Tremont City Barrel Fill Timeline

1976 to 1980:

Active onsite burial and dumping.

51,500 barrels received and buried; some crushed during burying; 300,000 gallons of uncontainerized wastes also dumped into the 50 unlined pits.

1983:

Citizens group, CF Water, forms to address exposures of odors, runoffs, emissions, and evidence of highly toxic exposures in the vicinity of the Barrel Fill.

October 3, 2002:

US EPA Region 5 enters into a consent agreement with Responsible Environmental Solutions Alliance (RESA). RESA represents the Potentially Responsible Parties (PRPs) at the site that are currently operational. In the consent agreement RESA agrees to hire consulting companies to conduct a Remedial Investigation (RI) of the geology and hydrogeology at the site, and to prepare a Feasibility Study (FS) of applicable remedies at the site.

[RESA is Delphi Corporation; Franklin International Inc.; General Motors Corporation; International Paper Company; The Proctor and Gamble Company; PPG Industries; Strebor/Roberts; and Worthington Cylinder Corporation. Waste Management is invited to be a member of RESA but declines. RESA sues Waste Management to force its inclusion.]

October 2006:

The Remedial Investigation Report (RI) (2169 pages) is accepted by US EPA.

July 2008:

The Feasibility Study (FS) is submitted detailing 6 cleanup alternatives.

October 8, 2008:

The court finds that Waste Management is a PRP and orders it to participate with RESA. The court finds that Waste Management owns a 55% interest in costs of the cleanup.

November 25, 2008:

US EPA modifies and approves the Feasibility Study.

December 18, 2008:

The PRPs ask US EPA to withdraw their letter of approval for FS 1-6 and modification of FS 1-6. The PRPs submit a new Alternative FS 7.

March 26, 2009:

Ohio EPA informs US EPA that Ohio EPA cannot support the draft comments or selection of Alternative 7.

May 14, 2009:

US EPA Region 5 informs all parties that it will take the Barrel Fill remedy selection in front of the National Remedy Review Board (NRRB).

July 29, 2009:

US EPA Region 5 presents new Alternative 7 to the Springfield/Clark county area at the CF Water Annual Meeting. Ohio EPA presents their issues and concerns with Alternative 7.

August 3, 2009:

US EPA Region 5 presents FS Alternative 7 to the NRRB. Ohio EPA presents problems with FS Alternative 7 and endorses any of the alternatives that remove the liquid and solid hazardous waste from the site.

August 27, 2009:

US EPA notifies Ohio EPA that they now support FS Alternative 4a.

June 10, 2010:

US EPA Region 5 releases FS Alternative 4a for public comment at a meeting in Clark County.

July 12, 2010:

US EPA Region 5 extends the public comment period to 60 days based on a request from Waste Management.

August 11, 2010:

Waste Management submits two new FS Alternatives (8 and 9) to US EPA Region 5 as public comments on the FS Alternative 4a.

September 21, 2010:

US EPA Region 5 responds to Waste Management, asking them to include the solid waste landfill from 4a in their FS Alternative 9, leading to FS Alternative 9a, the current (10/16/2012) proposed cleanup alternative.

October 11, 2010:

Waste Management presents US EPA with FS Alternative 9a.

December 1, 2010:

US EPA Region 5 provides Ohio EPA with a new Feasibility Study, known as Feasibility Study Addendum 2, in support of selecting FSA 9a.

December 9, 2010:

US EPA Region 5 solicits position papers from Ohio EPA and CF Water for the NRRB review of Alternative 9a.

December 22, 2010:

Ohio EPA submits detailed comments to US EPA Region 5 on FSA 2 ARARs (ARARs = Applicable, or Relevant and Appropriate Requirements).

December 29, 2010:

CF WATER submits objections to FSA 2 to US EPA Region 5 and requests that FS Alternative 4a remain the selected alternative.

January 7, 2011:

Ohio EPA submits detailed comments on remainder of FSA 2 to US EPA.

January 27, 2011:

US EPA presents FSA 2 to NRRB. Ohio EPA presents objections to FSA 2 following the outline of earlier comments to US EPA, emphasizing Alternative 9a’s lack of compliance with ARARs, inappropriate redefinition of principal threat waste, and a bias in the cost estimates underestimating the cost of 9a and inflating the cost of 4a.

February 1, 2011:

US EPA requests additional information from Ohio EPA regarding their arguments of bias in the cost estimates.

February 16, 2011:

Ohio EPA provides detailed cost analysis of 9a and 4a cost estimates.

Major issues in the Ohio EPA analysis:

  • The cost of 4a is inflated by as much as $14 million based on overestimation of the quantity of contaminated soil classified as hazardous waste. Ohio EPA states that RI data does not support classifying as much soil as hazardous.
  • The cost of 4a is inflated by including treatment of sludge wastes destined for offsite incineration. Ohio EPA states that no treatment of sludge wastes is needed prior to incineration.
  • The cost of 9a would increase substantially if Alternative 9a complied with applicable hazardous waste requirements.

April 6, 2011:

Region 5 provides Ohio EPA, Clark County Combined Health District, and CF Water with the NRRB recommendations regarding 9a. The recommendations parallel the issues raised in Ohio EPA’s presentation to NRRB and the Ohio EPA position paper on 9a.

June 22, 2011:

US EPA presents Clark County with 9a as their preferred FS Alternative, which did not directly address the hazardous waste requirements identified by Ohio EPA. The cost estimates remained unchanged.

October 2011:

US EPA issues the Record of Decision (ROD), the “final” cleanup plan for the site, based on the Remedial Investigation of October 2006.

April 2012:

People for Safe Water (PfSW) organizes to reactivate citizens’ grassroots voices following CF Water’s disbandment.

June 2013:

US EPA takes surface water, soil and sediment samples in and around the site to evaluate the conditions of the site.

April 18, 2014:

Region 5 Administrator Susan Hedman requests concurrence from Gov. Kasich for the TCBF to be submitted for consideration to be listed on the National Priorities List (NPL).

April 21, 2014:

Wittenberg University hosts a community forum with Region 5 leaders participating in a panel about the Tremont City Barrel Fill, organized by People for Safe Water.

June – August 2014:

Tremont Work Group meets, facilitated by Joseph McMahon, with representatives from Region 5, OEPA, Clark County leaders, and PfSW. Recommendations to modify Plan 9a include a RCRA double liner with leak detection and leachate collection to replace the slurry wall and 1075 leak detection.

November 2014:

US EPA Community Involvement Coordinator Ginny Narsete spends several days in Clark County, interviewing leaders and citizens about the TCBF.

December 2014:

Selective well sampling is done at TCBF by Ohio EPA, per agreement from all involved in the Tremont Work Group.

February 27, 2015:

Ohio EPA hydrogeologist Jeff Martin sends Interoffice Memo with test results, opining that the well sampling results could now “facilitate concurrence among US EPA, Ohio EPA, the PRP group and People for Safe Water with regard to the remedy.”

March 4, 2015:

Letter sent to Governor Kasich, signed by 29 local leaders including Greater Springfield Chamber of Commerce CEO Mike McDorman, stating concern for unaddressed issues in Plan 9a and asking for Ohio EPA’s continued support for permanent removal of all hazardous wastes.

May 1, 2015:

Region 5’s updated Community Involvement Plan is released, documenting continuing and unanimous opposition to reburying untreated hazardous wastes at the TCBF.

August 2, 2015:

Region 5 Administrator Susan Hedman sends a second letter to Ohio EPA Director Craig Butler, requesting Gov. Kasich’s concurrence for the TCBF to be submitted for the NPL.

August 27, 2015:

Region 5 officials host public forum at Northwestern High School, attended by more than 700 people. “This is highest attendance I have ever seen at an EPA public meeting,” declared Superfund spokeswoman Joan Tanaka. All local leaders and citizens voice serious concern for our sole source aquifer, given Plan 9a’s reburying of untreated hazardous wastes at the site.

October, 2015:

Nine local leaders and Ohio EPA administrators travel to Chicago to meet with Region 5 staff. Assistant Administrator Robert Kaplan orders Superfund staff persons to “review all options” for a resolution to Plan 9a.

June 10, 2016:

Newly named Project Manager Jim Saric meets with local leaders to present the Army Corps of Engineers (ACE) report. It recommends modifying Plan 9a by adding stabilization agents to wastes reconsolidated in the newly engineered waste cell. Treatability studies will be needed to determine the most effective agent(s) and method(s) to use.

October 28, 2016:

Tetra Tech recommends a modification to Plan 9a to remove the “worst of the worst.” Their memo recommends permanent removal of 997 barrels containing still bottoms from the TCBF.

November 21, 2016:

People for Safe Water sends a letter to Ohio EPA Director Butler, outlining acceptable modifications to Plan 9a. Critical to acceptance is permanent removal or treatment on site of any barrels containing high concentrations of the eleven VOCs which are regulated by EPA’s Toxicity Characteristic Leaching Procedure (TCLP), with those VOCs which are the most mobile and most toxic.

January 23, 2017:

Ohio EPA Director Craig Butler, DERR Chief Mike Proffitt and four other OEPA officials meet in Springfield with local leaders and citizens to discuss next steps with EPA Region 5.

Updated 1.23.17
People for Safe Water – Peter Townsend and Marilyn Welker