Cytec Statement of Basis and Permit Modification July 16, 2012 Public Hearing Ohio Environmental Protection Agency
Cytec Public Hearing The purpose of tonight’s hearing is to receive comments from the public on Ohio EPA’s preferred remedy (called “the Statement of Basis”), for SWMU 1 (North Landfill), and draft permit modification.
Permit Modification Process Ohio EPA issues draft Statement of Basis and permit modification for public comment (6/13/12) 45 day public comment period (6/13/12-7/28/12) Public hearing (7/16/12) After comments are received and reviewed, Ohio EPA will respond to all relevant comments in writing After considering comments, Ohio EPA issues final decision
History of Cytec 54 acre site located on Greene Street in Marietta Industrial activity since 1915 Manufactured dyes, DDT, UV absorbers, rubber additives, specialty chemicals Wastes disposed of in on-site landfills, ponds and other waste areas Ponds 1 and 2 used for wastewater equalization & settling North Landfill closed in 1979; clean soil (clay) added, leachate collection system installed Chemical manufacturing ceased in 1996 In 2002, production buildings were demolished
North Landfill Recent Site Investigation (2011) Soil sampling - 19 soil borings installed Three ground water monitoring wells Three monitoring wells (piezometers) installed within the landfill boundary to measure ground water levels Geotechnical Analysis completed from soil boring information Ground water Pump Tests
North Landfill Site Investigation Findings Soil near the landfill consists primarily of clay and silt Waste material is 20-30 feet thick Primary ground water flow is in the weathered bedrock zone Ground water flows into Duck Creek
Corrective Measures Study A study to evaluate different cleanup options. The study resulted in a CMS Report which was reviewed and approved by Ohio EPA. Cytec recommended cleanup measures for the site. For the North Landfill, alternatives divided into (1) soil/waste and (2) ground water.
Corrective Measures Study Soil cleanup options evaluated for SWMU 1 : No Action - $50,000 Cap augmentation with soil (clay) - $280,000 Cap augmentation with synthetic liner-$260,000 Cap augmentation with clay, synthetic liner, drainage layer - $740,000 Excavation with off-site disposal - $29,740,000 (assumes 50% hazardous waste) Excavation with off-site disposal - $13,458,785 (assumes 100% solid waste)
Corrective Measures Study Ground water cleanup options evaluated specific to the North Landfill: • Hydraulic control (pump and treat) - $200,000 • Containment (ground water barrier) • Sheet pile wall - $1,960,000 • Sheet pile wall w/hydraulic control - $2,030,000 • Slurry wall (Bentonite clay) - $800, 000 • Slurry wall w/hydraulic control - $850,000
Ohio EPA Proposed Alternative for the North Landfill • Soil & plastic liner cap augmentation with leachate collection • Slurry wall installation along the western and southern boundaries of the landfill
Ohio EPA Proposed Alternative for the North Landfill Installation of a clay berm (or equivalent berm/barrier) in the northeast portion of the landfill Institutional controls (environmental covenant)
Additional Actions SWMU 26, East Storage Pad – Excavation with off-site disposal “OSC-A” (Tank Saddle Area) – Extend the cap from SWMU 10 Drainage Swale – No further action Duck Creek – Periodic monitoring to ensure that remedies are effective
Remedial Alternatives Proposed to be Applied Site-wide Site-wide ground water contamination will be addressed by ground water pumping wells, placed along the east side of the property, to prevent migration of ground water off-site; monitoring plan to be submitted to Ohio EPA Areas with waste remaining will be addressed with an Environmental Covenant – a legally enforceable document that will impose use and activity limitations on the property or a portion of the property (for example, prohibiting the use of on-site ground water and prohibiting on-site soil excavation)
Next Steps in Clean Up Process Public comments accepted through July 28, 2012 Ohio EPA written response to comments Ohio EPA selects final remedies, written final action Corrective measures workplan submitted by Cytec within 90 days of Ohio EPA’s written final action Ohio EPA review, subsequent approval Cytec implements remedies Operation, maintenance, financial assurance
Ohio EPA Contacts Questions about public involvement: Amber Finkelstein (614) 644-2160 email@example.com Questions about remedial alternatives: John Rochotte (740) 380-5262 firstname.lastname@example.org Questions about permit/permit modifications: Donna Goodman (740) 380-5293 email@example.com
Public Information and Comments Link to Draft Statement of Basis: http://www.epa.ohio.gov/dmwm(bottom right corner under “stakeholder input”, click on “read more”) Verbal and written comments accepted tonight Additional written comments by July 28, 2012 to: Ohio EPA , Division of Materials and Waste Management Attn: Engineering, Remediation and Authorizations Section P.O. Box 1049 Columbus, OH 43216-1049 phone (614) 644-2621 fax (614) 728-5315 e-mail: firstname.lastname@example.org