Congressional District # 08
NORTH SANITARY LANDFILLEPA ID# OHD980611875
Last Updated: November, 2013
Site DescriptionThe North Sanitary Landfill (NSL) site occupies almost 102 acres in Dayton, Ohio. More than half of those acres were used for landfilling industrial and municipal wastes into unlined former gravel pits which intersected the water table. Five disposal areas have been identified within the NSL site, one of which is a designated drum disposal area. The NSL site sits atop and within a federally designated sole-source aquifer composed of highly transmissive sands and gravels. The site is situated in between and in close proximity to the City of Dayton's two major municipal well fields. These well fields supply over 430,000 people in the greater Dayton metropolitan area with drinking water. The NSL site is located in a mixed residential/industrial setting and is surrounded on all sides by residential and industrial land use. Several residential drinking water wells in the area have become contaminated with organic substances believed to be related to the NSL site. It is believed that at this time all affected residents have been connected to the municipal water supply. Industrial wastes disposed of at the NSL site, some of which were disposed of beneath the water table, include used oils, solvents, scrap paint, lampblack, electrical transformers, brake grindings containing asbestos, and sewage. Numerous fires have occurred at the site, both during active disposal operations and after disposal operations had ceased. The most recent fire occurred in September of 1996, when the city of Dayton Fire Department, the Regional Hazmat Team, and Ohio Environmental Protection Agency (OEPA) Emergency Response personnel were called in to mitigate an underground fire in an area of the site known to contained drummed industrial wastes.
The responsible parties are conducting the RI/FS, with OEPA as the designated lead agency for RI/FS oversight through a cooperative agreement with the U.S. EPA. U.S. EPA was the lead for the drum removal and soil treatment activities.
U.S. EPA completed a Record of Decision in August 2013 and is completing a referral to the Department of Justice to begin negotiations to implement the design and construction of the remedy. It is anticipated that negotiations will commence in spring 2014.
Threats and ContaminantsGroundwater and soil at the site are contaminated with volatile organic compounds (VOCs), such as trichloroethylene (TCE), tetrachloroethene, 1,1-dichloroethene, vinyl chloride, and methylene chloride; semi-VOCs, such as Phenol and bis(2-ethylhexyl)phthalate; heavy metals, such as lead, mercury, cadmium, and cyanide; and polychlorinated biphenyls (PCBs). Long-term exposure or ingesting contaminated soil or groundwater could pose a health threat. An in-depth evaluation of the potential health risks associated with the site is included in the Remedial Investigation and Feasibility Study (RI/FS) reports and is summarized in the August 2013 Record of Decision.
Cleanup ProgressOn January 31, 1995, OEPA entered into an Administrative Order on Consent (AOC) to complete a RI/FS with seven of the identified potentially responsible parties (PRPs) collectively known as the Valleycrest Landfill Site Group (VLSG). The VLSG is conducting the RI/FS through a phased approach. The first phase of the RI, a scoping phase was based, in part, upon U.S. EPA's Presumptive Remedy for Comprehensive Environmental Resource Compensation and Liability Act (CERCLA) Municipal Landfill sites guidance and OEPA's Statement of Work. Use of the presumptive remedy guidance is intended to focus data collection, accelerate remedy selection, save costs and time, and provide consistency in remedy selection.
OEPA and the PRPs disputed a number of issues as part of the AOC that delayed the RI/FS but the issues been resolved. The parties agreed that a presumptive remedy approach could only be used upon a commitment by the PRPs to the remedy. The PRP's refusal to conduct non-intrusive investigatory activities for identified "hot spots" at the site was resolved through an AOC between select PRPs and U.S. EPA for removal of buried drums and drum impacted waste. In late March 1999, the PRPs submitted to OEPA a draft RI/FS work plan addendum as the comprehensive RI/FS work plan required by the AOC.
U.S. EPA Involvement
In January 1998, OEPA referred the "hot spot" areas of the site to U.S. EPA's Emergency Response program for evaluation. Those areas represented the principal threat. Pursuant to CERCLA §106, in September 1998, U.S. EPA entered into an AOC with selected PRPs to undertake a drum and soil removal action for drum disposal areas at the site and, in light of threats associated with the landfill gas, to install a landfill gas abatement system.
The PRPs installed a system to reduce or eliminate the migration of the landfill gas in September 1998. The system underwent an evaluation and corrective action period to determine its effectiveness. The evaluation demonstrated that the system was not able to meet the criteria for controlling the migration of landfill gas and raised new concerns over the emissions from the system. The PRPs modified the system and extended it in areas where landfill gas exceedances were previously identified.
In October 1998, U.S. EPA conditionally approved the drum removal work plan. The PRPs began drum removal work in a number of areas in November 1998. Over 26,000 drums were removed from area 5, which was completed in summer 2001. The second area of drum removal was completed in 2002.
Contaminated soils were also removed. Vapor treatment of soil stockpiles was conducted during 2002. Portions of one stockpile did not meet treatment standards and were disposed of off-site. The rest of the stockpiled material did meet treatment standards and was back filled on-site.
In addition, additional soil vapor treatment was needed in area on. A work plan for vapor treatment of area one contaminated grids was approved in January 2004. Area one soil treatment was completed in fall 2005.
U.S. EPA completed a Record of Decision in August 2013 and is completing a referral to the Department of Justice to allow for the commencement of negotiations to implement the design and construction of the remedy. It is anticipated that negotiations will commence in spring 2014.
Other Removal Actions
The OEPA has required the VLSG to respond to two time critical emergency situations at the site. One situation involved the underground fire within an area of drum disposal. As part of this emergency action a drum removal action was completed in November 1997. Even though thousands of buried drums exist at the site, the scope of work for this emergency action only required specific drums to be removed. The removal was limited to only drums currently protruding from the landfill surface and resulted in approximately 100 drums being excavated. The drummed waste and associated soil generated by this removal action were classified as hazardous waste. Analytical data for the drummed waste indicated the presence of TCE [as high as 370,000 parts per million (ppm)] and other VOCs. Analytical data for the impacted soils indicated the presence of several VOCs, semi-VOCs, heavy metals, and PCBs.
EPA working with the local community in a face to face interaction where the local citizens had direct input into the work that was being planned at the site. This culminated in a good working relationship that continues throughout the RI process.
EPA was able to help the City of Dayton to develop a reuse framework for the site that had input from a number of local entities. EPA was successful at helping focus their needs and comments into a framework that will be used to properly calculate risk at the site as well as to guide future site redevelopment.
Community InvolvementThe community was actively involved throughout the removal actions at the site. EPA had yearly community meetings where progress was presented. EPA also actively involved the community throughout the workplan and work implementation process, regularly meeting with a consortium that represented City and local interests. This community remains active.
Congressional InterestCongressional interest was high during the initial stages of the removal actions at the site. Interest has waned as the removal actions have been completed.
Property ReuseThe City of Dayton worked with EPA to develop a site redevelopment framework that was approved by the Dayton commissioners in July 2005. This framework provides a blueprint for any future redevelopment and is also being used for the site risk assessment to develop the proper exposure scenarios to calculate risks remaining at the site.
ContactsRemedial Project Manager, U.S. EPA
dion novak (firstname.lastname@example.org)
Community Involvement Coordinator, U.S. EPA
AliasesNORTH SAN LDFL INC
NORTH DAYTON SANITARY LANDFILL
NORTH SANITARY LANDFILL - DAYTON
NORTH SAN LDFL INC AKA VALLEYCREST LDFL