,4,5,6


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Alternatives:

OAC 3745-270-48 (A) - Universal Treatment Standards

Applicable for sites with waste generation or on-site disposal.

Action, Chemical Gives contaminant chemical specific standards for land disposal. 2,3,4,5,6

OAC 3745-270-49 (A-E) - Land Disposal Restriction for Contaminated Soils

Applicable at sites where contaminated soils are generated. Action, Chemical Specifies standards for soil treatment. 2,3,4,5,6

OAC 3745-270-50 (A-F) - Prohibitions on Storage of Restricted Wastes

Applicable at sites where remediation includes storage of wastes.

Action, Chemical Rules for storage of wastes that violate LDRs. 2,3,4,5,6

OAC 3745-27 - Solid Waste Regulations Substantive requirements applicable for solid waste landfilled on-site.

Action These regulations specify the requirements for construction, permitting, operation, and closure of solid waste disposal facilities. 5

OAC 3745-30 - Residual Solid Waste Disposal

Relevant and Appropriate Action These regulations specify the requirements for characterization, permitting, operation, monitoring, and closure of residual waste disposal facilities. 5

OAC 3745-50 RCRA Hazardous Waste Management System - General

Applicable requirements if RCRA-hazardous wastes are removed from the site (substantive and administrative) or generated and managed on-site (substantive only).

Action, Chemical These regulations set forth general requirements of the RCRA hazardous waste management system. 2,3,4,5,6

OAC 3745-51 Identification & Listing of RCRA Hazardous Waste

Applicable requirements if RCRA hazardous wastes are removed from the site (substantive & administrative) or generated and managed on-site (substantive only).

Action, Chemical These regulations set forth Identification and Listing of RCRA Hazardous Waste. 2,3,4,5,6

OAC 3745-52 RCRA Generator Standards


Action These regulations set forth RCRA generator requirements of manifests, pre-transport labeling/marking/placarding, record keeping, and reporting. 2,3,4,5,6

OAC 3745-53 RCRA Transporter Standards Applicable to Transporters Action These regulations set forth RCRA transporter standards for compliance with manifest and record keeping, and clean up of discharge. 2,3,4,5,6

OAC3745-54 RCRA New Facility Standards (and OAC 3745-65 Interim Standards)

Applicable requirements if new RCRA facility is constructed on site (substantive only).

Action These regulations set forth RCRA requirements for new Facility Standards, CQA, Preparedness and Prevention, Contingency Plan & Emergency Procedures, Manifest/Recordkeeping/Reporting, and Groundwater Protection. 2,3,4,5,6

OAC 3745-55 RCRA Closure & Post-closure Containers & Tank Systems (and 3745-66 Interim Standards)

Applicable requirements if new RCRA facility is constructed on site (substantive only).

Action These regulations set forth RCRA requirements for closure, post-closure, and financial assurance for container units and tank systems. 2,3,4,5,6

OAC3745-56 SI, Waste Pile, Land Treatment (and OAC 3745-67 Interim Standards)

Applicable requirements if new RCRA SI, Waste Pile, Land Treatment is constructed on site (substantive only).

Action These regulations set forth RCRA requirements for Surface Impoundments, Waste Piles, and Land Treatment Units. 2,3,4,5,6

OAC 3745-57 Landfills, Incinerators, CAMU, Drip Pads and Misc. Units

Applicable requirements if new RCRA unit is constructed on site (substantive only).

Action These regulations set forth RCRA requirements for Landfills, incinerators, CAMUs, Drip Pads, and misc. units. 2,3,4,5,6

OAC 3745-68 Interim Standards Landfills, Incinerators, Thermal Treatment & Misc. Units


Action These regulations set forth RCRA interim facility requirements for landfills, incinerators, thermal treatment, and misc. units. 2,3,4,5,6

OAC 3745-69 Interim Standards UG Injections, Drip Pads, Misc. Units


Action These regulations set forth RCRA interim facility requirements for underground injection, drip pads, and misc. units. 4,5,6

OAC 3745-114 Toxic Air Contaminants Applicable Chemical Requirements for TAC fenceline concentration modeling to meet state criteria. 4,5,6

OAC 3745-270 Hazardous Wastes Restricted from Land Disposal


Action, Chemical These regulations set forth RCRA prohibitions on Land Disposal, treatment standards, and prohibitions on storage of Restricted Wastes. 4,5,6


6 of 6 4/23/2009

TABLE 7 Tremont City Barrel Fill Site Feasibility Study

Net Present ValueSummary of Alternatives

CAPITAL COSTITEM DESCRIPTION RA-1 RA-4a RA-4b RA-5a RA-5b RA-7

A Fencing and Signage $0 $103,000 $103,000 $103,000 $103,000 $103,000B Groundwater Extraction Trench $0 NA NA NA NA $1,065,000C Groundwater Treatment System $0 NA NA NA NA $912,000C1 Groundwater Diversion (Upgradient) $0 NA NA NA NA $6,530,000D Groundwater Monitoring $0 $452,000 $452,000 $452,000 $452,000 $991,000E Institutional Controls $0 $25,000 $25,000 $25,000 $25,000 $25,000F Surface Water Relocation $0 $79,000 $79,000 $79,000 $79,000 $79,000G Surficial Grading / Vegetation $0 $517,000 $517,000 $517,000 $517,000 $517,000H1 On-site Disposal of Treated and\or Non_Hazardous Residuals $0 $1,410,000 $3,650,000 $1,971,000 $5,176,000 NAI Waste Removal and Disposal *** $0 $53,084,000 $53,084,000 $52,941,000 $52,941,000 NAJ Liquid Waste Sumps $0 NA NA NA NA $5,433,000

TOTAL CAPITAL COST $0 $55,670,000 $57,910,000 $56,088,000 $59,293,000 $15,655,000

OPERATIONS AND MAINTENANCEITEM DESCRIPTION RA-1 RA-4a RA-4b RA-5a RA-5b RA-7

A Fencing and Signage $0 $2,000 $2,000 $2,000 $2,000 $2,000B Groundwater Extraction Trench $0 NA NA NA NA $13,000C Groundwater Treatment System $0 NA NA NA NA $126,000D Surface Water Relocation $0 $2,000 $2,000 $2,000 $2,000 $2,000G Surficial Grading / Vegetation $0 $9,000 $9,000 $9,000 $9,000 $9,000H1 On-site Disposal of Treated Residuals $0 $9,000 $9,000 $13,000 $13,000 NAJ Liquid Waste Sumps $0 NA NA NA NA $259,000

TOTAL ANNUAL O&M COST $0 $22,000 $22,000 $26,000 $26,000 $411,000

NET PRESENT WORTH OF O&M COST * $0 $273,000 $273,000 $323,000 $323,000 $5,100,000

Net Present Worth of Groundwater Monitoring** $0 $940,000 $940,000 $940,000 $940,000 $1,713,000

NET PRESENT WORTH OF TOTAL COST (CAPITAL PLUS O&M) $0 $56,883,000 $59,123,000 $57,351,000 $60,556,000 $22,468,000

Notes: * Net present worth of O&M for alternatives RA-2, RA-3, RA-4a, RA-4b, RA-5, RA-5a, RA-5b, and RA-7 are based upon a 30-year performance at 7% interest per year Net present worth of O&M for alternative RA-4 and RA-6 is based upon a 10-year performance at 7% interest per year** Annual costs of Groundwater Monitoring vary based on alternative and year. Refer to Table A-10a and Table A-10b for details. *** Waste removal and disposal for alternatives RA-4, RA-4a, RA-4b, RA-5a, RA-5b, and RA-6 based on actual contractor costs.

Table 8Barrel Fill Site Feasibility Study Comparative Analysis of Remedial Alternatives

Remedial Alternative Number

Remedial Alternative Synopsis

Overall Protection of Human Health and the Environment

Compliance with ARARs Long-Term Effectiveness and Permanence

Reduction of Toxicity, Mobility, or Volume through Treatment

Short-Term Effectiveness Implementability Cost as Net Present Value

RA-1 No Action Not protective. No elimination, reduction or control of exposure. Low long-term effectiveness. Cannot confirm compliance.

Will not comply, but cannot be confirmed without monitoring

Low degree of long-term effectiveness No reduction or treatment Not applicable Not applicable $0

RA-4a (Waste Treatment)

Waste Removal with Off-Site Disposal of Hazardous Waste and OnSite Disposal of Solid Non-Hazardous Drummed Waste and Residuals in a Constructed Non-Lined Landfill

Protective; eliminates, reduces and controls exposure through treatment of waste and residuals, relocation of unnamed tributary, engineering controls, and institutional controls. High degree of long-term effectiveness with long-term O&M. Significant short-term risks to workers, community and environment during implementation.

Complies with ARARs, except that the construction of a solid waste landfill without a liner may require a waiver. Comparable compliance to other alternatives.

Permanent remedy with long-term post-removal care. High degree of long-term effectiveness, but would be less than RA-4 and RA-6 because non-hazardous waste and residuals would be disposed on-site into a new waste cell.

All principal threat waste, liquid waste and hazardous contaminated soils would be transported off-site for treatment, recycling or disposal. High degree of reduction of waste toxicity and mobility at the site; less reduction of waste volume at the site compared to RA-4 and RA-6. Residuals would be replaced on-site.

Overall high impact during implementation, comparable to RA-4, RA-4b, RA-5, RA-5a, RA-5b, and RA-6. Significant occupational risks. Significant community impacts. Potential significant environmental impacts. Implementation time of 2 to 3 construction seasons is comparable to RA-6; and greater than either RA-2, RA-3, RA-4, and RA-7.

Implementable, difficult technical feasibility with significant unknown conditions. Administrative feasibility would require coordination with safety, health, transportation and emergency agencies. Potential for contamination of 1075 Intertill during excavation of soils beneath the waste cells.

$56,883,000

RA-4b (Waste Treatment)

Waste Removal with Off-Site Disposal of Hazardous Waste and OnSite Disposal of Solid Non-Hazardous Drummed Waste and Residuals in a Constructed Lined Landfill


Complies with ARARs. Comparable compliance to other alternatives.

Permanent remedy with long-term post-removal care. High degree of long-term effectiveness, but would be less than RA-4 and RA-6 because non-hazardous waste and residuals would be disposed on-site into a new waste cell.

All principal threat waste, liquid waste and hazardous contaminated soils would be transported off-site for treatment, recycling or disposal. High degree of reduction of waste toxicity and mobility at the site; less reduction of waste volume at the site compared to RA-4 and RA-6. Residuals would be replaced on-site.

Overall high impact during implementation, comparable to RA-4, RA-4a, RA-5, RA-5a, RA-5b, and RA-6. Significant occupational risks. Significant community impacts. Potential significant environmental impacts. Implementation time of 2 to 3 construction seasons is comparable to RA-6; and greater than either RA-2, RA-3, RA-4, and RA-7.

Implementable, difficult technical feasibility with significant unknown conditions. Administrative feasibility would require coordination with safety, health, transportation and emergency agencies. Potential for contamination of 1075 Intertill during excavation of soils beneath the waste cells.

$59,123,000

RA-5a (Waste Treatment)

Waste Removal with Off-Site Disposal of Hazardous Waste, On-Site Treatment of Contaminated/Hazardous Residuals and Placement of Solid Non-Hazardous Drummed Wastes and Residuals into an On-Site Non-Lined Landfill


Complies with ARARs, except that the construction of a solid waste landfill without a liner may require a waiver. Comparable compliance to other alternatives.

Permanent remedy with long-term post-removal care. High degree of long-term effectiveness, but would be less than RA-4 and RA-6 because non-hazardous solid drum waste, and treated residuals, and untreated solid waste would be disposed on-site into a new waste cell.

All principal threat waste, liquid waste and hazardous contaminated soils would be transported off-site for treatment, recycling or disposal. High degree of reduction of waste toxicity and mobility at the site; less reduction of waste volume at the site compared to RA-4, RA-4a, RA-5, and RA-6. Residuals would be replacedon-site.

Overall high impact during implementation, comparable to RA-4, RA-4a, RA-4b, RA-5, RA-5b, and RA-6. Significant occupational risks. Significant community impacts. Potential significant environmental impacts. Implementation time of 2 to 3 construction seasons is comparable to RA-6; and greater than either RA-2, RA-3, RA-4, and RA-7.

Implementable, difficult technical feasibility with significant unknown conditions. Administrative feasibility would require coordination with safety, health, transportation and emergency agencies. Potential for contamination of 1075 Intertill during excavation of soils beneath the waste cells. High temperature thermal desorption unit availability questionable/doubtful.

$57,351,000

RA-5b (Waste Treatment)

Waste Removal with Off-Site Disposal of Hazardous Waste, On-Site Treatment of Contaminated/Hazardous Residuals and Placement of Solid Non-Hazardous Drummed Wastes and Residuals into an On-Site Lined Landfill



Permanent remedy with long-term post-removal care. High degree of long-term effectiveness, but would be less than RA-4 and RA-6 because non-hazardous solid drum waste, and treated residuals, and untreated solid waste would be disposed on-site into a new waste cell.

All principal threat waste, liquid waste and hazardous contaminated soils would be transported off-site for treatment, recycling or disposal. High degree of reduction of waste toxicity and mobility at the site; less reduction of waste volume at the site compared to RA-4, RA-4a, RA-5, and RA-6. Residuals would be replacedon-site.

Overall high impact during implementation, comparable to RA-4, RA-4a, RA-4b, RA-5, RA-5a, and RA-6. Significant occupational risks. Significant community impacts. Potential significant environmental impacts. Implementation time of 2 to 3 construction seasons is comparable to RA-6; and greater than either RA-2, RA-3, RA-4, and RA-7.

Implementable, difficult technical feasibility with significant unknown conditions. Administrative feasibility would require coordination with safety, health, transportation and emergency agencies. Potential for contamination of 1075 Intertill during excavation of soils beneath the waste cells. High temperature thermal desorption unit availability questionable/doubtful.

$60,556,000

RA-7 (Waste Containment and Liquid Removal)

Liquid Waste Removal, Down Gradient Groundwater Collection Trench, Up Gradient Groundwater Diversion, Cap/Cover Regrading, Institutional Controls, Contingency Planning and Groundwater Monitoring

Protective; reduces and controls exposure through removal of a significant portion of liquid principal threat waste, redundant downgradient groundwater treatment, capping, relocation of unnamed tributary, engineering controls and institutional controls. Degree of overall protection would be greater than RA-3. Effective and reliable with long-term O&M. Overall moderate impact to workers, community and environment during implementation.


Effective and reliable with long-term O&M with a reasonable degree of certainty. Long-term effectiveness would be greater than RA-2 and RA-3 due to removal of a significant portion of liquid principal threat waste.

Removal of a significant portion of liquid principal threat waste with off-site disposal would accomplish reduction of toxicity, mobility and volume through treatment. The volume and mobility of impacted groundwater would be reduced through groundwater collection and treatment. Upgradient groundwater diversion would further reduce potential mobility and impacted groundwater compared to RA-2.

Overall low impact during implementation, comparable to RA-3 and much lower impacts thanRA-4, RA-5 and RA-6. Moderate occupational risks due to sump installation and waste removal that can be controlled. Moderate community impacts. Low potential environmental impacts. Implementation time of 10 to 16 months would be comparable to RA-3 and less than either RA-4, RA-4a, RA-4b,RA-5, RA-5a, RA-5b or RA-6.

Readily implementable using standard, proven technologies; comparable to RA-3. Some inherent difficulties in installing the liquid waste removal sumps and identification of topographic lows, mitigate through the use of established drilling techniques and geophysics. Proposed activities would not likely to preclude additional remedial activities if necessary.

$22,468,000

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FIGURE 3


ALTERNATIVE RA-7 LAYOUT

AS SHOWNAPRIL 2009


FENCE LINE

DRAINAGE REROUTE

GROUNDWATER COLLECTION TRENCH

EXTENT OF REGRADING


ACCESS AREA

GW DIVERSION


GROUNDWATER WELL CLUSTER W/ 4"RECOVERY WELL IN THE 1050 INTERTILL

PROPOSED SUMP LOCATION

N

W E

S

0 200 400

SCALE IN FEET

NOTES:1. EXISTING MONITORING WELLS AND PIEZOMETERS (NOT SHOWN ON FIGURE) WILL BE USED TO MONITOR CONTAINMENT PERFORMANCE.

2. ALL LOCATIONS APPROXIMATE.

A1B1

C1D1

A2 B2C2 D2

E2F2

G2 H2

A3 B3C3

F3G3

H3A4 B4 C4D4

E4

F4A5B5

A6 B6 C6E6 F6

G6

B7 C7 D7

A9 B9C9

E3

D6

D9

A8

A10

A11

B10

E7

B8

F7

D3

SCALE:

G:\2

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FIGURE 4

TREMONT CITY BARREL FILL SITETREMONT CITY, OH

ALTERNATIVE RA-7(PROPOSED SUMP LOCATIONS)

AS SHOWNAPRIL 2009

N

W E

S0 80 160

SCALE IN FEET

LEGEND

A1

NOTE:LOCATIONS DEFINED BASED ON DATA OBTAINED FROM OPERATIONAL RECORDS, HISTORIC GEOPHYSICAL SURVEYS (1984), RI FIELD EFFORT 1 - GEOPHYSICAL SURVEY (2003) AND WASTE CELL CHARACTERIZATION ACTIVITIES (2003).

C3

F7

C3

APPROXIMATE WASTE CELL LOCATIONS

WASTE CELL INVESTIGATIONDURING RI FIELD EFFORT 1

WASTE CELL INVESTIGATION DISCONTINUED DURINGRI FIELD EFFORT 1

WASTE CELL OBSERVED ASPART OF WASTE CELL INVESTIGATION ACTIVITIES

PROPOSED SUMP LOCATION

FLUSHMOUNT PROTECTIVE COVER

GROUND SURFACE

5 FT.

1'-6" TO 2'-0"

12" Ø STAINLESS STEEL RISER

5 FT. 12"Ø STAINLESS STEEL SCREEN

PORTABLE SUMP PUMP

GRANULAR MATERIAL

BENTONITE SEAL

CEMENT / BENTONITE GROUT

BOLLARDS (4 TYP.)

30 FT. (AVERAGE)

BOTTOM OF CELL

SCALE:

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FIGURE 5


ALTERNATIVE RA-7 SUMP SCHEMATIC

NOT TO SCALEAPRIL 2009

APPENDIX A

Economic Evaluation of Remedial Alternatives

Appendix A Economic Evaluation of Modified or New Alternatives

A.1 General To facilitate the evaluation of each modified or new alternative, preliminary capital and annual operations and maintenance (O&M) costs were developed for individual components (technologies and process options) selected for the alternatives. Total capital and O&M costs for each alternative are then determined by combining the costs of the appropriate components.

Quantities associated with the remedial activities were developed initially to serve as the basis for this economic evaluation. Specific aspects and quantities for each component used as the basis for the capital and annual O&M costs for each component are discussed in detail under each technology. The capital and O&M costs for each component are presented on a separate table. The sources of the unit prices are referenced on the tables. These sources include the RS Means Company, quotations from vendors, and past Haley & Aldrich experience. Several cost items are estimated as a percentage of the total cost based on past Haley & Aldrich experience and Peters and Timmerhaus “Plant Design and Economics for Chemical Engineers” (McGraw-Hill, Chemical Engineering Series, Third Edition). In addition, costs for construction oversight and design engineering were based on a percentage of capital costs as described in U.S. EPA guidance referenced in the attached tables. Finally, contingency costs were estimated based on Haley & Aldrich's and the PRP's previous experience on similar sites. For the evaluation of the alternatives, the capital and annual O&M costs are converted to their equivalent present worth. The modified or new Alternatives RA-4a, RA-4b, RA-5a, RA-5b, and RA-7 have assumed 30-year performance period with a discount rate of seven percent in the determination of the present worth of the total cost of each alternative. The accuracy of the estimated costs lies within the range of -30 percent to +50 percent of actual construction costs per U.S. EPA guidance. For clarity, only the sections that have been modified or added due the modified or new Alternatives in this addendum are included below. The reader is referred to the July 2008 FS for the Estimation of Quantities and Cost Estimates for Individual Technologies for sections still contained in the cost summary (Table 7) for this addendum. A.2 Estimation of Quantities The following section presents the calculations for the quantities used in the development of the remedial costs for the various modified or new alternatives. These quantities are preliminary and will be refined during remedial design.

A. Alternative 4a Alternative 4a is a variation of Alternative 4 (described in the July 2008 FS) that includes waste removal with off-site disposal of hazardous waste. The difference in this alternative is that the non-hazardous drummed wastes including soils that are non-hazardous would be placed into a structure at the current location of the Barrel Fill instead of being disposed off-site. The following list details the changes to the previously described Alternative RA-4 that comprise Remedial Alternative 4a:

Approximately 44,900 cubic yards of non-hazardous solid drum waste and other residuals would be placed into a structure at the current location of the barrel fill instead of being disposed of off-site.

The structure would be built consistent with requirements for a solid waste landfill as described for Remedial Alternative RA-5 in the July 2008 FS, but without a landfill liner.

The structure would be approximately 4.4 acres in size. The following items consistent with Remedial Alternative RA-5 in the July 2008

FS: Groundwater monitoring Surface water relocation Surficial grading and vegetation

B. Alternative 4b Alternative 4b includes all elements of Alternative 4a plus the installation of a liner in the constructed on-site landfill. The liner would be installed as described in Alternative 5 of the July 2008 FS. C. Alternative 5a Alternative 5a is a variation of Alternative 5 (described in the July 2008 FS) that includes waste removal with off-site disposal of hazardous waste. The difference in this alternative is that the non-hazardous drummed wastes would also be placed into the structure at the current location of the Barrel Fill instead of being disposed off-site. The following list details the changes to the previously described Alternative RA-5 that comprise Remedial Alternative 5a:

Approximately 3,100 additional cubic yards of non-hazardous solid drum waste would be placed into the solid waste landfill already included in Alternative 5.

The structure would be built consistent with requirements for a solid waste landfill as described for Remedial Alternative RA-5 in the July 2008 FS, but without a landfill liner.

The structure would be approximately 6.3 acres in size. D. Alternative 5b Alternative 5b includes all elements of Alternative 5a plus the installation of a liner in the constructed on-site landfill. The liner would be installed as described in Alternative 5 of the July 2008 FS.

E. Alternative 7 Alternative 7 includes all elements of the previously described Remedial Alternative RA-3 (described in the July 2008 FS) with the additional installation of liquid waste removal sumps at all waste cell locations. The following list details the changes to the previously described Alternatives RA-3 that comprise Remedial Alternative 7:

One (1) liquid waste removal sump per cell (50 total) would be installed. Each sump would be installed below the base of the drums, at the topographic low

spot of the cell, at an average of 30 feet below ground surface.

A 12-inch diameter, 5 foot section of stainless steel screen would be installed at the base of the sump.

Extending from the screen section to the ground surface would be a 12-inch diameter stainless steel riser.

Approximately 912,000 gallons of cell water, uncontainerized liquid wastes and LNAPL would be removed upon completion of the 50 sumps.

Sumps would be equipped with level sensors to alert operations and maintenance personnel when liquid wastes would need to be pumped.

Approximately 83,000 gallons of liquids from both infiltrate and drum releases would be generated each year.

The liquid wastes removed from the sumps would be stored, properly characterized, and properly disposed.

TABLE A-1 Tremont City Barrel Fill Site Feasibility StudySummary of Design Parameters

A Fencing and Signage

B Groundwater Extraction Trench

C Groundwater Treatment System

C1 Groundwater Diversion Upgradient

D Groundwater Monitoring

F Surface Water Relocation

G Surficial Grading/Vegetation

H1 On-Site Disposal of Treated Residuals

RA-4a- 4.4 acres- 44,900 cubic yards- No liner- Non-haz solid drum wastes and residuals disposed on-site

RA-4b- 4.4 acres- 44,900 cubic yards- Liner- Non-haz solid drum wastes and residuals disposed on-site

RA-5- 6.0 acres- 61,200 cubic yards- Liner- Non-haz solid residuals disposed on-site

RA-5a- 6.3 acres- 64,300 cubic yards- No liner- Non-haz solid drum wastes and residuals disposed on-site

RA-5b- 6.3 acres- 64,300 cubic yards- Liner- Non-haz solid drum wastes and residuals disposed on-site

I Waste Removal and Disposal

J Liquid Waste Sumps

Drum removal - 51,500 drumsUncontainerized waste removal and disposal - 910,000 gallons haz and 660,000 gallons of precipitation water hazLNAPL disposal - 2000 gallons hazThermal Desorption of Haz Soil (Between cells) - 37,000 tons (RA-5, 5a, 5b, and 6). Treated soils disposed onsite in RA-5, 5a, and 5b; off-site in RA-6

DESIGN SECTION DESIGN ITEM

Note: No costs have been included to upgrade and\or repair local roads.

DESIGN PARAMETERS

Fencing - 3500 linear feetSwing Gates - 2Hazard Signs - 30Length - 1100 linear feetDepth Range - 20-30 feet below ground surface (bgs); 23 foot averageWidth - 3 feetGeotextile Fabric - 42 square feet per foot of trenchFill - Gravel to 5 feet bgsFill - Clay to 1 foot bgs (0.45 cubic yard per foot of trench)Fill - Soil to ground surface (0.11 cubic yard per foot of trench)Cover - Crown vegetationUnit operations - Equalization, Filtration, Oil/Water Separation, Metals Removal, Air Stripping, Carbon AdsorptionFlow rate - 5 gpmTreatment building - 30 feet by 40 feetDischarge piping - 4 inch HDPE to relocated unnamed tributary

Length - 1500 linear feetDepth Range - 30-40 feet below ground surface (bgs); 37 foot averageSheet Pile - Waterloo Barrier or Equivalent

Well clusters - Up to 12 clusters (depending on alternative) with up to 5 individual wellsWells - 2 inch PVC riser and screen except for four downgradient 4 inch PVC wells in the 1050 IntertillWell depth - Total of 300 linear feet of well per well cluster

Length - 2000 feetDepth - 2 feetWidth - 1 foot wide at bottom with 1:3 side slopes

Area - 8 acresSlope - up to 3% slope away from drum disposal cells

1 per cell (50 total)30-feet deep (average)12-inch diameter stainless steel5-foot screened interval

TABLE A-2 Tremont City Barrel Fill Site Feasibility Study

Capital Cost EstimateFencing and Signage

ITEM DESCRIPTION UNITS QUANTITY UNIT COST SOURCE EXTENDED COSTDIRECT CAPITAL COSTS

Mobilization/Demobilization Lump Sum 1 $7,000 2,5 $7,000Bonds and Insurance Lump Sum 1 $1,000 2,5 $1,000Chainlink fencing LF 3500 $18 3 $63,000Swing Gates EA 2 $438 3 $876Hazard Signs EA 35 $75 3 $2,625Service Facilities and Ground Improvements Lump Sum 1 $3,000 2,5 $3,000Survey (based on 0.5% of construction) Lump Sum 1 $300.00 2 $300

Subtotal Direct Capital Costs $77,801

Other CostsConstruction Administration and Design Engineering % Direct Capital costs 18% 4 $14,004Contingencies % Direct Capital costs 15% 2 $11,670

TOTAL CAPITAL INVESTMENT $103,475

TOTAL CAPITAL INVESTMENT (ROUNDED) $103,000

Assumptions:1. The actual design may vary in design basis and equipment selection2. No taxes or duties are included in this estimate.3. Level of accuracy of this estimate is -30% to +50%4. Contingency includes USEPA\OEPA oversight, community relations

Sources:1. Quote from Independent Vendor2. Haley & Aldrich's previous experience on similar sites.3. Value from RSMeans CostWorks online software, 2004 MasterFormat, 2008 quarter 1 data release, adjusted for work in the Dayton, Ohio area.4. USEPA 540-R-00-002. OSWER 9355.0-75. July 2000.5. Peter and Timmerhaus "Plant Design and Economics for Chemical Engineers"


O&M Cost EstimateFencing and Signage

ITEM DESCRIPTION UNITS QUANTITY UNIT COST SOURCE EXTENDED COSTANNUAL COSTS

Quarterly Fence Inspection HR 8 $80 2 $640Post Repair EA 5 $166 3 $830Fence Repair LF 50 $18 3 $900

TOTAL $2,370

TOTAL (ROUNDED) $2,000

Assumptions:1. The actual final design may vary in design basis and equipment selection2. No taxes or duties are included in this estimate.3. Level of accuracy of this estimate is -30% to +50%

Sources:1. Quote from Independent Vendor2. Haley & Aldrich's previous experience on similar sites.3. Value from RSMeans CostWorks online software, 2004 MasterFormat, 2008 quarter 1 data release, adjusted for work in the Dayton, Ohio area.


Capital Cost EstimateGroundwater Extraction Trench


Mobilization/Demobilization Lump Sum 1 $71,000 2,5 $71,000 Bonds and Insurance Lump Sum 1 $14,000 2,5 $14,000Excavate trench (in-place) CY 2,800 $30 2,3 $84,000Provisions for Level "C" Personal Protection (Excavation) Lump Sum 1 $61,000 2,5 $61,000Slurry for excavation CY 2,800 $35 2 $98,000Manage excavated materials CY 2,800 $16 2 $44,800Geotextile filter fabric SY 6,204 $4 2,3 $24,816Slotted HDPE pipe LF 1,100 $48 2,3 $52,250Leachate lift station EA 3 $18,000 2 $54,000Equipment Installation (Lift Station only) Lump Sum 1 $54,000 5 $54,000Electrical (Lift Station only) Lump Sum 1 $6,000 5 $6,000Service Facilities / Ground Improvements (Lift Station only) Lump Sum 1 $6,000 2,5 $6,000Fill with permeable material CY 2,200 $28 3 $61,600Clay Barrier (4') LCY 588 $28 3a $16,464Compact/Smooth/Roll Fill LCY 588 $4 3 $2,352Place Topsoil (1") LCY 180 $8 3 $1,440Seeding with Mulch and Fertilizer 1,000 SF 4.4 $57 3 $251Piping (4 inch HDPE to WWT) Ln Ft 1,100 $10.50 3 $11,550Piping (4 inch WWT to Discharge) Ln Ft 200 $10.50 3 $2,100Discharge Piping Trench LN FT 1,100 $2.00 3 $2,200Backfill/Compact Discharge Piping Trench LN FT 1,100 $4.00 3 $4,400Soil Analysis (Full TCLP - 150% Rush) Each 4 $656.25 2 $2,625Soil Analysis (Total VOC's - 150% Rush) Each 4 $110.00 2 $440Provision for 10% Non-Haz Soil (to Waste Mgt. Dayton, OH) Tons 504 $51.36 1 $25,885Survey (based on 0.5% of construction) Lump Sum 1 $4,000.00 2 $4,000Disposable Supplies Day 40 $100.00 2 $4,000Personnel and Perimeter Air Monitoring Days 40 $2,250 2 $90,000Groundwater Waste Liquids (to EQ Belleville, MI) Gallons 1000 $1.81 1 $1,812



TOTAL CAPITAL INVESTMENT $1,065,310

TOTAL CAPITAL INVESTMENT (ROUNDED) $1,065,000

Assumptions:1. The actual final design may vary in design basis and equipment selection2. No taxes or duties are included in this estimate.3. Level of accuracy of this estimate is -30% to +50%4. Contingency includes USEPA\OEPA oversight, community relations5. Geotextile filter fabric assumes 20% material over run for costing purposes6. Backfill quantities for clay and topsoil utilize a 1.2 and 1.5 factor, respectively to account for compaction7. Use conversion of 1.8 tons per cubic yard of soil8. Stormwater control included in surface water relocation sheet

Sources:1. Quote from Independent Vendor2. Haley & Aldrich's previous experience on similar sites.3. Value from RSMeans CostWorks online software, 2004 MasterFormat, 2008 quarter 1 data release, adjusted for work in the Dayton, Ohio area.3a. Value from RSMeans Environmental Remediation Cost Data, 19994. USEPA 540-R-00-002. OSWER 9355.0-75. July 2000.5. Peter and Timmerhaus "Plant Design and Economics for Chemical Engineers"


O&M Cost EstimateGroundwater Extraction Trench


Electricity KW-HR 105,000 $0.08 4 $8,295Annual Well / Piping Refurbishment HR 40 $80.00 2 $3,200Routine Maintenance Each 1 $2,000.00 2 $2,000

TOTAL $13,495



Sources:1. Quote from Independent Vendor2. Haley & Aldrich's previous experience on similar sites.3. Value from RSMeans CostWorks online software, 2004 MasterFormat, 2008 quarter 1 data release, adjusted for work in the Dayton, Ohio area.4. Electrical costs $0.079 per kilowatt hour maximum rate (Piqua, Ohio). After 600 KW/hr, rates scale down based on usage


Capital Cost EstimateGroundwater Treatment System


Mobilization/Demobilization Lump Sum 1 $59,000 2,5 $59,000Bonds and Insurance Lump Sum 1 $12,000 2,5 $12,000Treatment Building (30' x 40') including foundation, and electrical service, and fire suppression Sq. ft 1,200 $72 3 $86,700Equalization / Holding Tank EA 1 $2,500 2 $2,500Bag Filter Housing EA 2 $5,400 2 $10,800Air Stripper EA 1 $18,000 2 $18,000Oil/Water Separator EA 1 $6,000 2 $6,000Metals Treatment System (incl. pumps, sludge holding tank, air compressor, EA 1 $85,000 2 $85,000Liquid Phase Carbon Vessel EA 2 $4,500 2 $9,000Filter Press EA 1 $60,000 2 $60,000Equipment Installation (includes 8% Markup) % of equipment 1 $97,000 5 $97,000Instrumentation and Controls (includes 8% Markup) % of equipment 1 $37,000 5 $37,000Piping (includes 8% Markup) % of equipment 1 $136,000 5 $136,000Electrical (utilize and upgrade existing) (includes 8% Markup) % of equipment 1 $23,000 5 $23,000Service Facilities and Ground Improvements (includes 8% Markup) % of equipment 1 $21,000 5 $21,000Discharge Piping LN FT 200 $10.50 3 $2,100Discharge Piping Trench LN FT 200 $2.00 3 $400Backfill/Compact Discharge Piping Trench LN FT 200 $4.00 3 $800Outfall protection ton 1 $48.00 3 $48Decommission and Demolish Treatment Building cu ft 14,400 $0.30 3 $4,320Survey (based on 0.5% of construction) Lump Sum 1 $3,000.00 2 $3,000Disposable Supplies Day 60 $100.00 2 $6,000Treatment system startup and shakedown HR 80 $80.00 2 $6,400





Assumptions:1. The actual final design may vary in design basis and equipment selection2. No taxes or duties are included in this estimate.3. Level of accuracy of this estimate is -30% to +50%4. Contingency includes USEPA\OEPA oversight, community relations5. Instrumentation and controls costs include remote monitoring costs6. Assumes NPDES permit costs are included in Construction adminstration and design engineering7. Electrical service exists to site8. Mobilization based on 10% and Bonds and insurance based on 2% of construction costs



O&M Cost EstimateGroundwater Treatment System


Electricity KW-HR 262,800 $0.08 4 $20,761Treatment chemicals DAY 365 $8.00 2 $2,920Bag Filter EA 104 $12 2 $1,248Filter Disposal DRUM 4 $350 2 $1,400TCL VOAs EA 24 $82 1 $1,968TCL SVOCs EA 24 $180 1 $4,320PCBs EA 24 $57 1 $1,368TCL Pesticides EA 24 $90 1 $2,160TAL Metals analysis EA 24 $97 1 $2,328TSS EA 24 $15 1 $360pH EA 24 $8 1 $192Vapor analysis EA 12 $82 1 $984Annual Reports EA 1 $5,000 2 $5,000Carbon Change-Out LB 12,000 $2.50 2 $30,000Sludge Disposal (non-haz) CY 26 $51.36 1 $1,335Oil Disposal GAL 2600 $1.85 1 $4,805Labor (10-hours per week) HR 520 $65 2 $33,800Monthly Preventative maintenance EA 72 $65 2 $4,680Preventative maintenance (equipment costs) of equipmen 1 $4,000 5 $4,000Waste Characterization Analysis Each 4 $656.25 2 $2,625

TOTAL $126,254



Sources:1. Quote from Independent Vendor2. Haley & Aldrich's previous experience on similar sites.3. Value from RSMeans CostWorks online software, 2004 MasterFormat, 2008 quarter 1 data release, adjusted for work in the Dayton, Ohio area.4. Electrical costs $0.079 per kilowatt hour maximum rate (Piqua, Ohio). After 600 KW/hr, rates scale down based on usage 5. Earth Tech’s Remedial Action Cost Engineering and Requirements (RACER)


Capital Cost EstimateGroundwater Diversion (Upgradient)


Mobilization/Demobilization Lump Sum 1 $419,000 2,5 $419,000Bonds and Insurance Lump Sum 1 $84,000 2,5 $84,000Sheet Pile - Waterloo Barrier or Equivalent VSF 55,500 $75 1,2 $4,162,500Service Facilities / Ground Improvements Lump Sum 1 $209,000 2,5 $209,000Survey (based on 0.5% of construction) Lump Sum 1 $21,000.00 2 $21,000Disposable Supplies Day 60 $100.00 2 $6,000Silt Fence ln ft 4,000 $2 3 $8,000

Subtotal Direct Capital Costs $4,909,500




Assumptions:1. The actual final design may vary in design basis and equipment selection2. No taxes or duties are included in this estimate.3. Level of accuracy of this estimate is -30% to +50%4. Contingency includes USEPA\OEPA oversight, community relations


Notes:1. "VSF" stands for Vertical Square Feet

TABLE A-9a Tremont City Barrel Fill Site Feasibility Study

Capital Cost EstimateGroundwater Monitoring (Alternatives 2, 3, 7)


Mobilization/Demobilization Lump Sum 1 $66,000 2,5 $66,000Bonds and Insurance Lump Sum 1 $13,000 2,5 $13,0002"\4" PVC wells (300 feet total length) EA 12 $54,450 1,2 $653,400Survey (based on 0.5% of construction) Lump Sum 1 $3,000.00 2 $3,000Disposable Supplies Day 60 $100.00 2 $6,000 Waste Characterization Analysis Each 4 $656.25 2 $2,625Non-Hazardous Soil (to Waste Mgt. Dayton, OH) Tons 15 $51.36 1 $770






Sources:1. Quote from Independent Vendor for the 2004 Field Event #2. 10% surcharge included to bring to 2008. 10% surcharge added for 4 four inch wells.2. Haley & Aldrich's previous experience on similar sites.3. Value from RSMeans CostWorks online software, 2004 MasterFormat, 2008 quarter 1 data release, adjusted for work in the Dayton, Ohio area.4. USEPA 540-R-00-002. OSWER 9355.0-75. July 2000.5. Peter and Timmerhaus "Plant Design and Economics for Chemical Engineers"

TABLE A-9b Tremont City Barrel Fill Site Feasibility Study

Capital Cost EstimateGroundwater Monitoring (Alternatives 4a, 4b, 5, 5a, 5b)


Mobilization/Demobilization Lump Sum 1 $30,000 2,5 $30,000Bonds and Insurance Lump Sum 1 $6,000 2,5 $6,0002" PVC wells (300 feet total length) EA 6 $49,500 1,2 $297,000Survey (based on 0.5% of construction) Lump Sum 1 $2,000.00 2 $2,000Disposable Supplies Day 30 $100.00 2 $3,000Waste Characterization Analysis Each 2 $656.25 2 $1,313Non-Hazardous Soil (to Waste Mgt. Dayton, OH) Tons 8 $51.36 1 $411






Sources:1. Quote from Independent Vendor for the 2004 Field Event #2. 10% surcharge included to bring to 20082. Haley & Aldrich's previous experience on similar sites.3. Value from RSMeans CostWorks online software, 2004 MasterFormat, 2008 quarter 1 data release, adjusted for work in the Dayton, Ohio area.4. USEPA 540-R-00-002. OSWER 9355.0-75. July 2000.5. Peter and Timmerhaus "Plant Design and Economics for Chemical Engineers"


O&M Cost EstimateSingle Groundwater Monitoring Event (Alternatives 2, 3, 7)


Sampling Labor (2 workers for 2 weeks) DAY 20 $1,000.00 2 $20,000Equipment rental LS 1 $2,500.00 2 $2,500Travel Expenses DAY 20 $150.00 2 $3,000TCL VOAs EA 60 $82 1 $4,920TCL SVOCs EA 60 $180 1 $10,800PCBs EA 60 $57 1 $3,420TCL Pesticides EA 60 $90 1 $5,400TAL Metals analysis EA 60 $97 1 $5,820Summary Report EA 1 $5,000.00 2 $5,000Liquids Analysis (Full TCLP - 150% Rush) EA 1 $656.25 2 $656Haz Waste (to EQ Belleville, MI Treat to D) Gallons 50 $1.81 1 $91

TOTAL $61,607





O&M Cost EstimateSingle Groundwater Monitoring Event (Alternatives 4a, 4b, 5, 5a, 5b)


Sampling Labor (2 workers for 1 week) DAY 10 $1,000.00 2 $10,000Equipment rental LS 1 $1,250.00 2 $1,250Travel Expenses DAY 10 $150.00 2 $1,500TCL VOAs EA 30 $82 1 $2,460TCL SVOCs EA 30 $180 1 $5,400PCBs EA 30 $57 1 $1,710TCL Pesticides EA 30 $90 1 $2,700TAL Metals analysis EA 30 $97 1 $2,910Summary Report EA 1 $5,000.00 2 $5,000Liquids Analysis (Full TCLP - 150% Rush) EA 1 $656.25 2 $656Haz Waste (to EQ Belleville, MI Treat to D) Gallons 25 $1.81 1 $45

TOTAL $33,632




TABLE A-10c Tremont City Barrel Fill Site Feasibility Study

O&M Cost EstimateNet Present Worth Costs for Variable GW Monitoring Events (Alternatives 2, 3, 7)

Cost per sampling event* = $62,000Interest Rate = 7%

Year Sampling Events per Year RA-2 RA-3 RA-7 RA-2 RA-3 RA-71 4 $248,000 $248,000 $248,000 $231,776 $231,776 $231,7762 4 $248,000 $248,000 $248,000 $216,613 $216,613 $216,6133 4 $248,000 $248,000 $248,000 $202,442 $202,442 $202,4424 4 $248,000 $248,000 $248,000 $189,198 $189,198 $189,1985 4 $248,000 $248,000 $248,000 $176,821 $176,821 $176,8216 2 $124,000 $124,000 $124,000 $82,626 $82,626 $82,6267 2 $124,000 $124,000 $124,000 $77,221 $77,221 $77,2218 2 $124,000 $124,000 $124,000 $72,169 $72,169 $72,1699 2 $124,000 $124,000 $124,000 $67,448 $67,448 $67,44810 2 $124,000 $124,000 $124,000 $63,035 $63,035 $63,03511 1 $62,000 $62,000 $62,000 $29,456 $29,456 $29,45612 1 $62,000 $62,000 $62,000 $27,529 $27,529 $27,52913 1 $62,000 $62,000 $62,000 $25,728 $25,728 $25,72814 1 $62,000 $62,000 $62,000 $24,045 $24,045 $24,04515 1 $62,000 $62,000 $62,000 $22,472 $22,472 $22,47216 1 $62,000 $62,000 $62,000 $21,002 $21,002 $21,00217 1 $62,000 $62,000 $62,000 $19,628 $19,628 $19,62818 1 $62,000 $62,000 $62,000 $18,344 $18,344 $18,34419 1 $62,000 $62,000 $62,000 $17,144 $17,144 $17,14420 1 $62,000 $62,000 $62,000 $16,022 $16,022 $16,02221 1 $62,000 $62,000 $62,000 $14,974 $14,974 $14,97422 1 $62,000 $62,000 $62,000 $13,994 $13,994 $13,99423 1 $62,000 $62,000 $62,000 $13,079 $13,079 $13,07924 1 $62,000 $62,000 $62,000 $12,223 $12,223 $12,22325 1 $62,000 $62,000 $62,000 $11,423 $11,423 $11,42326 1 $62,000 $62,000 $62,000 $10,676 $10,676 $10,67627 1 $62,000 $62,000 $62,000 $9,978 $9,978 $9,97828 1 $62,000 $62,000 $62,000 $9,325 $9,325 $9,32529 1 $62,000 $62,000 $62,000 $8,715 $8,715 $8,71530 1 $62,000 $62,000 $62,000 $8,145 $8,145 $8,145

$1,713,247 $1,713,247 $1,713,247

$1,713,000 $1,713,000 $1,713,000


Note: * Refer to Table A-10a for Cost per Sampling Event details** Net present worth of O&M for alternatives RA-2,RA-3, and RA-7 are based upon a 30-year performance at 7% interest per year

Cost of Alternative O&M for Year X

Net Present Worth** of Alternative O&M for Year X

TABLE A-10d Tremont City Barrel Fill Site Feasibility Study

O&M Cost EstimateNet Present Worth Costs for Variable GW Monitoring Events (Alternatives 4a, 4b, 5, 5a, 5b)

Cost per sampling event* = $34,000Interest Rate = 7%

Year Sampling Events per Year RA-4a RA-4b RA-5 RA-5a RA-5b RA-4a RA-4b RA-5 RA-5a RA-5b1 4 $136,000 $136,000 $136,000 $136,000 $136,000 $127,103 $127,103 $127,103 $127,103 $127,1032 4 $136,000 $136,000 $136,000 $136,000 $136,000 $118,788 $118,788 $118,788 $118,788 $118,7883 4 $136,000 $136,000 $136,000 $136,000 $136,000 $111,017 $111,017 $111,017 $111,017 $111,0174 4 $136,000 $136,000 $136,000 $136,000 $136,000 $103,754 $103,754 $103,754 $103,754 $103,7545 4 $136,000 $136,000 $136,000 $136,000 $136,000 $96,966 $96,966 $96,966 $96,966 $96,9666 2 $68,000 $68,000 $68,000 $68,000 $68,000 $45,311 $45,311 $45,311 $45,311 $45,3117 2 $68,000 $68,000 $68,000 $68,000 $68,000 $42,347 $42,347 $42,347 $42,347 $42,3478 2 $68,000 $68,000 $68,000 $68,000 $68,000 $39,577 $39,577 $39,577 $39,577 $39,5779 2 $68,000 $68,000 $68,000 $68,000 $68,000 $36,987 $36,987 $36,987 $36,987 $36,98710 2 $68,000 $68,000 $68,000 $68,000 $68,000 $34,568 $34,568 $34,568 $34,568 $34,56811 1 $34,000 $34,000 $34,000 $34,000 $34,000 $16,153 $16,153 $16,153 $16,153 $16,15312 1 $34,000 $34,000 $34,000 $34,000 $34,000 $15,096 $15,096 $15,096 $15,096 $15,09613 1 $34,000 $34,000 $34,000 $34,000 $34,000 $14,109 $14,109 $14,109 $14,109 $14,10914 1 $34,000 $34,000 $34,000 $34,000 $34,000 $13,186 $13,186 $13,186 $13,186 $13,18615 1 $34,000 $34,000 $34,000 $34,000 $34,000 $12,323 $12,323 $12,323 $12,323 $12,32316 1 $34,000 $34,000 $34,000 $34,000 $34,000 $11,517 $11,517 $11,517 $11,517 $11,51717 1 $34,000 $34,000 $34,000 $34,000 $34,000 $10,764 $10,764 $10,764 $10,764 $10,76418 1 $34,000 $34,000 $34,000 $34,000 $34,000 $10,059 $10,059 $10,059 $10,059 $10,05919 1 $34,000 $34,000 $34,000 $34,000 $34,000 $9,401 $9,401 $9,401 $9,401 $9,40120 1 $34,000 $34,000 $34,000 $34,000 $34,000 $8,786 $8,786 $8,786 $8,786 $8,78621 1 $34,000 $34,000 $34,000 $34,000 $34,000 $8,211 $8,211 $8,211 $8,211 $8,21122 1 $34,000 $34,000 $34,000 $34,000 $34,000 $7,674 $7,674 $7,674 $7,674 $7,67423 1 $34,000 $34,000 $34,000 $34,000 $34,000 $7,172 $7,172 $7,172 $7,172 $7,17224 1 $34,000 $34,000 $34,000 $34,000 $34,000 $6,703 $6,703 $6,703 $6,703 $6,70325 1 $34,000 $34,000 $34,000 $34,000 $34,000 $6,264 $6,264 $6,264 $6,264 $6,26426 1 $34,000 $34,000 $34,000 $34,000 $34,000 $5,855 $5,855 $5,855 $5,855 $5,85527 1 $34,000 $34,000 $34,000 $34,000 $34,000 $5,472 $5,472 $5,472 $5,472 $5,47228 1 $34,000 $34,000 $34,000 $34,000 $34,000 $5,114 $5,114 $5,114 $5,114 $5,11429 1 $34,000 $34,000 $34,000 $34,000 $34,000 $4,779 $4,779 $4,779 $4,779 $4,77930 1 $34,000 $34,000 $34,000 $34,000 $34,000 $4,466 $4,466 $4,466 $4,466 $4,466

$939,523 $939,523 $939,523 $939,523 $939,523

$940,000 $940,000 $940,000 $940,000 $940,000


Note: * Refer to Table A-10b for Cost per Sampling Event details** Net present worth of O&M for alternatives RA-4a, RA-4b. RA-5, RA-5a, and RA-5b is based upon a 30-year performance at 7% interest per year

Cost of Alternative O&M for Year X

Net Present Worth** of Alternative O&M for Year X


Capital Cost EstimateInstitutional Controls


Consultant/Attorney Fees for Covenant Preparation LS 1 $25,000 2,6 $25,000




Sources:1. Quote from Independent Vendor2. Haley & Aldrich's previous experience on similar sites.3. Value from RSMeans CostWorks online software, 2004 MasterFormat, 2008 quarter 1 data release, adjusted for work in the Dayton, Ohio area.4. USEPA 540-R-00-002. OSWER 9355.0-75. July 2000.5. Peter and Timmerhaus "Plant Design and Economics for Chemical Engineers"6. Based on 15% of Earth Tech’s Remedial Action Cost Engineering and Requirements (RACER) estimate (See attached documentation)


Capital Cost EstimateSurface Water Relocation (Alternatives 2, 3, 4a, 4b, 5, 5a, 5b, 7)


Mobilization/Demobilization Lump Sum 1 $5,000 2,5 $5,000Bonds and Insurance Lump Sum 1 $1,000 2,5 $1,000Excavation for new creek (in-place) CY 1,100 $8 3 $8,800Vegetate new unnammed tributary area 1000 SF 27 $57 3 $1,539Culvert Installation ln ft 16 $121 3 $1,936Fill and compaction of old creek CY 1,100 $20 3 $22,000Vegetate old unnamed tributary 1000 SF 27 $57 3 $1,539Silt Fence ln ft 4,000 $2 3 $8,000Survey (based on 0.5% of construction) Lump Sum 1 $200.00 2 $200Disposable Supplies Day 20 $100.00 2 $2,000


Other CostsConstruction Administration and Design Engineering % Direct Capital costs 18% 4 $9,363Contingencies % Direct Capital costs 15% 2 $7,802Stormwater Permitting (401\404) Lump Sum 1 $10,000 2 $10,000



Assumptions:1. The actual final design may vary in design basis and equipment selection2. No taxes or duties are included in this estimate.3. Level of accuracy of this estimate is -30% to +50%4. Contingency includes USEPA\OEPA oversight, community relations5. Disposable Supplies based on $100/day x 20 days



O&M Cost EstimateSurface Water Relocation (Alternatives 2, 3, 4a, 4b, 5, 5a, 5b, 7)


Vegetate new unnammed tributary area 1000 SF 5 $57 3 $285General Fill Cu Yd 35 $6 3 $210Replacement of General Fill Cu Yd 35 $30 3 $1,050

TOTAL $1,545


Assumptions:1. The actual final design may vary in design basis and equipment selection2. No taxes or duties are included in this estimate.3. Level of accuracy of this estimate is -30% to +50%4. Assume stormwater BMP inspection during GW monitoring (Alternatives RA-2, RA-3, RA-4a, RA-4b, RA-5, RA-5a, RA-5b, and RA-7)



Capital Cost EstimateSurficial Grading & Vegetation (Alternatives 2, 3, 4a, 4b, 5, 5a, 5b, 7)


Mobilization/Demobilization Lump Sum 1 $35,000 2,5 $35,000Bonds and Insurance Lump Sum 1 $7,000 2,5 $7,000Spread Fill from Stockpile (12" lift) CY 46,680 $3 3 $140,040Final Grading SY 46,680 $1 3 $46,680Compact/Smooth/Roll Fill CY 13,000 $2 3 $26,000Strip and Place Topsoil (6") CY 6,500 $16 3 $104,000Seeding with Mulch and Fertilizer 1,000 SF 350 $57 3 $19,950Silt Fence ln ft 2,800 $2 3 $5,600Survey (based on 0.5% of construction) Lump Sum 1 $1,700.00 2 $1,700Disposable Supplies Day 30 $100.00 2 $3,000








O&M Cost EstimateSurficial Grading & Vegetation (Alternatives 2, 3, 4a, 4b, 5, 5a, 5b, 7)


Maintain Surface (incl. mowing) HR 96 $80 2 $7,680Replacement of Topsoil CY 12 $25 3 $300Revegetate 1000 SF 12 $57 3 $684

TOTAL $8,664





Capital Cost EstimateOn-Site Disposal of Treated Residuals (Alternative 4a)


Mobilization/Demobilization Lump Sum 1 $91,000 2,6 $91,000Bonds and Insurance Lump Sum 1 $18,000 2,6 $18,000Service Facilities and Ground Improvements Lump Sum 1 $45,000 2,6 $45,000Cap Layer ACRE 4.4 $175,000 4 $770,000Survey (based on 0.5% of construction) Lump Sum 1 $5,000.00 2 $5,000Disposable Supplies Day 22 $100.00 2 $2,200Backfill Replacement\Regrade (Leachate Collection) Cubic Yards 7099 $7.50 1 $53,240Leachate lift station EA 2 $18,000 2 $36,000Equipment Installation (Lift Station only) Lump Sum 2 $18,000 6 $36,000Electrical (Lift Station only) Lump Sum 1 $4,000 6 $4,000






Sources:1. Quote from Independent Vendor2. Haley & Aldrich's previous experience on similar sites.3. Value from RSMeans CostWorks online software, 2004 MasterFormat, 2008 quarter 1 data release, adjusted for work in the Dayton, Ohio area.4. http://www.frtr.gov//matrix2/section4/4-27.html - Cap as described in reference permeability < 1x10E-5, infiltration layer 45 cm, and erosion control layer 15 cm5. USEPA 540-R-00-002. OSWER 9355.0-75. July 2000.6. Peter and Timmerhaus "Plant Design and Economics for Chemical Engineers"


Capital Cost EstimateOn-Site Disposal of Treated Residuals (Alternative 4b)


Mobilization/Demobilization Lump Sum 1 $235,000 2,6 $235,000Bonds and Insurance Lump Sum 1 $47,000 2,6 $47,000Service Facilities and Ground Improvements Lump Sum 1 $117,000 2,6 $117,000Barrier Layer ACRE 4.4 $325,000 4 $1,430,000Cap Layer ACRE 4.4 $175,000 4 $770,000Survey (based on 0.5% of construction) Lump Sum 1 $12,000.00 2 $12,000Disposable Supplies Day 44 $100.00 2 $4,400Backfill Replacement\Regrade (Leachate Collection) Cubic Yards 7099 $7.50 1 $53,240Leachate lift station EA 2 $18,000 2 $36,000Equipment Installation (Lift Station only) Lump Sum 2 $18,000 6 $36,000Electrical (Lift Station only) Lump Sum 1 $4,000 6 $4,000








Capital Cost EstimateOn-Site Disposal of Treated Residuals (Alternative 5a)


Mobilization/Demobilization Lump Sum 1 $127,000 2,6 $127,000Bonds and Insurance Lump Sum 1 $25,000 2,6 $25,000Service Facilities and Ground Improvements Lump Sum 1 $63,000 2,6 $63,000Cap Layer ACRE 6.3 $175,000 4 $1,102,500Survey (based on 0.5% of construction) Lump Sum 1 $6,000 2 $6,000Disposable Supplies Day 63 $100 2 $6,300Backfill Replacement\Regrade (Leachate Collection) Cubic Yards 10164 $7.50 1 $76,230Leachate lift station EA 2 $18,000 2 $36,000Equipment Installation (Lift Station only) Lump Sum 2 $18,000 6 $36,000Electrical (Lift Station only) Lump Sum 1 $4,000 6 $4,000








Capital Cost EstimateOn-Site Disposal of Treated Residuals (Alternative 5b)


Mobilization/Demobilization Lump Sum 1 $333,000 2,6 $333,000Bonds and Insurance Lump Sum 1 $67,000 2,6 $67,000Service Facilities and Ground Improvements Lump Sum 1 $166,000 2,6 $166,000Barrier Layer ACRE 6.3 $325,000 4 $2,047,500Cap Layer ACRE 6.3 $175,000 4 $1,102,500Survey (based on 0.5% of construction) Lump Sum 1 $17,000 2 $17,000Disposable Supplies Day 63 $100 2 $6,300Backfill Replacement\Regrade (Leachate Collection) Cubic Yards 10164 $7.50 1 $76,230Leachate lift station EA 2 $18,000 2 $36,000Equipment Installation (Lift Station only) Lump Sum 2 $18,000 6 $36,000Electrical (Lift Station only) Lump Sum 1 $4,000 6 $4,000








O&M Cost EstimateOn-Site Disposal of Treated Residuals (Alternative 4a)


Maintain Surface HR 70 $80 2 $5,600Excavation of Damaged Cover (in place) CY 20 $30 2,3 $600Disposal of Damaged Cover Tons 30 $43 1 $1,284Replacement of Clay Layer CY 10 $28 3a $280Repair of Liner SF 0 $15 2 $0General Fill CY 4 $6 3 $24Replacement of General Fill CY 4 $30 3 $120Replacement of Topsoil CY 4 $25 3 $100Revegetate 1000 SF 10 $57 3 $570

TOTAL $8,578


Assumptions:1. The actual final design may vary in design basis and equipment selection2. No taxes or duties are included in this estimate.3. Level of accuracy of this estimate is -30% to +50%4. Assume 1.8 tons/cubic yard5. Revegetation for repair based on revegetating the entire 6 acres over 30 years.6. Cap cross section described in Table A-16.

Sources:1. Quote from Independent Vendor2. Haley & Aldrich's previous experience on similar sites.3. Value from RSMeans CostWorks online software, 2004 MasterFormat, 2008 quarter 1 data release, adjusted for work in the Dayton, Ohio area.3a. Value from RSMeans Environmental Remediation Cost Data, 19994. USEPA 540-R-00-002. OSWER 9355.0-75. July 2000.5. Peter and Timmerhaus "Plant Design and Economics for Chemical Engineers"6. Backfill quantities for clay and topsoil utilize a 1.2 and 1.5 factor, respectively to account for compaction


O&M Cost EstimateOn-Site Disposal of Treated Residuals (Alternative 4b)



TOTAL $8,878





O&M Cost EstimateOn-Site Disposal of Treated Residuals (Alternative 5a)



TOTAL $12,780





O&M Cost EstimateOn-Site Disposal of Treated Residuals (Alternative 5b)



TOTAL $13,230




TABLE A-18a Tremont City Barrel Fill Site Feasibility Study RA-4a, 4b

Capital Cost EstimateWaste Removal and Disposal (Alternative RA-4a and RA-4b)

ITEM DESCRIPTION UNITS QUANTITY UNIT COST SOURCEEXTENDED

COSTDIRECT CAPITAL COSTS

Mobilization & Setup Lump Sum 1 $200,000 1,2 $200,000Bonds and Insurance Lump Sum 1 $778,000 2,6 $778,000Road Construction Lump Sum 1 $89,172.00 1 $89,172Staging Pad Construction Lump Sum 1 $106,250.00 1 $106,250Labor (23 Construction Personnel) Days 344 $8,840.00 1,2 $3,040,960Equipment (Construction Equipment Rental) Months 16 $135,000.00 1,2 $2,160,000Per Diem (Construction Personnel) Days 344 $2,300.00 1,2 $791,200Fuel (On-site Consumption) Days 344 $6,120.00 1,2 $2,105,280Fencing Lump Sum 1 $106,250.00 1 $106,250Disposable Supplies Days 344 $1,000.00 1,2 $344,000Frac Tanks (4 tanks x 344 days) Days 1376 $40.00 1,2 $55,040Hydraulic Drum Crusher Lump Sum 1 $9,250.00 1 $9,250Overpacks (2% of 50,000 drums) Each 1000 $104.00 1 $104,000Lime (Solidification for drum sludge wastes only) Tons 1960 $72.63 1 $142,355Level B PPE (8 Construction Personnel) Days 344 $1,000.00 1,2 $344,000Basic Haz-Cats (Waste ID of 90% of 51,500 drums) Drums 46350 $20.00 1 $927,000Full Haz-Cats (Waste ID of 10% of 51,500 drums) Drums 5150 $40.00 1 $206,000Soil Analysis (Full TCLP - 150% Rush) Each 344 $656.25 2 $225,750Soil Analysis (Total VOC's - 150% Rush) Each 344 $110.00 2 $37,840Liquids Analysis (Full TCLP - 150% Rush) Full Frac Tanks 121 $656.25 2 $79,406Solidified Waste Analysis (Full TCLP - 150% Rush) Each 79 $656.25 2 $51,844Hazardous Soil (Between cells - to EQ Belleville, MI Treat toC) Tons 37000 $373.20 1 $13,808,400Non-Hazardous Soil (Between cells - Waste Mgt. Dayton, OH) Tons 0 $51.36 1 $0Solidified Haz Waste Sludge (Drums - Ross Incin. Grafton, OH) Tons 5880 $1,118.40 1 $6,576,192Solidified Non-Haz Waste Sludge (Drums - Waste Mgt. Dayton, OH) Tons 0 $51.36 1 $0Cell Water - Haz Waste (to EQ Belleville, MI Treat to D) Gallons 1240000 $1.81 1 $2,246,880Uncontainerized Waste Liquids (to EQ Belleville, MI Treat to D) Gallons 330000 $1.81 1 $597,960Hazardous Liquids (Drums - PCI East Chicago, IN) Gallons 425000 $1.85 1 $785,400Non-Haz Liquids Drums (Drums - EQ Belleville, MI) Gallons 425000 $0.90 1 $382,500LNAPL Liquids (Drums - PCI East Chicago, IN) Gallons 2000 $1.85 1 $3,696Backfill Strip and Re-Placement Cubic Yards 160800 $7.50 1 $1,206,000Backfill Re-Placement Cubic Yards 104300 $7.50 1 $782,250Demobilization Lump Sum 1 $100,000.00 1,2 $100,000Stormwater Management Lump Sum 1 $500,000 2 $500,000Personnel and Perimeter Air Monitoring Days 344 $2,250 2 $774,000Confirmation sampling (8 soil samples per cell) Each 400 $0 1 $0TCL VOAs Each 400 $82 1 $32,800VOA Encore samplers (3 per sample @$10/each) Each 1200 $10 1 $12,000TCL SVOCs Each 400 $180 1 $72,000PCBs Each 400 $57 1 $22,800TCL Pesticides Each 400 $90 1 $36,000TAL Metals analysis Each 400 $97 1 $38,800Terracore (1 per sample @15/each) Each 400 $15 1 $6,000Total Solids Each 400 $3 1 $1,200Confirmation sampling reporting Each 1 $16,288 1 $16,288Emergency response (24 hrs Vac truck and 30 day frac tank rental) Lump Sum 1 $7,245 1 $7,245Emergency response (Spill booms) Each 10 $46 1 $460


Other CostsConstruction Administration and Design Engineering % Direct Capital costs 18% 5 $7,184,244Contingencies % Direct Capital costs 15% 2 $5,986,870




Sources:1. Quote from Independent Vendor2. Haley & Aldrich's\PRP's previous experience on similar sites.3. Value from RSMeans CostWorks online software, 2004 MasterFormat, 2008 quarter 1 data release, adjusted for work in the Dayton, Ohio area.4. http://www.frtr.gov//matrix2/section4/4_30.html5. USEPA 540-R-00-002. OSWER 9355.0-75. July 2000.6. Peter and Timmerhaus "Plant Design and Economics for Chemical Engineers"

Notes1. The costs for equipment is based on 14 pieces2. Fuel surcharge for diesel from August 2007 to March 2008 = 1.36 (See attached data) 3. Waste disposal T&D fuel surcharge assumed to be 20%

TABLE A-18b Tremont City Barrel Fill Site Feasibility Study RA-5a, 5b

Capital Cost EstimateWaste Removal and Disposal (Alternative RA-5a and RA-5b)

ITEM DESCRIPTION UNITS QUANTITY UNIT COST SOURCEEXTENDED

COSTDIRECT CAPITAL COSTS

Mobilization & Setup Lump Sum 1 $250,000 1,2 $250,000Bonds and Insurance Lump Sum 1 $775,000 2,6 $775,000Road Construction Lump Sum 1 $89,172.00 1 $89,172Staging Pad Construction Lump Sum 1 $106,250.00 1 $106,250Labor (23 Construction Personnel) Days 434 $8,840.00 1,2 $3,836,560Equipment (Construction Equipment Rental) Months 20 $135,000.00 1,2 $2,700,000Temporary Facilities Months 20 $5,000.00 1,2 $100,000Per Diem (Construction Personnel) Days 434 $2,300.00 1,2 $998,200Fuel (On-site Consumption) Days 434 $6,120.00 1,2 $2,656,080Fencing Lump Sum 1 $106,250.00 1 $106,250Disposable Supplies Days 434 $1,000.00 1,2 $434,000Frac Tanks (4 tanks x 434 days) Days 1736 $40.00 1,2 $69,440Hydraulic Drum Crusher Lump Sum 1 $9,250.00 1 $9,250Overpacks (2% of 50,000 drums) Each 1000 $104.00 1 $104,000Lime (Solidification for drum sludge wastes only) Tons 1960 $72.63 1 $142,355Level B PPE (8 Construction Personnel) Days 434 $1,000.00 1,2 $434,000Basic Haz-Cats (Waste ID of 90% of 51,500 drums) Drums 46350 $20.00 1 $927,000Full Haz-Cats (Waste ID of 10% of 51,500 drums) Drums 5150 $40.00 1 $206,000Soil Analysis (Full TCLP - 150% Rush) Each 434 $656.25 2 $284,813Soil Analysis (Total VOC's - 150% Rush) Each 434 $110.00 2 $47,740Liquids Analysis (Full TCLP - 150% Rush) Full Frac Tanks 121 $656.25 2 $79,406Solidified Waste Analysis (Full TCLP - 150% Rush) Each 79 $656.25 2 $51,844Thermal Desorption of Haz Soil (Between cells) Tons 37000 $296.40 2,1 $10,966,800Solidified Haz Waste Sludge (Drums - Ross Incin. Grafton, OH) Tons 5880 $1,118.40 1 $6,576,192Solidified Non-Haz Waste Sludge (Drums - Waste Mgt. Dayton, OH) Tons 0 $51.36 1 $0Cell Water - Haz Waste (to EQ Belleville, MI Treat to D) Gallons 1240000 $1.81 1 $2,246,880Uncontainerized Waste Liquids (to EQ Belleville, MI Treat to D) Gallons 330000 $1.81 1 $597,960Hazardous Liquids (Drums - PCI East Chicago, IN) Gallons 425000 $1.85 1 $785,400Non-Haz Liquids Drums (Drums - EQ Belleville, MI) Gallons 425000 $0.90 1 $382,500LNAPL Liquids (Drums - PCI East Chicago, IN) Gallons 2000 $1.85 1 $3,696Backfill Strip Cubic Yards 160800 $7.50 1 $1,206,000Backfill Re-Placement Cubic Yards 79700 $7.50 1 $597,750Demobilization Lump Sum 1 $100,000.00 1,2 $100,000Stormwater Management Lump Sum 1 $500,000 2 $500,000Personnel and Perimeter Air Monitoring Days 434 $2,250 2 $976,500Confirmation sampling (8 soil samples per cell) Each 400 $0 1 $0TCL VOAs EA 400 $82 1 $32,800VOA Encore samplers (3 per sample @$10/each) Each 1200 $10 1 $12,000TCL SVOCs EA 400 $180 1 $72,000PCBs EA 400 $57 1 $22,800TCL Pesticides EA 400 $90 1 $36,000TAL Metals analysis EA 400 $97 1 $38,800Terracore (1 per sample @15/each) Each 400 $15 1 $6,000Total Solids Each 400 $3 1 $1,200Confirmation sampling reporting Each 1 $16,288 1 $16,288Emergency response (24 hrs Vac truck and 30 day frac tank rental) Lump Sum 1 $7,245 1 $7,245Thermal Desorption Optimization Lump Sum 1 $20,000 2 $20,000Survey (based on 0.5% of construction) Lump Sum 1 $193,000.00 2 $193,000Emergency response (Spill booms) Each 10 $46 1 $460


Other CostsConstruction Administration and Design Engineering % Direct Capital costs 18% 5 $7,165,013Contingencies % Direct Capital costs 15% 2 $5,970,845




Sources:1. Quote from Independent Vendor2. Haley & Aldrich's previous experience on similar sites.3. Value from RSMeans CostWorks online software, 2004 MasterFormat, 2008 quarter 1 data release, adjusted for work in the Dayton, Ohio area.4. http://www.frtr.gov//matrix2/section4/4_30.html5. USEPA 540-R-00-002. OSWER 9355.0-75. July 2000.6. Peter and Timmerhaus "Plant Design and Economics for Chemical Engineers"

Notes1. The costs for equipment is based on 14 pieces2. Fuel surcharge for diesel from August 2007 to March 2008 = 1.36 (See attached data) 3. Waste disposal T&D fuel surcharge assumed to be 20%. Includes thermal desorption


Capital Cost EstimateLiquid Waste Sumps (Alternative 7)


Mobilization/Demobilization (drilling mobe included in unit rate) Lump Sum 1 $364,000 2,5 $364,000Bonds and Insurance Lump Sum 1 $73,000 2,5 $73,000Survey (based on 0.5% of construction) Lump Sum 1 $18,000 2 $18,000Geophysics (Each sump) EA 50 $750 1 $37,500Geophysics (Site wide pre-drill survey) Lump Sum 1 $5,000 1 $5,000Drilling Costs (1500 ln. feet) ln. ft 1,500 $300 1 $450,000Clean and Move Rig Around Site EA 50 $500 1 $25,00012" Well Casing (Stainless) LN FT 1,250 $426 3a $532,47512" Well Screen (Stainless) LN FT 250 $372 3 $92,87512" Well Plug EA 50 $166 3a $8,299Sump Pumps EA 2 $1,995 1 $3,990Level Sensors EA 50 $895 1 $44,750Manage excavated materials (Cuttings) CY 100 $16 2 $1,600Well Development WK 50 $213 3a $10,667Main Control Panel EA 1 $18,000 2 $18,000Equipment Installation (includes 8% Markup) % of non-drilling equipment 1 $34,000 5 $34,000Instrumentation and Controls (includes 8% Markup) % of non-drilling equipment 1 $13,000 5 $13,000Electrical (utilize and upgrade existing) (includes 8% Markup) % of non-drilling equipment 1 $8,000 5 $8,000Service Facilities and Ground Improvements (includes 8% Markup) % of non-drilling equipment 1 $7,000 5 $7,000Grout LN FT 50 $15 3a $760Bentonite Seal EA 50 $369 3a $18,440Well Protection Bollards EA 200 $232 3a $46,404Organic Vapor Analyzer Rental DAY 125 $100.00 3a $12,500Field Technician HR 1,000 $85.00 2 $85,000Dewatering DAY 125 $1,425.00 3 $178,125Frac Tanks (10) DAY 125 $400.00 1 $50,000Disposable Supplies Day 125 $100 2 $12,500Personnel and Perimeter Air Monitoring Days 125 $2,250 2 $281,250Groundwater Waste Liquids (to EQ Belleville, MI) Gallons 912,000 $1.81 1 $1,652,544






Sources:1. Quote from Independent Vendor2. Haley & Aldrich's previous experience on similar sites.3. Value from RSMeans CostWorks online software, 2004 MasterFormat, 2008 quarter 1 data release, adjusted for work in the Dayton, Ohio area.3a. Value from RSMeans Environmental Remediation Cost Data, 19994. USEPA 540-R-00-002. OSWER 9355.0-75. July 2000.5. Peter and Timmerhaus "Plant Design and Economics for Chemical Engineers"


O&M Cost EstimateLiquid Waste Sumps (Alternative 7)


Electricity KW-HR 2,000 $0.08 4 $158Annual Pump Replacement Each 4 $1,995 2 $7,980Routine Maintenance (Well and Pump Cleaning) Each 12 $5,000 2 $60,000Operations and Maintenance Labor hr 480 $85 2 $40,800Groundwater Waste Liquids (to EQ Belleville, MI) Gallons 83,000 $1.81 1 $150,230

TOTAL $259,168


Assumptions:

1. The actual final design may vary in design basis and equipment selection2. No taxes or duties are included in this estimate.3. Level of accuracy of this estimate is -30% to +50%

Sources: 1. Quote from Independent Vendor2. Haley & Aldrich's previous experience on similar sites.3. Value from RSMeans CostWorks online software, 2004 MasterFormat, 2008 quarter 1 data release, adjusted for work in the Dayton, Ohio area.4. Electrical costs $0.079 per kilowatt hour maximum rate (Piqua, Ohio). After 600 KW/hr, rates scale down based on usage

TABLE 7 Tremont City Barrel Fill Site Feasibility Study

Net Present ValueSummary of Alternatives

CAPITAL COSTITEM DESCRIPTION RA-1 RA-4a RA-4b RA-5a RA-5b RA-7

A Fencing and Signage $0 $103,000 $103,000 $103,000 $103,000 $103,000B Groundwater Extraction Trench $0 NA NA NA NA $1,065,000C Groundwater Treatment System $0 NA NA NA NA $912,000C1 Groundwater Diversion (Upgradient) $0 NA NA NA NA $6,530,000D Groundwater Monitoring $0 $452,000 $452,000 $452,000 $452,000 $991,000E Institutional Controls $0 $25,000 $25,000 $25,000 $25,000 $25,000F Surface Water Relocation $0 $79,000 $79,000 $79,000 $79,000 $79,000G Surficial Grading / Vegetation $0 $517,000 $517,000 $517,000 $517,000 $517,000H1 On-site Disposal of Treated and\or Non_Hazardous Residuals $0 $1,410,000 $3,650,000 $1,971,000 $5,176,000 NAI Waste Removal and Disposal *** $0 $53,084,000 $53,084,000 $52,941,000 $52,941,000 NAJ Liquid Waste Sumps $0 NA NA NA NA $5,433,000

TOTAL CAPITAL COST $0 $55,670,000 $57,910,000 $56,088,000 $59,293,000 $15,655,000

OPERATIONS AND MAINTENANCEITEM DESCRIPTION RA-1 RA-4a RA-4b RA-5a RA-5b RA-7

A Fencing and Signage $0 $2,000 $2,000 $2,000 $2,000 $2,000B Groundwater Extraction Trench $0 NA NA NA NA $13,000C Groundwater Treatment System $0 NA NA NA NA $126,000D Surface Water Relocation $0 $2,000 $2,000 $2,000 $2,000 $2,000G Surficial Grading / Vegetation $0 $9,000 $9,000 $9,000 $9,000 $9,000H1 On-site Disposal of Treated Residuals $0 $9,000 $9,000 $13,000 $13,000 NAJ Liquid Waste Sumps $0 NA NA NA NA $259,000

TOTAL ANNUAL O&M COST $0 $22,000 $22,000 $26,000 $26,000 $411,000

NET PRESENT WORTH OF O&M COST * $0 $273,000 $273,000 $323,000 $323,000 $5,100,000

Net Present Worth of Groundwater Monitoring** $0 $940,000 $940,000 $940,000 $940,000 $1,713,000

NET PRESENT WORTH OF TOTAL COST (CAPITAL PLUS O&M) $0 $56,883,000 $59,123,000 $57,351,000 $60,556,000 $22,468,000

Notes: * Net present worth of O&M for alternatives RA-2, RA-3, RA-4a, RA-4b, RA-5, RA-5a, RA-5b, and RA-7 are based upon a 30-year performance at 7% interest per year Net present worth of O&M for alternative RA-4 and RA-6 is based upon a 10-year performance at 7% interest per year** Annual costs of Groundwater Monitoring vary based on alternative and year. Refer to Table A-10a and Table A-10b for details. *** Waste removal and disposal for alternatives RA-4, RA-4a, RA-4b, RA-5a, RA-5b, and RA-6 based on actual contractor costs.

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