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 evaluated 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 responsible 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 summarized 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 population 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 industrial 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 incidents were reported at the Chem-Dyne facility. From 1976 to 1979, there were at least five fish kills in the Great Miami River that were attributed to Chen-Dyne operations. One fish kill stretched for nearly 37 miles from the Ford Hydraulic Canal to the mouth of the Great Miami River. In 1976, a series of fires and a fuming railroad tank car incident generated active public concern. Another series of fires occurred in 1979. LEGAL ACTIOHS Legal actions involving the Chem-Dyne Corporation began in June 1976 when Chem-Dyne filed a $30 million suit against the City of Hamilton and its officials for harassment. On September 29, 1976, the State of Ohio filed a suit against Nhltten, Kovacs, Chem-Dyne, et al. The suit alleged that the companies were responsible for killing more than a million fish and water animals in the Great Miami River and for emitting offensive odors into the air. The suit sought penal, compensatory, and punitive damages totalling $340,000 and called for a permanent end to illegal discharges into Ohio waters and abatement of air pollution nuisances. Both suits were settled on July 19, 1979, when all parties agreed to a stipulation and judgment entry whereby (Them Dyne agreed to prevent future pollution and to remove all inventory within 12 months. Chem-Dyne also agreed to drop its suit against the City of Hamilton and to pay $75,000 in fines. The U.S. EPA filed suit against Chem-Dyne et al. under the provisions of RCRA on Decenber 19, 1979. Two days later, the City of Hamilton and the Ransohoff Corporation joined in the federal suit against Chem-Dyne. The suit sought to force Chem Dyne to stop operations, remove wastes from the site, and clean up any soil or groundwatar contamination. On Jan- uary 25, 1980, the District Court granted a preliminary injunction prohibiting the defendants from hauling, receiving, or taking delivery of any industrial wastes at its premises. Also, as a result of noncompliance, on January 24, 1980, the Ohio Attorney General filed a motion in the state courts asking that a receiver be nimed to assume operations at Chem- Dyne. The state court appointed Jack Zettler, a Hamilton lawyer and accountant, as receiver on February 4, 1980. On August 26, 1982, the EPA reached agreement with over 100 companies for surface cleanup of the site. The generators agreed to pay $2.4 million in cleanup costs. The agreement also allowed the government to demand additional payments if unexpected costs arose. Simultaneously, the U.S. Department

2-4 of Justice filed a suit to recover additional costs from owners, operators, and major generators who refused to participate. WASTE CLEANUP ACTIONS The receivership, established February 4, 1980, was charged with the duty of carrying out the court's order to remove all waste from the site. With technical assistance from the Ohio EPA, the receivership directed cleanup operations until it had exhausted all Chem-Dyne money and assets in November 1981. During receivership, about 20,000 drums were removed, mostly by generators who agreed to remove their wastes. Additional cleanup operations were financed by selling assets of the company and by accepting and properly disposing of some industrial wastes. In December 1981, the State of Ohio submitted Chem-Dyne as Ohio's top priority Superfund project. In 1981, the site was included on the U.S. EPA's Interim Priority List as Ohio's highest priority site. Between March and April 1982, several remedial actions were performed at the Chem-Dyne site with Superfund money. These actions included fence repair, cleanup of the loading dock area, waste removal from bulk tank No. 6, and plugging of selected site storm drains. From November 1981 until May 1983, voluntary removal of waste by generators proceeded under the supervision of the Ohio EPA. From May until November 1983, a cleanup contract for the planned removal of all remaining surface wastes from the Chem-Dyne site was undertaken and managed by the U.S. Army Corps of Engineers as an initial remedial measure in accor- dance with the National Contingency Plan (NCP). ENDANGERMENT ASSESSMENT SUMMARY The endangerment assessment prepared for tha Feasibility Study examined the potential human health effects under the "no-action" alternatives for each "operable unit" or environmental media including soil, groundwater, surface water, and onsite facilities. The endangerment assessment concluded that implementation of the no-action alternative for each operable unit could result in the following outcomes:

2-5 SOIL A potential excess lifetime cancer risk of 4 x 10 is associated with ingestion of soil with the site concentrations. Population exposure associated with dust entrainment and direct soil contact increased this cancer risk. GROUBDMATER The production of drinking water at the Hamilton well field is estimated to present an excess lifetime cancer risk of 2 x 10 and 9 x 10 for Cases 1 and 2, i.e., existing plume migration only and plume with leachate migration. The cancer risks are estimated to be 1 x 10~ and 2 x 10 for the two cases at a hypothetical future well located 100 feet from the Chem Dyne site. The potential for dermal absorptions and inhalation of released volatiles during household water use may increase this risk. Mean groundwater concentrations for volatiles are not projected to exceed the ACGIH threshold limit values at the Champion Paper production floor, and the discharge of groundwater by Mercy Hospital is estimated to produce contaminant concentrations in the Great Miami River that are generally below freshwater aquatic life toxicity values identified by EPA in its ambient water quality criteria documents. FORD CABAL There is no known immediate health endangerment caused by canal water or sediment. OBSITB FACILITIgS Potential health endangerment is caused by direct contact with contaminants in several onsite facilities. REMEDIAL ACTION ALTERHATIVE SOMMARY The Feasibility Study followed a stepwise process to assess, screen, and evaluate remedial action technologies and alternatives for problems identified at the Chem-Dyne site. The goals of the stepwise procedure were to reduce the range of alternatives to the most suitable remedial actions and to document the decision process. Assessment of applicable remedial action technologies (FS Chapter 3) was based on the following criteria: first, technical feasibility; second, environmental, public health, and institutional effects; third, estimated present worth costs. Bernedial technologies were assessed by these criteria indepen- dently without consideration of possible advantages or dis- advantages of technologies when applied in combinations.

2-6 Following assessment of individual remedial technologies, "assembled" remedial action alternatives were screened using the same criteria as applied to the technologies (FS Chap- ter 4). An example of an assembled remedial alternative for groundwater is the following: groundwater extraction with air stripping treatment and discharge to the Ford Canal. In this example, three technologies are combined or assembled into a single alternative. Finally, detailed analysis of selected assembled remedial action alternatives (FS Chapter 6) was based on more detailed consideration of the criteria applied to the remedial technologies, particularly technical performance and estimated present worth costs. Detailed analysis yielded four example remedial action alternatives that represent a reasonable range of response to the endangerment at Chem-Dyne according to the National Contin- gency Plan. To summarize the example remedial alternatives, four tables from the Feasibility Study are reproduced on the following pages. These summary tables present only outline descriptions of the alternatives and the estimated costs. The no-action alternative was also carried through the Fea- sibility Study for reference. The no-action alternative means essentially "do nothing;" it is therefore not included in the following tables. GLT267/50

2-7 Table 1 (Page l of 2) (FS Table 6-1) SUMIAKT 0? EXAMPLE ASSEMBLED ALTERNATIVE NO. 1 (AA-1)

Coat Estimates* Annual Operation & Present Renedial Action Capital Maintenance Worth Soil Excavate a 10'-deep trench around tha perlMter and renova soil; backfill with clay o Excavation and Backfilling $80,000 $80,000 Excavate and remove 2' of soil on and offsit* with 6' removal in Areas 9, 10, 11/12, and 13; o Excavation 1,800,000 1,800,000 o Transportation 2,200,000 1,200,000 o Disposal 2,900,000 11,900,000 Demolish and remove asphalt parkins lot south of blua warehouse o Demolition and Soil Excavation 260,000 260,000 o Transportation 390,000 390,000 o Disposal 520,000 520,000 Cap and seal entire site with multilayer clay/membrane system 1,900,000 $17,000 2,100,000 groundwster Extraction wallsj groundwater removal till 10"6 cancer risk criteria are set 130,000 50,000 390,000° Air stripping at 99 percent total VOC reaoval 1,500,000 16,000 1,600,000° Off-gee scrubbing by carbon adsorption 1,800,000 460,000 3,600,000° Facilities Deaolish and rsaove all buildings and structures o Demolition 980,000 980,000 o Transportation 610,000 610,000 o Disposal 770,000 770,000 Deeollsb and leeuve concrete slab and loading dock o Detention 76,000 76,000 o Transportation 150,000 150,000 o Disposal 190,000 190,000 Raeove two open top onelte burled tanks 1,000 1,000 Seal all connections to northwestern atom 10,000 10,000 reline northwestern storm sewer 15,000 15,000

GLX267/51-1 2 of 2)

_*™*r^ b OpUAUOB • PrCMBt Uorth

5,000

97,000

10,000

4.100.000 543,000 23,100,000 54,000 2,310,000 $5*7,000 $25,400,000 Table 2 (Pag* 1 of 2) (FS Table 6-2) SBMMAMt OT EXAMPLE ASSEMBLED ALXBWUXIVE NO. 2 (AA-2) Cost Estlaates' Annual Operation & Present" Remedial Action Capital Maintenance Worth Soil Excavate and remove 3' of soil; on and offsits; o Excavation $1,600,000 $1,600,000 o Transportation 1,900,000 1,900,000 o Disposal 2,500,000 2,500,000 Demolish and remove asphalt parking lot south of blue warehouse o Demolition and Soil Excavation 260,000 260,000 o Transportation 390,000 390,000 o Disposal 520,000 520,000 Cap and seel entire site with multilayer clay/membrane system 1,900,000 $17,000 2,100,000 Groundwater Extraction wells; gronndwater removal to detection limits 130,000 50,000 630,000° Air stripping at 90 percent total VOC ral 400,000 3,200 410,000d Off-gaa •crabbing by carbon adsorption 1,100,000 250,000 2,000,000d Facilities Daaolisb and reaove all buildings and •troctorw o Demolition 980,000 980,000 o Transportation 610,000 610,000 o Disposal 770,000 770,000 DesDlisb and reeove concrete •lab and loading dock o Demolition 76,000 76,000 o Transportation 150,000 150,000 o Dispossl 190,000 190,000 fleams tw> open top onsite burled V tanks 1,000 1,000 Seel all connections to northwestern •ton 10,000 10,000 Dacontaadnate and reline nortiwestern •tor* sewer 15,000 15,000 Clean 8" siphon seel with groat 5,000 5,000 Rehabilitate «<«»««g stocm sever (•outbeast aide) serf decontasdnete 97,000 97,000 Seal existing onsite prodoctlon wells with grout 10,000 10,000

GLI267/S1-3 2 (?••* 2 of 2)

Can Operation fc Capital

3.400.000 3.400.000

17,000,000 320,000 18,600,000 (at 10%) 1,700,000 32,000 1,900,000 $11,700,000 $380,000 $20,500,000 Table 3 (Page 1 of 2) (TS Table 6-3) SUMMARY OF EXAMPLE ASSEMBLED ALXERHAXIVE NO. 3 (AA-3)

Cost Estimates Annual h Operation & Present Remedial Action Capital Maintenance Worth Soil Excavate and remove 2" of soil on and off«ita; o Excavation $1,100,000 $1,100,000 o Transportation 1,300,000 1,300,000 o Disposal 1,700,000 1,700,000 Cap and seal araas of soil and concrete slab removal with lorn ovar clay system 980,000 $11,000 1,100,000 Remove aspbalt parking lot south of blua warehouse) axcavata and rsmove 2' of soil) backfill and repaves raplaca guardrails and catch basin o Demolition and Excavation 260,000 260,000 o Transportation 390,000 390,000 o Disposal 520,000 520,000 o Repaying *nd Backfilling 110,000 2,000 130,000 o Replace goardraila and catchbaains 10,000 10,000 Groundwater Extraction walla j groundwater removal until 10 cancar risk criteria are Bet 130,000 50,000 590,000° Air stripping at 70 percent total HOC val 130,000 1,000 130,000d Off-gas scrubbing by carbon adsorption 620,000 140,000 l,200,000d Facilities Demolish and remove Chev-Dyne, garage and boiler buildings; backfill and cap and seal with loaa over clay o Demolish 180,000 180,000 o Transportation 100,000 100,000 o Disposal 170,000 170,000 o Backfill 58,000 58,000 DcBolian and rsams concrete coal blnj cap and seal with loaa over clay o Deeoliah 24,000 24,000 o Transportatioa 45,000 45,000 o Disposal 60,000 60,000 Dewlish and slab and loading o Desnlisn 76,000 76,000 o Transportation 150,000 150,000 o Disposal 190,000 190,000 Decontamiaata Ford, Hard and blue warehouse buildings 420,000

CLX267/51-5 Tafcl* 3 tt««* 2 of 2)

CtMt C*tiH*CM Operation fc PnMBt Capital 5,000 5,000

97,000 97,000

10,000 10,000

I 2,200,000 2.500.000 11,100,000 200,000 12,600,000

(•CIA) 1,100,000 20,000 1,300,000 $12,200,000 $220,000 $13,900,000

_•_ . . -.»<_.»-- 4 A ifc • of *50 to -30 10 10 pnlo« «t 10

CU2f7/Sl-« Table 4 (?•«• l of 2) (FS Table 6-4< SUMMARY OF EXAMPLE ASSEMBLED ALTERNATIVE MO. 4 (AA-4)

Coit Estimates Annual Operation & Present Remedial Action Maintenance Worth Soil Excavate and remove hotspots Demolish and remove asphalt parking lot south of blue warehouse o Demolition $12,000 $12,000 o Transporation 49,000 49,000 o Disposal 65,000 65,000 Cap and teal entire lit* with multilayer clay/membrane system 1,900,000 $17,000 2,100,000 Groundvater Extraction wells; groundratmr raaoral until 10 c«nc«r risk criteria are oat 130,000 50,000 590,000* Air stripping at 99 percent total VOC ral 1,500,000 16,000 1,600,000* Off-gas scrubbing by carbon adsorption 1,800,000 460,000 3,600,000* Facilities Demolish and remove all buildings and structures o Demolition 980,000 980,000 o Transportation 610,000 610,000 o Disposal 770,000 770,000 Demolish and remove concrete slab and loading dock o Demolition 76,000 76,000 o Transportation 150,000 150,000 o Disposal 190,000 190,000 Remove two open top onslte burled tanks 1,000 1,000 Seal all connections to northwestern storm sever 10,000 10,000 Decontaminate and reline north* western storm sever segment 15,000 15,000 Clean 8" siphon and seal with grout 5,000 5,000 Rehabilitate existing scon (southeast side) end decontaminate 97,000 97,000 Seal existing production veils with groat 10,000 10,000

GLT267/51-7 4 (P*fi 2 of 2)

OpcntioB

Additional Inclndo pondttias'coot*) 2.100.000 2.700.000 10,300,000 13,700,000 (•e 10%) 1.100,000 1,400,000 TOOL SU.MO.OOO $15,100,000

•All , I.e., tte of +50 Co ~30 pnvoBC. ported «t 10 pncoBC latorMC. of fcutiyuc soil will bo oKondaod by iogling friar to mA JaplOBOBtatlon for tbi« actloa ok 27 y«ir pvrlotf «t 10 pnlod «t 10 latoxoit. 0X2*7/31

CU2*7/51-« Chapter 3 PUBLIC COMMENTS - U.S. EPA RESPONSES

Public comments on the Feasibility Study Report for the Chem-Dyne site were received by the U.S. EPA at a public meeting on December 3, 1984, and through written documents received by U.S. EPA through December 28, 1984. These comments fell into the following eight major categories: o Remedial Investigation (RI) Report Comments o Feasibility Study Technical Analysis Soil Groundwater Ford Canal Onsite Utilities o Remedial Actions - Public Recommendations Soil Groundwater Ford Canal Onaite Utilities o Schedule for Remedial Action Implementation o Site Risk* - Current and Future o Remedial Contingency Actions o Cost Versus Remedial Action Selections o FS Comment Period Public comments and U.S. EPA's responses are summarized in this chapter. Comments in this chapter are edited and sometimes paraphrased to combine similar comments under common topics. The intent has been to present the full range of topics and details of the overall comment set without lengthy repetition. Texts of the specific verbal and written comments are included in Appendix D. REMEDIAL INVESTIGATION (RI) REPORT COMMENTS During the public meeting in the City Council chambers at the Hamilton City Hall on December 3, 1984, several comments regarding the Final RI Report (May 22, 1984) were expressed. These comments were summarized in two letters to U.S. EPA. Because the comments were detailed and lengthy, separate responses were prepared, combined, and sent directly to those who commented in a letter from Don Bruce/U.S. EPA dated

3-1 December 11, 1984. The letters with these Final RI Report comments and Agency responses are in Appendix A of this responsiveness summary. FEASIBILITY STUDY TECHNICAL ANALYSIS Several comments concerned aspects of the technical discussions and analysis of the Chen-Dyne site and the alternative ramsdial actions presented in the FS. These comments and responses were grouped as they pertained to soil, groundwater. Ford Canal, and onsite utilities. son. Public comments: 1. FS should consider recent research that indicates the chemical effects of sosw wastes which render clay more permeable (public meeting). 2. Removed material should not become another problem in some other place (public meeting). 3. How was a soil removal depth of 2 feet determined and how are soil contamination hotspots to be identified? (Hamilton Appalachian Peoples Service Organization or HAPSO)

4. The final remedial package should include assurance and provisions that Superfund will be responsible for cleanup of future botspot discoveries (Hamilton Appalachian Peoples Service Organization or HAPSO). 5. A more extensive offsite sampling is needed to determine the true parameters of the contamination by toxic materials (Izaak Walton League). 6. The soil is suspected of being contaminated up to 15 feet and of having hotspots erratically located. Chen-Dyne site operators kept poor records and there is also a lack of scientific soil data. To start the remedial project with a complete predetermined plan would be naive. (Jocelyn Hamm) 7. One alternative to soil removals is to remove hotspots with testing being done at appropriate points during cleanup. To remove 2 feet of soil from the remaining site areas would be a negligent act. (Jocelyn Hamm) 8. To cap the site at a premature time during cleanup would be a waste of resources. (Jocelyn Hamm) Agency responses:

3-2 1. The clay in the clay/loam and clay/membrane/loam caps considered for Chem-Dyne would not be in direct contact with chemical wastes. Interactions between the clay and site contaminants are not expected. 2. Causing another contamination problem elsewhere is one of the concerns considered with removal of contaminated site soils. Limited soil removal is incorporated in the Agency's remedial action plan and care will be taken to relocate the contaminated soils in an approved and inspected RCRA permitted landfill facility to minimize the possibility of future problems. 3. Soil contamination removal to a depth of 2 feet was based on estimation of the overall site contaminant mass and the potential effect of soil contaminant infiltration on groundwater. The 2-foot excavation depth was based on estimated groundwater contamination reduc- tions with soil removal and various levels of site capping. The 2-foot excavation depth resulted in an estimated 90 percent removal of organic contaminants. Soil contaminant hotspots have been identified based on analysis of soil samples and on judgment regarding past operations, aerial photographs, and visual appearance of site soils. Identification of future hotspots during the progress of remedial actions on utilities at the site should be guided by the sain* information. 4. The final remedial package includes contingency provisions to account for the discovery and removal of additional "hotspots* of soil contamination if necessary. 5. Soil sampling was conducted offsite or outside the former perimeter of the site for two reasons: first, to take background soil samples, and second, to investigate offsite areas suspected to have been contaminated by Chem-Dyne operations or runoff. The extent of offsite soil contamination is limited to areas of reported discharges (e.g., west of the Chem-Dyne building along the railroad tracks) and runoff (e.g., south of the warehouse parking lot). Based on results of these samples, the site boundary was revised in the FS. During Chem- Dyne waste handling operations, contamination was also discharged to the Ford Canal and several fish and sediment samples ware analyzed to evaluate canal conditions.. These analyses led to issuance of the fishing advisory for the Ford Canal. Additional offsite sampling does not appear warranted at this time unless new information regarding unknown offsite contamination is presented. 6. The amount of data available on soil contamination is necessarily limited; however, sufficient data were developed to evaluate remedial alternatives. The

3-3 selected remedial plan for the Chen-Dyne site is detailed but flexible. The remedial plans have explicit contingency provisions allowing adjustments to meet actual field situations as they are identified. 7. Hotspot soil removal was considered as a reasonable remedial action in the PS. However, the FS concluded that hotspot soil removal must be accompanied with a low permeability cap to minimize infiltration and the migration of organic contaminants that are in the soil. The overall removal of 2 feet of soil recognizes that contamination is widespread and erratic. Rather than attempting to completely characterize contamination in soil with a large soil testing program in the remedial investigation, an alternative approach of soil removal overall was evaluated based on a smaller set of soil analysis data. In this evaluation, soil removal was always combined with a low permeability site cap. In this way, overall soil removal was considered as a general "insurance* approach. The final remedial alternative selected for soil was removal of hotspots of soil contamination and covering the entire site with a clay and membrane cap as opposed to removal of 2 feet of soil over the entire site. 8. The timing of cap placement is important to successful site rams illation. Capping must be done after all soil removal is completed and site surface preparation is finished. The low permeability site cap is critical to the design of the soil remediation goals. Even without soil removal, the low permeability cap will achieve the two goals of eliminating direct contact and minimizing endangerment caused by groundwater contaminated by contaminant migration through site infiltration.

UKUUBIPmTBR Public Commentsi 1. Contaminated groundwater should be extracted (public meeting). 2. POTW use for groundwater treatment should be rejected because sludge would become contaminated (public meeting). Use of the POTW as a groundwater treatment modality is unacceptable due to the number of hazards such an option could effect (HAPSO). 3. Rejection of the PACT treatment process should not be based on cost alone (public meeting).

3-4 Why is PACT, which is rated so high for its effectiveness, withdrawn from consideration simply due to cost; as the dollars for this cleanup are to come from the generators of the waste (HAPSO)? 4. EPA should pinpoint the extent and the rate of movement of groundwater contamination (public meeting). 5. Extracted groundwater should not lead to contamination of any other environment (public meeting). 6. Air stripping is not a complete treatment technology for removal of all the organic pollutants possible at Chem-Dyne; it is effective for volatile organics only (public meetings and HAPSO). 7. The Agency should identify the potential number of water systems, and therefore the number of people who can be affected by the toxic wastes known to be contaminating the aquifer. (IzaaJc Walton League) 8. The groundwater is contaminated with VOC's and other contaminants onsite. However, offsite groundwater remains a mystery to me due to lack of scientific data and contradictions in the study. (Jocelyn Hamm) 9. The groundwater is contaminated with compounds that cannot be completely broken down or bonded through any alternative mentioned. However, granular activated carbon accompanied by air stripping or the PACT system may be the only solution. (Jocelyn Hamm) 10. Are the extraction wells "cone of influence" intended to extend beyond the outer perimeters of the plume? (Robert C. Hubbard) 11. In determining the "cone of influence," were effects of existing industrial and municipal wells taken into consideration? If so, was full capacity operation or additional wells also considered? (Robert C. Hubbard) 12. We do not see how the groundwater contamination can ever be contained especially if contamination has been found at 65 feet. When you try to clean up the aquifer, all the money in the world cannot bring back our clean water once it is polluted. (The Chowning family and others) Responses: 1. The selected remedial action plan for the site includes groundwater extraction over a period of several years.

3-5 2. The comment recommending rejection of POTW treatment of groundwater recognizes one of the negative aspects of this alternative. The POTW alternative would be selected only after detailed pilot testing to investigate contamination problems which could include collection system sludges and airspace, treatment plant atmosphere, treated water discharge, and sludge contamination. POTW treatment was not selected in the remedial action plan. 3. PACT was rejected not because of cost alone but because it did not provide greater advantages in return for the high cost. In this case, PACT is somewhat impractical because it would require activated carbon treatment of the entire wastewater flow at the Hamilton wastewater treatment plant. The evaluation of remedial alternatives is independent of the source of remedial funding. Onsite treatment alternatives are favored over PACT. The source of cleanup funds was uncertain at the time of this evaluation; therefore, the Agency could not •Slums that Chem-Dyne would be a generator-financed cleanup. 4. The extent of groundwater contamination has been described in the RI report. The rate of contaminant migration was estimated in the FS. Both the extent and rate of contamination are described sufficiently to evaluate and select remedial actions. The implemented groundwater remedial actions will include monitoring and contingency plans to control and adjust the remedial measures as necessary to maintain proper performance. (Refer to additional discussion on monitoring in the section, •Remedial Contingency Actions" on page 3-17). 5. To minimize the spread of contamination from the extracted groundwater, the groundwater will be treated by air stripping and vapor phase carbon adsorption prior to release. Complete treatment technology selection and sizing will be based on bench or pilot tests on groundwater samples during the final design of the remedial actions. 6. Air stripping is effective for removal of volatile organics only. RI data indicate that volatiles are the predominant organic contaminant category in the extracted water. However, if monitoring of extracted and treated groundwater reveals the need for additional treatment, other treatment technologies will be added to the treatment system to meet discharge goals. If nonvolatile organics such as base/neutral or pesticide compounds occur in the extracted groundwater, an additional treatment technology of activated carbon adsorption, for example, would be added to the system.

3-6 7. Groundwatar contamination attributable to the Chem-Dyne site has not been found in any water supply or production systems presently used for drinking water. Part of the endangerment attributed to groundwater described in the FS is based on the potential use of a contaminated water supply. The scope of the potential contamination problem is discussed in Chapter 2 of the FS. The Hamilton south well field is the focus of concern in Chapter 2 although the Fairfield well field and Cincinnati water supplies could also have been included in the discussions. Alternatives in the FS are selected to mitigate contamination in these water supply sources as well as the Hamilton well field. 8. Estimates of volatile organic contamination offsite are presented in the Final Remedial Investigation Report. These estimates are based on groundwater sampling from several offsite monitoring wells. The "contradictions" mentioned by the comment must be better described before responses can be offered. 9. Most groundwater contaminants identified in the remedial investigation are volatile organic compounds. These types of compounds can be removed by either air stripping, granular activated carbon, or both. PACT would involve the POTW and would be very expensive and somewhat impractical because it would require treatment of all incoming sewage at the Hamilton wastewater treatment plant. Onsite treatment was favored over PACT. 10. Yes, the wells for groundwater extraction are arranged to intercept groundwater beyond the outer perimeter of the plume. 11. Other production wells were considered in the endangerment assessment to evaluate the potential for production well contamination. For the extraction wells, the effects of other production wells was considered through the use of the measured local groundwater gradients which included the affects of all local production wells. Future local well expansion could be accommodated by increasing extraction pumpage. 12. Groundwater movement can be controlled to a great extent: locally by extraction wells properly placed and operated. These walls create a groundwater "valley" or barrier which controls the escape of the contamination plume as it migrates along the natural direction of groundwater flow. The comment on money and cleanup is exaggerated, of course, but it emphasizes the valid point that groundwater remediation is expansive and costs increase dra- matically as the level of cleanup increases.

3-7 FORD CAHAL Public comments: 1. Public consumption of fish from the Ford Canal must be considered a serious health problem. Steps should be taken to restrict access and educate people to dangers of fish contamination in the Ford Canal and Great Miami River (public meeting). 2. PCB contamination in fish samples from the Ford Canal should be considered related to site contamination (public meeting). It is illogical to proclaim that the PCB's contaminating the fish (in the canal) could in no way be attributable to Chem-Dyne; which is the Agency's contention for not addressing the matter through Superfnnd (BAPSO). 3. Mercury contamination of Ford Canal sediment and possibly fish is a serious public health concern (public meeting). 4. Fish kill incidents were directly attributed to the Chem-Dyne PCB contaminants (public meeting). Agency responses t 1. Public consumption of fish from the Ford Canal is a concern in terms of public health. Based on the recommendation of the Agency's project officer in 1983, the Ohio Department of Health (ODE) issued a fishing advisory for the Ford Canal near Chem-Dyne. This advisory is presently in effect. The ODE is also considering additional studies of the canal and Great Miami River. 2. PCB's were identified in similar concentrations in fish upstream of the hydroelectric dam in the canal and in fish from the Great Miami River upstream of the river dam near the canal outlet northwest of the site. There- fore, while PCB's in downstream canal fish could be from the site, "background" concentrations in fish from the area preclude making the clear link to the site. Because PCB concentrations in the downstream fish from the Ford Canal are similar to concentrations in canal fish upstream and concentrations reported in fish tissues from upstream reaches of the Great Miami River, PCB releases from the site cannot be conclusively identified as the cause of PCB contamination in the downstream canal fish. Further, PCB's were not identified in either the storm sewer water sample or downstream canal sediment. Without the clear link of fish

3-8 contamination to the site, CERCLA action is not possible. Other actions such as the health advisory issued through the Ohio Department of Health are indicated and have been implemented. ' 3. Mercury was not identified in high concentrations in downstream canal sediment samples. Mercury compounds were reportedly included in Chem-Dyne wastes and mercury was identified in two downstream sediment samples. However, mercury was also identified in similar concentrations (0.31 to 0.55 mg/kg) in three out of four upstream sediment samples. Mercury concentrations in extracted groundwater will be monitored to mitigate the possibility of mercury discharge into the canal from extracted groundwater. 4. The fish kills related to Chem-Dyne were reportedly caused by release of concentrated pesticides and pesticide wastes, particularly endrin which is exceptionally toxic to freshwater fish. PCB's were not identified as having caused the fish kills. ONSITE UTILITIES Public comments: 1. All onsite buildings should be demolished and eliminated. Existing buildings are attractive to children and extremely hazardous (public meeting). 2. Onsite building demolition should not be excluded from remedial action consideration because of cost (public meeting). 3. Because steam cleaning is superficial and temporary at best, it is unacceptable as a remedial action for the structures (HAPSO). 4. The site calls for more investigation into sources of contamination, extent of contamination, and locations of underground facilities before any further action is taken dealing with underground structures. (Jocelyn Hamm) Agency responses: 1. Demolition and disposal of all onsite buildings was one of the alternatives considered in the feasibility study. Comment on the "attractive" nature of the buildings is noted. The attractive hazard quality of these buildings was considered in the feasibility study. The remedial action selected for Chem-Dyne includes demolition of all onsite buildings. Building rubble will be disposed of both on and offsite as appropriate.

3-9 2. The cost of building demolition was one of the evaluation factors. Other factors included public acceptance, technical feasibility, and benefits to public health. Cost along was not used to make the selection of remedial actions on the buildings. 3. Steam cleaning, as considered in the FS as an alternative remedial action, would have been performed with monitoring and sampling to check the thoroughness of the decontamination process. Steam cleaning is generally effective only for nonporons materials such as metal; porous materials like wood and masonry tend to soak up chemical contaminants and steam decontamination cannot effectively remove the penetrated material. Where properly employed, steam cleaning can be an effective and permanent remedial action which is why it is carried forward in the PS as an alternative remedial action. Its applicability is limited and it only addresses chemical contaminants, not the "attractive nuisance" problems. Complete demolition of buildings has been selected for the remedial action plan; therefore, decontamination will not be necessary. 4. Extensive information on specific sources, extent, and locations of contamination and buried utilities is not necessary to implement a remedial action or set of actions which controls releases from buried utilities. The site cap will control infiltration and a deep perimeter cutoff trench with utility sealing by grout will control lateral migration. Ramadial actions which address buried utilities, site cap, and perimeter trench with grout seals, can be evaluated without detailed information regarding buried utilities. REMEDIAL ACTIONS — PUBLIC RECOMMENDATIONS Several comments expressed opinions about which specific remedial actions should be selected for the Chem-Dyne site. Tfcese comments and responses are presented below. son. Some comments expressed the opinion that all contaminated soil should be removed from the Chem-Dyne site. Complete removal of contaminated soil was recommended by commentators for a variety of reasons. The reasons for complete contaminated soil removal have been compiled and paraphrased below. The responses are presented following the comments. Those commenting on soil remedial recommendations include the following: Hamilton City Manager, Department of Health, City Planning Commission, City Council (by Resolution No. R84-12-69), Gilbert Insurance Agency, Parrish and Haid

3-10 Insurance, Conastoga-Rovers and Associates Limited, and several private citizens. Public Comments: 1. As long as contaminated soil remains at the site, there will be percolation of toxic materials into the aquifer and doubts regarding damage to the aquifer and continued health risks will persist in the minds of all citizens. (J.P. Becker and others) 2. Capping is not a long-term, fool-proof remediation method to protect the aquifer. Capping is considered a short- term and unsafe method of protection. (William J. Karwisch and others) 3. The most heavily contaminated soil should be removed from the site (public meeting). 4. Site cap should be loam over clay with revegetation (public meeting). 5. There is no technical justification for extensive excavation of soils from the Chem-Dyne site. A surface cap will accomplish the same objectives without the problems that are associated with offsite disposal. (Conastoga-Rovers and Associates Limited) 6. Removal of contaminated soil will cause dust and odors to be released. Recommend a concrete cap with minimum disturbance of soil onsite. (Mary Estep) 7. Instead of removing soil and capping with clay, pour blacktop or concrete over the site to make tennis courts or a parking lot. The concrete or asphalt would prevent any rain from washing any contaminants down in the gravel aquifer and shorten or eliminate the 27 years expected for natural migration to occur. (Timothy G. Korver) Agency responses: 1. Soil contamination consists of inorganic and organic materials. Inorganic elements were primarily associated with the upper 5 feet of soil. Organic materials include a wide range of compounds with a wide range of behavior in soil. Some of the organic compounds, including pesticides and other high molecular weight compounds, tend to move very slowly in soil and these are found in near surface soils. Other organic contaminants, particularly chlorinated solvents, move more rapidly through soil and these compounds are found from the soil surface down to groundwater about 25 feet deep.

3-11 To remove all contaminated soil, practically all site soil would be excavated to an approximate depth of 25 feet. Because of the large volume and deep pene- tration of contaminated soil, an alternative to complete soil removal was evaluated. The alternative had to address two problems caused by contaminated soil: direct physical contact and groundwater contamination by leachate. Site capping is a technically workable and demonstrated remedial action for soil contamination as found at Chem- Dyne. Such caps are planned and engineered systems with finished thicknesses of about 4 to 5 feet. Site caps greatly retard infiltration and conduct rainfall/ snowmelt runoff away from the site. Caps do require regular maintenance and periodic replacement (assumed in the PS to be every 30 years at a minimum). The capping monitoring program selected for the site includes cap monitoring and periodic synthetic liner testing to determine cap condition and the possible need for replacement. In iiimmiiif. capping is considered a practical long-term remedial action that does provide reasonable protection of the aquifer. A final consideration for the site capping alternative is that Chem-Dyne will have a groundwater monitoring and extraction well system in place. The performance of the cap system will be monitored through the quality of groundwater moving below the site. Concerns regarding damage to the aquifer and associated potential health risks will be addressed with data from the groundwater monitoring system. soil removal, limited to areas of high chemical contamination, will be done at the site to give some extra margin of protection against chemical waste migration. The feasibility study evaluation concluded that no reasonable amount of soil removal could alone completely remedy soil contamination at the site. Therefore, the site requires a high qualityr low permeability cap to reduce both the possibility of physical soil contact and infiltration of rain through the contaminated soil. The soil contamination remedy is the sit* cap while soil removal is considered an extra step. The loam over clay cap system was one of the two cap systems considered in the feasible study as alternatives which meet the remediation goals for soil. The cap selected in the remedial plan is composed of loam over membrane over clay. This cap was chosen to comply with RC8A criteria and to more effectively reduce infiltration. The surface will also be revegetated to control erosion.

3-12 5. Technical justification for extensive soil removal and surface cap was presented in the FS. Some limited "hot spot" soil removal was considered as an extra measure of protection to be included with1the cap. 6. Dust generation has been recognized as one of the draw- backs or problems associated with soil excavation. During any soil excavation at the site, specific dust control procedures will be required of the contractors. A concrete cap is not a favored cap material because concrete requires frequent maintenance to repair cracks and settlement damage. 7. Capping with concrete or asphalt is a possible capping method, but both methods require careful maintenance to minimize leakage. Site reuse as a tennis facility or parking lot was considered in the final selection of cap method. Site reuse was judged impractical and would interfere with maintenance of the cap. Remedial actions will maintain access to onsite wells/ water treatment, and the hydroelectric facility. GROUNDWATER Several comments were that contaminated groundwater should be extracted and treated to remove chemical contaminants prior to discharge. Comments regarding additional monitoring of the groundwater contamination plume and treatment system were addressed in the previous section, Feasibility Study Technical Analysis, under the groundwater portion. Public comments: 1. Extract and treat the groundwater until there is no trace of pollution remaining. (Pamela E. Anderson and others) 2. Time problems, permit problems, construction problems all relate to deep well injection. Why contaminate a 3,000 foot deep zone we know practically nothing about? (Timothy 6. Korver) 3. Based on my experience, I offer recommendations on extraction well location, design, screen, and drilling method. (Timothy G. Korver) Agency response*: 1. Groundwater extraction was predicted to reduce concentrations of volatile organic contaminants to low concentrations. However, it is likely that detectable

3-13 concentrations of some contaminants would remain even after several years of groundwater extraction. Very low concentrations may remain in the groundwater if it becomes impractical to continue extracting and if public health and welfare are adequately protected. Similarly, detectable concentrations of contaminants may remain in the treated groundwater prior to discharge from the treatment system if public health and welfare are adequately protected. The selected alternative to be implemented under the forms of the Consent Decree requires the groundwater to be extracted until the level of contaminants can be reduced no further. 2. These problems related to deep well injection were recognized in the feasibility study and considered in deep well evaluation. Deep well injection was not selected for the final remedial action plan. 3. The well design and placement recommendations are well received and will be referenced in the design of the extraction well system. (Refer to the complete contents of Korver's letter in Appendix D of the Responsiveness

FORD CABAL Three specific comments were received on remedial action recommendations for the Ford Canal. One comment expressed general disagreement with the FS. Public comments: 1. The •no-action" plan for the Ford Canal sediment is unacceptable to the community (BAPSO). 2. The canal has been written off as not being a threat to biotic or antibiotic ecosystems. The canal is a threat to these systems and it could be an avenue to human exposures. (Jocelyn Hamm) 3. There are also hotspots in the Ford Canal particularly next to the Ford Park area. The City is presently filling in this area, and if action is not taken immediately to determine the extent of contamination, we will have a successful coverup. (Jocelyn Hamm) Agency responses: 1. On the basis of the RI data and the endangerment assessment, no remedial action is warranted for the Ford Canal under the provisions of CERCLA. Sediment removal from the canal would be expected to redistribute any contamination in the sediments over a wider area in the canal

3-14 and Great Miami River. Because existing storm sewers may be continuing to drain organic priority pollutants into the canal, the selected remedial plan incorporates cutoff and sealing storm sewers to prevent future discharges to the canal. 2. Based on results of the canal sediment and water analysis, as well as fish tissues, remedial actions do not appear to be warranted in the Ford Canal. The remedial investigation indicated that the storm sewers may be draining low concentrations of priority pollutant organics into the canal. Therefore, the selected remedial plan includes provisions for sewer cutoff and sealing to prevent future discharge of contamination to the canal. 3. The Ford Park area is understood to mean the ballpark and swimming pool facility immediately east of the Chem- Dyne site. The Agency has no information to suggest that there is chemical waste contamination in this portion of the Ford Canal. If any new observations or information are available, these data should be submitted to the U.S. EPA Region V and the Ohio EPA as soon as possible. Based on the present information regarding Chem-Dyne, the following responses are offered. The Ford Park area is upstream of the site and upstream of the hydroelectric dam in the canal north of the old Ford factory. It is very unlikely that runoff from the Chem-Dyne site could have affected the canal near Ford Park. Unless Chem-Dyne wastes were deposited in the area mentioned, the source of the su-- pected contamination cannot be reasonably related to Chem- Dyne. Again, if additional information can be presented, an inquiry into this area of the canal may be warranted. ONSITB UTILITIES Several comments expressed the recommendation that the Chem- Dyne building should be removed from the site because it is an attractive hazard, it is chemically contaminated, and it is partially damaged (by fire) already. Some comments called for the removal of all contaminated buildings (including the Chem-Dyne building). Finally, some comments simply recommended the removal of all buildings onsite. One comment suggested that the buildings could be buried onsite. Public comment: 1. If the buildings were turned into rubble, they could be buried in or under the pavement. (Timothy G. Korver)

3-15 Agency response: Demolition of the Cbem-Dyne and other onsite buildings was one of the remedial alternatives carried forward in the FS. The chemical contamination of the Chem-Dyne building was recognized as well as the possible contamination of several other buildings. The attractive hazard nature of these dilapidated structures was also recognized and was considered in the selection of a final remedial action which is the demolition and disposal of all onsite buildings. 1. Burial of some selected building demolition debris is a component of the selected remedial action plan in conjunction with a high quality, low permsability site cap. SCHEDULE FOR REMEDIAL ACTION IMPLEMENTATION Public comment: 1. Time is of the essence for remedial actions at the site. Remedial work should begin as soon as possible (public meeting). 2. The City of Hamilton requests that the U.S. EPA proceed with all possible haste to correct the three critical environmental problems (contaminated soil, groundwater, and site buildings) in order that further contamination of the aquifer can be minimized (City Council Resolution R84-12-69). Agency responsest 1. The Agency has procdeded through the analysis and decision process with deliberate speed so that remedial actions for the Chem-Dyne site can be implemented as soon as possible. Negotiations with settling defendants have been conducted with emphasis on timely settlement to hasten the implementation of effective remedial actions. 2. The Agency recognizes that one of the primary reasons for timely remedial action is to minimize further contamination of the aquifer. In this regard, some contaminated soil has been removed from the site and building demolition is expected to occur this year. SITE RISKS — CURRENT AND FUTURE Public comments: 1. The public must be informed of the health risk caused by the site now and in the future. As the groundwater

3-16 plume moves, any new or different level of risk should be made public (public meeting). The Hamilton residents have a right to know the health and environmental risks they are facing. It is the U.S. EPA1s responsibilitv to provide that information (Mary B. Loeffler). 2. The Agency should more fully inform the public as to what toxic materials are present and the hazards that the known substances present to the health of the citizens (Izaak Walton League). Agency responses: 1. The present public health risk is described in the FS, Chapter 2, Endangerment Assessment. As remedial actions are implemented and frequent routine monitoring begins, regular releases of data will be available to the public from the Agency. If risks to public health arise at any time, the Agency will notify the public. 2. The endangerment assessment in Chapter 2 of the FS addresses the toxicity and hazards of the known substances at the Chem-Oyne site. More detailed listings of the chemicals identified at the site in various samples are presented in the Final Remedial Investiga- tion Report issued in May 1984. REMEDIAL CONTINGENCY ACTIONS Several comments addressed the need for monitoring and contingency actions during remedial work. These comments have been combined and paraphrased below. Public comments: 1. The Agency should continuously sample and monitor during the remedial action implementation to check performance. (Public meeting) 2. If the remedial performance fails, the Agency should correct the situation to safeguard public from unneces- sary risk. (Public meeting) 3. Monitoring data should be made public in a timely and open manner. (Public meeting) Agency responses: 1. Frequent regular monitoring of the site during remedial implementation is part of the selected remedial actions.

3-17 Monitoring incorporated in the remedial plan includes the following: a. Sampling in a manner and at a frequency required by the HPDBS permit which allows the discharge of treated groundwater to the Ford Canal. b. Testing air emissions from the air stripper according to requirements of the permit to install and permit to operate the system. c. Sampling groundwater prior to startup of remedial extraction, during groundwater extraction, and for 5 years after termination of the operation to assess performance of the system, compliance with remedial goals, and the possible need for corrective actions to improve performance. d. Measurement of water levels in all monitoring wells and new piezometers (wells designed for water level measurement only) on a semimonthly and, later, monthly schedule during groundwater extraction to monitor the hydraulic gradients generated by groundwater extraction. e. Programs of sampling and analysis to support the safety plan for onsite workers. f. Air measurement and analysis programs to evaluate the effects of remedial activities on the neighboring I'ommnni \y and provide for public safety. g. Programs for assessing performance of the site cap including the synthetic liner material. 2. Linked to the monitoring program, all remedial actions have contingency plans for adjustment of the remedial actions to account for changes in performance. 3. All site monitoring data will be made public by the Agency on a regular basis. COST VKBSUS REMEDIAL ACTIOH SELECTIOHS

Public comments: 1. The financial limits of the remedial fund should not limit the remedy selected (public meeting). 2. Whatever is decided for remedial actions at Chem-Dyne, the decision must be based on health and environmental factors, not saving money. (Mary Loeffler)

3-18 Do not be limited in your imagination or by the amount of funds - especially do not be limited to funds collected from third parties. (Richard Haird) Agency responses: 1. The cost of any remedial action is one of the criteria in every evaluation at every site including Chem-Dyne. However, cost is secondary to the goal of protection of human health, welfare, and the environment. Within the range of remedial alternatives which protect human health, welfare and the environment, cost is evaluated as one of the selection and judgment criteria. 2. The remedial actions to be implemented at the Chem-Dyne site have been selected with the primary goal of protection of human health and the environment. Several approaches or remedial alternatives considered in the FS fulfilled this primary goal. Cost was one of the considerations used to select among the different, yet acceptable, remedial approaches. PS COMMENT PERIOD Public comment: 1. The time allowed for public comment on the FS report was very short, from the time the document was available during the week of November 19 until the end of Friday, December 14, 1984 (public meeting). Response: 1. Since the time of the public meeting and this comment, the comment period was extended through Friday, Decem- ber 28, 1984. GLT267/52

3-19 Appendix A OXFORD AUDUBON SOCIETY AND HAPSO COMMENTS AND RESPONSES ON CHEM-DYNE FINAL RI REPORT

GLT267/53-1 Oxford Audubon Society Conservation Committee September 28, 1984

Don Bruce U.S. Environmental Protection Agency Region V Remedial Response Branch 230 South Dearborn Street Chicago, IL 60604

Dear Don, The nation has slowly become aware that environmental crises do not always belong to someone else, someplace else. In our individual communities we are being forced to recognize the unpleasant facts that environmental crises belong to each of us. This realization has been particularly severe and unsettling to the residents of southwestern Ohio as we have faced the complexities and enormity of the environmental insult represented by the Cham-Dyne facility in Hamilton, Ohio. As citizens concerned with environmental quality we have been closely following the SPA's study of the Chen-Dyne Site. Seeking to understand the issues, we reviewed the EPA's findings that were presented in the Final Remedial Investigation Report. In doing so, we hoped to stimulate reasoned debate and voice our concerns over some shortcomings which we have detected, while we emphasize that we are not experts in cleaning and restoring toxic waste dump sites, we point out that our efforts entailed many hours of careful, detailed work. While not experts, the points we raise require no specialised knowledge beyond a good grasp of scientific principles and practices. We divided the subject area, and will subsequently present our results, in the following fashions On-Site Structures; Soil; Groundvateri and the Pord Canal.

A major shortcoming of the investigation was inadequate analyses of areas of documented or suspected contamination. Adequate documentation of contamination is essential to provide sufficient information upon which to organize and successfully execute an effective cleanup. As an example, the report mentions the existence of two partially buried tanks which were used for the storage of liquid wastes. No information pertaining to their contents or the integrity of their sub-surface portions is presented. Further, the OBPA suspects the existence of more buried tanks just east of the Ford Factory Building but their presence has yet to be confirmed or denied. Surely, this would constitute critical missing information. The report documents that, upon inspection, the Boiler Building was found to have an electrical conduit penetrating the south wall; this conduit was draining contaminated fluids onto the floor, mo steps were taken to locate the source of the contaminants which remains unknown. To our knowledge, the remedial investigation has not conducted tests to determine the extent and/or existence of contamination of other onsite utility piping; piping which was identified by the report as a possible avenue for the spread of contaminantsI An investigation into the possible contamination of the Ford Factory Building was never mounted. The apparent reason for this omission, aside from the fact that the building was not "visually contaminated", was that no knowledge of the storage of 'significant amounts of Chem-dyne waste* exists. Certainly when we are dealing with the potent carcinogens that have been found on the site, there is no need for a large quantity of material to be present before it is "significant". Prudence dictates that no onsite facility should be dismissed from investigation on such grounds, particularly with the haphazard state of record keeping that prevailed at Chem-Dyne during its active phase. Similarly, no samples were taken from the Garage, which was known to "have been used for waste storage" and whose "floor was visibly contaminated". The detection of six known carcinogens in the single sample taken from the storm sewer main raises vital and urgent questions concerning their origins and the dynamics of the entire storm sewer system. These questions were not addressed in the report. It is apparent from these brief comments that additional investigation of en-site structures and utility hardware is justified in order to establish an adequate data base. At the moment it is difficult to understand bow statements can be made with confidence concerning the extent of contamination and route of contamination flow.

The soil investigation section of the Final Remedial Investigation Report raises several questions regarding soil sampling protocols and associated •assumptions* of contaminant behavior. Many assumptions which have been made require a more detailed explanation before they can be accepted. For example, the word significant is used rather loosely to define the amount of flooding necessary for surface runoff to carry contaminated soil from the site. Significant, in this non-statistical usage is unacceptably subjective. What *CR the conditions that can be defined as 'significant* for runoff to occur? Additionally, to assume that "current site topography* ux not allow for the movement of contaminated runoff to areas offsite is naive and, if mistaken, very unfortunate. Such statements are unacceptable without substantiated facts. Of course the problem arises of how substantiated facts are obtained when less than mimimal numbers of offsite soil samples were taken? Further doubts are raised concerning the accuracy of the soil study when the evaluation of inorganic contamination offsite is considered. "Background" samples that were taken offsite present validity problems, two were heavily contaminated and could not be used for background. The remaining two offsite samples listed as having come from an "unaffected" area also revealed contamination, albeit to a lesser degree. The fact that contaminated samples OS-3 and OS-4 were taken offsite, in close proximity to the waste site, indicates that runoff did occur despite site topography. Finally, we object to the term "unaffected area". The area was manifestly affectedl Considering the history and extent of contamination to date it would appear that only the tip of the iceberg has been found during this remedial study. This should come as no surprise since the sampling scheme was not statistically sound. The number of soil samples taken both outside and inside are insufficient to accurately estimate contamination. Estimating the extent of contamination offsite requires more samples than were taken and background should really be chosen as such. It would now seem desirable to further investigate the soil contamination problem using proper statistical analysis. A sampling protocol indicating the type of sampling being done (i.e., stratified, etc.) must be based on stastistical sampling strategy. Such a strategy was not mentioned in the report, yet there was continual use of the statistically loaded term "significant." We would urge you to reconsider the accuracy of the study especially for offsite areas and in all directions (concentric to the site). Residential neighborhoods mast be included. Sample size offsite was too low to allow for statistical evaluation, the same may also apply to other areas sampled. After evaluating the soil investigation data presented, it is clear that more data gathering is necessary before statements about contaminated areas can be made. Throughout the report not enough attention is given to the real problem presented by the toxic contaminants found in the soil. There has been no satisfactory explanation about the toxicity of the materials detected both in and out of the facility. An explanation along these lines is necessary so that those not having knowledge of the chemicals can evaluate findings. Finally, one of the many inaccurate statements that is salient in the soil investigation report appears on page 3-12. To say that phenol is not particularly toxic is both wrong and misleading. Grotindwafc»f/Ford Canal The Technical Memorandum of Dec. 20, 1983 (Vol. 2A of 2) provides an historical survey of the Chem-Dyne site. In 1917, the Miami Conservancy District leased the site to the Hamilton and Rossville Hydraulic company, which operated at least two canals and a reservoir on the site. In 1919, the west canal and reservoir were filled in. Using the Figures in the technical memoranda, this west canal can be seen to occupy the western border of the present Chem-Oyne site. Similarly, the reservoir occupies the south to southeastern border. Presumably, surface waters, such as represented by the canals and reservoir, could only be maintained over a porous aquifer if they were underlain by an impervious clay barrier. In describing the subsurface soil characterization, the Site Geology Section in the Summary Report presents evidence that the canal and reservoir can yet be distinguished. The review of onsite large-container bulk waste storage indicates that Tanks 1 through 7, and 13 may have been situated atop the west canal. These bulk tanks contained the largest concentrations of chlorinated pesticides and aromatic hydrocarbons. Coincidentally, there is a pattern of •»»•«•<»« surface soil contamination in this former canal area. We have been able to extract the following information from Figures 6 thru 12 (Vol.lj pp. 3-27 thru 3-54)s SOIL COBTAMTBATIOB ABOVE THE WEST CABAL Approximate Distance from Inorganic Organic BW corner of Contaminants Contaminants Cham-Dyne * + f base (ug/kg) * (ft) Cn Cd Cr neutral V.O.C.

68-1 0 445 7.0 61 00 88-9 100 597 10.3 93 185,000 -110 68-2 200 306 10.4 1100 32,890 133 S8-8 250 660 7508 286 393,000 6300 B-20 300 587 3.3 8.7 33,300 1000 B-10 375 109 4.6 11.9 600 8300 88-10 375 372 13.1 189 227,000 4600

* - total concentration of Co, Be, Pb, za (mg/kg); + * total ^ concentration of Cd, Be, 8b, Se, Tl, Bg, Sn, Ag, Cn; t - total concentration of Cr, Co, Bi, B, V, As. * * volatile organic compounds

In addition, one soil sample at BW-11 (B-12) approximately 1200 feet from the northwest corner of the Chem-Dyne site along the former west carnal indicates accumulation of toxic contaminants in the subsurface soil (12-13 feet deep, in the vicinity of the clayey silt/ silty clay leas which could represent the bed of the former canal. Any remedial action on gronndwater/soil contamination must incorporate the distinct possibility that Chem-Dyne toxicants have percolated through the soil to be temporarily sequestered in the old canal and reservoir beds. Episodes of heavy rainfall may leach additional surface contaminants, and there may be a directed flow in the canal/reservoir beds. Since these old beds extended offsite into the present residential community, a future offsite contamination investigation should focus upon the former hydraulic works as. routes of contaminant transport via a multiple date sampling' analyses of mobile toxicants over a significant portion of the beds. The major trend of groundwater monitoring to date indicates south-southwest migration of low molecular weight volatile organics. However, only one well is more than 400 feet to the south of the site and only a single well is more than 400 feet to the southwest of the site. This occurs despite statements from this FIT report indicating probahi* contamination 650 feet offsite. The wells for the city of Hamilton, located south of the site, are the major human concern. More detailed and frequent resolution of the migration pattern are essential as noted in the summary evaluation. The data base for prediction of migration is based upon wells drilled 30-60 feet. However, the report indicates contamination below at least 65 feet in one of the few deep wells. The Champion pumping wells may be encouraging migration westward deep below the Great Miami River. Surely, any remedial action must include rapid ,,,d expansion of the monitoring well network for mobile chemicals not ^ only in a broader south-southwest surface area, but also in the depth profile. Limited groundwater sampling seems to indicate a generally greater rate of groundwater movement to the west of the site as the Great Miami River is approached. It would seem reasonable and prudent therefore, that instead of deriving a migration profile based upon the range of all measured values, rates of transport for toxic materials from Chen-Dyne should be calculated on a sector by sector basis incorporating hydrogeological parameters characteristic of those sectors. The lack of a coherent pattern of material migration in groundwater is made obvious by examination of the tables in Appendix B, Volume 2A of 2. For example, 1,1,2-trichloroethane at MW-15 sampled by CH2M varied from 12,000 ug/1 during April 1983 to ||| 3,400 in July to 29,000 in October. Acetone, on the October 1983 sampling date (CH2N), varied on an east west gradient from 49,000 ug/1 at the MW-15 site (approx. 100 feet west of Chem-Dyne); to 540 ug/1 at MW-18 (approx. 500 ft west of Chem-Dyne)j to 4900 ug/1 at MW-19 (approx. 1200 feet west of Chem-Dyne). what level of confidence can be attributed to the values reported as representative of that site? Logic suggests that the sampling regimen may have overlooked episodes when toxicant concentrations were conceivably several orders of magnitude greater than those reported. Similar criticisms can be leveled at the cursory dismissal of the Chem-Dyne site as responsible for contamination of the Ford Canal Area. Can the limited temporal and geographic sampling assure us that there has not been, nor will be, significant contamination of this aquatic system? Sampling of the fish species was haphazard and difficult to interpret biologically. Different species were sampled at up and downstream sites, and varied as to trophic levels (herbivores compared to carnivores). Apparently, tba fiab that wara sampled wara not aged ao we hava no idea how long thay had baan exposed to tha watara of tha pord Canal. Conaidaring tba limited naefnllneaa of tha data obtained from the fish studies and conaidaring the known abilities of various long-lived toxina to migrate, both biotically and abiotically, wa believe that it ia premature and irresponsible to dismiss any effects of toxina entering the Pord Canal from tha Cham-Dyne aita aa inconsequential. In summation, wa hava addraaaad a variety of concerns. We faal that it ia imperative that remedial decisions ba baaed upon aolid information in order to insure that a aacond "final* round of remedial daciaiona naad not ba made. There ia little doubt that conducting a atody of this kind requires a Major effort, wa are grateful that it baa baan attempted. There are, however, aariona queationa that reaain unanswered and naada that remain unfulfilled. We trust that tha work will ba completed with these qaaationa and concarna being addreaaad in a thorough and timely fashion. We aak that yon respond to the qaaationa that wa hava raiaed in addressing the next phase of the Cbemdyne aita cleanup.

Sincerely,

Andy Garcia-aivera John Lahorra 713 Sooth Locust 10 Papparwood Oxford, OB 45056 Papper Pike, OH 44124 513-523-5576 216-831-4043

_ *oja 115 B. Oniveraity Avenue 733 B Daniel Drive Oxford, OB 45056 Oxford, OB 45056 513-523-4525 513-523-5987

6 David Reeae Paul B. Woods 716 Sooth College 219 Worth Bin Apt §42 Oxford, OH 45056 Oxford Sqoara Apai Oxford, OB 45056 513-523-7210 cc) Ohio EPA City of Hamilton HAPSO HAMILTON APPALACHIAN PEOPLE'S SERVICE ORGANIZATION 522 BUTLER STREET • HAMILTON, OHIO 45011 (513) 868-O95O

September 13, 1984 Mr. Don Bruce U.S. EPA, Region V 230 South Dearborn Street Chicago, Illinois 60604 Dear Mr. Bruce, It was good talking to you again last week. I was pleased to learn that the feasibility study is moving along so well. I will be looking forward to receiving a copy of the document in the near future and to receiving notice of the next public meeting date. As I mentioned during our phone conversation, I would like to direct a few com* ments and questions to your office. *1. In volume 2A of 2 of the Remedial Investigation Report you have Included a historical map of the site (Figure 3). As we discussed earlier, our con- sultants at Miami University stated that this map pointed out a number of possibilities for natural conduits which would affect groundwater flow be* neath the site. Thus, given the proper attention, the map may indicate areas where additional testing for soil and groundwater contamination should occur. Futhermore, this map may lend support to the possibility of local fish contamination having Chem-Dyne as its point of origin. 2. In regard to the PCB contamination of the fish, am I correct in my understanding that the U.S. EPA will not address this problem unless it is found to be directly attributable to the Chem-Dyne site? If this is in fact the case, will you be submitting a recommendation for another party to investigate this matter futher? 3. In the* feasibility study, will you be addressing the issue of future monitoring—both on-and-off-site? That is, will the U.S. EPA periodically check on the effectiveness and efficiency of the below-surface cleanup plan it im- plements? Also, if another pocket of contamination is found at a later date (post-cleanup) which was caused by Chem-Dyne and was not addressed in the feasibility study, will the U.S. EPA cleanup such an area as well(at that due to the nature of its origin*?

A United Way Agency Ihank you for your tlae, attention and concern. I will be looking forward to hearing froai you soon. . Sincerely, . til ^Skvwk ^x^>-"" Judy A. Gllleas ^•"""^ Executive Director

*P.S.—In regard to lte» ouaber one* you amy contact Or. Poje' at #(513)529-3624 or at * (313)529-3451 to leave a •Maage If you would like additional Information on or the rationale behind die University staff's findings in this Batter. DEC 12 1984

December 11. 1984 Ms. Judy A. 6111ens Executive Director Hamilton Appalachian People's Service Organization 522 Butler Street Hamilton, Ohio 45011 Oxford Audubon Society Conservation Committee <_ji 733 8 Daniel Drive ^ Oxford. Ohio 45056 Dear Ms. Gil lens, HP. Poje, et. al: The following 1s the agency's response to a number of comments and concerns raised by the Hamilton Appalachian People's Service Organization (HAPSO) and the Oxford Audubon Society regarding the Remedial Investigation conducted at the Chen-Dyne site by U.S. EPA. These comments are being addressed separately from the additional comments received on the Feasibility Study. The original comments are enclosed and the response Is as follows: September 13, 1984; HAPSO comments:

1. The historical map of the site has been reviewed and 1s discussed ^^ further under the Oxford Audubon Society responses. 2. Contamination of fish In the Ford Canal with PCB's was found during the Remedial Investigation both above and below the hydroelectric dam on the canal. With the data available, attributing contamination directly to conditions at the site 1s not possible because both upstream and downstream fish had similar PCS concentrations. Furthermore, the concentrations ware similar to PCS results reported for fish (carp) 1n the Great Miami River several miles upstream from the discharge of the Ford Canal. I have already sutwitted a recommendation for another party to Investigate this matter further. Upon my recommendation in 1983, the Ohio Department of Health Issued a fishing advisory for the Ford Hydraulic Canal near Chem-Oyne, and that advisory 1s still In effect. The Department of Health Is also considering further studies to be conducted in the canal and the Great Miami River. 3. Future monitoring of the performance of the proposed remedial cleanup alternatives Is an essential part of the feasibility study recommendations. The remedial alternative selected for the Chem-Oyne site will Include long term monitoring and contingency provisions to extend be- September 2S. 1984; Obcford Audubon Society Comments;

OJISTTE STRUCTURES Page 1. Paragraph 1 Tht two partially burled open-top tanks were sampled In previous Investi- gations before the RI study. Based on these data, removal of the liquids and sludges during the 1983 surface cleanup was performed. Integrity of the tanks Is unknown but assumed to be poor. The suspicion of burled tanks east of the Ford Building was addressed by Inspection. The burled tank Is apparently an abandoned fuel oil tank which Is evidenced by typical fill and vent pipes above ground. As part of the remedial actions evaluated In the FS, removal or sealing of these tanks was considered. Final remedial actions should Include some *tans of revving these tanks.

Page 2. Paragraph 1 No additional work was done to track the specific source of the conduit contamination because such an effort would not have aided 1n determining the need or fora of a remedial action. Further, the RI did not Include tests to determine the occurrence and extent of utility contaarination. Based on the conduit observation and stor* sewer sampling, It was reasonable to assuee that all onslte utility piping and pipe bedding was contaminated. A search and testing program for onslte burled utilities at an old, highly developed Industrial site such as Chen-Dyne could cost more than the remedial actions which Include deep perimeter trenching (to locate and cutoff conduits exiting the site) and grouting both the conduit and surrounding pipe bedding. Page 2. Paragraph 2 The Ford Building was Investigated by an Inspection of all floors Including connecting utility tunnels In October 1983. The Final RI Report concludes a...1t Is reasonable to suspect that waste drums (from Cham-Dyne) may have been stored In the Ford Building". This 1s not a dismissal of possible contamination. It Is not necessary to have analytical data to make reasonable Judgements In the Feas1bl1ty Study on remedial actions for the Chem-Oyne buildings. Strong suspicion of building use (Ford) and visible spillage (garage) 1s sufficient to evaluate decontamination or demolition/disposal as remedial alternatives. Addltonal testing to confirm or refine remedial actions (such as decontamination) was Identified In the Final RI Report on page 3-126. Page 3. Earagrapoh 3 Contaminants 1n the storm sewer sample Included the wastes known to have been stored at Chem-Dyne, particularly In the northwest corner. The origin of these compunds 1s very likely contaminated Infiltration from Imperfectly sealed catch basins and subsurface Infiltration. The solution to storm setter releases Involves eliminating or sealing the existing storn sewer and sealing the sewer bedding materials. The solution does not require study of the dynamics of the entire storm sewer system. (Upstream drainage 1s accommodated 1n the remedial solution of course.) Page 2, Paragraph 3, last sentence The purpose of the RI Is expressed on page 1-1 of the Final RI Report. In short, the RI 1s aimed at determining the need for and extent of remedial actions at the site. The RI data Includes laboratory results and observations such as soil types 1n test pits and soil borings, topography, and signs of chemical spills. Decisions can be made without sampling and chemical analysis of every suspicious area. For example, an extensive study of burled utilities Is not necessary to decide, using storm sewer analysis and conduit observation, that all utilities exiting the site will be cutoff and sealed. A major goal of Superfund Is to control the release of hazardous substances Into the environment from abandoned waste sites. In part, the RI generates Information necessary for evaluation of the alternative control methods. SOIL Page 2. Paragraph 4 Site runoff 1s unlikely because the Chem-Dynt property 1s generally at a lower elevation than surrounding property. Current site topography was determined during the RI by aerial photography (flown November 21, 1983) methods. This "bowl" topography reduces the likelihood of site runoff from accumulated precipitation and Increases the tendency for percolation through the contaminated unsaturated zone. Both runoff and percolation are problems: which are addressed 1n the remedial actions evaluated In the FS. Overflow of the site by the Great Miami River and canal flooding Is also unlikely because of the flood control levees In the area which are designed for a greater than 100 year flood event. The comments on site runoff are well taken. Site drainage Is a critical Issue which Is addressed by remedial actions evaluated In the FS. Page 3, Paragraph 1 Of the "offtlte" soil samples referenced, only two samples, OS-1 and OS-2, were considered "beckground" samples. The other two samples. OS-3 and OS-4 Were taken 1 wed lately south of the warehouse parking lot which had been used by Chem-Dyne to store druos; these saaples were taken to Investigate surface soils which were possibly contaminated by parking lot runoff or direct spills. Samples OS-1 and OS-3 were taken fro* areas In the site vicinity which were not subject to or affected by site runoff or spills. Inorganic results of these samples Is considered to be within the range of Inorganic composition for background soils In the art*. Runoff fro* the warehouse parking lot was recognized as a factor which could have caused contamination of soils south of the lot. The topography map presented In the TH for Subtask 3-6 In Volune 28 of 2 of the Final RI Report shows the parking lot slope. This Is why OS-3 and OS-4 were taken and why the site boundary was drawn to Include a portion of the soil south of the parking lot as well as the lot Itself. Page 3, Paragraph 2 Cooaents on statistical methods applications to soil sampling schemes are well taken. Statistics can be useful for evaluation of soil analysis data. However, the RI sampling and analysis program was constrained by practical limits of laboratory capacity and cost. As the comment on can appreciate, soil sampling at depths to almost 30 feet on a 20 acre site where contaminants can Include almost every priority pollutant (and numerous nonprlorlty compunds) to achieve a high statistical level of confidence would require hundreds of soil saoples. For the purpose of remedial action alternative evaluation, this amount of work Is not necessary. Within the real constraints on sample numbers, the decisions on soil saople location were based on advice from OEPA (based on historical operations), aerial photography from 1976 to 1982, and visual signs of contamination. The sampling was biased toward areas of obvious or strongly suspected contamination. The goal of sampling was not to exhaustively characterize the contamination but to develop enough Information to make reasonable decisions regarding remedial actions. The statistical connotation of the word "significant" was recognized yet the the word was Intended In a nonstatlstlcal context. Therefore, the meaning of "significant* In the context of the report was explained on pages 3-9 and 3-10 of the Final RI Report. Page 3, Paragraph 3 Soil sampling In residential neighborhoods would seem warranted In cases where chemical spills or runoff from the site have possibly contaminated soils. Statements about onslte contaminated areas can be made without statistical evaluation. A goal of onslte sampling was to locate contamination and Identify major contaminants. The onslte data fulfills this goal. Page 3» Paragraph 4 •>. ;*:-• The toxlclty of soil and groundwater contaminants 1s dlsdcussed 1n the FS In Chapter 2, Endangerment Assessment* Commentors are referred to this document where more specific comments may be focused, as appropriate. Commentor'$ reference to "the many Inaccurate statements" Is vague and nonconstructlve. Unless specific references or comments are expressed, no response can be made. Consent on the toxlclty of phenol 1s noted; the report did not Intend to disregard phenol toxlclty. The toxic properties of phenol are well documented 1n the literature. GROUND HATER/FORD CANAL Page 3 last paragraph through page 4 The speculation regarding clay lining of canals and the reservoir 1s In- teresting. The location of the bulk tanks (now removed) was apparently very near where the old north-south canal was located* Remedial actions Implemented at the site will Include measures such as a deep utility cut-off trench which will cut off and seal utilities leading offsite. The utility trench should be designed to Intercept remains of the old canal and cut off a preferred groundwater transport route 1f one exists. Page 5, Paragraph 1 The existing monitoring well system used for the RI was adequate to locate and describe the volatile organic compound plumes at Chen-Dyne* Over three successive RI sampling episodes In 1983, well MW-8 (south), MH-16 (south). MW-17 (southwest), MU-20 (west), MU-3 (northeast), and MW-l (east) yielded groundwater samples without any priority pollutant VOC's. Further, MW-11 (south) and MW-35 (south) samples had very low concentrations of priority pollutant VX's. These results Indicate that the existing VCC plume 1n the upper portion of the aquifer was completely Inside of the monitoring well network 1n 1983. Mora monitoring wells located 1n the area southwest of the site would help refine the exact plum* shape but would not contri- bute new Information useful to evaluation of remedial actions. Page 5, Paragraph 2 Additional deep monitoring wells will be Installed as a part of the groundwater remedial actions. Pema S» Paragraph 3

This cm Mint 1* unclMr. The rate of groundwater movement 1s not calculated or estlaatad based upon groundwater sampling. Hydraulic gradients, which Influence groundwater flow rate and direction, do Increase as the Great Hlaarf *1ver Is approached fro* tht site. (In the ftl, grotndwater flow rates were estimated considering a gradient which approrfiaated the combined Influence of tht changing gradients. Velocity 1o the vlclncfty Rear the Great Wasrt River Is Influenced by the river during periods wnen the river acts to recharge the aquifer.

A sectgr-by-sector contvalnant transport Modeling ttuoy based on the variations of hydrogaoloytcal and geachemlcal properties for each sector would bt a major undertaking, particularly considering tRe complex hydrologlc sett1*w, trfxtore of corfmids, and highly developed erftan enrlronnent. SBC* a study cauld be conducted to optlarize technoloqles stwHed during design of tne gronndwatgr renedlal actions. Page S. Paragraph 4

On the contrary, a conerent pattern 9f VOC contaetnatldn and migration In groenoweter seen* clear. The exeaple cited. 1.^.. 1.1.2-TCA at W-15, agrees with the concentration vs. water table elevation discussed In tiie Final 81 iioport on pages 101*103. Acetone was used to decontanlnate sampling eqolpnent* Because acetone was a possible Meld contaminant. acetone data was not esed to assess grovndwater contaal nation 10 the Final RI fteport. nevlew of the acetone data reveals Inconsistencies as noted. Acetone aside. VQC concentrations appear to be related to groundwater elevations which Is consistent with the hypothesis that, near the site, the frtgnest coBceatratlons of VOC's occvr at the top of the aquifer and decrease rapidly with depth.

S. paragraph 5

It 1s clear that the Chea-Qyne site was historically responsible for con- tanrl nation of the Ford Canal. Store sewer analysis and analysis of the April 1983 sevfnwnt sanple Illustrate the connection of tne site to canal contiHlMtlon. Fish sampling was deliberate and results were presented on the fish species as cawght. Upstream flsn were shad and carp, species which were Included In the downstream set of tissue samples. Shad and carp from the vpstream portion of the canal were selected dell tmrately for comparison with twe downstream species. Agleg ef downstream fish . would not confirm the duration of exposure since there 1s no means of knowing what fraction ef time the Individual fish spent In the portion of the canal Influenced by site discharges. The Final *I Report does not dismiss the effects of contaminants as Inconsequential, lather, the report presents and discusses the data as reported. Finally* we agree that decisions on the evaluation and selection of rwiedlal actions should be based on "solid Information.* During the RI we have developed sufficient Information to sake decisions concerning renedlal actions. Once a remedial alternative 1s selected for the site, additional sampling, analysis and testing could be required during the design phase of remediation 1n order to more well define the conceptual alternative. Sone additional analytical work could be required during laplenentatlon to verify that remedial actions are properly executed. Performance monitoring trill no doubt be conducted during the complete course of remedial actions and oonltorlng will continue after "close-out" of the remedial action to verify that remedial actions have been successful In achieving performance standards set for the site. e that these responses have addressed all of the concerns outlined 1 a your coranents on the Remedial Investigation. If you have any questions, ? Tease feel free to contact me at (312)886-0399. In tn« aea«it1r», w# are looking forward to receiving *ny comments you nay have on the Feasibility Study. Sincerely.

Oonald J. 8 nice . £PA On- Scene Coordinator cc: Joftn Flelssner, CH2H Hl'lT t«cCue, OPA Hannahs, JE?A Appendix B OXFORD AUDUBON SOCIETY COMMENTS AND RESPONSES ON CHEM-DYNE FEASIBILITY STUDY

GLT267/53-2 Oxford Audubon Society Conservation Committee December 12, 1984

Don Bruce U.S. Environmental Protection Agency Region V Remedial Response Branch 230 South Dearborn Street Chicago, IL 60604

Dear Don, We were at once pleased and concerned to read of a probable settlement in the Chem-Dyne cleanup on the first page of the Cincinnati Enquirar last Saturday (12/8/84). Pleased because we, like everyone else, are anxious to see an untenable situation quickly resolved. Concerned because we fear that the rush to a final settlement may employ less-than-acoeptable technologies. We stress that we are, indeed, grateful for all attempts at assessment and related clean-up proposals put forth by the United States Environmental Protection Agency. The intended goal of obtaining a reliable, feasable, and cost effective abatement program to protect public health, welfare and the environment represents a monumental task. However, we also stress that this worthy goal can be achieved only if careful, multifaoeted* scientific analyses of all problem areas are incorporated in the decision making process prior to* and during clean-up activities. In addition* a dialogue with the community at large must be just as vigorously pursued. Chem-Dyne is of more than local environmental significance. As one of the first Superfund sites to undergo complete clean-up* Chem-Dyne will serve as an example for the hundreds of sites to follow. It is imperative that the cleanup at Chem-Dyne serves as an appropriate model of public concern for the health and well-being of its immediate neighbors; individuals who remain more removed in space or time; and the health of the natural environment upon which all individuals depend. We hereby provide our public commentary for the Feasibility Study* and will subsequently present our results, in the following catagories: On-Site Structures; Soil; Oroundwater; and the Ford Canal. * Qtt-STTB STBOCTOBES A major shortcoming of the Remedial Investigation was inadequate analyses'of areas of documented or suspected contamination in on-slte structures. Adequate documentation of contamination is essential to provide sufficient information upon which to organize and successfully execute an effective cleanup. As an example, the report mentions the existence of two partially buried tanks which were used for the storage of liquid wastes. Bo information pertaining to their contents or the integrity of their sub-surface portlona la preeented. Furthert the OEPA soapeota the existence of acre buried tanks Just east of the Ford Factory Building but their presence has yet to be confined or denied. Surely, this would constitute critical missing information. The Bemedlal Investigation report documents that, upon Inspection* the Boiler Building was found to have an electrical conduit penetrating the aouth wall; this conduit was draining contaminated fluids onto the floor, to steps were taken to locate the source of the contaminants which remilnn unknown. To our knowledge* the remedial inveatlgatioa baa not conducted tests to determine the extent and/or existence of contamination of other onsite utility piping; piping which was identified by the report as a possible avenue for the apread of contaminants! An Investigation Into the possible contamination of the Ford Factory Building was never mounted. The apparent reason for this omission* aside from the fact that the building was not "visually Btamlnated". waa that no knowledge of the storage of "significant its of Cham-dyne waste* exlata. Certainly when we are dealing with the potent carcinogens that have been found on the alte. there is mo need for a large quantity of material to be present before it is •significant*. Prudence dictates that no onaite facility ahould be dims!teed from condemnation and demolition on such grounds* particularly with the haphazard state of record keeping that prevailed at Cham-Dyne during ita active phase. Similarly, no samples were taken from the Oarage, which was known to "have been used for waste storage* and whose "floor was visibly contaminated". The detection of aix known oarelnogena In the single sample taken from the storm sewer main raises vital and urgent questions concerning their origins and the dynamics of the entire storm sewer system. These questions were not addressed in the Bemdelal report. It is apparent from these brief comments that additional investigation of on-aite structures and utility hardware is Justified la order to establish an adequate data base. At the moment it Is difficult to understand how atatementa can be made with confidence concerning the extent of contamination and route of contamination flow. Divan the Inadequacy of aamiilliig information, we believe that the aafeat action at this time win be complete demolition of all on-aite facilities. Off-site containment of all debris should be In an approved baxardoua waste landfill, unless that material can be certified as uncootam/1 nated.

The soil investigation section of the Final Bemedial Investigation Beport raises several questions regarding soil sampling protocols and associated •assumptions" of contaminant behavior. Many assumptions which have been made require a more detailed explanation before they can be accepted. For example, the word significant Is used rather loosely to define the amount of flooding necessary for surface runoff to carry contaminated soil from the site. Significant* In this non-statistical usage la unacceptably subjective. The following questions are representative of those which oust be answered before any second soil sampling effort is considered sufficient: 1. On what statistical basis was the decision made to take only four offslte soil samples? On what basis were those particuylar sites chosen? 2. PS comments regarding the onsite buildings are vague. Have all soils beneath buildings been sampled? The garage and Ford building are single out as appearing to be contaminated but the nature of the contaminants is unapeciflfed. They should be identified. Other buildings were apparently uncontaminated to the eye. Were they sampled? If noti why not? If they were sampled why were the results not reported? 3. The storm sewer discharges low concentrations of Endrin into the Ford Canal... What is "low" concentration? Do we have assurances backed by reasonable data that this concentration would not worsen in years to come? What is the potential for bioaccumulation from this and other organic and inorganic contaminants? 4. Given the lack of statistical sophistication and rigor of your soil sampling regime can you confidently make statements concerning the areal extent of soil contaminations? The conclusions reached thus far are generalizations based on untenable assumptions and therefore unacceptable to the communities at risk.

One of the more glaring deficiencies of the Feasibility Study and the Remedial Investigation is the failure to consider important historical information concerning a route of contaminant transport. The Technical Memorandum of Dec. 20* 1983 (Vol. 21 of 2) provides a historical survey of the Chen-Dyne site. In 1917 the Miami Conservancy District leased the site to the Hamilton and Rossville Hydraulic company which operated at least two canals and a reservoir on the site. In 1919 a multi-group effort filled in the west canal and reservoir. Using Figure 3 (TM W65310.CO) as a guide* this west canal can be seen to occupy the western border of the present Chem-Dyne site. The reservoir occupies the south to southeastern border. Presumably* surface waters could only be maintained over a porous aquifer if they were underlain by an impervious clay barrier. The Site Qeology Section in the Remedial Investigation Summary Report (Vol. 1; pp. 3-1 thru 3-9) describes the subsurface soil characterisation. Evidence is presented that the canal and reservoir can be distinguished. The review of onsite large-container bulk waste storage indicates that Tanks 1-7, and 13 may have been situated atop the west canal (Remedial Investigation* Figure 12, 13; TM W65310.CO). These contained the largest measured concentrations of chlorinated pesticides and aromatic hydrocarbons. Coinoidently* there is a pattern of extensive surface soil contamination in this former canal area. We have been able to distill the following information from Figures 6 thru 12 (Remedial Investigation. Vol. 1; pp. 3-27 thru 3-54): Vhat are the conditions that can be defined as "significant" for runoff to occur? Additionally, to assume that "current aite topography* majL not allow for the movement of contaminated runoff to areas off site Is naive and. if mistaken, very unfortunate. Such statements are unacceptable without substantiated facts. Of course the problem arises of how substantiated facts are obtained when leas than mlmlmal numbers of offaite soil samples were taken? Further doubts are raised concerning the accuracy of the soil study when the evaluation of inorganic contamination offaite la considered. •Background* samples that were taken offaite present validity problems, two were heavily contaminated and could not be used for background. The remaining two offaite samples listed as having come from an •unaffected" area also revealed contamination, albeit to a lesser degree. The fact that contaminated samples 03-3 and OS-4 were taken offsite, in close proximity to the waste site, indicates that runoff did occur despite site topography. Finally, we object to the term •unaffected area*. The area was manifestly affectedI Considering the history and extent of contamination to date it would appear that only the tip of the iceberg baa been found during the remedial atudy. This should come as no surprise since the t^T1"1"! scheme was not statistically sound. The number of soil samples taken both outaida and inaide are insufficient to accurately estimate contamination. latimating the extent of contamination off site requires more aamplea than were taken and background should really be chosen as such. It would now seem desirable to further investigate the soil contamination problem using proper atatlstical analysis. A sampling protocol indicating the type of sampling being done (i.e.i atratified. etc.) moat be baaed on atastistioal sampling strategy. Such a atrategy waa not mentioned in the report* yet there sontinual use of the statistically loaded term •significant.* The accuracy of the ramadlil study especially for offsite areas and in all directions (concentric to the site) can not support any final remedial action of soil cleanup. Besidential neighborhoods must be included as a first step of reevaluation of Cham-Dyne soil contamination. Sample alxe offaite was too low to allow for statistical evaluation( the same may also apply to other areas sampled. After evaluating the soil investigation data presented, it is clear that more data gathering is necessary before statements about cleanup of contaminated areas can be made. Throughout the report not ••""g*' attention is given to the real problem presented by- the toxic contaminants found in the soil. There has been no satisfactory explanation about the toxioity of the materials detected both in and out of the facility. An explanation along these lines is necessary so that those not having knowledge of the chemical • can evaluate findings. Finally, one of the many- inaccurate statements that la salient in the soil Investigation report appears on page 3-12 of tv« lemedlal Investigation. To say that phenol is not particul -toxic is both wrong and misleading. SOIL CONTAMINATION ABOVE THE WEST CANAL Approximate Distance from Inorganic : " Organic Sample NW corner of Contaminants Contaminants Chen-Dyne • + f base (ug/kg) ' (ft) Cu Cd Cr neutral 7.0.C.

GS-1 0 445 7.0 61 0 0 SS-9 100 597 10.3 93 185.000 110 GS-2 200 306 10.4 1100 32,890 133 SS-8 250 660 7508 286 393,000 6300 B-20 300 587 3.3 8.7 33,300 1000 B-10 375 109 4.6 11.9 600 8300 SS-10 375 372 13.1 189 227,000 4600

• a total concentration of Cu, Ba, Pb, Zn (mg/kg); + * total concentration of Cd, Be, Sb, Se, Ti, Hg, Sn, Ag, Cn; # » total concentration of Cr, Co, Ni, B, V, As. * * volatile organic compounds In addition one soil sampling at Mtf-11 (B-12) [approximately 1200 feet from the northwest corner of the Chem-Dyne site along the former west canal] indicates accumulation of toxic contaminants in the subsurface soil (12-13 feet deep, in the vicinity of the clayey silt/silty clay lens which could represent the bed of the former canal.) Any remedial action on groundwater/soll contamination must incorporate the distinct possibility that Chem-Dyne toxicants have percolated through the soil to be sequestered in the old canal and reservoir beds of the site. Episodes of heavy rainfall may leach additional surface contaminants, and there may be a directed flow in the canal/reservoir beds. Since these old beds extended offsite into the present residential community, an immediate offsite contamination investigation should focus upon the former hydraulic works as routes of contaminant transport via multiple date sampling analyses of mobile toxicants over a significant portion of the beds. In summary, the rapidity with which a court settlement is being sought from Chem-Dyne officials and generators is disturbing. To date, all available soil data indicates that only the tip of the iceberg has been found'. More scientific investigation In terms of additional statistically feasable off-site sampling strategy has to be performed to get a better understanding of both the magnitude and extent 9f soil contamination created by Chem-Dyne. A true picture of remedial costs for soil contamination is necessary before any settlement takes place. Moat important, it must be realized that a cosmetic clean-up of the site will not suffice, this would be totally unacceptable. The potential for continuing contamination of groundwater, runoff from on and off-site contaminated soil and volatization of organlos from the problem area has to be thoroughly investigated scientifically. The Boat prudent immediate on-slte action will be complete (and off-site disposal at an approved hazardous waste lanrtfm) of all contaminated soil identified in the remadlil investigation even down to a depth of 12-13 feet identified in some •ample*. A workable loading and transport protocol where volatisation of onemloals is ml planted* aust be prepared. Trucks should use the spill-free beds. All trucking routes are to be checked for spillage of contaminated soil and spills are to be cleaned-up Immediately. If cost-effectiveness becomes your rationale for dismissal of this atrategy* the community demands that full disclosure of the public risks be adequately aired. Simultaneously* a soil sampling program should be initiated and presented to the public within three months for their commentary. To •inimlxe future potential problems related to soil contamination* we urge that the most complete method of soil removal be considered after a better understanding of the extent of both on-slte and off-site contamination Is obtained. Additional sampling is necessary In both locations. GBOONDWATEB Qroundwater Monitoring Aa a first step In this phase of the Chen-Dyne cleanupt an extensive, scientifically-designed, publicly-reviewed sampling program must be incorporated in the initial remedial action. The major trend of groundwater monitoring to date indicates south-southwest migration of low molecular weight volatile organics. However, only one monitoring well is more than 400 feet to the south of the site and only one well is more than 400 feet to the southwest of the site. This occurs despite statements from the FIT report (1982) indicating probable contamination 650 feet offsite. The drinking water wells for the city of Hamilton are the major human concern, and these are south. More detailed and frequent resolution of the migration pattern are essential as noted in the summary evaluation (Remedial Investigation; Vol. 1; pp. 3-69) The data base for prediction of contaminant migration is based upon wells drilled 30-60 feet. However, the Remedial Investigation Report indicates contamination below at least 65 feet in one of the few deep wells (Vol.1; pp.2-14). The Champion and Mercy Hospital pumping wells may be encouraging migration southward and westward deep below the Great Miami River (Remedial Investigation; Vol.1; pp.2-13). Surely* any remedial action must include rapid expansion of the monitoring well network for mobile chemicals in a broader south-southwest surface area, and also in the depth profile. The limited groundwater sampling indicates a generally greater rate of groundwater movement to the west of the site as the Great Miami River is approached. Rather than deriving a migration profile based upon the range of all measured values, rates of transport for toxic materials from Chem-Dyne should be calculated on a sector by sector basis Incorporating bydrogeological parameters characteristic of those sectors. The lack of a coherent pattern of material migration in groundwater is apparent when the tables in Appendix B of Remedial Investigation Volume 21 of 2 are examined. For example. 1,1,2-triohloroethane at Mtf-15 sampled by CH2M varied from 12*000 ug/1 during April 1983 to 3*400 In July to 29.000 In October. Acetone on the October. 1983 sampling date (CH2M) varied on an east west gradient from 49*000 ug/1 at the Mtf-15 site (approx. 100 feet west of Chem-Dyne)} to 540 ug/1 at Mtf-18 (approx. 500 ft west of Chem-Dyne); to 4900 ug/1 at Mtf-19 (approx. 1200 feet west of Chem-Dyne). What level of confidence can be attributed to the values reported as representative of that site? It Is certainly plausible that the sampling regime may have overlooked .episodes when toxicant concentrations were several orders of magnitude greater than those reported. Similar criticisms can be levied at the cursory dismissal of the Chem-Dyne site as responsible for contamination of the Ford Canal Area. Can the limited temporal and geographic sampling assure us that there has not been nor will be significant contamination of this aquatic ecosystem? In summary we stress the need for a more extensive monitoring well network. We particularly emphasize the need to address: 1. the complex kinetics of contaminant interactions which could enhance desorption* solubility and movement throughout the aquifer; 2. the transport of toxic material via percolation along historic canals and reservoirs; 3. more detailed survey of the rate of contaminant transport In the south-southwest direction; 4. more detailed profile of the three dimensional aspects of the groundwater contamination including depths as deep as 65* feet; 5. a more complete assessment of the aniaotropic and heterogeneous nature of groundwater flow on and around the site. Until this is accomplished and recognized as such by the public* no amount of extracted and treated groundwater can be considered sufficient.

The Keeley atudy upon which the groundwater movement is based has not been adequately addressed by the EPA as to its broad applicability in the Chem Dyne case. We summarize from the April 17* 1984 internal memorandum from Joseph F. Keely (Final Bemedial Investigation Beport Tolnme 2B of 2. IPA, 1984). 1. The "crucial relationship: the influence of the Miami Biver (and the Ford Hydraulic Canal)* Is not addressed by the remedial investigation. Therefore we have no confidence in the efficacy of treatment strategies based upon the 'less sophisticated analytical approaches»• 2. The values determined during the HI study pumping test reflect local* shallow conditions and should be utilized in that light only. Those values are leas appropriate for projections concerning the regional flow or for deeper zones of the aquifer (which appear to be the most permeable* and which supply most of the major IT*"! wells in the valley).* On a scientific basis* the extent of contamination la uncertain both vertically (aa deep or deeper than 65 feet in some well samplea) and horizontally (a poor distribution of sampling wells in the direction of hypothesized general groundwater movement, see above). Oiven this uncertainty* prudence dictates a simultaneous expansion of groundwater monitoring during the placement and operation of extraction wells. 3. the Keeley report speaks of a 'rough estimate of how long it would take for oontamlnanta to reach a certain point*, based upon four,assumptions. Three of the assumptions of the model are considered tenuous by its author! a. First, that aquifer properties are very variable* and the assumption that they are constant 'cannot be further limited unless numerical modeling is attempted*. b. Secondf that contaminant behavior ia conservative without dispersion depends upon "reliable estimates of the kinetics and capacity for sorptiqn, biodegradation, etc., [which] are not readily available for this site." '? o.Finally• that natural flow direction is straight from the site to the point of interest (i.e., the Hamilton city wells) "presupposes some idea of the directional changes in hydrualic conductivity and gradient (which are already assumed constant)". We question the validity of feasible actions based upon inadequate assumptions. When dealing with the public health of almost 60,000 residents 'rough* estimates derived from shallow assumptions, incomplete samplings, and minimization techniques of averaging are not acceptable. At the very least, a worse-case-analysis with full explanation of every selected variable must be presented for public scrutiny. The EPA has not done this. They have not responded to our previous comments on the Remedial Investigation upon which they based the present Feasibility Study Options. The estimate of groundwater flow rate at 3 ft/day does not represent the highest flow estimate from the HI. Nor has the EPA described what proportion of the yearly flow that it would represent or why it was selected. In addition, we do not have an adequate explanation of wide fluctuation in contaminant concentrations from one sampling date to the next. We do not have an adequate profile of oontaminmant distribution in a three dimensional view. We do not have any estimate of contaminant interactions which would alter the retardation coefficients (I.e., it is highly likely that the low molecular weight chlorinated solvents would enhance transport of high molecular weight organic: such as pesticides). Travel times of contaminants are based upon averaging of pore water velocities, not a maximum pore water measurement. Assumptions of homogeneity of soil carbon character is assumed, but no analysis of its validity Is presented. Until the uncertainties Inherent In the EPA estimates of groundwater flow and contaminant transport are aqequately addressed, we ask that the triple well extraction well strategy be impllaented Immediately with expanded pumping capacity at an initial 1000 gpm at each well. We set a goal of subsequent revaluation of pumping speed and number of extraotion wells at 3 month Intervals based upon more accurate characterization of groundwater flow In the region. Host importantly* should this strategy be rejected, we ask that the EPA provide a detailed response as to why they reject it.

i As outlined In the above analysis of the HI groundwater study and In the soil analysis, the Chem-Dyne citizen's advisory group should not accept the assumption that all sources and amounts of chemical contamination have been identified. Nor should they accept the averaging assumptions utilized in deriving the estimates of extraction concentrations for various classes of contaminants. This limits the confident selection of an appropriate treatment strategy. However, working within the mandate of the national Continfency Plan goala of protecting public health* welfare and the environment and the uncertainties of the remedial investigation* we set the following conaerratire agenda for treatment of groundwater: 1. The proposed air stripping systea for removal of volatile organios appears to address several important components of the groundwater contaminants* but neglects others such as higher molecular weight organics and inorganic oontaainants. Therefore! as step one of a multi-step cleaning process, we ask that the air stripping systesi be Installed. Ve also believe that it is Mandatory for all carcinogenic and toxic agents to be restored from that air stream before being emitted into the local community. Therefore, we ask that the EPA install a carbon adsorption and regeneration systesi to treat the air effluent, we are dismayed that odor control via hypochlorite treatment is discussed with the save seriousness as carcinogen removal fro» the Lty air. 2. The estiamted extracted groundwater quality Is presented for a such samller subset of possible contaminants than actually expected (see Feasibility Study; Table 5-10). Oiven this* estiamted concentrations from extraction wells ««e««d water quality criteria for the protection of huamn health from carcinogens with one of three base/neutrals (bis(2-chloroethyl)ether) and the only pesticide (*.«'-DOT) analysed. The Oreat Miami Hirer is part of the Great Miami Aquifer. Ve reject the concept that cleanup of Cham Dyne requires the addition of mixtures of carcinogens and toxins to the downstream community. Treatment via an activated carbon adsorption system had been summarily dismissed aa too expensive. This is unconscionable when lack of consideration may lead to increased cancer Incidences in a population already at risk. As step two of a multi-step treatment process, we ask that after air-stripping, the groundwater effluent be stripped of remaining organic carcinogens and toxicants by contact with a bed of activated carbon. Again, a regeneration system for the carbon must be developed and maintained on site. At the very least, full disclosure (weighing estimates of worse osse carcinogen concentrations; addltlvity and multiplicative scenarios for mixtures of carcinogens; and costs for treatment) of the rationale for rejection of this technology must be Insured. How can a settlement be discussed without this question being addressed? 3. Estimated concentrations of extracted groundwater inorganic contaminants are presented in Feasibility Study Table 5-9. Again using our caveats about the SPA data base and model assumptions which we stated at the beginning of this section, the EPA's own analysis indicates that: a. Barium concentrations from extraction trails will exceed the chronic level of Ambient Hater Quality Criteria for Protection of Freanwater Aquatic Life. b. Silver concentrations from extraction wells will exceed the chronic level of Ambient Hater Quality Criteria for Protection of Freshwater Aquatic Life. c. Mercury concentrations from extraction wells will exceed not only the chronici but also the acute level of Ambient Water Quality Criteria for Protection of Freshwater Aquatic Life. In addition, the mercury level approaches the Interim Primary Drinking water Standards (1.3 ug/1 vs.2 ug/1). *>w Again* the Great Miami River is part of the Great Mimai Aquifer. We reject the concept that cleanup of the Chen-Dyne site requires the pollution of the downstream community with agents that are highly toxic and can become teratogenio. The EPA has not presented any treatment strategy for this material. Until they do, we ask that step three of the multi-step include passing of the organic-stripped extraction effluent through a cationic exchange resin system to remove the inorganic toxicants. Again* an appropriate regeneration system for the extraction technique must be installed on site. 4. Appropriate analytical expertise must be based on site to address efficacy of the extraction technology. Periodic public reports (3 month intervals) must be part of any treatment strategy.

PQBD CAMAL Similar criticisms can be leveled at the cursory dismissal of the Chen-Dyne site as responsible for contamination of the Ford Canal Area (Remedial Investigation). Can the limited temporal and geographic sampling assure us that there has not been, nor will be* significant contamination of this aquatic system? Sampling of the fish species was haphazard and difficult to interpret biologically. Different species were sampled at up and downstream sites, and varied as to trophic levels (herbivores compared to carnivores). Apparently* the fish that were sampled were not aged so we have no idea how long they had been exposed to the waters of the Ford Canal. Considering the limited usefullness of the data obtained from the fish studies and considering the known abilities of various long-lived toxins to migrate* both biotically and abiotioally. we believe that it is premature and irresponsible to dismiss any effects of toxins entering the Ford Canal from the Chem-Dyne site as inconsequential. As part of the next phase of the Chem-Dyne cleanup* we believe that a detailed profile of sediment contamination of the Ford Canal Region be addressed. Simultaneously* a plan must be developed to assess th» significance of the following: a. the biooonoentration of pesticides* high-molecular weight organic contaminants* and inorganics such as mercury in maorophytes* nicrorooplankton, macrozooplankton and fish communities of, the Ford Canal. b. the consumption of fish in the surrounding human community of Hamilton* and the relative risks that that poses for public health. ' o. the contribution of contaminants in the Ford Canal to the Great Miami River and the significance of these to the biological organisms dependent upon that resource. d. the significance of contaminant leaching from the Chem-Dyne site into the Ford Canal. While present methods are deemed unacceptable for removal of contaminated sediments, tremendous advances in cleanup technologies have occurred over that past five years. The physical cleanup of the Ford Canal must remain open ended at this time* pending development of the appropriate methods. Therefore, no settlement can be deemed final for this problem at this time.

The EPA truly has an opportunity to make a model clean-up case oat of Chem Dyne. To do so would restore faith in the Chemical Industry* the Federal Legal System and the EPA by members of Hamilton City. Butler County and the State of Ohio. The feasibility study as it currently stands raises a multitude of critical questions which yet remain to be answered. The overriding concern of the Chem Djue Advisory Group remains that the EPA will engage the responsible parties in an out-of-court settlement which is based upon scientifically incomplete data and which will be monetarily-inadequate to protect the public health; public welfare; and environmental quality. To date* much has been learned about the extent of contamination attributed to Chem Dyne, lonetheless. we remain dissatisfied with the lack of scientific evaluation of certain aspects of soil* groundwater, Ford canal, and om-aite findings. EPA'a Feasibility Study is not complete. The complex environmental pollution problem at Chem Dyue requires thorough investigation where no stone is left unturned. Scientific investigation and evaluation should not take a back seat to budget oonatralnta, project deadlines* and community pressure. There should be no compromise for a totally scientific approach in data collection* assimilstion and interpretation. Ignoring sound scientific evaluation in this case has resulted in making •assumptions" about serious problems. Such assumptions are totally unacceptable where human and environmental health* safety and welfare are concerned. yjl The nation has slowly become aware that environmental crises do not always belong to someone else* someplace else. In our individual communities we are being forced to recognise the unpleasant facts that environmental crises belong to each of ua. This realisation has been particularly severe and unsettling to the residents of southwestern Ohio as we have faced the complexities and enormity of the environmental insult represented by the Cham-Dyne facility in Hamilton* Ohio. Sincerelyi <\ Andy Garcia-Rivera John Lahorra 713 South Locust 10 Pepperwood Lane Oxford* OH 45056 Pepper Pike, OH 44124 513-523-5576 216-831-4043

Town Peterson Jerry Poje 115 N. University Avenue 733 B Daniel Drive Oxford, OH 45056 Oxford, OH 45056 513-523-4525 513-523-5987

G "Da^Id Reese Paul E. Wooda 716 South College 219 North Elm Apt #42 Oxford, OH 45056 Oxford Square Apartments Oxford, OH 45056 513-523-7210 oo: Margaret MoCue, U.S.EPA Lee Thomas, U.S.EPA Judy Oillens, HAPSO Judge Carl Rubin Senator Howard Metzenbaun Senator John H. Olenn Representative Thomas N. Kindness Governor Richard P. Celeste State Senator Donald B. Lukens State Senator Eugene Branstool State Representative Michael A. Fox State Representative Thomas P. Oilmartin State Representative Bohner Mayor George V. Molfally and Hamilton City Council Butler County Commisioners Robert Maynard, Ohio EPA Thomas Winston, Ohio EPA Appendix B RESPONSES TO COMMENTS ON THE FEASIBILITY STUDY BY THE OXFORD AUDUBON SOCIETY

INTRODUCTION The following are responses for the written comments on the Feasibility Study (November 19, 1984) submitted by the Oxford Audubon Society (OAS) dated December 12, 1984. Many of the OAS comments were repeated from earlier comments on the Final RI Report (May 22, 1984), which were dated Septem- ber 28, 1984. These RI comments and U.S. EFA's responses are included in this Responsiveness Summary as Appendix A. Where these comments are repeated in the FS comment set, the response is a reference to Appendix A. -OXFORD AUDUBON SOCIETY COMMENTS ONSITE STRUCTURES The first four paragraphs were received in the earlier RI comments. Refer to Appendix A for response. Page 2, Paragraph 5 Complete demolition and offsite disposal in a proper facility was among the potential remedial alternatives considered in the FS for onsite structures. The selected remedial plan incorporates complete demolition of all onsite buildings with offsite disposal of contaminated material and miscel- laneous waste. Some selected scrap steel will be salvaged. Uncontaminated demolition debris will be disposed of onsite under the site cap. Demolition debris will be placed to minimize settlement. SOIL The first five paragraphs were received in the earlier RI comments. Refer to Appendix A for responses. Page 4, Paragraph 1 The consMnt raises four questions which are addressed in order: 1. During the RI soil sampling, five offsite samples were collected: two samples (OS-1 and OS- 2) were taken from areas not affected by Chem-Dyne wastes and three samples were taken from areas suspected of being contaminated by wastes. The two offsite soil samples OS-1 and OS-2, were taken to represent "background.11 They were

B-l selected from areas where frequent human contact was likely. Two offsite samples were taken immediately south of the warehouse parking lot where Chem-Dyne contamination was suspected (OS-3 and OS-4). A third "offsite" sample (SS-10) was taken immediately west of the site fence near the railroad right of way west of the Chem-Dyne building where contamination was suspected. Based on results of these samples, the site boundary was revised in the PS. (Refer to Appendix A for additional response.) 2. Soil beneath the buildings has not been sampled. All data developed during the RI were reported and used in the PS. 3. As part of the selected overall remedial action for Chem-Dyne, contaminated infiltration to the storm sewer will be eliminated. Following implementation, future low concentration drainage should not be discharged and, therefore, the potential for any future bioaccum- nlation will also be eliminated. The use of the term •low* in the feasibility study to describe concentration is based on the routine detection limit required from the laboratory. The routine detection limit was 0.1 ug/L and the reported endrin concentration was 0.05 ng/L. 4. The conclusions regarding onsite soil contamination are based on analysis of onsite soil samples which were collected after consideration of previous sampling, soil appearance, site topography, aerial photography, and reported historical operating practices. Past Chem-Dyne site operations were carried out within known areas at the site. Because the blue warehouse and south parking lot were used for waste storage, these areas are now included within the updated site boundary in the PS. Frequent sampling outside of the areas known to have been occupied or contaminated by Chem-Dyne operations was not done so that sampling and analysis resources could focus on characterizing areas of likely contamination. Page 4, Paragraphs 2 and 3 These paragraphs were received in the earlier RI comments. Refer to Appendix A for responses. Page 5, Paragraph 1

B-2 Although the speculation regarding the old canal as a possible route for contaminant migration is interesting and con- structive, this comment is puzzling. The comment is apparently based on the FIT report issued in June 1982 by E&E, Inc. Analysis of soil sample B-12 (FIT Table 6) indicated low concentrations of 10 priority pollutant organics; nine of these organics were phthalates or polynuclear aromatics, organic compound classes which migrate extremely slowly in soil. None of the more mobile chlorinated VOC's, known to be in the contaminated unsaturated zone, were identified. Without occurrence of these chlorinated VOC's, linkage to site infiltration is unclear. The B-12 sample was taken from 12.5 feet below surface (FIT Table 16, p. 146) where the boring log (p. 98) reports the material to be sand and gravel fill with cinders and debris (0 to 14 feet). No clay is reported until 28.5 feet. Because offsite migration in the unsaturated zone along old abandoned canal routes is a possibility, the Agency has reviewed the existing data from the RI in terms of the locations of old canals and wastes stored onsite. Page 5, Paragraph 2 Refer to Appendix A for responses. Page 5, Paragraph 3 The schedule of the cleanup settlement was dictated by the Federal District Court judge who presided over the Chen-Dyne suits. The judge determined that further delay was not acceptable. As a result of negotiations, a Consent Decree was lodged in Federal District Court in June 1985. The FS has evaluated and put forward remedial alternatives which address the commentators' stated concerns, i.e., potential for continuing contamination of groundwater, runoff from on and offsite contaminated soil and volatilization of organics from the problem area ..." The alternatives evaluated are complete. Implementation of remedial actions will include contingency plans and regular monitoring to check performance. Specific details of these contingency plans and monitoring requirements are in the Consent Decree and remedial action plan prepared by the settling defendants, Page 6, Paragraphs 1 and 2 Complete removal of all contaminated soil identified in the RI would involve excavation and removal of onsite soil to a depth of about 25 to 30 feet because VOC contamination is known to extend to the water table. To illustrate the practical meaning of complete soil removal, quantity estimates should be considered. Assuming an active site area of

B-3 15 acres and excavation to 25 feet, the soil volume to be removed would be 605,000 cubic yards or roughly 61,000 truckloads. Assuming a typical disposal cost of $100 per CY and hypothetical one-way haul distance of 75 miles to the nearest suitable landfill with capacity, the disposal and transportation costs alone would be approximately $74 million, excluding onsite work costs and replacement fill. Transpor- tation would involve additional risks of spills and consequences of heavy truck traffic. These material quantities, transportation effects and costs were considered in the evaluation and assessment of remedial actions in the FS. The FS analysis for soil remedial actions determined that no reasonable amount of soil removal alone would be an adequate remedial action and that the most critical component of site remediation (for soil contamination) is capping. With a properly selected, installed and maintained site cap, further migration of contaminants from the unsaturated zone would be minimized. The FS concluded that no reasonable amount of soil removal would eliminate the need for an impervious cap.

Page 7, all paragraphs Refer to Appendix A for responses. Page 8, paragraph 1

1. Contaminant interactions and behavior kinetics should be investigated. Remedial action implementation should not be postponed pending such studies, however. The state of science and understanding of groundwater contaminant migration is developmental. The effects of adsorption/desorption, degradation, volatilization and so forth on contaminant migration are recognized generally, but cannot be currently predicted with confidence. Groundwater extraction will perform in a reasonably well understood manner. Regular monitoring to measure performance and contingency adjustments to the extraction system as needed have been incorporated in the selected groundwater remedy. 2. Commentators' suggestions regarding contaminant migration along old canal routes are interesting but specula- tive. The existence of clay lining in the old canals is a presumption. However, because offsite migration along old abandoned canal routes is a possibility, the Agency has reviewed the existing data from the RI regarding

B-4 the location of the old canals and wastes stored onsite. (Refer to response for OAS comment from page 5, paragraph 1 presented previously.) Remedial actions evaluated for the site in the FS included consideration of offsite migration in the unaaturated zone via buried utility lines. As part of the overall remedial actions selected for the site, a deep (approximately 15-foot) perimeter cutoff trench and backfill will minimize the potential for future migration, if any, along old canal routes. 3. Additional monitoring wells, including deep wells, that have been incorporated in a selected remedial action for groundwater are part of the groundwater monitoring program which will be implemented. 4. Some additional hydrogeologic studies have been conducted by the Ohio EPA and the potential responsible parties. Data from these studies will be used in final design and implementation of the groundwater extraction well system. In general, the performance of the extraction system will be judged by frequent sampling of the monitoring well system. If performance is not as expected, the contingency measures will be used as necessary to adjust the operation and maintain the necessary level of groundwater extraction to meet remedial goals. Page 8, Paragraph 2 The comments on the Keely memorandum (April 17, 1984) , which was prepared prior to the Final RI Report are detailed and responses will be presented in order. 1. The influence of the Ford Canal and Great Miami River is discussed in the RI Report beginning on page 3-68. Since issuance of the Final RI Report, additional groundwater level and river level data have been developed. These data will be considered in final design of the groundwater remedial action. 2. Th* groundwater contamination is more concentrated in th* upper portion of the aquifer below and adjacent to Chen-Dyne. At the present level of detail used in the FS, extraction wells were assumed to be 80 feet deep to extend beyond the 65-foot limit in RI data. The selected groundwater extraction system incorporates more wells placed according to results from three consecutive monthly samplings which will determine the current location of the 100 ppb VOC isopleth. The selected extraction system will include 19 wells, 3 wells will be

B-5 70 feet deep (screened between 45 and 70 feet) and 16 wells will be 45 feet deep (screened between water table and 45 feet). A combined pumping rate of 550 gpm will be used. An expanded groundwater monitoring program will be used to maintain proper performance of a groundwater extraction system. 3. The estimates of organic migration in the Keely memorandum were calculated for illustrative purposes only. These estimates emphasized the need for action; the assumptions used to calculate the estimates are reasonable and based on general experience. Given the developmental state of groundwater contaminant migration science, more detailed contaminant behavior modeling would not have necessarily added accuracy to the migration estimates. Page 9, Paragraph 1 Chapter 2 of the PS addressed the "endangerment" or added risks to public health resulting from "no action' at the site. The endangerments need not necessarily be based on "worst case* analysis conditions but, rather, on evaluation of contaminant dilution, contaminant transport, mass balance calculations, and lifetime exposure estimates. Using these methods, endangerment was demonstrated and remedial action is required. Worst case conditions need not be invoked. Page 9, Paragraph 2 The horizontal velocity of 3 feet/day was not the highest velocity estimated but it is a good approximation of the regional velocity in the area upgradient of the extraction well system evaluated in the fS. The range of horizontal groundwater velocities reported on page 3-69 of the RI was 0.15 feet/day to 3.5 feet/day. Concentration variation was discussed In the RI on pages 6-101 and 6-102 (refer also to Table 19). The existing information on contaminant migration was sufficient for the assessment of technologies for remediation. Monitoring for performance of the Implement oil remedial actions will be conducted using both existing and new groundwater monitoring wells. Contaminant interactions are not expected to change the applicability of groundwater extraction as a remedial action. The assumption of soil carbon content was applied consistently to all groundwater alternatives and, therefore, a consistent common base was used for all assessments. Page 9, Paragraph 3

B-6 The 3-well groundwater extraction system conceptualized in the PS is reasonable but was intended only to approximate the general features necessary for the extraction system. The selected extraction well system will be different in configuration from the systems described for assessment of alternatives in the FS because the selected system is somewhat optimized during the more detailed predesign. The opti- mization process aims at capturing contaminants while minimizing the water volume extracted. The extraction system will be designed considering the most recent field data and hydrogeologic evaluations. Groundwater monitoring and con- tingent adjustment of the extraction system as needed (to maintain performance) is part of the selected remedial action plan. Page 9, Paragraph 4 In the FS, two different approaches were used to estimate organic groundwater contamination concentrations. Selection of these approaches was deliberate based on the evaluation needs. Averaging assumptions based on mass balance calculations were used in parts of the endangerment assessment in Chapter 2 because cancer risk calculations are based on lifetime exposure. Average concentrations were suitable for these estimates. Groundwater treatment evaluations were based on estimates of the actual individual contaminant concentrations from October 1983 data for plume concentrations, horizontal dimensions, rates of migration, and dilution during extraction. This approach resulted in estimates of maximum concentrations of each volatile organic and the time of occurrence in the extraction system. These estimates were used to evaluate the groundwater treatment system. Page 10, Paragraph No. 1 The air stripper was intended to remove VOC's; frequent effluent monitoring will be part of implementation. Further,, the actual selection and sizing of any groundwater treatment system will be based on bench and pilot testing to confirm performance criteria. Present data indicate that pesticides and base/neutral compounds have not migrated to groundwater in consistently detectable amounts yet. However, if these heavier compounds do appear in air stripper effluent, a contingency action would be inclusion of activated carbon for treatment. Commentators should not underestimate the potential seriousness of odor control in terms of the welfare of the community. Page 10, Paragraph No. 2 If actual extracted and air stripped groundwater does have unacceptable concentrations of VOC or non-VOC compounds as revealed during startup of the system, then additional

B-7 treatment will be incorporated in the groundwater treatment system. The Agency was well aware of the need for such con- tingencies and had them incorporated in the Consent Decree. The fS did not incorporate a carbon adsorption followup process because the data do not appear convincing that non-VOC compounds will be a problem. Page 10, Paragraph No. 3 The inorganic element concentrations estimated for extracted groundwater (FS Table 5-9) were below standards and criteria except for silver and mercury. Following dilution in the canal, the concentration of silver is expected to be well below WQC for freshwater aquatic life. The concentration of mercury is a concern and discussed on page 5-36 of the FS. If mercury is a problem in actual extracted groundwater, then mercury removal will be incorporated in the treatment scheme. The actual selection of treatment technologies will be based on pilot and bench testing on extracted groundwater. Ion exchange or chemical precipitation are possible treatment alternatives. At present we are not aware of any published Ambient Water Quality criteria for the protection of aquatic life which list concentrations for barium. In the 1979 review of the EPA Red Book by the Water Quality Section of the American Fisheries Society, it was suggested by U.S. EPA that "barium concentrations in both marine and freshwater environments would need to exceed 50 mg/L Ba before toxicity to aquatic life would be expected." However, to our knowledge no official criterion for barium regarding chronic or acute exposure of aquatic life has been published to date. Page 11, Paragraph Bo. 4 A fully equipped onsite laboratory is probably not appropriate because of the variety of analytical work required for monitoring. Monitoring samples are expected to be analyzed in offsite laboratories. Some selected analytical equipment is appropriate onsite to monitor characteristics such as pH, conductivity, and possibly atmospheric or headspace VOC concentrations. Although a fully equipped laboratory does not appear necessary at this time, a laboratory setup onsite would be considered by the Agency if monitoring work does develop the practical need for such equipment. Periodic public reporting of monitoring data is planned. FORD CAMAL Page 11, Paragraph 3 Refer to Appendix A for responses.

B-8 Page 11, Paragraph 4 Discharges of concentrated contaminants to the Ford Canal reportedly occurred in the period 1976 to 1979 during Chem- Oyne facility operation. Large fish ^ills were reported related to the site operation. Data from the RI indicates that some priority pollutant VOC and pesticide compounds are currently being discharged at low concentrations in storm sewer infiltration draining from the site. Selected remedial actions for the site incorporate actions to eliminate storm sewer infiltration and eliminate future contaminant discharges to the canal. Fish tissues have been analyzed for pesticides and base/ neutral (high molecular weight) compounds and/ with the exception of PCB's, none were found. PCB occurrence has been discussed in the RI, FS and the previous responses in Appendix A. Don Bruce/ U.S. EPA RSPO, has submitted a recommendation for another party to investigate the matter of fish consumption in more detail. Upon recommendation by Bruce in 1983, the Ohio Department of Health issued a fishing advisory for the Ford Hydraulic Canal near Chem-Dyne, and that advisory is still in effect. The Department of Health is also considering further studies to be conducted in the canal and the Great Miami River. Page 12, Paragraph 1 Sediment removal/ by any method/ would redistribute and scatter some portion of whatever contamination remains. Sampling of both fish tissues and sediment during the RI does not demonstrate a need for canal sediment removal. Page 12, Paragraph 2 The Agency does not believe that the data upon which the FS is based are incomplete to evaluate remedial actions for the Chem-Dyne site. Some additional sampling work was identified in the FS and has been incorporated as part of the selected remedial actions. Monitoring and contingency plans are also incorporated in the overall selected remedial approach to the site. The Agency has included provisions for groundwater sampling, performance monitoring/ and contingency plans in the selected remedial action for the site. Page 12, Paragraph 3 The FS is complete for the purposes it addresses/ i.e./ evaluation and comparison of remedial action alternatives suitable for the Chem-Dyne site. A "thorough investigation where no stone is left unturned," i.e., investigation to

B-9 eliminate all uncertainty would take a very long time to conduct. A reasonable balance must be struck between study and implementation. The study must be sufficient to allow evaluation of remedial action implementation in a timely manner so that uncontrolled site releases can be brought under control. In regard to the 'scientific" nature of the FS, the FS is not intended to be a research tool. Many of the scientific topics involved are in early stages of development, e.g., migration and degradation of mixed VOC contaminants in groundwater and techniques for health risk estimation. Rather, the purpose of the RI and FS is to characterize in a technically correct manner releases of hazardous substances from uncontrolled sites sufficiently to evaluate and assess the applicability of alternative remedial actions with the goal of selecting and implementing cost-effective remedies in a timely manner. Uncertainties will remain; but, if sufficient data are developed to understand the limits of the site problems and reasonably assess remedial alternatives, the RI and FS are complete. The uncertainty remaining after the RI is addressed in the remedial actions through regular site monitoring and through contingency plans built into the remedial actions. GLT114/37

B-10 Appendix C U.S. EPA NEWS RELEASES AND AGENDA FOR DECEMBER 3, 1984, PUBLIC HEARING AND COMMENT PERIOD EXTENSION

GLT267/53-3 vvEPA Environmental NEWS

For !!niMfc»l:'ar.t! Kel^jse: Mov N:J. :^-?7M

•'i.S. K»JA ID iiOI.O PUBLIC ^KT (NC ;)« C!!tM-nv"i: •'•l.tAKi

Thr; -j..:^. l-nvironi.wnf.-i I r'roci^tlop <\«j«r »-..>• (I'.o fVA; ::?.;! ;r V

o jjjbiic meeting 01 'V.-cswibur 3, I9S'J, "SM-'uviiP;} rs .«:;1"'! i Icy '•.|.i;'v ol" •.•'!:•

r/i:j:;i-Dynf> hd^drdoiiS '/MStt- 51 to ':< liiinH t'.)H, !.''i. l!

/ p.d'., at i;'>e Han 51 ton City Hai ! , '?U Hie;* TSt.

•'JlC'^ans j^ii J'W'itu'J !:;• OMM.iern. an ttv» feas-rii :i'jdy, which ;;v.il-

•!6*;?i o,;t;o-is for JeaHTj v/:t:!i co)jt-.-iinifi.'iMO'i .i> t?n> >!!;-. '^.lin'niiiir. :• //lit f?

.j';:ti,.iL-:."J .u th*e mc-Jiiny j.-?.l iy ur in writf-iy, or is* v»r1*.iriy • .t '! S, tf-A'^

i'. office In C^ilC'i^') -iot.i; Peawber 14, '^Si. It ia ii.S. !IP*i po'icv

<)i'j''.i, A r«."!t».":Jiti j i^vHSt iij'i'v ion fount: c'tic'^iLcul r.on^ainiiatioi! in t'ie soil

il Lr-.e jroijmi 'Vat?r on .'jrnl ne-iriv/ 'fie r.Ui.

Options sv-iliiai'.aa in tn;-; faA>ibi i ity '.t-j-Jy i'?o !u.:<^ r^.'.ovin^ sul i r.o

V5riu'.is depths, extractiny «IK.I treiiti^y yrounri wat«?f, ^uttifrj a C'^y cjp c/*r

the site, dnn tho :;ifcs. Fetch option is f>voil-

ii-it-r-i for rif f'ectivenu:;-;. Sdf'.ity, cost, anil Crv/micrtl f^i.".ihi: ity.

Copies of the Ohwii-Oyno f»s?iiiri h ty ,t;idy a-n ^vdiianle for puhric

review at the Hamilton city wander's offic.».v, t:he "li-:!,ni i.'.Ti'verslty science -2- library in Oxford, and the Hamilton Appalachian People's Service Organiza- tion (HAPSO) office in Hamilton. Comments on the study may he sent to Margaret NcCue. 5PA-14, U.S. EPA Region V, 230 S. Dearborn St., Chicago, IL 60604.

1*11 Note to Editors: A summary of the feasibility study Mill be mailed to you the week before the meeting. UNITED STATES r ENVIRONMENTAL PROTECTION AGENCY £ RIQION S .SE * 230 SOUTH DEARBORN ST ^ jf CHICASO. ILLINOIS 60604 "*< **O*t& REPLY TO ATTENTION OF; U.S. Environmental Protection Agency Announces PUBLIC COMMENT PERIOD and PUBLIC MEETING for the Chem-Dyne Superfund site Feasibility Study

The feasibility study evaluates options for responding to contamination at the Chem-Dyne site in Hamilton, Ohio. The U.S. EPA wili consider public comments received on the study in its choirs of cleanup ypLions c-iosen for the site. PUBLIC COMMENT PERIOD: November 21 - December 14, 1984 Written comments will be accepted until 5 p.m., December 14, 1984. Comments should be mailed to: Margaret McCue 5PA-14 U.S. EPA Region V 230 South Dearborn St. Chicago, IL 50604

PUBLIC MEETING: Monday, December 3, 1984 7 P*I». Hamilton City Hall Monument & High streets At the meeting, U.S. EPA staff will describe the cleanup options being considered, and will accept oral and written public comments.

Copies of th«ftas1b1l1ty study are available for review at: Hamilton Municipal Building, (city manager's office, 20 High St.) Miami University (science library, Oxford Ohio) HAPSO (522 Butler St., Hamilton)

FOR MORE INFORMATION: contact Margaret McCue, U.S. EPA Community Relations Coordinato- 312-886-1728, or toll free, 1-800-621-8431 (3:30-4:30 weekdays, Central Time) UNITED STATES ENVmONMENTAL PROTECTION AGENCY NtGKMB 230 COUTH OCMIMMN §T CMCAOO UUNOtS CO6O4 MfPtY TO ATTENTION OF:

Chew-Dyne Superfund Site

PUBLIC MEETING ON FEASIBILITY STUDY

Hamilton City Hall Monday, December 3, 1984

AGENDA

Introduction 1 Purpose of Meeting McCue. U.S. EPA Community Relations Coordinator Presentation on Feasibility Study Donald 3ruce. 'J.S. EPA On-scene Coordinator Questions I Clarifications Moderator: Donald Bruce Public Consents Moderator: Marg«--?u McCue

Written consents on the study »ill be accepted until 5 p.n. December 14. Coonents should be sent to: Margaret McCue SPA.I4 U.S. EPA Region V 230 South Dearoori Chicago, IL 60604

FOR MORE INFORMATION, contact:

Margaret McCue 312-386-1723 or toll free 1-300-621-8431 (8:30-4:30, Central

Donald Bruce 212-886-0399 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGIONS 230 SOUTH DEARBORN ST CHICAGO. ILLINOIS 606O4 REPLY TO ATTENTION OF: U.S. Environmental Protection Agency Announces PUBLIC COMMENT PERIOD and PUBLIC MEETING for the Chem-Oyne Superfund site Feasibility Study

The feasibility study evaluates options for responding to contamination at the Chem-Oyne site in Hamilton, Ohio, The U.S. EPA wili consider public comments received on the study in its choice of cleanup options chosen for the site. »UBLiC COMMENT PERIOD: November 21 - December 14, 1984 Written comments will be accepted until 5 p.m., December 14, 1984. Comments should be mailed to: Margaret McCue 5PA-14 U.S. EPA Region V 230 South Dearborn St. Chicago, IL 60604

PUBLIC MEETING: Monday, December 3, 1984 7 p.01. Hamilton City Hall Monument & High streets At the meeting, U.S. EPA staff will describe the cleanup options being considered, and will accept oral and written public comments.

Copies of the feasibility-'study are available for review at: Hamilton Municipal Building, (city manager's office, 20 High St.) Miami University (science library, Oxford Ohio) HAPSO (522 Butler St., Hamilton)

FOR MORE INFORMATION: contact Maryaret McCue, U.S. EPA Community Relations Coordinator 312-886-1728, or toll free, 1-800-621-8431 (3:30-4:30 weekdays, Central Time) I...-. =, \VUUH Environmental 'E\VS RELEASE

f'ort-j.:«.t •! -'.-.I:-,-* i :•)•<; S*-:?- -9=

For Tianediate Release: December 14, ll}£4 Me. '14-295 u.s EXTEWS PUBLIC oiJwr..,:T fjy TOR ;>:L^-DYKE ^

Tne ?i.S. Lfwi'*ciwental Projection Ayenty (:-J.S. E?.\) P.e^lon V or»--jo«v-c:.a

that U Is ext?nd1r.g the ;)uhlic cr.'iwent .>er1o«j DO j f«?a£i3i:Uy

study of the Chew-Dyne ha*«rJo:is i«stc sUe •"» M^wiitur, 'JH. C?>aent3 wil!

de accepted until December ^3, "i7R-.

fh« feasibility study evaluate'* options fnr J-iai.'Mt with cont *:-••! na'.icr.

at the site. It 1s U.S. E.°* policy to consider the puftnc coa>«.i's when it

chooses cieanup options for a "ozardo-is wjs*? s:ti.

es cf the feasloility s^::dy «nv .iv. i'cri^e -o*" :-«;R':C

city n'naQer'^ orfici, c-'ia f-:?oo- J-* : - vrs . v_. v._i.;i..t.

•>fo"l, «r-(t the Har.:: UGH A(jp-L»ciiiar. ''-.-.•, ;.-••<• . ••'— c*- ••;•;:-.

ui~;:z-r in HaRi*ton.

uO-Tisnts v-r» r>i itJ.J« *iy v >ont .; vu' Mir.-: Mc~ , . . ^r'

Region v, 230 S. Dearborn St., r.fc1c*go. :i iv.jf'i.i. * * * t

to Editors: This is a fa11o*up to EP^ release Ko, S**--"1?1;, issued

21. n?-4. Appendix D V- ., PUBLIC COMMENTS

GLT267/53-4 Appendix D PUBLIC COMMENTS

PUBLIC COMMENTS ROSTER Appendix D lists persons and organizations who submitted public comments on the Chen-Dyne Feasibility Study. PUBLIC MEETING COMMENTS The following persons made statements for the record during the public comment period at the public meeting At the Hamilton City Hall on December 3, 1984. Name Affiliation 1. Town Peterson Oxford Audubon Society 2. Jerry Poje Oxford Audubon Society 3. Peggy Collins League of Women Voters 4. Philip Combs Miami.University 5. Judy Gillens HAPSO1 6. Michael Fox Ohio State Representative 7. Mr. Gallaigl Citizen HAPSO, Hamilton Appalachian People's Service Organization. WRITTEN PUBLIC COMMENTS Data Affiliation

1. Judy A. G1114 9/13/U4 Executive Director, HAPSO 2. Andy Garcia-Rlvera 9/28/84 Oxford Audubon Society 3. Town Peterson 9/28/84 Oxford Aodubon Society 4. G. David Reese 9/28/84 Oxford Audubon Society 5. John Lahorra 9/28/84 Oxford Audubon Society 6. Jerry Poje 9/28/84 Oxford Audubon Society 7. Paul E. Woods 9/28/84 Oxford Audubon Society 6. Donald G. Schirmer 12/06/84 Board of County Commissioners, Butler County, Ohio 9. Cale L. Logsdon 12/06/84 Board of County Coe»i»« loners, Butler County, Ohio 10. Donald L. Dixon 12/06/84 Board of County CoavUaioners, Butler County, Ohio 11. Lela Frechtllng 12/06/84 Citizen 12. Louis C. Sobngen Undated Citlsen 13. Elizabeth L. Sohngen Undated Citixen 14. J.P. BacXar 12/06/84 City Manager, Hamilton, Ohio 15. William J. Karvi*ch, 12/06/84 Director of Health, Department D.P.M., M.P.H. of Health, Hamilton, Ohio 18. Earl Chovning 12/11/84 Citizen 19. Wanda Chovnlng 12/11/84 Citizen 20. George Cnovning 12/11/84 Citizen

D-l Data

21. 13/11/84 CitlMD 22. Jetta Arlln 12/11/84 Cltlxan 23. Bay 12/11/84 President HealUnn Cbaptar Isaak Raltoo L. Bald, CKS, 00 12/11/84 Varrtab and Bald •ary S. loaf Cer (Mated Cltlxan C. Bobberd 12/12/84 GarclaHtlvera 12/12/84 12/12/84 12/12/84 12/12/84 U/12/M 12/12/84 12/12/84 12/12/84

12/12/84 12/13/84 12/13/84 12/13/84

39. ttbelda F. 12/14/84 40. Dcvld H. Carter 12/14/84

41. David 1. 12/14/84

42. 12/14/84 43. 1th 12/14/84

12/14/84 45. Stanley •. 12/16/84 4C. TJaotbr 6. 12/21/84 47. Jeoalyn BBM 12/22/84 4*. CbarlM I. tuaila, Jr. 12/28/84

49. tarry J. 12/28/84 lac.

PUBLIC COMMENTS

PUBLIC MEETIHG COMMEHTS given as «tar«8i«nt» at the December 3, 1984, public tting were recorded by a court reporter. The transcript of the cosjBent period portion of the public meeting is presented in the following pages (A complete transcript is available from U.S. EPA Region V by request.)

D-2 49

•tripping technology option is on* that h«» been used at a number

of sites* both here in the Great Lakes area and around the

country. Capping* again* im another type of alternative that has

been used in other cases* am mentioned earlier* sometimes with

not complete success. Again* that is why we stress that with any

type of alternative selected there would be full wonitor ing of

anything that is installed.

Soil removal is pretty much tried and has been done.

There were some experimental alternatives in the report that have

not been tried to a great extent. Some of those were screened

out. Z would say both ways* some have been tried* some are more

experimental.

MS. McCUEi Why don't we take a real short break, and if

people want to make comments that didn't sign UP* get one of

these blue cards and fill it out. If you had planned to say

something and don't want to comment* come forward and take your

out« (Short break.)

MS. McCUEi O.K.* what we are going to do here is I nave

8 people who want to comment. If we give each person five minutes* that will be about 40 minutes. If five minutes isn"t

enough time for someone to comment* they can come up afterwards

and make them longer.

What I want to do is call people UP in the order they n signed UP. What I would appreciate your doing IB comm to the

Microphone* spell your last naee or your whole nape* so we can get it for the court reporter. And this is the part that we officially Mill take into consideration during the responsive sueatary where we are required to say why ee took a coeevent into account and why we didn't if we don't* and so we have to

Justify our response to your coeaents. This is a pretty ieportant part here. \,

If you happen to have your cos*ents also written* it would be helpful for us to leave a copy of it if you could do that. And* again* anybody is able to send any written consents they have until the 14th. 80 we will start out with five

•inutes which I feel should be plenty of tiee* I think, for most people. But if you have something lengthier to say* we will set your tiee at the end. O.K.

The first person is A. Town Peterson with the Audubon

Society.

MM. TOWN PETERSONS I will keep this short. I would Just like to bring to your attention and eake sure that you arv going to address the subject of the usage of fish taken froe, the Ford

Canal. In two or three of your alternatives in the Feasibility

Study you state that the Ford Canal and the Great Hia»i River

ild be available for use of recreational or sport fishing. I

ild Just like to coeeent that in that area of the city and in 51 this arc* of the country sport fishermen arc not likely to go to such places* and I would suggest that the people who do fish in the Great Miami and the Ford Canal are the people who eat the- meat. And I have talked to quite a few people from the area who have told me that the prime usage in the area is for eating.. So Z would like you to reply to what steps would be taken * to reduce access and to increase the education of people concerning the dangers of eating fish taken from the great Miami River and the Ford Canal. Thanks. M8. McCUEi Thank you. The next person is David Morris. Is David Morris here? O.K.« well* if he comes back in* we can get him later. Hilton Skipper. Is there no Hilton Skipper? Is Joe Poje here?

MR. POJEi I suppose some people are embarrassed about coming UP* having their name called. The first thing I want to say is that we have been given this document ~ as of last Tuesday it was received in the library at Miami University ~ and have been asked to give commentary as of the 14th of December. I think in our discussions that ww had this afternoon I made mention that there would be an extreme amount of difficulty to get a lay group of concerned citizens together to adequately address all of the points that are brought in this Feasibility Study and that we are a little bit dismayed that the comments that we had prepared for the Remedial 3'

Investigation haw not been responded to at this point in tint*.

Therefore* as a concerned citizens* group* we are faced with the task of wonduring whether the comments that have bean put into c the Fsasibility Study, incorporated* are sizeable questions about

the validity and extent of sampling that had been oone during the

lial investigation.

If I can make use of your own overhead* I would like to

>int out a couple of things that I think should go into our

itions about sampling. First of all* we understand that the great bulk of the proposed alternatives to this particular investigation are based upon the endangerment assessment* and the endangerment assessment as proposed in Chapter 2 of this study assimilates and apparently integrates all of the information that was generated during the Remedial Investigation. Therefore* the concentrations of Chemical X in the groundwater that would be determined at that point in time forms the basis for estimating proposed increased cancer risk to a population from drinking water. The concentrations that were measured in soil at that ti»* are the basis for proposing increased risk to people walking on the site* concentrations on the on-site facilities that were measured at that time are the basis for clean-up of those on-site facilities, we* in our address as of September 26th* I believe* made some rather seering inquiries as to the extent of sampling.

We are very happy with what the State EPA had done to date, we 93

did not mean to criticize your action* but what we want to say i»

that as citizens here* us- are wry much concerned about as to how

our material can ba> — how much we can assume of the material that you pointed out to us is actually safe.

Let me Just take UP that one picture that you have* and we will Just use* for example* again* because I Just want to

reiterate some points that have been made a while ago. We know

that there was quite a bit of sampling done on site* and if we

follow the boundaries of the site here* we can see the bulk of what, was done. As far as we could imagine from the Remedial

Investigation* four soil samples were taken off site to estimate contamination of soil and potential leachable materials into the aquifer off site.

Cne of those samples was taken in the middle of the ball field! another one was taken in somebody's back yard? two others were presumably taken in this area here and were highly contaminated. The center of the ball field* obviously* nobody took a barrel out there and dumped it. Somebody's back yard* nobody took a barrel out there and dumped it. The two areas that were off site* close proximity to the site* were heavily contaminated. From your own picture here we see high peaks of contamination in this area here* and the highest peaks in this north end are off site* indicating that the points* hot spots of concentration of this material fall into that particular area and : »

•has* in that particular area.

lut what we are very much concerned with is the proposed actions on site* we are going to miss this additional material C around site. As 1 said at the close of the meeting in June* we are very much concerned about this being a closed- ended remedial action or closed-ended solution to the problem of Chem-Dyne. We believe that there are perhaps still many, many unenamined questions out there of contaminated sites. \

Poms of the things I would like to see done is a much ~. more systematic* overall survey of the site. Perhaps that is incorporated* although we haven't assimilated all that information from this report. We are very much concerned that cursory information saying there was obvious contamination in building No. X is not a scientific way of approaching the problem of chemical contamination. If we can see ugly paint* plastic N material laving in there* yes* we can see that* but I am telling you right now* I can't tell you what mercury-salt contamination should look like on soil or should smell like on soil, and it only can be done with very hard analytical evidence to be able to address that.

gome of the strategies that are proposed on site, say* removal of soil, we don't know ho» deep all of the soil should be removed. How will that be addressed, if that iVan accepted ^ treatment strategy. Zf we don't know where all the hot spots are S3

right now* how are we going to address protection of groundwater

based upon an unknown factor. If tarn don't know how many of those

areas of those bui11dings are contaminated. How are we going to

assess whether we should demolish them and cart them awaw or

leave some of them standing?

In Ford Canal we know that the fish are contaminated with

PCBs right now. It is not scientifically logical to assume that

the site at Chem-Dyne is not responsible for that. Even though

^r there are fish upriver that have PCBs* we know there are PCBs on

the Chem-Dyne site. We knew PCBs can accumulate in sediments.

We know fish can accumulate material consumed from the sediments*

and therefore we say this is a real risk to that particular

site.

And as we have said before* there are people who have

consumed that resource and* in fact* there is more reason than w Just personal consumption of that resource to be concerned about it. We want it* as the National Contingency Plan saws* we want a

feasible study* one that is reliable and one that protects public

health* the environment and our institutions of this city. We

are at the bottom line of protection of public health* and where

the environment lies* I think* is something that is to be

discussed in dialogue* not in a monologue.

There will be additional commentary coming from our

group* but* like I said* it is only going to be cursory* because we are limited in terms of time as to how much we can present.

Thank you.

MB. HcCUEi Thank you. I wouldn't normally comment on

somebody's comments* but in this case there are a couple of

things I want to say. On* is that what Hr. Poje is referring to

is that the group ho represents that he has Mack* momf commant on

the Msflwdial Invsstiqation to th» a««ncy and M» havvn't

r«s»onosd to tha» y»t. I think what «• Mill do is incorporats

thss)« consider thoss- to b» current cosaisnts< and •• will respond

to thss) alon« with all ths- othsr cosaants* bvcaus* it sounds lik*.

that's kind of what you wars addressing this swnine. So w* will • trsat that as coMwnts r»c»iv»d during this period* and we will

respond to those officially.

The other thin* is on the content period we dc normally

have a 3 wsali public coement period. We have had SOPS people

express to us that three weeks isn't enouah time to evaluate such

a lone* technical report. There is no arsuaent from *e; I agree

it is very technical and long.

We have a couple of constraints that we are working under

that are pretty ieaediate. One thing is that we are due* if there

isn't a settlement* we have to go to trial in early January* and

we do want to have people's comments and a decision made on how we want to approach the site before we go to ti*ial.

The other thing is that we want to have people's comments 31

before we settle. So our concern is that if we extended the public comment period* that perhaps the comments wouldn't work

their way into the decision-making process as well as they would

if we followed through on Just the three weeks. So I Just want

everybody to know that that is where we stand there. And we recognize the difficulty of commenting on something so technical

in so short of a time.

On the other hand* the addressing of comments that we have

had so far have been very impressive. So it seems that people aren't really having a problem addressing them. So* thank you.

The next person is Peggy Collins with the League of Women

Voters.

MS. COLLINSi Six months ago it was a little warmer as we were all gathered here. The problem is still the samet water is our most valuable natural resource* and I am speaking as the

Chairman of the League of Women Voters in the Hamilton-Fairfield area.

e have a position in natural resources in which we strongly promote an environment beneficial to life* and included under our water management provisions we urge that we insure —

•we" being the country of which we are the stewards — to insure the safe treatment* storage* disposal of all wastes. Obviously*

Chem—Dyne is a lovely* big waste dump in downtown or north vnd of

Hamilton* and I1 took the time last week to pore ever the large n

>tt and X caM UP with MM InterMting f Ml ings* f Ml ing very strongly in particular about the importance of good* clean, safe groundwater.

And what I read in the report* I Ml lav* it Mas in

Section 2* that within threw years Hercy Mils and the other industrial valla would very possibly have groundMSter contaaination within it» «Mlla within two u«ar«. and I rvad further down to aaa that in nina uaara la ia wrw poaaibla that the- walla in south field could be contaeinated, which Mans not only the drinking water of Greater Haailton will be affected.

The south field for Haailton is adjacent to the field where

Fairfield is pushing their water, which eeans that the City of

Fairfield will have water which is contaminated, and right down the center ia the Charles Bel ton Plant, which Means the northwestern section of Cincinnati* Hamilton Countw* will be also having their share of unpleasant water, no longer clean and potable. So* therefore* again, I urge* let's get going. fj}

I m» looking at charts, looking through the report*

Picking and choosing SOM various ways. There are a nuaber of iteas that need to be addressed, an overall pragmatic view.

Definitely* va need to get rid of the buildings. They need to be disposed of safely. We need to take these buildings down.

Nobody has addressed this this evening. Last June several people got UP here and testified the fact that people were getting in. 39

breaking into the fences* getting into an area which i» contaminated with lord knows what. We need to get rid of them*

but don't hid* them under the rug. We have to safely dispose of them. How you do it is not my concern. My concern in that it get don*.

Number two* I think v*ry definitely w« need to consider

on* form of your groundwater extraction treatment. I think it sounds quit* interesting* b*cau»* th* wat*r which is starting to r*ach th* plum*s n**ds to b* tak*n out* r*mov*d as quickly as possible. That would b* Just on* ar*a.

Th*n l*t's 9*t rid of som* of th* soil* th* parts* say th* thr**-quart*rs of it that would b* th* most d*l*t*rious. Get rid of that* safely* again* and dispos* of it. Again* th* probl*m is not min* wh«r* to do it* but w* need to do it in a safe Place — w* remove the soil containing the most serious contaminants and then w* put a clay cap cov*r over it to which

then* to my understanding* would prevent the rain which falls* luckily — w* want things to grow green — w* hav* an av*rag*

40-inch rainfall this year — th* rain* as it falls* will not b* percolated down through the clay cap* therefore* the contaminants which are th*r* now hav* less chance of moving out to th* south or w*st-southw*st area into our aquifers. We put on a clay cap*

cover on top of that* we put some lawn so w* can hav* som* grass to grow* so at least it will giv* th* appearance of looking a little better. Psychologically we will feel better, because we

Mill know the IOSM is O.K., we will know soMething isn't going to

COMS UP through the clay and* again* the necessity of Monitoring. lut let's get Moving, folks* Please* because nine years is a very short tie*. Thank you.

MB. HcOJEi Thank you. We have next Philip COMDS with

Mia*i University.

MR. CONBS* I aM a student fro* MiaMi University. I have

Just coMPleted a study on application of sewage—slushed far* land regarding heavy *stal concentration. I have noticed and concluded fro* various studies done and published in the Journal of Environmental Quality that local treatment plants have problCMS dealing with the waste that they treat in sludge. Yet I know it inevitably ends UP on far* land. Since local

Municipalities have an inability to extract heavy Metals. I would assuss that they would also have a proble* if you utilize that particular Methodology to try to get rid of so*e of your organic

Materials. In other words* it is going to COB* full circle again. I suggest that the option of off-site groundwater ( treatMent utilizing local sewage facilities be rejected for that

•ticular

X also suggest that you process in a tMO—fold Manner that

P of that topsoil layer to prevent the leaching plu*e fro*

eading, which this lady has coaspnted on. It SSSMS to be a 61

able means of trying to encapsulate that. gfr Also* as Z have indicated* Z have a preference for direct discharge* since this can be injected in substrata layers and* hopefully* encapsulated.

Z would like to go on record while I am here. Most people think the quality of water is drastically deteriorating.

We have a great problem with that. Z am from the Middletown area. The EPA has a test well there monitoring the leachiate

Plume that is spreading- down from a local land-fill area about

900 yards upstream. We have about 17 known carcinogens following that leachiate plume* and they are coming toward Hamilton. They are going to reach Fairfield* and they will inevitably be in

Cincinnati and cities to the south of Middletown.

We speak in terms of tyring to deal with these problems as best we can. Yet it seems like we are always too late. Z have noticed in one of the -texts that is published and we were using at Miami University this particular semester that about 80 per cent of the dump sites in the United States are located close to waterways. Z think invariably there is a problem there* also* that we have to address in the sense that we can't go on making these same mistakes over and over again. We have that problem in

Middletown. You have another dump site in Butler County at

Woodsdale that is going to have the same problem. We have it here in Hamilton. All X am saying, folks* Is we have got to do •pssthlm about this* and ws should do it vsry quickly. Thank ueu.

MS. HeCUEi Thank uou. Z sss Vincsnt Dslaudsr cas* back in. Did you want to asks momm cammwntm now* or will you wait?

MR. DELMfDEfti I will wait.

H8. HcCUEt You will wait. Ths nsxt is Judy Sillsns* who is with the Hamilton and Appalachian People's Riwr Organization. and while she is walking UP here, X would like to thank ths City of Hi asii sours for havins copies available for people who have bssfi coa)in9 and rsadins1 tha*.

Nl. CILLENBi I hats to brinq up a dsad hors* aflain, but ths Isttsr that was ssnt to you in rssards to thv rsaadial invwstisation that was datsd S*PtMb*r 28th of this war, I bslisvw you Just asntionwd a littl* bit a«o that you would hav»

its to us aftsr the two~wMk coMMwnt pvriod* 3'^tswks coMBwnt

-iod. That is what I was volng to ask.

MS. HcCUC< Yss, ws will do it as part of the suMMry.

H8. 6ILLCNSI I M dissatisfisd with that answsr to that

ts«« bsin« that thss* ^usstions that ws hav« hsrs* ths answers that ws rscvivs hsrs would h«lp us in bsin« abls to

it on ths Fsasibility Study. If ws havs- a docuswnt that is

tisatsly an inch* inch-and-a-half thick and ws haw thrs*

cs to cosswnt on that docuasnt and you havs> a 6-pass Isttsr and two sonths to cosasnt on ths 6~pa«s Isttsr* I think it is not A3 unreasonable to ask you to comment within a week so that we can apply these answers to these questions and to our comments in the

Feasibility Study. That is on* thing I would like to start off with.

There are a number of things already in the Feasibility

Study here we are concerned about. One of them i« th« demolition @ of th« buildings that P»99U Collins m«ntion«d. That is a major concvrn of ours and a beginning of •ndvavor. I mentioned* I b«li«v«, stvam cleaning would be a »1 mi 11 ioni and the entire demolition would be *1.2 million* that the demolition of the buildings would be cost-prohibitive. I am a little concerned I maw be interpreting that wrong? but I wonder as to whu 42081*000 in the scope of the ultimate cost* why that would be cost- prohibitive* Just that little additional sum.

Also* the air-stripping method* I believe it would onlw address volatile organics and not nonvolatile organies. So I /^Uy> think that would be imcomplete as well in addressing all the kinds of compounds that we have on the site.

Also* I am not sure* but the EPA in the past said that they would disregard* simply due to cost* anything that would address the nonvolatile organic compounds. I am wondering as to whu one option is not being looked at simply due to the cost- prohibitive factor* being that the generators are not going to court until the first of the year* being that at that time you 64

Mill be addressing the issue of hOM such you Mant to obtain for this site for the clean-up. So then* therefore* Mhy should a

Methodology of clean-up be denied si»ply due to cost Mhen you can ask for that cost to be supplied by the generators Mho caused the

out here to begin Mith.

O.K.* one of the other things that Me have Mentioned

lin has besn the soil. Thers SSSMS to be a lack of soil

»ling that Me have out there. I aM extreeely concerned over the fact that Me have addressed concerns over the remedial investigation* and MS feel that a lack of sampling has gone on at the facility. We feel it is inadequate* that it has not been applied to this point* and Me. as residents in the area* one that

Me have felt Mas of great concern* Mhy hasn't the EPA responded* or Mill they truly respond to our concerns over the Feasibility

Study* as they have not rsspondsd to our concerns for the

lial investigation? X understand that you May have

»laints* coMMents* either May* but Me have not heard one May or the other. So I aM Mondering* you knoM* if Me are going to get any adsguats response from the Feasibility Study as Mell.

The fish siMpling has also been Mentioned* and the PCB content out there* in viOM of the Kovacs out here* the residents of the city have found ChSM-Dyne Materials all over the area.

They are on River Road. In your report you have the fish kills in the area* a 37-Mile strip along the Great HiaMi River that is 63 directly attributed to Chem-Dyne PCB contaminants in those fish _ kills. So why* again* therefore* is the fish contamination out ^ there not related to Chem—Dyne in your Feasibility Study? Why is that stated as such? O.K.* the last comment that we need clarification on is unofficial* but the industrial wells. One of our committee members asked at their meeting* "What would happen if the industrial wells were to be contaminated?" Z believe — is the • Champion well contaminated? At the industrial hearing — MR. BRUCEi One of the last samplings that we did at the Champion wells did indicate trace levels of three contaminants. We could not make a direct correlation of the contaminants with Chem-Dyne* however. There were contaminants that were found in Chem—Dyne* but they are also commonly used chemicals that caul? have been coming in from the sewers. MS. GILLENSi O.K.* Z thought that the Champion wells* contaminants had been found out there* and Z am glad you referred to that. Z was told that your response to* if there was contamination in the industrial wells* that nothing would be done about them. The question was asked if they were found to be contaminated* would they be shut down* and you responded that nothing would be done about that in that manner. That was the other thing Z had about the industrial wells. MR. BRUCEi That was not the response* that nothing would MS. CILLENSi Pardon?

MR. BRUCEi I don't believe the response would have been

that nothing whatever would be done. The response was to the

•uestion of the trace levels of the contaminant in one well and

whether that would be cause for shutting wells down* and 1 stated

that it would net be done.

MS. CILLENSs At this time* if contaminants —

MR. BRUCE* If specific concerns —

MS. CILLENBi If contaminants would be found in that

well* that would be an option?

MR. BRUCEt Yes* that would be an option. Something

would be done* I am sure* if contaminants have bean found above a

concern level. Current levels are not high enough to give

concern.

MB. CIULENBi I Just wanted to get clarification on that

point.

MB. McCUEi Thank you. You might have noticed Don nod

his head when Judy asked whether then could have a response to

their earlier comments within a week* and Don is the one who is going to have to do it, and he has agreed to it. So forget what

I said about the Feasibility Center. So he has agreed to do it.

The final parami who has signed UP to comment is Michael

Fox* State Representative. 67

MR. FOXi First* I want to commend you all for being here and moving us closer to the clean-up of the site. Albeit a long time* it's still closer.

I want to focus on some specific things that I would hope that are part of the end product. First* they are based on certain rights that I think our community is entitled to. Frirst* our people have a right to know the risk that we are being asked to take at all times. Implicit, in that is a predetermination of what is at risk* be it the wells that are used for industrial purposes* be it our water supply* be it our fish* aquatic life* whatever it might be* identifying what things are at risk and what are the risk thresholds in advance. It is list of those thresholds. At one point* for example* as the contaminants move either outward* vertically or horizontally* at what point does it pose risk to various parts of our community?

Secondly* in the context of predetermining what the risk factors are and the thresholds that trigger those risk factors* we have a right to have a monitoring system that adequately tracks that risk at all times during the clean-up Phase.

Finally* with respect to the right to know the risks we are being asked to assume* I believe that we have a right to free p and unimpeded access to this data as it's collected and that at 0 predetermined intervals at release of this information should be established and adhered to* so at no time will there be a moment when any citizen of this community has any doubt about exactly what the risks are.

X feel strongly about that because of the history of this site. There has been a history of hide-and-seek* there has been a history of information being hard to cos* by. There has

a history of people being confused* aisled and at times have

lied to about what the risks were* what measures were being taken to deal with those risks.

Secondly* 1 think we have a right to an adequate response to those risks as they are determined in terms of the resources that are expended at the agency. This is why I raised the question in the question period abouts is the time frame and the technology that you have chosen a function of your budget or a function of what is needed to adequately protect our community and to* in a timely manner* clean UP the site? If it is a function of your budget* then shame on you. The proposals that you should be making should be based on what is necessary to* at all times through the clean-up phase, adequately deal with the risk as you found it.

Let me make a side comment with respect to the case that you mentioned. By way of advice and comment* take no position in your litigation that in any way compromises your building clean-up at the site. Cut no deals with industry* cut no deals with the generators* cut no deals with anyone. X would suggest 69

to wou that the EPA in in the driver's seat* that those people who were found to have disposed of material in the site haw

Joint and several liability* that any on* of those generators

could be assessed exorbitant amounts of clean-up bill. You have

a club as big as has ever been given any agency in the history of government* and you don't have to be compromising in your

dealings with them. And at no time should any "Compromises be made that affect timely* full clean-nip of the site.

Finally* we have a right to trust and believe that you are doing everything reasonably possible to protect our community

and the right to believe that you will never betray that trust.

On that note I will conclude my comments* becasue I think if

there is one thing that you can accomplish beyond the immediate task and goal of cleaning UP this Chem-Oyne site* gou can do a lot

towards restoring the confidence and trust of our people in this community and the agencies of the government. From the beginning of the first day I received a call from my constituents on the north end* we had been told repeatedly by* first* Mr. Kovacs himself* saying* "Trust me. We won't hurt you** then by various government agencies and arms of agencies* "Trust us* we will solve it*" throughout this period. So often that trust has been betrayed. You have an opportunity to restore that* and the restoration of that trust will be a function of the competence and 71 diliaanca Mith Mhich you pursue this goal* and I Mould encourage you to laava no stona unturned in doing that. We Mould appreciate that vary auch. Thank you.

MB. HcCUEt Thank you. Boas body Mho signed UP before now has his hand UP. Are you wanting to aake a coaaajnt? Why don't you coae UP? Hr. 6allaigl* Mho is the seventh one.

MM. 6ALLAI6L* I Mould like to reiterate what I asked earlier. That is going on a scientific* technical point of view.

One is MS Mould like to be sure that the EPA takes a auch aore

riantific aethod to Pinpoint the actual extent and rate of the

illution* because this could really affect the timetable for

lial action.

Tha newt is Mith regard to Metallic poisoning that haa

found in fish in the Hydraulic Canal. You have given ae

"ml reasons for not tasting for aetallic Poisons* but I think this could be a very serious problaa.* because you raaaabar soae years ago salt of e*rcury« Mhich is a very heavy »etal and supposedly conesdad to sink to the bottoa* have coabined Mith other eleaants and bacoaa Mater—soluble as aethana of aercury and have been ingested by food fish* and that is Mhy there Mas a ban on SMordfish for a Mhile* and I have seen aany children on tha river* as Mall as in the Hydraulic Canal fishing* and I a»

ae* take the fiah hoe* and eat the*.

Another question I'd like to pose to you is the effect of 71 catalytic or other chemical reactions between the pollutant and

the clay and the soil, because it im possible that there could torn

some reaction which would render the clay permeable or mortr

pourous* and there i» an incident in on* month, you know* I think

it was in the paper recently about an encapsulated wast* storage

where some chemical reaction had taken place and r«nd«r«d a

bottom r»««rvoir lining d«f»ctiv« and allowed som* chemicals to

•••P through.

Vr On* other question I have to wou people is whatever you

make election for, EPA* in connection with the brochure, we would

like to be sure that removed soil or what not would never be any

i additional contamination or contamination of other sites. And

I'd like to also be assured that whatever remedial action the EPA

undertakes* it is not dictated /so much by whether thew have a

large fund or not but whether they have concern for the healt. h of , the people who live in Hamilton.

And* finally, how about other sites in the area? I drive

on 128 on the way to work* the Hamilton-Cleves road* and I am

seeing): these trucks covered UP with something, and they dump — I

think there is a dump site along the river. And also there is a

duump site that used to be called Chemical Waste Disposal Site,

Schllchter's* but later on they removed the name "Chemical" from

the name of the place and Just used "Dump Site." But a few times

last year X was passing by* Z could smell some sort of a chemical 7'

liks sasllsd similar to what Z ussd to sasll whsn I livsd in St.

Loui» nsar ths Monsanto Chs*ical plant* and I was Mondsring about

possibls illegal dusping of chawicals in ths Schlichtsr land

sits* That is ovsr an aouifsr. That i» the saw* kind of a d»al

M» hav« over th«r«. And I'd lik» to know if th« EPA is doing

anwthin* about •onitorinv that sit* to mmmurm that •• hav« no

contaaination th«r».

MS. HcCUC* Thank you v»ru Much for all your coMwnts.

As «• said bvfor*. M will aeem>t any additional written cowo«nt»

until D»c«»b«r 14th. You should satid th«a to our offic«.

Mr. tellaivl* I think* on your 9u««tion about th«

possibility of illssal dus*in«« you probably ou«ht to talk to Roast

Hannon with ths stats* bseauss ths stats tsnds to handls that

•ors local typs of thin«.

I would aarss that ths psopls in Hamilton ars vsry

patisnt. I apprsciats your sittin« through what was a prstty

technical prssantation. Us will taks your eosssnts and

susstiofis frosi this svsninv and any additional onss you havs and

put tossthsr a rsaponaa and susnary* ssnd that out* and thsn ws

Mill bs back to dsscribs what MS finally dseids what to do.

Thank you.

(At 9i32 p.s.t ths ssstin« Mas concluded.) RECEIVED

Regarding Chem-Dyne Clean Op - Hamilton, Ohio

My husband ia a fourth generation Hamiltonian, ao for many years, we have rejoiced in collecting "old" photographs of much of the heritage of the city.

When I first noved to the area, some forty years ago, the

* area of Fordson Heights (quite near to Chem Dyne), was only one of many unique lovely home sites for those of modest means - how precious was the dear home there!!!

After quite a few years away from the area, to return and find the BLOT THAT WAS THE HORROR OF CHEM DYNE ON THE MAP OF HAMILTON

WAS A VERY REAL NIGHTMARE.

As all concerned citizens in today's world ask, "HOW COULD * THIS TERRIBLE INJUSTICE RAVE HAPPENED?' AND THE ETERNAL CRY

OF THE POOR AND DISAVANTAGED NEIGHBORS, "DOESN'T ANYONE

CARE?". • Do you REALLY know? Do you REALLY care?

If so, will you pledge your utmost to right this dreadful wrong? If we cannot trust those in authority, shall we not all perish in doubt and mistrust? For many years, I have lived far removed physically from the area of concern, but God forbid that I should ever forget

"MAN'S INHUMANITY TO FELLOW MAN"!!

PLEASE CARE FOR THOSE WHO ARE UNABLE TO HELP THEMSELVES - • CARE FOR THEM _CARE FOR YOU AND YOURS _ CARE FOR ALL

HUMANKIND. . We place our future in hands such as your own.

Mrs. Louis C. Sohngen, 2073 Sunset Drive, Hamilton, Ohio 45013 December 6, 1984 Mr. Don Bruce December 6, 1984 Page 2

of the citizens so that in future years they will realize that the soil that was contaminated was removed. We feel as long as the contaminated soil is allowed to remain, there will still be percolation of toxic materials into the aquifer and doubts will persist in the minds of all our citizens. » 2. Pumping of the aquifer. We feel that technology exists today that can be properly used to pump water out of the aquifer as the consultant suggests, and through the air stripping process, remove the contaminants and inject the clean water either back into the aquifer direct or be placed in the Ford Canal for placement in the river. The pumping operation probably will have to continue many years in order to cleanse the aquifer of all contaminants. This will insure future usability of the aquifer for this region, which we sincerely believe has to be accomplished to solve this problem.

3. Removal of the Chem-Dyne building. The Chem-Dyne building is contaminated and has been partially destroyed by fire. These buildings must be torn down and properly buried in a hazardous landfill. If not, these buildings eventually will create another environmental problem in future years.

We feel that if these three major undertakings are completed, the Chem-Dyne site will no longer be a threat to the aquifer or to the health and welfare of the citizens of this region. We sincerely hope that USEPA understands the significance of the aquifer for Hamilton and this area of Ohio. Finally, we would hope that the project would not be unnecessarily delayed through lengthy contracting procedures. We will work with USEPA and Ohio EPA in any way possible to see that some remedial work begins in 1985. We thank you for your assistance in what we feel is the most important environmental project ever undertaken in the State of Ohio. We will assist you in any way possible. Please feel free to call on any of us if we can be of any assistance.

Sincerely,

. P. Becker City Manager

JPBtdr cc: The Honorable Thomas N. Kindness The Honorable Howard Metzenbaum Representative Michael Fox The Honorable John Glenn Mr. Val Adamkus, Administrator, USEPA Region V Mr. Robert Maynard, Director, OEPA Mr. Lee Thomas, Asst. Administrator, USEPA Mr. Roger Hannahs, OEPA Mr. Hal Shepherd, Assistant City Manager 73

COURT REPORTER'S CERTIFICATE

I« Bcssi* J. Gibbsv Court Reporter* do hereby certify that the fore«oinno transcript is a true transcription of my stenotype notes takvn at the abov»-caption«d m««tin9.

I am not counsel» attorney or r»lativ» of any of th« parties or oth«rwis« intvrvstvd in thv «v»nt of this caus« and was* at th« tim« of taking th« msvting* a fr««—lane* court r»port«r in Cincinnati* Hamilton County* Ohio.

Dated this 7th day of D«c»mb«r, 1984. «,u &dM> Court R»port«r WRITTEN PUBLIC COMMENTS Copies of all written public comments on the Chem-Dyne Feasibility Study received by U.S. EPA are presented in this section. Comments appear in chronological order as shown on the public comment roster. GLT267/56

D-5 BOARD OF COUNTY COMMISSIONERS CALE L. LOQ8OON DONALD 0.SCHIRMCR DONALD L. DIXON MEOAI •UTtER COUNTY ADMINISTRATIVE CENTER • UOMOHST. • HAMILTON. OHIO 41011 • PHONE (51J) M7-UOO

DONALD •.MMU. DIANA MADFOftD Ctoffc ft KM M*r«

December 6, 1984 RECEIVED DEC1019J4 Ms. Margaret McCue U.S. EPA, Region 5 230 South Dearborn Street Chicago, Illinois 60604 Re: Chem-Dyne Hazardous Waste Site Hamilton, Ohio Dear Ms. MeCue: After reviewing the EPA Superfund Program Fact Sheet and Decision Matrix for the Chem-Dyne Hazardous Waste Site and hearing the presentation of facts, possible consequences and possible solutions to this problem by Mr. Don Bruce of the U.S. EPA at the December 3rd, 1984 public meeting in Hamilton, the Board of County Commissioners of Butler County, Ohio wish to advise the U.S. EPA of its unqualified support for corrective actions that will protect the citizens of Butler County and southwest Ohio from the potentially harmful effects of the Vrir remaining hazardous wastes at this site. It is our opinion that the corrective actions recommended by U.S. EPA should provide for a reasonable level of protection; be achievable; and be capable of being implemented within a reasonable period of time. The citizens of Butler County are dependent upon Ohio EPA and U.S. EPA to accomplish these objectives prior to the further migration of these waste materials through the water, air or soil to locations that would potentially affect the health and welfare Page 2 Ms. Margaret McCue December 6, 1984

of the people of Butler County. We consider our underground water supply to be the Number 1 asset and viability of our community and any threat to the quality and quantity of this water supply is the Number 1 threat to our community. We therefore plead for your assistance in bringing this matter to a prompt and satisfactory conclusion. Very truly yours, *. BOARD OF COUNTY COMMISSIONERS BUTLER COUNTY, OHIO

*-' .'vw Donald G. Schirmer, President

Donald L. Dixon DGS/CLL/DLD/db cc: Ohio EPA, Mr. Robert Maynard, Director City of Hamilton, City Council City of Hamilton, City Manager U.S. Senator, John Glenn U.S. Senator, Howard Metzenbaum U.S. Representative, Thomas Kindness Ohio Governor, Richard Celeste State Senator, Buz Lukens State Representative, Michael Fox State Representative, William Donham State Representative, John Boehner .J*. h)c

RECEIVED 101984 . iri .'i! \; i ' Hamilton, December 6, 1984

Mr. Don Bruce -_ — f* C I V E U. S. Environmental Protection Agency 1C C V 6 • w fc

230 S/Dearborn St. DEC 1 1 1934 Chicago, Illinois 60606

Dear Mr. Bruce: -, 1 would like to take this opportunity to thank you for your assistance In presenting the feasibility study to the citizens and staff of the City of Hamilton on Monday, December 3, 1984. Your previous work in the cleanup of the Chem-Dyne site is most appreciated. Of course, this is not a new problem to the City of Hamilton since we have been in litigation against the Chem-Dyne Corporation since 1976 and have worked toward the final cleanup of this site with the help of Ohio EPA and your agency.

We hope that the final cleanup of the aquifer, the soil and buildings will be as complete as the surface cleanup was in 1983. Your supervision of the surface cleanup was effective and efficient. Even though the explosion and fire potential have been eliminated, we are now obviously concerned with an even greater threat to this region over the next several decades. This threat is, of course, the contamination of one of the greatest water resources in the United States, the Great Miami Valley Aquifer. I am sure that you and your staff desire the final cleanup to be one that USEPA can be proud of and point out to other states and agencies how the Superfunrl can and should be utilized. The feasibility study continues to indicate to us the disastrous environmental problem that still exists below this site. In order for you and your staff to understand our concerns, I would like to mention three areas that we consider most important to the citizens of Hamilton as well as the people of our region.

Our greatest concern is to protect our invaluable water supply, which is threatened by soil and groundwater contamination in the vicinity of the Chem-Dyne site. The value of the aquifer for us is immense. This will continue to provide water supply for this region of Ohio for hundreds of years if it is not contaminated. I am not speaking only for the City of Hamilton, since the water is directly taken from the aquifer for the City of Cincinnati, Fairfield and all of Butler County, as well as much of Hamilton County. Certainly this water resource will be of greater value to this area as water resources become more scarce in the decades to come. Since we know where the contamination exists, it seems logical to us that we should do all that we can to protect this resource before it has a chance to be destroyed.

We feel that three steps must be authorized and accomplished to complete the final phase of the cleanup of the Chem-Dyne site.

I. Removal of all contaminated soil. We do not feel that a capping alone of the Chem-Dyne site is the safest and best method to be utilized. We are not requesting that all soil be removed at the Chem-Dyne site. We feel that the contaminated soil, which is in a depth of a few inches to a few feet, can be selectively removed. By removing this soil we will eliminate the concerns of all MP-V- LXJILDIMG • HK;H AND MON(J/-'"'-n STREETS 450!1• .^£ >^^. 513—866-5978

DEPARTMENT OF HEALTH

December 6, 1984 ^^^^R E C E I V E D DEC 111984 Mr. Donald Bruce United States Environmental Protection Agency Region V 230 So. Dearborn Street Chicago, Illinois 60606 Dear Don: The public hearing you conducted on December 3, 1984 was quite Informa- tive. As you can tell, interest in the Chem-Dyne clean-up remains Intense. Over the past several years, the Hamilton City Health Department has received innumerable complaints that our residents are suffering from health problems which they associate with the Chem-Dyne site. These complaints range from headaches, nausea and skin eruptions, to cancer, miscarriages and birth defects. A health survey will soon be conducted by the State and our local Health Department to begin assessing this situation. Aside from whatever physical effects may be found, one thing appears evident - the psychological and emotional damage Inflicted on the people living near Chem-Dyne has already been extensive. In order to provide some relief from these problems, the site must be thoroughly cleaned up. This can be accomplished by the following steps: (1) Removal of all contaminated soil. A capping process will not be a foolproof method over the long term to protect the aquifer. As long as this soil is allowed to remain, toxic materials will continue to perculate through the soil Into the aquifer. (2) Siphon the aquifer. Present technology can be utilized to pump the contaminated water from the aquifer and through the air stripping and carbon absorption process to eliminate the toxins and return the water to the river.

"This Agency is an equal provider of services and an equal opportunity employer • CRA 1964" Mr. Donald Bruce December 6, 1984 Page 2 Re: Chem-Dyne Clean-up

(3) Removal of the Chem-Dyne buildings. The Interior of the building are contaminated with hazardous waste and have been partially destroyed by fire. These buildings must be torn down and properly burled 1n an approved hazardous landfill. Please accept my gratitude for the progress you have made so far. I hope the rest of your work will be completed as soon as possible. Sincerely yours,

William J. Karwlsch, D.P.M., M.P.H. Director of Health mf *»*

« —

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RECEIVED07 DECU1984

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\ f Jthejzaak Waltdl ue of America JNCORPORATj

NATIONAL OFFICES • SUITE 1100 .1701 N. FT. MYER DRIVE . ARLINGTON, VIRGINIA 22209 • (703) 528-1818 900 Morman Road, Hamilton, Ohio U5013

'. (DICK) JONES (CA) December 11, 1984 d'lonjf X re e-PrfMi/pm ALEMENTNAU (IA)

T I (SO) Mr. Don Bruce lAuof•.HARRIS.stjiiuntlTreiturer . (VA) U.S.. -, . TTEP3A A RegioT>~.~-:~.-n~ Vtr Remedial Response Branch (AZ) 230 South Dearborn Street Chicago, Illinois 6060M ONAlDLHttB (OH) Dear Mr. Bruce: I lARDVANOWHOtN (IA) Chairman *m A. COOPER (CA) The Hamilton Chapter of the Izaak Walton League of e Chairman America is genuinely concerned about the cleanup of the < 'IN R. MEAKIRON (PA) Chem Dyne site. We feel that it would be helpful if the ONALOLFfRRIS (OH) agency would do the following: ONA1OC FREEMAN (IA) >l lORfRTLWRE(FL) t ILBI.K1AAS (II) 1. More fully inform the public as to what toxic materials are present and the hazards that the REDWIOLAK (IN) known substances present to the health of the « :HAtUSWIUS.lt. (MD) citizens. \ 2. A more extensive off-site sampling to determine the true parameters of the contamination by the toxic materials. 3. The potential number of water systems, therefore, the number of people who can be affected by the toxic wastes known to be contaminating the aquifer. The real interest and ultimate desire of our chapter is that all contaminants be removed from the site and the surrounding areas which have been contaminated by toxic wastes. If there is anything regarding possible publicity, possible hearings, that our chapter can participate in, we would be eager to do so. Sincerely,

President Hamilton Chapter IWLA

DEFENDERS OF SOIL. AIR, WOODS, WATERS, AND WILDLIFE RECEIVED

DEC 131984 : PARRISH if HAID insurance

218 SOUTH THIRD STREET, P.O. BOX OB. HAMILTON, OHIO 46012 • 1613) December 11, 1984

Ms. Margaret McCue 5PA-14 U.S. EPA Region V 23O South Dearborn Chicago, Illinois 60604

Chem-Dyne

Dear Margaret:

As an interested citizen and businessman of Hamilton, I urge you to recommend a complete cleanup of the Chem-Dyne site.

Knowing that you will be designing as you progress with the cleanup, you should set the standards that call for removal of the buildings, removal of the contaminated soil, adequate treatment of underground pipes and a complete cleanup of the underground water. You still have a few questions about the technologies at this point but don't be limited in your imagination or by the amount of funds - especially don't be limited to funds collected from third parties.

Historically, water has been one of the most important factors in the development of this community. Our underground water continues to be one of our greatest resources.

Do what needs to be done!

Sincerely,

Richard L. Haid CPCU CLU

RLH:pk ^ X**Cr • / •'T*'*"-^.

i , PecembeA 12, 1984

McCue RECEIVED 230 South. PeaAboAn Street nrr i . 1904 Chicago, Illinois 60604 M Re: Chem Pi/ne Site Feasibility Study PeaA M-6. McCue: FiA-it Of$ a££, I wo* veAt/ pleased to mad OjJ the Decent settlement with many o^ the. ge.n&iatoiA cont>i4.buting to the. contamination ofa the. Chem-Dyne. Site.. Second^/, on behalf of. The, WateA Aôcueticw, I expê4-4 out appêc-ca^con on the. efjj$a4£6 o^ U S EPA ^.n e.vaJLuating and pie-pasi-ing tlie. vaAx.ou-6 c£ea«-up- option* *u.bnu.tte.d to the. public, who m&y be. aêcted 6i/ îî u«)Jo^*iKuiê 4^.ûation. /ouA4fe£(5, Don BAuce and otneA member o(J ^ne U 5 EPA *ta^ did an admiiabte. (but not enviable.] job in pfieênting the. vasiiou* cte.an-up option* fa* pubtic. conment. I submitt the fallowing questions fan. you* consideration and Aeview. These may be covered in the feasibility study, however, I have not Aead the AepOAt. I have Aequested a copy o& the. complete Aeport tfAom the City 0(5 Hamilton but as 0|$ th-is date it has not been Aeceived. Pue to the. Pecember Nth deadline I fait it be^&t to at least comment concerning -the extraction wel-ls, which I understand are to be approximately SO1 deep with a capacity 0(J 700 - 750 GPM. 1. AAe the we-tls "cone o($ influence" intended to extend beyond the. outer parameters o^ 'the plume? 2. In detetmotcng the "cone o($ -tnijluence" , were exiting 0|J cu^txent induAttiat and municipal we£t* take* into con&ideAation? 3. 1)5 ex-cAting we^Zi wete taken -tnto account, wcw given to operation o& the-tA cuAAent weJLtt> at fait capacity, OA the po4J>ibility o& additional we.ll& fax. anticipated growth OA -cnCAeaêd demand? Thanfe

RobeAt C. HubbaAd, Manage* cc: hcipso HAMILTON APPALACHIAN PEOPLE'S SERVICE ORGANIZATION 522 BUTLER STREET • HAMILTON, OHIO 45011 (513) 868-O95O

December 12, 1984 Mr. Don Bruce U.S. EPA, Region 5 230 S. Dearborn Street Chicago, Illinois 60604 Dear Mr. Bruce: On behalf of North End residents, I would like to document a number of our concerns over the proposed treatment modalities itemized in the Feasibility Study Report: 1. "PACT is excluded from future consideration based on extreme costs." (Feasibility Study, 1984). Why is a form of technology which is rated so high for its effectiveness withdrawn from consideration simply due to cost; as the dollars for this cleanup are to come from the generators of the waste (i.e., the suit goes to court in 1985)7 This presents a rather poor picture of the U.S. EPA as an "advocate of the people;" rather it causes the U.S. EPA to appear as an "advocate of big business." 2. Structures; Steam-cleaning is unacceptable. It is both superficial and temporary at best. Complete demolition of the buildings is the community's choice. 3. Air Stripping: This technology addresses volatile organic compounds. How would the non-volatile organic compounds be removed from the groundwater; prior to returning this groundwater into our environment? 4. Soil Removal: The soil testing was sketchy at points (eg., only four off-site samples). How was a depth of two feet of soil removal determined and how are the "hotspots" to be identified? Such a plan for soil removal is insufficient unless there is a statement of assurance included in the package which stipulates that the U.S. EPA (Superfund) will be responsible for the cleanup of future hotspot discoveries. 5. Ford Canal (Sediment): A "no action" plan is unacceptable to the community. 6. Fish: As there were five fish kills between 1976-1980 credited to Chera- Dyne infour waterways, it is illogical to us to proclaim that the PCBs contaminating our fish could.in no way be attributable to Chem-Dyne;

A United Way Agency which is your contention for not addressing the matter through Super- fund. A "no action" plan is unacceptable to the community. i 7. POTW Plantt Use of the POTW plant as a groundwater treatment modality is unacceptable to the community due to the number of hazards such an option could effect. Thank you for your time and assistance in this cleanup endeavor. We will be awaiting your respone (s) to our aforementioned concerns. Respectfully,

Judy A. Gillens Executive Driector JAG:ebb RESOLUTION NO.

A RESOLUTION REQUESTING THE CONTINUED ASSISTANCE OF THE UNITED STATES ENVIRONMENTAL PROTECTION AGENCY IN CONJUNCTION WITH THE FINAL PHASE OF THE CHEM-DYNE SITE CLEANUP WITHIN THE CITY OF HAMILTON, OHIO. WHEREAS, the City of Hamilton has been involved in a serious environmental problem with regard to the Chem-Dyne Corporation and has been in litigation with such corporation since 1976; and WHEREAS, the City of Hamilton has sought aid and assistance from the Ohio Environmental Protection Agency and the United States Environmental Pro- tection Agency to effect the eventual cleanup of the Chem-Dyne site; and WHEREAS, the Chem-Dyne site is located above an extremely large underground water supply that serves the City of Hamilton, the City of Fairficld, the City of Cincinnati, and many other areas in southwestern Ohio; and WHEREAS, this aquifer has been partially contaminated as a result of the soil contamination at the Chem-Dyne site; and WHEREAS, said contamination must be removed from the aquifer and further contamination of the aquifer must be prevented; and WHEREAS, the Chem-Dyne site has the following three critical environmental problems that remain after the surface cleanup: soil contamination, water contamination and building contamination; NOW, THEREFORE, BE IT RESOLVED by the Council of the City of Hamilton, Ohio: SECTION I: That the City of Hamilton hereby request* that the United States Environmental Protection Agency remove the contaminated soil on the Chem-Dyne site to an effective depth and that the same be placed in a licensed hazardous waste landfill to protect the aforementioned aquifer from future percolation of hazardous wastes that arc presently contained in the contaminated soil. SECTION II: That the City of Hamilton hereby requests that the United States Environmental Protection Agency proceed with an air-stripping carbon absorption program to properly cleanse the contaminated portion of the aforemcn- tioned aquifer until the contamination is removed from said aquifer. SECTION in: That the 'City of Hamilton hereby requests that the United States Environmental Protection Agency remove from the Chem-Dyne site all buildings that are contaminated and/or fire-damaged so that the site surface will be entirely free of hazardous chemicals. SECTION IVt That the City of Hamilton hereby requests that the United States Environmental Protection Agency proceed with all possible haste to correct the three aformcntioncd critical environmental problems in order that further contamination of the aquifer can be minimized. SECTION V: This resolution shall take effect and be in full force from and after the earliest period allowed by law. PASSED: peoaiter 12, 1984 Effective Date: *"**"** . George V. McNally Anna Manna llukfcard MAYOR The undersigned does hereby certify the foregoing to be a true and correct copy of Resolution No. R84-12-69, adopted by the Council of the City of Hamilton, Ohio, at a regular meeting held on December 12, 1984.

Anna Manna Hubbard City Clerk City of Hamilton, Ohio GILBERT INSURANCE AGENCY. INC. — OontU 401 PARK AVENUE P.O. BOX 13139 HAMILTON, OHIO 45013 PHONE: 863-8989 December 12, 1984

RECEIVED Ms. Margaret McCue 5FA-14 DEC 1 1984 U.S. EPA Region V 230 South Dearborn Chicago, Illinois 60604 RE: Chen-Dyne Catastrophe Clean-Up Hamilton, Ohio Ms. McCue: As a life long resident of Hamilton, Ohio and a mother-to-be; I am very concerned about the proper and permanent clean-up of the Chem-Dyne site here. Our water supply is one of the most important resources we have. Everyone depends on our water and the reassurance that it is not contaminated* To adequately clean up the Chem-Dyne site, the Superfund money should be used to: 1. Remove all contaminated soil from the site - not the short term capping process 2. Remove all buildings from the site 3. Treat the underground water until there is no trace of pollution. Thank you for your help in this serious matter. We need a ._ permanent solution to protect our City from further contamination^ Respectfully* GILBERT INSURANCE AGENCY, INC.

Pamela E. Anderson Agent r^^555T

John P. Wheeler, Pros/dent "lntur«nc« CeriMr" John C. Dodsworth, Vice President Phone (513) 003 J«BI 868 3633

December 13t 1984 Ms. Margaret McCue 5PA-14 U. S. EPA Region V 230 South Dearborn •*ff-r»E'lVED Chicago, Illinois 60604 R fc w t »w RE: Chem-Dyne DEC 18^ Superfund Site Dear Ms. McCue: As a citizen who lives and has a business in this area, I am writing to express my concern about adequate cleanup of the Chem-Dyne Site. One of our greatest natural resources in this area is our underground water supply. In fact, this was the key factor for getting the Miller Brewing Company to build a new brewery in this area. This water supply is in peril unless the Chem-Dyne mess is totally cleaned up. From what I can determine, it appears that the EPA needs to remove the buildings and soil from the contaminated area, and then to continue to pump and treat the underground water until it is free from pollution. Any additional steps necessary to assure a total cleanup should also be undertaken. ••-.*-. ^> The concern of many people in this area seems to be that only a partial effort will be done because of cost considerations. This approach, as you know, would only postpone this problem and be more costly in the long run. Thank you for your concern about our problem and for the opportunity to express my thoughts. Sincerely, .

M«h i MclGnlvy, P.O. Bw 3116 HMifton, Ohio 45013 JCD:mf GILBERT INSURANCE AGENCY, INC.

401 PARK AVENUE P.O. BOX 13139 HAMILTON, OHIO 45013 PHONE: 863-8989 December 13, 1984

RECEIVED Ms. Margaret McCue DEC 1 8 1984 5PAr-14 U.S. EPA Ragion 7 230 South Dearborn Chicago, Illinois 60604 RE) Cham-Dyne Sita Clean-Up City of Hamilton, Ohio Dear Ms. Margaret McCue: I wish to advise you as a life long resident of Haailton, that I am very concerned about our greatest asset - our underground water supply. Since the Chen-Dyne catastrophe, I an concerned about proper clean-up of this affected area - not a temporary clean-up. I want to see full use of the Super fund (not funds collected froii third parties) to: 1. Remove all buildings from the site 2. Remove all contaminated soil, not just a plastic capping of the area 3. Treat the underground water until the pollution is removed. Thank you for your prompt attention to this serious situation* Respectfully, GILBERT INSURANCE AGENCY, INC.

Richard A. Gilbert President r pea American Society for Environmental Education

EttciMivc Offkt: - » heeler 1'rok-sg.ional Park PU Box MX I I'.O Box MNI Hanwer. N H. U."?< Hanoier. VH U.V735 10031 M.VWt. December 13, 1984 IK02) 2V-MIU RECEIVED FWU SUINNK ^ Niintucket. Mais. Himoran PmMcni— DEC 1 A 1984 Ur Uitiil K Scon llnrnKr NASA Aslronaun Margaret McCue Ldwardi. Calflurnu 5PA-14 Honoran Vfet-PraMnN- Mrs. Norman Vinctni Peak U.S. EPA Region V Sew N ork Cil>. New York 230 South Dearborn Street

Dr. William L. Ma>» Chicago, IL 60604 Norwich. Vi.

Vicr-PmMcm— Dr. J B Burncll Dear Ms. McCue: Cleveland State L mvcr>ii> Vicr-PmMcM for ProfrMM— These are comments on the Chem-Dyne Superfund Dr. Wesk-> llllnc> N'antuckci. Mat*. site as requested by interested parties by Vio-PuiMtm * S**f*un Tna December 14, 1984:, George Wahr Salladi- i 'i • Ann Arbor. Michigan The American Society for Environmental Education Ljvcrnr Alkn is a partial owner of this site, since the former Siraiham. N.H. Ford Motor Company Tractor Plant building was Dincior of U-rMtoc— Dr. James Joseph Calto|ther donated to us three years ago by Middendorff, I ni\crsilx Robson, et. al. We anticipate that the remainder •on tf of Tnulm- l)r. 'led K Andre*-. of the site plus an additional nine acres may Hoi Spciny> Vilbfc. Ark. be donated to us this year by the same group. Ur. J.B Burncll Ckxeland. OhHi Upon being approached for the donation, we checked Ur Arthur Ed«ard> New Brunswick. VJ. with the EPA both in Chicago and Washington and Dr James . I were assured that the property would receive E Lansing. attention for clean-up by the federal government. Alden Howard Hampton. N H. Subsequently, we were assured by the Attorney

Ur. Roger Locandro General of Ohio that, since we were owners after New Brunswick. N.J. the fact, that we would in no way be held responsible Roben Luhell New >, urk. New York for the contamination at the site. (>r William L M»>o Norwich. Vt. It is our intention, that since we are a national Mr. Mai Owmfs environmental education organization, and are Slumlord. Cl. committed to such education for the general public,. Mrs. Norman Vincent Peak- New York. New York as well as school programs; that we embark on ficortv Wahr Sallade an educational program relating to this clean-up, Ann Arbor. Michigan as was our original intent. We forsee that such IX David R. Scott a program could educate the public on the EPA's Edwardt. California role in such a clean-up using the site we own Dr. Wnk> Ti(Tnc> Nantuckci. Mau. ' as a mode|.. Since we already receive funding Dr. Jonathan Wen from the EPA-in the form of a training grant Harrisburg. Pa. under the Clean Water Act, we are familiar with the rules and regulations and procedures for such support, and intend to apply shortly for

Publishers of The Environmental Education Report & Newsletter \ American Society for Environmental Education December 13, 1984 Ms. Margaret McCue EPA Page 2

a grant to develop an educational film about this clean-up. Therefore, we will seek the support and cooperation of the EPA as well as the State of Ohio and other agencies and groups, including a major university. In so far as our comments on alternative means of clean-up at the site, we leave the technical decisions, of course, to the EPA and the State of Ohio. Although we might suffer some considerable financial loss if certain alternatives are employed, obviously the health and well-being of that community must be foremost in these considerations. Yours sincerely^-——-""""

i. Mayo, Ph.D. President

WLM/kdc cc: The Administrator, EPA, Washington, DC Pat Powers, EPA, Washington, DC Middendorff, et.al., Cincinnati, OH Dinsmore & Shohl, Cincinnati, OH Ohio State Attorney General, Columbus, OH City Manager, Hamilton, OH President, Miami University, Oxford, OH President, University of Cincinnati, Cincinnati, OH December 14, 1984 RECEIVED DEC 181984 Ms. Margaret McCue 5PA-14 U.S. EPA Region V 230 South Dearborn Chicago, Illinois 60604 HE: Chen-Dyne Site Clean-Up City of Hamilton, Ohio Dear Ms. Margaret McCuet I wish to advise you as a life long resident of Hamilton, that I am very concerned about our greatest asset - our underground water supply. Since the Chem-Dyne catastrophe, I am concerned about proper clean-ap of this affected area - not a temporary clean-up. I want to see full use of the Super Fund (not funds collected from third parties) to: 1. Remove all buildings from the site, 2. Remove all contaminated soil, not just a plastic capping of the area. 3. Treat the underground water until the pollution is removed. Thank you for your prompt attention to this serious situation. Respectfully,

Bthelda F. Blades 6400 Osage Drive Hamilton, Ohio 45011 Butler Soil And Water Conservation District

1810 Princeton Road Telephone: 867-5013 Hamilton. Ohio 45011 December 14, 1984 Ms. Margaret McCue RECEIVED U.S. E.P.A., Region 5 230 South Dearborn Street DEC 1 a 1984 Chicago , Illinois 60604 Dear Ms. McCue: Butler Soil and Water Conservation District is a political subdivision of the state of Ohio organized in 1942 by concerned landowners interested in protecting and im- proving the soil and water resources of the county. The district is governed by a board of five elected supervisors. The major purpose of the organization is to analyze natural resource needs and design and implement programs to solve soil and water conservation problems. As part of this responsibility, we have been monitoring the progress of the clean-up work at the Chem-Dyne Hazardous Waste Facility in Hamilton and have some comment!;' concerning the final completion of this project. There is no question in our minds that the Great Miami Valley aquifer is one of the greatest water resources in the United States. It not only supplies Hamilton with water but also the City of Fairfield, all of Butler County and much of Hamilton County. This underground water supply has been a major contributing factor to the development of the Great Miami River valley in the past and should prove to be of even greater importance to our area in the future as watee supplies become more scarce. Studies conducted by your agency have proven that soil and groundwater contamination is continually occurring at the Chem-Dyne site and that underground chemicals leaching from the site spread even further into the invaluable aquifer aa each day passes. Given the facts that all concerned realize the importance of the aquifer, the location and cause of the contamination, the potential harmful effects of inaction and possible solutions to the problem, it seems only logical that action needs to be taken Immed- iately, to protect this valuable resource before it is destroyed. After reviewing your agency's proposed solutions to the problem, we don't feel that we have the proper staff expertise to make a recommendation on the exact processes needed to complete the final phase clean-up of the Chem-Dyne site; however, we do concur in general with the recommendations submitted by the City of Hamilton and Butler County. We trust that the U.S.E.P.A. understands the importance of this aquifer to Hamilton and all of SW Ohio, and that the final clean-up phase is not delayed through lengthy contracting procedures. If we can be of any assistance to your agency or the Ohio E.P.A. in successfully comp- , leting this project, please contact our office. Sincerely,

**.'•• LJJU^L l^» f^LmOujGuj dd R. Brate, Chairman David M. Carter .Board of Supervisors District Administrator -* U\-:>;* :' -.'..'• City of; Fodrfield ^m-^^-M

OWMOltM Robert J.Gerhardt ClIyManagtf City Manager December 14, 1984 RECEIVED DEC 18198* Ms. Margaret McCue U.S. EPA, Region 5 230 South Dearborn Street Chicago, Illinois 60604 Re: Chem-Dyne Hazardous Waste Site Hamilton, Ohio Dear Ms. McCue: After reviewing the EPA Superfund Program Fact Sheet and Decision Matrix for the Chem-Dyne Hazardous Waste Site and hearing the presentation of facts, possible consequences and possible solutions to this problem by Mr. Don Bruce of the U.S. EPA at the December 3, 1984 meeting in Hamilton, the City of Fairfield, Ohio wishes to advise the U.S. EPA of its unqualified support for corrective actions that will protect the citizens of the City of Fairfield and southwest Ohio from the potentially harmful effects of the remaining hazardous wastes at this site. It is our opinion that the corrective actions recommended by U.S. EPA should provide for a reasonable level of protection; be achievable; and be capable of being implemented within a reasonable period of time. The City of Fairfield citizens are dependent upon Ohio EPA and U.S. EPA to accomplish these objectives prior to the further migration of these waste materials through the water, air, or soil to locations that would potentially affect the health and welfare of the people of the City of Fairfield. The City of Fairfield considers our underground water supply to be the Number 1 asset and viability of our community and any threat to the quality and quantity of this water supply is the Number 1 threat to our community. We therefore plead for your assistance in bringing this matter to a prompt and satisfactory conclusion. Sincerely,

Robert J. Gerhardt City Manager R3G:dr

5350 Pleasant Avenue. Fairfield. Ohio 45014 513 - 867-5300 Hamilton

December 14, 1984

Mr. Don Bruce U.S. Environmental Protection Agency Region 5 230 S. Dearborn Street Chicago, Illinois 60606 Dear Mr. Bruce: The Hamilton City Planning Commission would like to take this opportunity to express its concern about the proposed cleanup of the Chem-Dyne site on Ford Blvd. While the City and its residents have been concerned for the past eight years, it now appears that acceptable solutions are available. The solution chosen has to not only answer the site problems but also enable the City to assure the citizens and neighboring industries that the problem is solved. Because the aquifer has been found to be contaminated, it is essential that the removal of the contaminates be of highest priority. The health of hundreds of thousands of citizens in the City of Hamilton, Butler County and Hamilton County will be affected. The City Planning Commission endorses the following steps in the remaining cleanup process: a) Pumping of the acquifer and use of air-stripping to remove the affected material, b) Removal of the Chem-Dyne building. This is an attractive hazard and should not ever be reused because of further environmental problems, c) Removal of all contaminated soil. No contaminated soils should remain to pose problems for future citizens. We do appreciate the efforts of your agency on behalf of the City in this disaster. It will be years before the City can divorce itself from the adverse national publicity. However, we feel that through the Joint cooperation of all federal, state, and local agencies, a great step can be taken to alleviate Hamilton's problem. The Commission will be glad to work in cooperation with you in any way possible. .

Jack Smith, Chairman City Planning Commission

JS:ee cc: The Honorable Thomas N. Kindness The Honorable Howard Metzenbaum Representative Michael Fox The Honorable. John Glenn Mr. Val Adankus, Administrator, USEFA Region V Mr. Robert Maynard, Director, OEPA Mr. Lee Thomas, Asst. Administrator, USEPA Mr. Roger Hannahs, OEPA Mr. Hal Shepherd, Assistant City Manager **-*-~l ^5LJ-^<-. /c^***-^*"" i«,'|-j)-^-o^3-^' 1,

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Dear Ms. McCue, t I have attended both the June andruovernber public meetings held in Hamilton pursuant to the Cheai-Dyne cleanup. As a geologist with 10 years experience in water well design, I would like to take this opportunity to offer ay opinions on the cleanup solutions as put forth on a chart and presented at the November meeting (I have not had the opportunity to read the full report). My comments are on the ground water extraction and soil treatment methods. I) GROUND WATER EXTRACTION A) Injection well. Time problems, permit problems, construction problems and besides - why contaminate a 3000-FT deep zone we know practically nothing about? I favor extraction wells with air strippers. B) Well location. TWO or even three large diameter pumping wells to, In effect, create a "wall" past which the contaminated plume could not pass makes sense, although much "clean" water on the downstream side of the plume would unneccessarily be pumped out too. In addition, I would sink two wells in the "heart" of the most contaminated zones and use them to reverse the natural hydraulic gradient, create deep cones of depression around them by mining the water and thereby extract the bulk of the plume in a f^r shorter time than simply waiting for the plume to migrate towards outside wells. C) Well design. According to Watklns and 3pieker (1971), seismic refraction mapping in the valley shows that at the location involved, the bedrock ' could be as much as 220 feet deep, if the plume's maximum depth can be ascertained by exploratory drilling, then I would install 20-inch wells to a depth of ten feet below that point. Why 10 feet? Simply that the interference of several cones of

-1- / depression and the resulting composite drawdowns / would neccesaitate setting the pumps near the botton of the well. Since 3pleker (1968) contends that the aquifer transmisslvity Is on the order of 2CCC GPD/FT, a 1000-12CC 3FK well Is not out of the question, assuming coarse gravel Is present. D) Screen. It has been my experience that wire-wound V-slot well screens are the most efficient, allowing the least drawdown. 20 feet of 20-inch pipe size screen with a no. 60 slot (.060") and a .190" wrap wire (24^ inlet area) will provide ll'l GPM @ C.I feet per second slot velocity. Of course, slot would be based on sieve analysis. E) Drilling method. I would use either cable - pullback, or reverse circulation rotary_ with a 26" x 20" gravel pack. Historically, mud rotary has not ^worked well in Ohio gravels. II) Soil Treatment. I am not a soil chemistry expert, but Instead of removing soil and spreading a layer of clay, compacting it, re-spreading the soil and planting grass consider this idea: Pour concrete or blacktop over the entire area and make it into a tennis court or parking lot.1 The concrete or asphalt would prevent any rain from washing any contaminants down into the gravel and shorten or eliminate the 27 years expected for natural migration to occur. If the buildings were turned into rubble, they could be buried in or under the pavement. In conclusion, my overriding concern about all dump- sites is that it makes no sense at all to haul chemicals to an "approved" site, and when it leaks haul them to another "approved" site, and so on, ad inflnitum, all over the country. Where does it stop? When will chemical producers and users be regulated at their source? I would appreciate hearing your comments at your earliest convenience.

Sincerely Youro,

Timothy G. Korver B.A., Geology References Sited: Spieker, A.M. (1968), Ground-Water Hydrology and Geology of the Lower Great Miami River Valley, Ohio, usOS Prof. Paper 6C5-A Watkins, J.S., ar.d A.K. Spieker (1971), Seismic Refraction Survey of Pleistocene Drainage Channels in the Lower Great Miami River Valley, Ohio. U3GS Prof. Paper 605-B. Jocelyn Hamn 951 Vine Street Hamilton, Ohio 45011 (513) 868-6105 December 22, 19&4

Don Bruce U. S. Environmental Protection Agency Region V 230 South Dearborn Street Chicago, Illinois 6o60*f

Dear Mr. Brucet After reviewing the Feasibility Study, In the limited time alloted, I have several comments. Although my research has been limited, I hope my comments will be acknowledged and taken In serious review. These comments will be discussed In the following orderi on site structures, soil, ground water, and the canal. The on site structures have been contaminated with Incompatables and known carslnogens. Due to lack of recordes and lack of scientific data, I believe all struvtures should be demolished. To let these buildings remain In there present delapltated conditions would be an unjustifiable mistake. The site calls for more Investigation Into sources of contamination, extent of contamination, and locations of underground facilities before any furthur action Is taken dealing with underground structures. The soil Is suspected of being contaminated up to fifteen feet and of having hot spots erratically located. Due to the fact tne °"ners of tne *ite mre extremely negligent In maintaining aliquate records, and that there Is a lack of scientific data, I believe to start the project with a complete pre-determined plan would be nleve. One alternative to soil removal Is to remove hot spots with testing being done at appropriate points during clean up. It Is my bellefe that this would be a solution* but to remove two feet of soil from the remaining areas would be a negligent aot on part of the EPA. Testing should be done through-out the clean-up, and information should be made available to the public upon request. The faat remalnes that Cham Dyne la located over an aquifer. Because of the location of the site, to cap the site at a prc-mature tine during clean-up, would be a waste of resourses. I feel that while we have the resources at hand we should see to It that the clean-up of the site Is done In the most efficient and scientific manner possible. The ground water Is contaminated with VOC,s and "other Identified contaminants" on site. Off site ground water zemalnes a mystery to me due to lack of scientific data and contrldlc- tlons In the study. The water Is contaminated with compounds that cannot be completely broken down or bonded through any alternative mentioned. However, the granular activated carbon absorption accompanied by air stripping or the PACT system may be the only solution. Although, lack of monitoring could be detrimental In both cases, what solutions do we really have? The canal has been written off as not being a threat to blotlc or abiotic ecosystems. I truly believe this is not the case. Not only is it a threat to these systems* but it could be an avenue to human exposures. It is my belief that there is also hot spots In the canal, particularly next to the-Ford Park area. The EPA should authorize sampling to be done in this area. The city is presently filling in this area, and if action is not taken immediately to determine the extent of contamination we will have a successful cover-up.

Slncerly,

Jocelyn Hamm 951 Vine Street Hamilton, Ohio *5011 (513) 868-6105 c.o December 28, 1914

Mr. Barry fandala U.S. Department of Juatiee Keen 17U 10th and Pennaylvania Avenue Washington, D.C. 20530 Mr. Miehael Donovan Aaaiatant Attorney General Environmental Law section Office of the Attorney Oantral Stata Offiea Tower, 17th Floor 10 Baat iroad street Coluinbua, OH 42315 Has Chatn-Ovna Feasibility fftudy Gentlemeni Eneloaad plaaaa find commenta praparad by Conaatoga- Hov«ra ralating to tha Novambar 1984 draft faaaibility atudy for tha Cham-Dyna aita* Sinea th* partiaa to tha Chan-Oyna litigation hav« agraad in principle upon a ramady for tha aita, our conaultanta hava not praparad datailad oonaanta on tha faasibility atudy, Should th« details of tha propoaad ramady not ba finally agraad to, the dafandanta and third party dafendanta raaarva tha right to lubrait further eooaianti on tha draft faaaibility atudy. Bincerely, / .. '• •i. Charles H. Tiadala, Jr. CMT/ljw inclosura eei Mr* Jaaaa R. Adana Mr* Thacdora L. Garrett Mr. Kogtr W. Fry Mr. Jwea Kelly Mr. Joseph D, Lonardo Mr* Thomas T. Terp CONlITOaMIOVfM ft AMOOIATU (JMITtO HCslI

Deoeatoer 28, 1984 asference *>. 1410

COMM1MT1 ON TEAitBILITY BTUffi - CMEM-OWl

•oil* froa the un saturated xone at the Chea-Dyne Site have been •hewn to be contaminated by a wide renge of cheaicali froa the volatile, b«tt ntutral, ptstiaidt and 4cid tctotioni oi th* priority pollutant* lilt* Th« vertical distribution ol contaminant• at th« lita if auch that tha p«atioidaa and baat nautrala ara gtnarally loottad in th« uppor <*w faat of aita aoil, whila tha majority oi tha aoid fraction compound a ara found within tha upptr ona-third of thii unaaturatad aoil profila. VDlatlia oonpounda ara diatributad vertically through tha tita from tha ground turfaca to tha top of tha groundwatar tabla. Araally, alavatad lavala of eontamination *xiat in ralativaly locallead araaa of tha aita. Lower levela of oontaainanta generally exiet aeroaa the aita. K aurfaee eap installed over the aite will affeotively aitigata the potential adverae effecta of aurfioial aoil oontaaination by preventing huaian or animal contact with native aoila, by preventing exposure of contaainated toila to turface water runoff* and by allowing the oolieetion and traataant of volatiliied chemiatla in a controlled faehion. finilacly, a low paraeability aurfaee cap inetaliad over the eite will effectively aitigatc the potential of adverae impact to the groundw«ter by minimiaing and controlling the quantity of aurfaoe water infiltration to the unaaturatad aone. Excavation with ofl-aite aecure diapoaal of eantaainated aoila will mitigate the potential adverae impacta of eurfioial aoil contamination to the ea>t degree aa a aurfaee eap. However, aurfioial contaaination ia spread aeroaa the aita- Therefora, any attempt to excavate aignificantly contaainated aoil would raquire. tne removal of tena of thouiande of cubic yarda of aoil to accc»pliah the aeae purpoae aa a aurface cap. In addition to coat, excavation and off-alt* diapoaal of contaminated sails suffers froa the following diaadvaniAgee?

continued «t * * I XCHOX

CONf ITOaAJWVIM I AMOCIATIB UMITID

December 21, 1904 Mftronco mo. 1410 . 2 -

• the unavailability of landfill capacity at a *CRA permitted faeility(ies) within a reasonable distance of the Che*-Dyne site for the volume of eoil which would be removed • the difficulty in preventing exposure to eurrounding residential and industrial receptors by windborno contaminated dust and volatited chemicals during soil removal • the disruption, inconvenience and disturbance of the City of Hamilton residsnts and businesses by noise, dust, and traffic congestion caused by thousands of truck trips necessary to transport the excavated soils and bring in clean fill for backfilling •i • the damage to the City of Hamilton streets and state and federal highways by the large number of truck movements involved in excavation and backfilling • the potential for accident, spillage or upset of one or more trucks while transporting hasardous waste from the Chem-Oyne property to the MftA disposal sito. The groundwatsr beneath the Chem-Dyne site has been contaminated by chemicals which migrated to the groundwater through the site* Essentially all groundwmter contamination has been caused by volatile compounds, these being relatively highly mobile under the influence of surface water infiltration through the unsatorated sens, tieavation of surficial toils at the site, while effective for reducing the potential impact of surficial contamination, will do little for reducing the future adverse impact to the groundwater. For example, removal of two feet of eoil from ths surface of the entire eite will remove less than four ?jrcent of the soil volstile contamination at the site, Further, any depth of excavation, unless all or nearly all site soils are excavated, will require a low permeability cap in addition to control the discharge of the remaining residual volatile contamination. For the reasons set forth above, there is no technical justification for exteneive mmftvttion of soils from the Chem-pyne site. A surface cam will accomplish the same °?J! «•* Viftn««* «i« problems noted above that are associated with offi-sitsj disposal*

COVCffOOA-llOVVM I, MSOCIATlf t TMZTID _. ,. John P. Wheeler. President Inturanc* Conwr"_ _ John C. Dodsworth, Wee President Phone (513) »M-fr*0<-

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