Background on the ESOI facility

The ESOI facility is operating under a permit extension from the Ohio Environmental Protection Agency (Ohio EPA). While the original permit has expired, the facility has submitted an application for renewal within the RCRA guidelines and the permit is continued. The ESOI site was used originally as a municipal and industrial solid waste landfill, beginning in 1954. Later, the site received municipal, commercial and industrial wastes, and the facility has operated since the late 1980s under a RCRA permit from U.S.EPA and Ohio EPA. The primary waste stored in the currently operating hazardous waste cell is electric arc furnace dust, also known as K061.

The original landfill was owned by a local firm, Fondessy Enterprises (commonly known as the Fondessy brothers), who purchased the land (a portion of which was an orchard) and began the landfilling operation in the late 1950’s. In 1985, I.U. International purchased the landfill operation from the Fondessy brothers for a reported $20 million. I.U. also owned another hazardous waste landfill in Mountain Home, Idaho. I.U. changed the name of the operation to Envirosafe; Envirosafe was part of a subsidiary of I.U. International, Conversion Systems Inc. (CSI). In 1989 another subsidiary was formed Envirosource, Inc. and at that time, NEOAX attempted to sell the hazardous waste operations. When that failed, Envirosource was “spun off” of NEOAX and CSI, and Envirosource was listed on the NASDAQ stock exchange. In 2001, Envirosource was merged into a private company, GSC Recovery II, L.P., an affiliate of GSCP (NJ) L.P. GSC is the current owner.

The site has closed some cells under the Resource Conservation and Recovery Act (RCRA) Closure process and is investigating other inactive landfill cells under the Corrective Ac-tion program. The ESOI corrective action process began in 1987 with a RCRA Facility Assessment (RFA). The RFA is designed to identify areas of concern (AOCs) that are, or are suspected to be, potential sources of releases to the environment. Working for ESOI, Metcalf and Eddy, Inc (M&E), in association with the Jacobs Engineering Group conducted the RFA. M&E’s report, submitted to EPA Region 5 on September 8, 1987, indicated that no releases had been detected at the facility that would require further investigation. In a Federal RCRA Permit of November 8, 1988, the U.S. EPA required ESOI to submit a plan for completing the RCRA Facility Assessment that would describe the lateral and vertical extent of contamination from all Solid Waste Management Units (SWMUs). In 2000, the U.S. EPA issued a revised RCRA permit to ESOI detailing specific require-ments for undertaking a sitewide investigation.

Midwest Environmental Consultants, Inc., of Toledo, Ohio prepared a Description of Current Conditions (DOCC) for ESOI. The DOCC was submitted to the EPA on June 23, 2000, with revisions on November 28, 2000 and March 23, 2001. The DOCC included:

• a summary of previous site investigations,
• information on each SWMU and AOC to be included in the Corrective Action Program,
• a groundwater characterization,
• previous investigations and monitoring data pertaining to identification of migration pathways and potential impacts to human health and the environment from releases from the facility,
• areas for further investigation, and
• references.

Contamination has been found outside of a number of the landfill cells at ESOI, as described in the DOCC document. Cell F, for example (also called SWMU 1), has caused leachate migration to shallow groundwater with potential migration to the potable bedrock aquifer and/or migration to the offsite Gradel ditch (which then discharges to Otter Creek, west of the site). Volatile Organic Compounds (VOCs) have been detected in the shallow groundwater near Cell F. Likewise, the Millard Road Landfill (also called SWMU 5), which operated from 1976 to 1981, has caused contamination in both the shallow till (two wells contaminated) and the deep till (one well). Contaminants include trichlorofluoromethane, 1,4-dioxane, and benzene. In the RFI Work Plan, U.S. EPA requests that ESOI investigate further nine of the twelve SWMUs and ten of the eleven Areas of Concern (AOCs). Closed landfill cells, designated as Cells F, G, H and I, are located in the northern portion of the property.

Other sections of the TOSC Outreach Plan:

• Summary of the Outreach Plan
• Introduction
• Site background
• ESOI facility arrangement
• Current status of the project
• Citizen concerns
• TOSC services
• Additional activities