Responsiveness Summary for the Fs

HAZARDOUS EPA Region 5 Records Ctr. SIT I CONTROL DIVISION 253058 RESPONSIVENESS SUMMARY FOR THE FEASIBILITY STUDY CHEM-DYNE SITE HAMILTON, OHIO WA21.5M10.0 W65310.DO JUNE 1985 CONTRACT NO. CHJMBHILL RESPONSIVENESS SUMMARY FOR THE FEASIBILITY STUDY CHEM-DYNE SITE HAMILTON, OHIO WA21.5M10.0 W65310.DO JUNE 1985 GLT267/57 CONTENTS Chapter Page 1 INTRODUCTION 1-L Purposfe of the Responsiveness Summary Background 2 FEASIBILITY STUDY OVERVIEW 2-1 Site Background Information Endangennent Assessment Summary Remedial Action Alternative Summary 3 PUBLIC COMMENTS - U.S. EPA RESPONSES 3-1 Remedial Investigation Report Comments Feasibility Study Technical Analysis Soil Groundwater Ford Canal Onsite Utilities Remedial Actions - Public Recommendations Soil Groundwater Ford Canal Onsite Utilities Schedule for Remedial Action Implementation Site Risks - Present and Future Remedial Contingency Actions Costs Versus Remedial Action Selection Feasibility Study Comment Period Appendixes A Oxford Audubon Society and HAPSO Comments and Responses on Cham-Dyne Final RI Report B Oxford Audubon Society Comments and Responses on Chem-Dyne Feasibility Study C U.S. EPA Newspaper Advertisements for December 3, 1984, Public Hearing and Comment Period Extension D Public Comments GLT267/49 Chapter 1 INTRODUCTION PURPOSE OF THE RESPONSIVENESS SUMMARY The U.S. Environmental Protection Agency (U.S. EPA) has eval- uated and selected remedial actions to control the chemical waste contamination of the Chem-Dyne site in Hamilton, Ohio. Remedial evaluations were presented in a Feasibility Study issued in November 1984. A decision on the specific remedial actions to be taken has been made by the Agency and has been incorporated in the Consent Decree entered into by the res- ponsible parties. The purpose of this document is to report both verbal and written public comments received on the Agency's remedial action evaluations in the Feasibility Study and to report the Agency's responses to public comments. Authority for this work is from the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) also known as "Superfund." BACKGROUND The Feasibility Study (FS) for Chem-Dyne was issued on Novem- ber 19, 1984. The FS was based upon numerous site investi- gations conducted in 1983 and reported in the Final Remedial Investigation Report issued in May 1984. A public meeting on the FS was held on December 3, 1984, at the City Hall in Hamilton, Ohio. Verbal comments on the FS were received during the meeting. Written public comments were received by the U.S. EPA through Friday, December 28, 1984. GLT267/54 1-1 Chapter 2 FEASIBILITY STUDY OVERVIEW This responsiveness summary is based on the Chem-Dyne Fea- sibility Study Report issued on November 19, 1984. For background, major elements of the Feasibility Study are sum- marized in this chapter. SITE BACKGROUND INFORMATION SITE DESCRIPTION The Chem-Dyne site is within the limits of the City of Hamil- ton, Butler County, Ohio, which had an estimated 1980 popu- lation of 66,400. The site covers approximately 20 acres on the northern border of the city. The site is bounded immediately on the south by a residential district. Farther to the south are the business district and additional residential districts. It is bounded on the east by a municipal park whose facilities include six ball- parks and a municipal swimming pool. Residential dwellings lie to the east of the park. The site is bounded on the north by the Ford Hydraulic Canal, which flows west to the Great Miami River. Immediately north of the canal is an agricultural field. Approximately 1,500 feet north of the site is one of Hamilton's two water treatment plants, which pumps groundwater from deep wells during the summer months. The site is bordered on the west by a railroad right-of-way. Next to the railroad tracks is the Ransohoff Company, a sheet metal fabrication plant. Also to the west is the City of Hamilton Power Plant. About 75 yards from the site are coal piles I and a large petroleum storage tank for the power plant. Farther to the west are warehouses for Champion Paper and a small residential area. At th» start of initial surface cleanup remedial activities in xiay 1983, there were approximately 8,600 drums, 30 above- grade tancs, and 2 open-top, belowgrade tanks onsite. The tan>s and drums contained an estimated 463,000 gallons of fluid, 109,000 gallons of sludge, and 86,000 gallons of solids. were generally in a badly deteriorated condition; many were leaking or open. Other onsite equipment included two tanker trucks (5,000 gallons) , four semitruck trailers, two flat beds, an empty fuel type tank (300 gallons), one outdoor reaction vessel (100 gallons) <| six reaction vessels (4,700 gallons each), and miscel- laneous debris inside the Chem-Dyne building. I' : !ii There are five major buildings on the Chem-Dyne site. 2-1 o Chem-Dyne building o Boiler building o Ward Manufacturing building o Ford building (formerly a Ford tractor factory) o A blue warehouse (prefabricated) Former operations by Chem-Dyne centered around the Chem-Dyne building. The building housed the Chem-Dyne offices, blend- ing tanks, and other equipment; it is presently in a dilapidated condition. Three nearby buildings, the boiler. Ward Manufacturing, and Ford building, are also dilapidated. There is no historical evidence to indicate that they were used by the Cham Dyne Corporation. A detailed inspection of the buildings in Octo- ber 1983 by CH2M HILL did, however, find occasional drums and evidence of contamination in the basement of the boiler building caused by seepage draining into the basement. The blue warehouse and the parking lot to the south were previously used by the Chem-Dyne Corporation to store drums. The inspection conducted in October 1983 by CB2M HTLL found signs of drum storage in the building and on the parking lot. HISTORICAL PROPERTY OWNERSHIP Information pertaining to property ownership was obtained from a title search conducted for the U.S. EPA by Lawyers Title of Cincinnati, Inc. The Chem Dyne site is situated on a reclaimed wetland. The earliest found property records indicate that the wetland area was owned by the Miami Conservancy District (MCD) as early as 1916. In 1917, the MCD leased the property to the Hamilton and Rossville Hydraulic Company (HRH). HRH constructed levees and operated at least two canals, a reservoir, and a power plant on the property until 1919. In 1919, MCD sold portions of the property to the Ford Motor Company and the HRH. In a joint effort by the three parties, the wetland area, reservoir, and west canal were filled and the south canal was relocated to the north end of the present site. Material for the new levees was excavated from the new channel area. The eastern portion of the site was used as a spoil area for the north end channel improvements. The remaining fill material for the site was excavated from the Great Miami River. Ford constructed a hydroelectric plant adjacent to the canal and operated a tractor plant at the site starting around 1928. Operations at the plant lasted approximately 10 years. 2-2 Records indicate that in the early 1950's Bendix Aviation Corporation acquired all of the stock of the HRH. In June 1951, the Ford Motor Company sold its property to Bendix. Bendix conducted manufacturing operations at the site until 1959. In 1959, the former Ford site was split. The two tracts passed through several ownership arrangements including the Chem-Dyne Corporation. A detailed summary of the property ownership is reported in the Remedial Investigation Report, Volume 2, Task 1 Technical Memorandum. Parts of the tracts of land described above are included within the boundaries of the Chem-Dyne site because of encroachment by Chem-Dyne operations onto these adjacent properties. The Ford Hydraulic Canal is not within the hazardous waste site boundaries as defined in the FS. However, as a previous receptor of direct stormwater runoff and discharges from the Chem-Dyne site, this property is considered in the feasibility study. Most of the canal was obtained by the HRH in the 1919 agreement with the MCD. The HRH conveyed the property to the City of Hamilton in 1963. HAZARDOUS WASTE SITE HISTORY As early as 1974,. chemical wastes may have been trucked to the Chem-Dyne site. In the fall of 1975, Kovacs and Whitten formed Spray-Dyne which made antifreeze by recycling chemical wastes. In 1976, the operations were expanded and the Chem- Dyne Corporation was formed to collect and dispose of indus- trial chemical wastes. Some effort was made to recycle oil wastes as fuel. Wastes that were unsuitable for recycling were stored in drums and tanks on the site or shipped to other disposal sites. The Chem-Dyne facility operated until February 1980. In 5 years of operation, the facility accepted waste from nearly 300 generators. The materials handled included pesticides and pesticide residues, chlorinated hydrocarbons, solvents, waste oils, plastics and resins, PBB's, PCB's, TRIS,.acids and caustics, heavy metal and some cyanide sludges, and pack- aged laboratory chemicals. More than 30,000 drums and 300,000 gallons of bulk materials were onsite when the operations were closed. Operations of Chen-Dyne resulted in uncontrolled releases of hazardous materials. Mixing of liquid wastes was often done in open pits releasing noxious vapors. Reportedly, 55-galIon drums were punctured with pickaxes and allowed to leak or were dumped onto the ground or into a trough or pit. 2-3 Taak cars were reportedly emptied onto the ground, into troughs and sewers. In its 5 years of operation, a number of environmental inci- dents were reported at the Chem-Dyne facility.

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