Congressional District # 08
NORTH SANITARY LANDFILLEPA ID# OHD980611875
Last Updated: September, 2014
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 at the NSL site, some of which were disposed 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 conducted 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 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 conducted 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 were 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.
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.
The PRPs began drum removal work in a number of areas in November 1998. The PRPs completed the removal of over 26,000 drums from area 5 in the summer of 2001. They completed the second area of drum removal in 2002.
The PRPs also removed contaminated soils. 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.
Additional soil vapor treatment was also needed in area one. Under U.S. EPA ovesight the PRPs completed the area one soil treatment in fall 2005.
U.S. EPA completed a Record of Decision in August 2013. U.S. EPA is anticipating that negotiations to implement the design and construction of the remedy will begin in fall 2014.
Other Removal Actions
The OEPA 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 the PRPs completed a drum removal action in November 1997. Even though thousands of buried drums existed at the site, the scope of work for the emergency action only required specific drums to be removed. The removal was limited to drums protruding from the landfill surface at the time and resulted in the excavation of approximately 100 drums. 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 worked with the local community in a face to face interaction where the local citizens had direct input into the work planning at the site. This culminated in a good working relationship that continues throughout the cleanup process.
EPA helped the City of Dayton develop a reuse framework for the site with input from a number of local entities. EPA successfully helped focus their needs and comments into a framework that wasused to 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 waned as the removal actions have been completed.
The 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.
EPA and their contractor continue to work with local officials on redevelopment plans and have held several meetings to discuss potential ideas. This coordination will continue throughout the remedy design.
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