Remedial Alternative Cost Issues Tremont City Barrel Fill, Clark County, Ohio Ohio EPA, June, 2014

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1 Remedial Alternative Cost Issues Tremont City Barrel Fill, Clark County, Ohio Ohio EPA, June, 2014 Alternative 4a The $13,808,400 1 cost estimate for off-site treatment and disposal of 37,000 tons of characteristic hazardous soil is the single most expensive component of Alternative 4a. The 37,000 ton estimate is based on the assumption that each drum cell with cell water or bulk liquid waste or perhaps leaking drums has an envelope of hazardous soil surrounding it. Contaminated cell water is assumed to have penetrated into the soil envelope in concentrations sufficient to contaminate the envelope soils to the point where they must be managed as characteristic hazardous waste. The Description of Calculations for the hazardous soil envelope reads: Variable Thickness of Cell Wall To Be Considered Contaminated Soil: If liquid wastes were placed in a cell or if some drums have leaked and the cell contains groundwater, some amount of soil in the cell-wall may contain contaminants and need to be treated. A default value for thickness of the cell-wall needing treatment is placed as variable above Column L, and then carried down the column for each cell. The variable is not repeated in any lines in Column L in which there was no bulk waste disposal and there is an indication that there is no groundwater. 2 A cell is assumed to have cell water if it extends more than eight feet below the original native surface, as is the case with 43 of the Barrel Fill s 51 drum cells. Cost calculations for each of these 43 wet cells assume a hazardous soil envelope with a wall thickness of two feet and a top and bottom thickness of one foot. 3 That works out to 37,000 tons of soil assumed to require off-site management as hazardous waste. The results of sampling cell water and cell wall and bottom soils during the Remedial Investigation (RI) do not support the hazardous soil quantity estimate of 37,000 tons or the selected management approach of off-site treatment and disposal. Table 7 of the RI Report (attached) summarizes the results of sampling the cell walls and bottoms of cells C-3 and D-7. Although cell D-7 contained cell water, none of the constituents analyzed for in the side wall and bottom soils failed the 20 times rule for characteristic hazardous waste. In cell C-3, the only constituent failing the 20 times rule in the side wall and bottom soils was trichloroethylene (TCE). Both cells contained cell water, but cell D-7 tested clean for characteristically hazardous soils while cell C-3 did not for TCE. Put another way, 50% of the side wall and bottom soil samples passed the 20 times rule 1 Table A-18a, Capital Cost Estimate for Waste Removal and Disposal, Alternative RA-4a and RA-4b (attached) - Feasibility Study Addendum, Tremont City Barrel Fill Site, April 2009, Haley & Aldrich, Inc., as modified and approved by EPA. 2 Tab B, Spreadsheet to calculate number and volume of drums, waste, and water; and Tab: B, Description of Calculations (attached), Appendix E, Economic Evaluation, Feasibility Study, Tremont City Barrel Fill Site, Haley & Aldrich, Inc., July 2008 as modified and approved by EPA and subsequently disputed by RESA, leading to the Feasibility Study Addendum referenced in footnote 1 above. 3 List of Assumptions Used to Develop Feasibility Study Level Cost Estimates, Remedial Alternatives 4, 5, and 6, (attached). See footnote 2 for source.

2 Cost Issues with Barrel Fill Alternatives 4a and 9a Ohio EPA, June, 2014 Page 2 of 5 and 50% did not. Consistent with the approach used to estimate costs for the drummed waste, 50% of these soils should be assumed hazardous and 50% should not. 4 The 37,000 tons of hazardous soils should be halved to 18,500 tons and the $13,808,400 cost for off-site treatment and disposal should be halved to $6,904,200. Costs for onsite disposal of contaminated non-hazardous soil should be increased by $138,750 (18,500 tons at $7.50 a ton) for a revised on-site disposal cost of $921,000. Even then the only constituent failing the 20 times rule in cell soils is TCE, a volatile organic compound (VOC). Pages 4 through 6 of Table 7 of the RI summarize the results of the cell water sampling in cells B-7, C-3, and D-7. The only constituents to fail TCLP limits were benzene, trichloroethene (TCE), and tetrachloethene (PCE), all VOCs. None of the metals, pesticides, or semi-volatiles failed TCLP limits in cell water or the 20 times rule in the cell soils. The only failures were for VOCs, one in the soil and three in the water. In order to expedite remedy selection at similar types of sites, EPA recommends the use of presumptive remedies - preferred technologies for common categories of sites, based on historical patterns of remedy selection and EPA's scientific and engineering evaluation of performance data on technology implementation, says EPA s User s Guide to the VOCs in Soils Presumptive Remedy, Directive No FS, EPA 540/F-96/008, July 1996, (attached). This Guide identifies SVE as the preferred presumptive remedy for VOCs in soils because it is a highly cost effective alternative. This has been borne out by drum removal work of a similar scope completed at Valleycrest Landfill in Dayton, Ohio. The work was conducted by Waste Management and overseen and approved by EPA. VOC contaminated media was not transported off-site for treatment and disposal because on-site treatment using SVE was effective and cost a whole lot less. In fact, 65,000 cubic yards of characteristically hazardous VOC contaminated media were treated on-site at Valleycrest using soil vapor extraction (with a catalytic oxidizer to treat the off-gases) for a known cost of $4 million. Using the FS conversion factor of 1.8 to convert cubic yards of in-place soils to tons, the 18,500 tons of VOC contaminated Barrel Fill soils can be back-calculated to equate to 10,277 cubic yards. Even if all cell roof, bottom, and two foot thick side wall soils from all wet drum cells are assumed to be hazardous, this still amounts to only 20,555 cubic yards, or approximately 1/3 of the volume of material treated on-site at Valleycrest. If Waste Management can treat 65,000 cubic yards of VOC contaminated media on-site at Valleycrest for $4 million with EPA was looking on, why would Alternative 4a at the Barrel Fill propose to spend $14 million to take less than a third of that quantity off-site for treatment and disposal? The cost estimate for managing the hazardous cell roof, wall and bottom soils for Alternative 4a should be revised to assume on-site treatment of 18,700 tons of VOC contaminated soils using soil vapor extraction. The treated soils should then be disposed of in the new on-site solid waste disposal cell as non-hazardous solid waste. 4 The cost estimate is based on half of the RI drum samples returning hazardous results and half not. 50% of the drummed waste is considered hazardous for costing purposes and 50% is not.

3 Cost Issues with Barrel Fill Alternatives 4a and 9a Ohio EPA, June, 2014 Page 3 of 5 Costs for on-site disposal of non-hazardous solid waste should be increased again by $138,750 (another 18,500 tons at $7.50 a ton) for a revised total cost estimate of $1,059,750 for on-site disposal of solid non-hazardous waste. NOTE: Treating the hazardous Barrel Fill soils on-site has the added benefit of eliminating 1,682 truck trips and 672,800 truck miles traveled, reducing Alternative 4a s relative transportation risk to community to essentially that of Alternative 9a. Occupational on-site risk for Alternative 4a would increase slightly due to the on-site treatment and disposal of these soils. The second most expensive component of Alternative 4a is the cost for off-site incineration of the hazardous half of the drum sludge waste, which Table A-18a estimates to cost $6,576,192. This estimate is based on a cost of $1, per ton for off-site incineration. Table A-18a also includes a cost of $142,355 for 1,960 tons of lime used to stabilize the hazardous drum sludge before taking it to the incinerator. At $1, per ton, the incineration cost for just the lime tonnage added to the sludge is $2,192,064. There is no need to add lime to the hazardous drum sludge prior to incineration. There is no explanation for the use of the lime anywhere in the text of the FS or the FSA. It just appears in Table E-18 of the FS (off-site disposal costs for Alternative 4) and Table A-18a of the FSA (off-site disposal costs for Alternative 4a). If one accepts that off-site incineration is the only viable option for the hazardous drum sludge, the $6,576,192 cost of that incineration needs to be reduced by the cost of incinerating 1,960 tons of lime ($2,192,064), leaving an incineration cost for the hazardous drum sludge of $4,384,128. The rationale for selecting off-site incineration for the hazardous drum sludge is unclear. Tab G of Appendix E of the FS, Basis of Disposal Cost of Drummed Waste, using price quotes provided by Waste Management (attached) assumes up front that Hazardous liquids are incinerated. Hazardous waste solids and Non-Hazardous Waste is landfilled. The Tremont Working Group needs to discuss how much hazardous waste drum sludge requires off-site treatment at the Barrel Fill, and how this sludge can be managed in the most cost-effective manner. Lastly, Table A-18a has about 20 line items with costs ranging from several hundred thousand dollars up to more than $3 million. An example is the $927,000 included for basic haz-cat waste identification analysis of 90% of the 51,500 drums. Add to that another $206,000 for full haz-cat waste identification analysis of the remaining 10% of the drums. All 51,500 drums at the Barrel Fill are sampled for waste identification. This has not been our experience with this type of work at other sites. During the drum removal at Valleycrest the vast majority of the drummed waste sludge was bulked in roll-off boxes which were then analyzed for waste identification. Only a

4 Cost Issues with Barrel Fill Alternatives 4a and 9a Ohio EPA, June, 2014 Page 4 of 5 small percentage of the drums were individually analyzed. No operational records specifying the contents of the drums existed at Valleycrest, and yet Waste Management was able to bulk the majority of the drum sludge prior to conducting waste identification sampling. At the Barrel Fill, the owner/operator kept detailed records throughout the operational life. The records identify the generator, content, number, and location of drums disposed in each drum pit. Referred to as Cell Reports, 5 the accuracy of these operational records was evaluated during RI test pitting and drum sampling activities, when 92% of the drums sampled [46 of 50] were confirmed as meeting anticipated range of characteristics for wastes disposed in the target cells. We know from the Cell Reports what went into each cell at the Barrel Fill and where in the cell it is located. We also know from Table 1 6 of the ROD that: 31% or 15,965 of the drums are paint sludge ; 19% or 9,785 are polyol ; 15% or 7,725 are "Latex or Latex Sludge"; 15% or 7,725 are Glues, Adhesives, and Rubber Cement; 10% or 5,150 are Soap, Shampoo, Detergent, and Toothpaste; 5% or 2,575 are Resins; 2% or 1,030 are still bottoms, and 0.8% or 412 are Asbestos or Asbestos slurry. 1) So why spend $1,133,000 testing each and every drum at the Barrel Fill when we know the vast majority of drum wastes at Valleycrest were bulked before sampling even though no detailed operational records existed? 2) Why does the Alternative 4a spend $14 million transporting 37,000 tons of VOC characteristic hazardous soils off-site for treatment and disposal when we know they can be treated on-site at a fraction of the cost? 3) Why does the Alternative 4a cost estimate assume the relatively expensive option of incineration for the off-site treatment and disposal of the hazardous drum sludge? There are 44 line item cost entries on Table A-18a. Three are discussed above. While Table A-18a includes the majority of the costs for implementing Alternative 4a, it still only estimates the costs associated with waste handling and off-site disposal. Other cost tables for the other components of Alternative 4a are not reviewed here, nor are the other 41 line items on Table A-18a. Conclusion: The Alternative 4a cost estimate needs to be revisited and verified. The TWG needs to discuss how this can be accomplished. 5 See example for cell B-1, circa 1976, attached. 6 ROD Table 1, Categories of Containerized and Uncontainerized Wast, attached.

5 Cost Issues with Barrel Fill Alternatives 4a and 9a Ohio EPA, June, 2014 Page 5 of 5 Alternative 9a There are some significant differences between Alternative 9a as proposed by EPA and Alternative 9a as documented in EPA s Record of Decision (ROD). These differences are highlighted in Section 21.0 of the ROD, Documentation of Significant Changes from Preferred Alternative of Proposed Plan. Although Alternative 9a in the ROD has evolved, the cost estimate has not. It is the same estimate that was in EPA s FSA 2 and Proposed Plan (PP). Some of the differences: FSA 2 and the PP crushed all drums with contents after decanting liquids. The ROD crushes only non-hazardous drums with contents after decanting liquids. FSA 2 defined liquids as "wastes that flow under their own weight to fill the container in which they are placed" or "are readily pumpable." EPA s PP discussed liquids without defining them. EPA s ROD defines liquid for all wastes based on the paint filter test, including hazardous and non-hazardous drum contents. As described in the ROD, any waste that may be a liquid is subjected to the paint filter test. Any waste that fails the test must be removed from the site as liquid regardless of its source (drum waste, bulk waste, saturated media, etc.). FSA 2 did not stabilize waste to make it less mobile. The PP stabilized both bulk waste and drum contents using fly ash or cement to make it less mobile so it could be disposed on-site. The ROD does not stabilize any waste. If the waste fails the paint filter test it is removed from the site. FSA 2 did not excavate soils, including cell wall soils, unless they interfered with construction of the new waste cell. The PP does not explain which soils are excavated and which are left in place. The ROD excavates all contaminated hazardous and nonhazardous soils at the Barrel Fill and places them in the new waste cell. Conclusion: The cost estimate for Alternative 9a needs to be revised to reflect the remedy that EPA selected in the ROD, and the cost components for Alternative 9a need to be reviewed and verified. The TWG needs to discuss how this can be accomplished.

6 TABLE A-18a Tremont City Barrel Fill Site Feasibility Study RA-4a, 4b Capital Cost Estimate Waste Removal and Disposal (Alternative RA-4a and RA-4b) ITEM DESCRIPTION UNITS QUANTITY UNIT COST SOURCE EXTENDED COST DIRECT CAPITAL COSTS Mobilization & Setup Lump Sum 1 $200,000 1,2 $200,000 Bonds and Insurance Lump Sum 1 $778,000 2,6 $778,000 Road Construction Lump Sum 1 $89, $89,172 Staging Pad Construction Lump Sum 1 $106, $106,250 Labor (23 Construction Personnel) Days 344 $8, ,2 $3,040,960 Equipment (Construction Equipment Rental) Months 16 $135, ,2 $2,160,000 Per Diem (Construction Personnel) Days 344 $2, ,2 $791,200 Fuel (On-site Consumption) Days 344 $6, ,2 $2,105,280 Fencing Lump Sum 1 $106, $106,250 Disposable Supplies Days 344 $1, ,2 $344,000 Frac Tanks (4 tanks x 344 days) Days 1376 $ ,2 $55,040 Hydraulic Drum Crusher Lump Sum 1 $9, $9,250 Overpacks (2% of 50,000 drums) Each 1000 $ $104,000 Lime (Solidification for drum sludge wastes only) Tons 1960 $ $142,355 Level B PPE (8 Construction Personnel) Days 344 $1, ,2 $344,000 Basic Haz-Cats (Waste ID of 90% of 51,500 drums) Drums $ $927,000 Full Haz-Cats (Waste ID of 10% of 51,500 drums) Drums 5150 $ $206,000 Soil Analysis (Full TCLP - 150% Rush) Each 344 $ $225,750 Soil Analysis (Total VOC's - 150% Rush) Each 344 $ $37,840 Liquids Analysis (Full TCLP - 150% Rush) Full Frac Tanks 121 $ $79,406 Solidified Waste Analysis (Full TCLP - 150% Rush) Each 79 $ $51,844 Hazardous Soil (Between cells - to EQ Belleville, MI Treat toc) Tons $ $13,808,400 Non-Hazardous Soil (Between cells - Waste Mgt. Dayton, OH) Tons 0 $ $0 Solidified Haz Waste Sludge (Drums - Ross Incin. Grafton, OH) Tons 5880 $1, $6,576,192 Solidified Non-Haz Waste Sludge (Drums - Waste Mgt. Dayton, OH) Tons 0 $ $0 Cell Water - Haz Waste (to EQ Belleville, MI Treat to D) Gallons $ $2,246,880 Uncontainerized Waste Liquids (to EQ Belleville, MI Treat to D) Gallons $ $597,960 Hazardous Liquids (Drums - PCI East Chicago, IN) Gallons $ $785,400 Non-Haz Liquids Drums (Drums - EQ Belleville, MI) Gallons $ $382,500 LNAPL Liquids (Drums - PCI East Chicago, IN) Gallons 2000 $ $3,696 Backfill Strip and Re-Placement Cubic Yards $ $1,206,000 Backfill Re-Placement Cubic Yards $ $782,250 Demobilization Lump Sum 1 $100, ,2 $100,000 Stormwater Management Lump Sum 1 $500,000 2 $500,000 Personnel and Perimeter Air Monitoring Days 344 $2,250 2 $774,000 Confirmation sampling (8 soil samples per cell) Each 400 $0 1 $0 TCL VOAs Each 400 $82 1 $32,800 VOA Encore samplers (3 per Each 1200 $10 1 $12,000 TCL SVOCs Each 400 $180 1 $72,000 PCBs Each 400 $57 1 $22,800 TCL Pesticides Each 400 $90 1 $36,000 TAL Metals analysis Each 400 $97 1 $38,800 Terracore (1 per Each 400 $15 1 $6,000 Total Solids Each 400 $3 1 $1,200 Confirmation sampling reporting Each 1 $16,288 1 $16,288 Emergency response (24 hrs Vac truck and 30 day frac tank rental) Lump Sum 1 $7,245 1 $7,245 Emergency response (Spill booms) Each 10 $46 1 $460 Subtotal Direct Capital Costs $39,912,468 Other Costs Construction Administration and Design Engineering % Direct Capital costs 18% 5 $7,184,244 Contingencies % Direct Capital costs 15% 2 $5,986,870 TOTAL CAPITAL INVESTMENT $53,083,582 TOTAL CAPITAL INVESTMENT (ROUNDED) $53,084,000 Assumptions: 1. The actual final design may vary in design basis and equipment selection 2. No taxes or duties are included in this estimate. 3. Level of accuracy of this estimate is -30% to +50% 4. Contingency includes USEPA\OEPA oversight, community relations Sources: 1. Quote from Independent Vendor 2. Haley & Aldrich's\PRP's previous experience on similar sites. 3. Value from RSMeans CostWorks online software, 2004 MasterFormat, 2008 quarter 1 data release, adjusted for work in the Dayton, Ohio area USEPA 540-R OSWER July Peter and Timmerhaus "Plant Design and Economics for Chemical Engineers" Notes 1. The costs for equipment is based on 14 pieces 2. Fuel surcharge for diesel from August 2007 to March 2008 = 1.36 (See attached data) 3. Waste disposal T&D fuel surcharge assumed to be 20%

7 List of Assumptions Used to Develop Feasibility Study Level Cost Estimates Remedial Alternatives 4, 5, and 6 Tremont City Landfill Barrel Fill Site The following cost assumptions were made to estimate barrel and soil handling activities for Alternatives 4, 5, & 6 of the Tremont City Barrel Fill Site. 1. General Approach and Assumptions a. No contingency amounts were added to the individual sheets used to build costs from the bottom up. A 10 percent contingency is added to total construction cost for each Remedial Alternative, in Tab A, the Costs of Alternatives sheet. b. A drum removal rate of 200 drums per day is used to build the costs. c. We assumed that each cell is in an envelope of contaminated soil. It extends 2 feet out, one foot below and one foot above the cell dimensions. Additionally, 40,000 cubic yards outside of the envelope is impacted and is special waste. d. We assumed that 2 million gallons of water will be collected during the drum removal and will be trucked off site and treated as hazardous waste. One million gallons exists now in the cells and one million more will recharge into the cells during remediation. e. We assumed 57,500 cubic yards of soil would be transferred to the landfill. The resulting landfill is designed conceptually to be 15 feet high with a footprint of 2.2 acres. f. We included a 10 percent contingency amount for each Remedial alterative on Tab A, under the Construction Subtotal that rolls into the overall cost for the alternative. g. Costs for design, engineering, and construction management are included for each alterative as 15 percent of the Construction Subtotal on Tab A. h. Costs for bonding and insurance are included as two percent of the Construction Subtotal on Tab A. 2. Barrel and Soil Handling Assumptions a. The road upgrades unit cost was based on the National Constructors Estimating Guide for the total square footage and a 4 inch base of aggregate. b. The excavation of the overburden unit cost was based on the cost of a mass excavator moving 720 cubic yards per hour for ten hours divided in the daily cost of the excavator plus operator rate.

8 c. The transport of the overburden unit cost was based on the mass movement of the material using 25 cubic yard off-road trucks doing four cycles per hour or 100 cubic yards per hour divided into the daily rental cost of the truck plus operator rate. Equipment rate is derived from the National Constructors Estimating Guide. Operators rates were derived from previous projects plus PPE. The PPE rate was based on a quote from a contractor for another project. d. Monthly rental of a vacuum truck was based on a phone conversation with a rental equipment firm. e. The removal of the contaminated soil is based on the removal of uncontaminated soils using standard equipment. The rate was double based on the hazardous nature of the material being excavated. The rate also includes the rate of the operator and PPE. f. The removal of the drums from the cell is based on using standard equipment with a grappler type attachment. The rate also includes the rate of the operator and PPE. g. The transportation of the clean backfill material from the storage area to the cells is based on using 10 cubic yard trucks plus the operator. The rate increases due to the slower transport rate. h. The placement of the clean backfill material into the cells is based on an excavator with a 3.5 cubic yard bucket plus the operator. The rate increases due to the slower transport rate. i. The placement of the treated waste in the new landfill is based on a similar rate for moving the hazardous soils. The volume is small but the landfill is close to the treatment site. j. Shipment and disposal of onsite treated waste is based on the waste being classified as a special waste. The disposal and transportation fees are about $100 per ton each. This rate is based on previous recent projects. k. Shipment and disposal are about $295 per ton each. This rate is based on a quote for another recent project. l. 50 percent of the drums and drummed waste will need to be disposed of as hazardous material. The other 50 percent will be a special waste. Assumptions for Cost Estimate November 20, 2007 Tremont City Barrel Fill Site Alternatives 4, 5, and 6 Page 2

9 Tab: B - Volume Cales Spreadsheet to calculate number and volume of drums, waste, and water Average Average thickness of Thickness Volume of contaminated of Cell 1 drum: floor soil: Wall: 7.36 cu ft 1.0 feet 2.0 feet Porosity of Soil Backfill in Cell: 0.5 A B c D E F G H I J K L M N Drum Volume Volume of Cell Cell Drum Number Volume in of Soil Fill Soil in Cell Cell Wall Cell Wall Contains East North Depth Volume Stackina of Drums Cell Bulk Waste in Cell Floor Thickness Volume Water #Of Cell feet feet feet cu ft LxWxD drums cu ft gallons cu ft cu ft cu ft ft cu ft yes/no A ,820 15x9x11 1,525 11,224 6, feet 5,016 Yes A ,440 14x12x7 1,177 8,663 72,000 9,200 4, feet 4,160 Yes A ,800 1,620 11,923 6, , feet 5,280 Yes A ,440 14x12x7 1,176 8,655 4, feet 4,160 Yes A ,016 14x14x ,100 12,200 1,600 3, feet 2,57S Yes AS ,088 ~ 910 6,S98 4,390 1, feet 2,592 Yes A7 A ,800 2 layers 1,06S 7,84S 2, No A ,840 16x ,828 4, No A ,200 20x ,013 1,187 o o No A , , o o No B ,760 15x12x11 1,980 14,573 35,000 4,500 9,187 1, feet 5,808 Yes B ,880 Sx14x ,121 25,012 3,200 2, feet 2,800 Yes B ,168 14x11x8 1,232 9,068 1, , feet 4,600 Yes B ,000 3SO 2,650 2, No B ,440 12x14x7 1,114 8,199 20,000 2,600 ' 5, feet 4,160 Yes B ,592 ~ 966 7,110 4,482 1, feet 2,664 Yes B ,228 22x14x4 1,743 12,828 6,400 1, feet 3,772 Yes BS ,200 2 layers 501 3,687 3, feet 1,920 Yes , ,492 7,908 1, feet 3,360 Yes B ,400 3 layers 1,517 11,165 21, No C ,600 15x12x6 1,008 7,419 5, feet 3,780 Yes C ,3SO 9x13x7 7S3 5,61S 5,000 soo 3, feet 3,520 Yes C ,200 10x15x ,734 72,000 9,200 S,4S6 soo 2.0 feet 4,400 Yes C S,300 9x10x ,835 2,4S5 3SO 2.0feet 2,S60 Yes cs ,744 14x2Sx4 1,470 10,819 5,925 1, feet 3,680 Yes C ,97S 20x19x4 1,4SS 10,790 10,186 1, feet 3,95S Yes C ,800 12x25x3 S60 4,858 4, ,942 1, feet 2,520 Yes D ,440 11x13x ,925 2, , feet 3,840 Yes D ,400 12x15x7 1,089 8,015 20,500 2,600 6, feet 4,320 Yes D ,832 8x14x ,057 5,000 soo 2, feet 3,680 Yes ,780 11x14x ,278 20,000 2,600 4, feet 3,500 Yes ,050 15x15x ,189 25,861 2, feet 5,520 Yes D ,000 25x20x4 2,768 20,372 3,628 2, feet 4,320 Yes , ,962 8,438 1, feet 3,360 Yes E ,560 11x12x ,366 4, feet 3,680 Yes E ,9SO 10x12x ,129 2, , feet 2,552 Yes E3 20 2S 20 10,400 10x13x ,873 4, feet 3,680 Yes E ,400 10x13x ,667 4, feet 3,680 Yes E ,010 ~ 2,150 15,824 4,186 1, feet 4,408 Yes E ,400 20x20x3 1,337 9,840 4,560 1, feet 2,880 Yes F ,500 10x13x ,593 1, feet 2,300 Yes F ,560 9x12x ,460 3, feet 2,940 Yes F ,960 10x11x ,318 1, feet 1,512 Yes F ,300 14x25x5 2,294 16,884 3,416 1, feet 4,524 Yes F ,640 20x37x3 2,005 14,757 11,883 2, feet 4,104 NAPL G ,880 15x16x ,533 2, No G ,400 9x12x ,409 3, feet 3,080 Yes G ,120 13x18x4 1,620 11,923 3, feet 4,176 Yes H ,500 10x12x ,311 2, feet 1,620 Yes H ,000 15x16x ,232 22,768 3, feet 4,680 Yes 0 p Q R s A Volume of Total soil Water in Information Volume in Total soil Cell Note Source Cell Volume in Cell gallons cu ft CY (250Min) Cell 24,700 B 12, A1 17,900 B 9, A2 29,500 1 B 14, A3 17,900 B 9, A4 14,600 B 7, A5 16,400 B 8, AS c 0 0 A7 2 A&C 2, A8 1,2 B 4, A9 1,2 c 1, A10 2 A&C A11 34,400 B 16, B1 10,300 B 5, B2 19,100 B 10, B3 1,2 c B4 19,600 B 10, B5 16,800 B 8, B6 23,900 A 11, B7 13,100 1,3 c 6, B8 29,600 1 c 12, B9 2 A 21, B10 19,400 B 9, C1 14,000 B 7, C2 24,200 A&B 11,4SS 425 C3 9,200 B 5, C4 22,200 B 11, C6 38,100 B 15, C7 22,200 1 c 9,6S2 358 C9 20,600 B 9, D1 23,900 B 11, D2 10,400 B 6, D3 16,800 B 8, D4 9S,700 B 34, D6 13,600 A, B&C 9, D7 31,600 1 B 12, ,700 4 B 8, E1 10,600 B 5, E2 16,900 B 8, E3 17,700 B 8, E4 15,700 B 9, E6 17,100 B 9, E7 7,100 B 4, F2 11,SOO B 6, F3 6,100 B 3, F4 12,800 B 9, F6 44,400 A 18, F7 2 c 2, G2 14,900 7, G3 12,000 1 c 8, G6 8,200 c 4, H2 85,200 c 30, H3 51 Quantity; 663,734 51, , ,212 39, ,069 43, ,740 Cells Units of Measure: cu ft drums cu ft gallons cu ft cu ft cu ft cu ft Source of lnfonnation A RI Appendix H. Summary of Waste Cell Characterization Activities B Hand drawn maps of cells with dimensions, number of drums, stacking, and start and finish dates C Measured off 1985 Geophysics Map 946, ,063 19,438 cy gallons cu ft 33,045 tons Note 5 Notes 1 Depth of Cell was not provided in Handwritten table developed during barrel fill construction. Depth estimated based on cell dimensions and number of drums 2 On the basis of the Waste Cell Characterization, cells that were 8 feet or less deep tended not to contain groundwater Based on proximity to Cell B-7 found to contain water during the Waste Cell Characterization, Cell B-8 is assumed to contain water, Cell E1 is shown on lists of cells, but not shown on the Map of Cell Locations - Drum stacking dimensions were shown in Hand drawn table, but appear to be lined out. 5 A conversion factor of 1.7 was used to convert from cubic yards (cy) to tons.

10 Tab: 8-Description of Calculations Page 1of2 Explanation of Variables and assumptions used to calculate volumes in Tab B. Information available in the Tremont City Landfill Barrel Fill web database has been used to develop estimates of the volumes of waste, contaminated soil and contaminated groundwater that will be managed under Alternatives 4, 5, and 6 as described in the AAD. The following is an explanation of the data, the estimate, or the calculation that is contained in each of the columns of Tab B "Volume Cales." Column Data or Variable Exolanation A Cell Numbers Cell numbers were assigned during construction of the barrel fill. These are listed on maps of the site and on a handwritten summary of the contents of each cell B, C, &D Dimensions of Cell Most of the numbers used to define the cell sizes, depths, number of in feet drums, and the array of layers, columns and rows of the drums were derived from a handwritten documentation developed during construction of the barrel fill, and available in the project files. E Calculation Multiplying the numbers in Columns B, C, and D for each cell provides an of Cell Volume estimate of the dimensions of the original excavation for the cell in cubic feet. F Drum Stacking Most of the cells listed on the hand-written description of drum disposal included a length by width by depth listing of the drum stacking. The stacking description for each cell is listed in column F G Drum Count This column contains the number of drums that were recorded as having in Cell been disposed of in each cell H Calculation The volume (in cubic feet) of drummed waste in each cell was derived by of Volume of multiplying the number of drums in Column G by 7.36 (cubic feet/drum). Drummed Waste I Bulk Waste Bulk Waste Volume disposed in each cell was recorded during the construction added to Cell of each cell. This number was not explicitly used in the calculation of volume of waste in the cell, but is included for evaluation purposes. The volume of soil and waste surrounding the drums in each cell is calculated in Column J. J Calculation The volume of soil fill in each cell was calculated by subtracting the cubic Volume of Residual feet of drummed waste (Column H) from the total volume of the cell Waste/Soil in Cell (Column E). K Calculation Additional soil in the floor of each cell will likely need to be treated, if the Volume of cell is filled with groundwater, if liquid waste was put in the cell, or if any of Contaminated Soil the drums have leaked. Column K was included to calculate the volume of In Floor of Cell additional soil from the floor beneath the cell that might need treatment. The volume was calculated by multiplying Column B by Column C and by a one-foot thickness to represent the floor. The spreadsheet is set up so the one-foot thickness can be changed, by changing the number listed above column K. L Variable If liquid wastes were placed in a cell or if some drums have leaked and Thickness of the cell contains groundwater, some amount of soil in the cell-wall may Cell Wall to be contain contaminants and need to be treated. A default value for Considered thickness of the cell-wall needing treatment is placed as variable above Contaminated Soil Column L, and then carried down the column for each cell. The variable is not repeated in any lines in Column L in which there was no bulk waste disposal and there is an indication that there is no groundwater.

11 Tab: 8-Description of Calculations Page 2 of 2 Column Data or Variable Exolanation M Calculation The volume of cell-wall soil potentially requiring treatment is calculated for Volume of each cell using values from Columns B, C, D and L. Contaminated Soil The soil volume is calculated in cubic feet. Represented by Cell walls N Variable Column N indicates whether it is likely that each cell is filled with groundwater. Information was derived from Appendix H in the RI Report, which reports the results of test pits dug into seven of the cells. 0 Calculation The volume of groundwater that could be contained in each cell is calculated in Volume of Column 0. It is assumed groundwater will be contained in the soil porosity and Contaminated Water in the void spaces between stacked drums. 0.5 is selected as the variable to in Cell represent the total porosity of the cell volume, calculated from Column J. p Notes This column contains notes to identify the source or sources for data used in making the calculations. Numbered notes are listed at the bottom of the table. Q Notes This column contains notes explaining the assumptions used to define dimensions that were missing for a particular cell. R Calculation Of interest is the total amount of contaminated soil and residual waste J+K+M represent by each cell. Column R sums the number of cubic feet of contaminated soil from the drum cell itself (J), the floor of the cell (K) and the soil represented by two feet of the cell wall (M). s Conversion Column S converts the volume of soil from cubic feet to cubic yards by from cf to cy dividing the number in Column R by 27. Each cell in column Sis given a minimum value of 250 CY. Contaminated Soil (cubic yards) Contaminated Soil (tons) The sum of the values in column S provides the total number of cubic yards of hazardous waste and contaminated soil requiring treatment. The value is 19,438 CY. The number of tons of contaminated soils is useful for some calculations. Using a conversion factor of 1.7 tons per cubic yard, yields an estimated 33,045 tons of waste and contaminated soil requiring treatment and disposal.

12 Page 1 of 6 TABLE 7 SUMMARY OF TEST PIT SOIL ANALYTICAL RESULTS TREMONT BFOU TREMONT CITY, OHIO chemical_name C-3 Side Wall ft 11/13/2003 C-3 Bottom 11/13/2003 D-7 Bottom ft 4/20/2004 D-7 Side Wall ft 11/17/2004 Metals (MG/KG) Aluminum Antimony 0.77 J 0.62 J 0.94 J ND (0.57) UJ Arsenic J Barium Beryllium 0.18 J 0.35 J ND (0.01) 0.43 J Cadmium ND (0.02) ND (0.02) 0.13 J 0.3 J Calcium J Chromium Cobalt J Copper J Cyanide ND (0.07) ND (0.08) ND (0.18) ND (0.20) Iron Lead J Magnesium J Manganese J Mercury ND (0.003) J J Nickel J Potassium J Selenium ND (0.17) ND (0.19) ND (0.11) ND (0.25) UJ Silver ND (0.02) ND (0.03) ND (0.08) ND (0.19) Sodium 306 J 357 J J Thallium ND (0.29) ND (0.31) ND (0.26) 2.1 J Vanadium Zinc J PCBs (UG/KG) Aroclor-1016 ND (15) ND (15) ND (10) ND (6.2) Aroclor-1221 ND (14) ND (14) ND (26) ND (8.4) Aroclor-1232 ND (5.4) ND (5.4) ND (23) ND (23) Aroclor-1242 ND (10) ND (10) ND (15) ND (8.2) Aroclor-1248 ND (9.1) ND (9.1) ND (17) ND (12) Aroclor-1254 ND (9) ND (9) ND (5.2) ND (5.2) Aroclor-1260 ND (9.2) ND (9.2) ND (6.3) ND (6.3) Pesticides (UG/KG) 4,4-DDD ND (0.33) ND (0.33) ND (0.33) ND (0.33) 4,4-DDE ND (0.4) ND (0.4) ND (0.17) ND (0.17) 4,4-DDT ND (0.5) ND (0.5) ND (0.50) ND (0.50) Aldrin ND (0.17) 2.3 J ND (0.16) ND (0.16) alpha-bhc 0.46 J ND (0.26) ND (0.084) ND (0.084) alpha-chlordane 1.2 J ND (0.22) ND (0.17) ND (0.17) beta-bhc 5.6 J 12 J ND (0.27) ND (0.27) delta-bhc 1.6 J 0.33 J ND (0.16) ND (0.16) Dieldrin 2.2 J ND (0.43) ND (0.17) ND (0.17) Endosulfan I 3.2 ND (0.43) ND (0.17) ND (0.17) Endosulfan II ND (0.58) ND (0.58) ND (0.33) ND (0.33) Endosulfan sulfate ND (0.4) ND (0.4) ND (0.33) ND (0.33) Endrin ND (0.35) R ND (0.35) R ND (0.33) ND (0.33) Endrin aldehyde ND (0.35) ND (0.35) ND (0.33) ND (0.33) Endrin ketone ND (0.83) ND (0.83) ND (0.83) ND (0.83) gamma-bhc (Lindane) 1.5 J ND (0.22) ND (0.12) ND (0.12) gamma-chlordane 2.8 J ND (0.35) ND (0.084) ND (0.084) Heptachlor 2.5 ND (0.34) ND (0.084) ND (0.084) Heptachlor epoxide ND (0.26) ND (0.26) ND (0.092) ND (0.092) Methoxychlor ND (1.4) ND (1.4) ND (1.1) ND (1.1) Toxaphene ND (18) ND (18) ND (17) ND (17) Haley & Aldrich, Inc. 10/23/2006

13 Page 2 of 6 TABLE 7 SUMMARY OF TEST PIT SOIL ANALYTICAL RESULTS TREMONT BFOU TREMONT CITY, OHIO chemical_name C-3 Side Wall ft 11/13/2003 C-3 Bottom 11/13/2003 D-7 Bottom ft 4/20/2004 D-7 Side Wall ft 11/17/2004 Semi-Volatile Organic Compounds (UG/KG) 2,2-oxybis(1-Chloropropane) ND (67) ND (67) ND (67) ND (67) 2,4,5-Trichlorophenol ND (67) ND (67) ND (67) ND (67) 2,4,6-Trichlorophenol ND (67) ND (67) ND (67) ND (67) 2,4-Dichlorophenol ND (67) ND (67) ND (67) ND (67) 2,4-Dimethylphenol ND (67) ND (67) ND (67) ND (67) 2,4-Dinitrophenol ND (170) ND (170) ND (170) ND (170) UJ 2,4-Dinitrotoluene ND (67) ND (67) ND (67) ND (67) 2,6-Dinitrotoluene ND (67) ND (67) ND (67) ND (67) 2-Chloronaphthalene ND (67) ND (67) ND (67) ND (67) 2-Chlorophenol ND (67) ND (67) ND (67) ND (67) 2-Methylnaphthalene 420 ND (67) ND (67) ND (67) 2-Methylphenol 160 J 96 J ND (67) ND (67) 2-Nitroaniline ND (130) ND (130) ND (130) ND (130) 2-Nitrophenol ND (67) ND (67) ND (67) ND (67) 3,3-Dichlorobenzidine ND (67) ND (67) ND (67) ND (67) 3-Nitroaniline ND (130) ND (130) ND (130) ND (130) 4,6-Dinitro-2-methylphenol ND (130) ND (130) ND (130) ND (130) UJ 4-Bromophenyl phenyl ether ND (67) ND (67) ND (67) ND (67) 4-Chloro-3-methylphenol ND (67) ND (67) ND (67) ND (67) 4-Chloroaniline 88 J ND (67) ND (67) ND (67) 4-Chlorophenyl phenyl ether ND (67) ND (67) ND (67) ND (67) 4-Methylphenol ND (67) 140 J ND (67) ND (67) 4-Nitroaniline ND (130) ND (130) ND (130) ND (130) 4-Nitrophenol ND (130) ND (130) ND (130) ND (130) Acenaphthene ND (67) ND (67) ND (67) ND (67) Acenaphthylene ND (67) ND (67) ND (67) ND (67) Acetophenone 540 ND (67) ND (67) ND (67) Anthracene ND (67) ND (67) ND (67) ND (67) Atrazine ND (67) ND (67) ND (67) UJ ND (67) Benzaldehyde ND (67) ND (67) ND (67) ND (67) Benzo(a)anthracene ND (67) ND (67) ND (67) ND (67) Benzo(a)pyrene ND (67) ND (67) ND (67) ND (67) Benzo(b)fluoranthene ND (67) ND (67) ND (67) ND (67) Benzo(g,h,i)perylene ND (67) ND (67) ND (67) ND (67) Benzo(k)fluoranthene ND (67) ND (67) ND (67) ND (67) Biphenyl ND (67) ND (67) ND (67) ND (67) bis(2-chloroethoxy)methane ND (67) ND (67) ND (67) ND (67) bis(2-chloroethyl)ether ND (67) ND (67) ND (67) ND (67) bis(2-ethylhexyl)phthalate J ND (67) 100 J Butyl benzylphthalate 190 J ND (67) ND (67) ND (67) Caprolactam ND (67) ND (67) ND (67) ND (67) Carbazole ND (67) ND (67) ND (67) ND (67) Chrysene ND (67) ND (67) ND (67) ND (67) Dibenzo(a,h)anthracene ND (67) ND (67) ND (67) ND (67) Dibenzofuran ND (67) ND (67) ND (67) ND (67) Diethyl phthalate ND (67) ND (67) ND (67) ND (67) Dimethyl phthalate ND (67) ND (67) ND (67) ND (67) Di-n-butylphthalate ND (67) ND (67) ND (67) ND (67) Di-n-octyl phthalate ND (67) ND (67) ND (67) ND (67) Fluoranthene ND (67) ND (67) ND (67) ND (67) Fluorene ND (67) ND (67) ND (67) ND (67) Hexachlorobenzene ND (67) ND (67) ND (67) ND (67) Hexachlorobutadiene ND (67) ND (67) ND (67) ND (67) Hexachlorocyclopentadiene ND (68) ND (68) ND (68) ND (68) Hexachloroethane ND (67) ND (67) ND (67) ND (67) Indeno(1,2,3-cd)pyrene ND (67) ND (67) ND (67) ND (67) Isophorone ND (67) ND (67) Naphthalene 1200 /1300 ND (67) ND (67) ND (67) Nitrobenzene ND (67) ND (67) ND (67) ND (67) N-Nitrosodi-n-propylamine ND (67) ND (67) ND (67) ND (67) N-Nitrosodiphenylamine ND (67) ND (67) ND (67) ND (67) Pentachlorophenol ND (130) ND (130) ND (130) ND (130) Phenanthrene ND (67) ND (67) ND (67) ND (67) Phenol ND (67) ND (67) Pyrene ND (67) ND (67) ND (67) ND (67) Haley & Aldrich, Inc. 10/23/2006

14 Page 3 of 6 TABLE 7 SUMMARY OF TEST PIT SOIL ANALYTICAL RESULTS TREMONT BFOU TREMONT CITY, OHIO chemical_name C-3 Side Wall ft 11/13/2003 C-3 Bottom 11/13/2003 D-7 Bottom ft 4/20/2004 D-7 Side Wall ft 11/17/2004 Volatile Organic Compounds (UG/KG) 1,1,1-Trichloroethane 2900 J 1 J ND (50) ND (1) 1,1,2,2-Tetrachloroethane ND (1.00) ND (1.00) UJ ND (67) ND (1) 1,1,2-Trichloroethane 13 ND (1.00) ND (81) ND (1) 1,1-Dichloroethane 910 J 2900 J 140 J 21 1,1-Dichloroethene 22 ND (1.00) ND (50) ND (1) 1,2,4-Trichlorobenzene ND (1.70) ND (1.70) UJ ND (50) ND (1.7) 1,2-Dibromo-3-chloropropane (DBCP) ND (1.00) ND (1.00) UJ ND (76) ND (1) 1,2-Dibromoethane ND (1.00) ND (1.00) ND (50) ND (1) 1,2-Dichlorobenzene ND (1.30) ND (1.30) UJ ND (50) ND (1.3) 1,2-Dichloroethane ND (50) ND (1) 1,2-Dichloropropane ND (1.00) ND (1.00) ND (50) ND (1) 1,3-Dichlorobenzene ND (1.40) ND (1.40) UJ ND (50) ND (1.4) 1,4-Dichlorobenzene ND (1.50) ND (1.50) UJ ND (50) ND (1.5) 2-Butanone J J ND (1.9) 2-Hexanone 4700 J 1100 J 360 J ND (1.7) 4-Methyl-2-pentanone 3300 J J J Acetone J J Benzene ND (50) ND (1) Bromodichloromethane ND (1.00) ND (1.00) ND (50) ND (1) Bromoform ND (1.00) ND (1.00) ND (76) ND (1) Bromomethane ND (1.00) ND (1.00) 360 J ND (1) Carbon disulfide 77 J 5 J ND (50) ND (1) Carbon tetrachloride 650 J ND (1.00) ND (50) ND (1) Chlorobenzene ND (1.00) ND (1.00) ND (50) ND (1) R Chloroethane ND (50) ND (1) Chloroform (Trichloromethane) 41 ND (1.00) ND (50) ND (1) Chloromethane 12 6 ND (50) UJ ND (1) cis-1,2-dichloroethene 42 5 ND (50) ND (1) cis-1,3-dichloropropene ND (1.00) ND (1.00) ND (50) ND (1) Cyclohexane 32 ND (1.30) ND (50) ND (1.3) Dibromochloromethane ND (1.00) ND (1.00) ND (76) ND (1) Dichlorodifluoromethane (CFC-12) ND (1.00) ND (1.00) ND (50) UJ ND (1) Ethylbenzene 3200 J 1 J ND (53) ND (1) Isopropylbenzene 67 ND (1.20) ND (50) ND (1.2) Methyl acetate ND (1.00) ND (1.00) 580 J ND (1) Methyl cyclohexane ND (1.70) 2 J ND (50) ND (1.7) Methyl Tert Butyl Ether ND (1.00) ND (1.00) ND (50) ND (1) Methylene chloride J J 4200 ND (1) Styrene 36 ND (1.00) ND (50) ND (1) Tetrachloroethene 170 ND (1.00) ND (56) ND (1) Toluene J 49 ND (53) ND (1) trans-1,2-dichloroethene 12 1 J ND (56) ND (1) trans-1,3-dichloropropene ND (1.00) ND (1.00) ND (75) ND (1) Trichloroethene J J ND (50) ND (1) Trichlorofluoromethane (CFC-11) 40 9 ND (50) ND (1) UJ Trifluorotrichloroethane (Freon 113) 12 9 ND (60) ND (1) Vinyl chloride 6 6 ND (50) ND (1) Xylene (total) J 6 J ND (63) ND (1.3) Notes and Abbreviations: 1. ND ( ) - The compound was not detected. MDL in parenthesis. 2. J - An estimated value. 3. UJ - An estimated reporting limit. 4. R - Data was rejected, unable to verify. Haley & Aldrich, Inc. 10/23/2006

15 Page 4 of 6 TABLE 7 SUMMARY OF AND LNAPL ANALYTICAL RESULTS TREMONT BFOU TREMONT CITY, OHIO chemical_name B-7 11/20/2003 B-7 (FD) 11/20/2003 C-3 10/29/2003 C-3 11/13/2003 D-7 12/1/2003 F-7 LNAPL 10/28/2003 Metals (UG/L) Aluminum Antimony J J Arsenic Barium Beryllium 0.4 J 0.44 J 0.8 J J 0.59 J Cadmium ND (0.18) ND (0.18) J 1.5 J Calcium Chromium Cobalt Copper ND (1.3) Cyanide J 9.8 J Iron Lead Magnesium Manganese Mercury 0.12 J 0.15 J Nickel Potassium Selenium Silver 2.1 J 1.9 J 0.62 J ND (0.50) 0.97 J ND (0.50) Sodium Thallium ND (3.8) 20.3 ND (3.6) ND (3.8) Vanadium Zinc PCBs (UG/L) Aroclor-1016 ND (1.4) ND (1.4) ND (1.9) ND (0.47) UJ ND (0.53) ND (0.47) Aroclor-1221 ND (2.9) ND (2.9) ND (3.8) ND (0.95) UJ ND (1.1) ND (0.95) Aroclor-1232 ND (1) ND (1) ND (1.4) ND (0.35) UJ ND (0.39) ND (0.35) Aroclor-1242 ND (1.3) ND (1.3) ND (1.7) ND (0.43) UJ ND (0.48) ND (0.43) Aroclor-1248 ND (0.9) ND (0.9) ND (1.2) ND (0.3) UJ ND (0.33) ND (0.3) Aroclor-1254 ND (1.2) ND (1.2) ND (1.5) ND (0.39) UJ ND (0.43) ND (0.39) Aroclor-1260 ND (0.98) ND (0.98) ND (1.3) ND (0.33) UJ ND (0.36) ND (0.33) Total PCBs ND ND ND ND ND ND Pesticides (UG/L) 4,4-DDD ND (0.12) ND (0.12) ND (0.16) ND (0.04) UJ 1.7 J ND (0.04) 4,4-DDE ND (0.06) ND (0.06) ND (0.08) ND (0.02) UJ ND (0.022) ND (0.02) 4,4-DDT ND (0.18) ND (0.18) ND (0.24) ND (0.06) UJ ND (0.067) ND (0.06) Aldrin ND (0.015) ND (0.015) ND (0.02) ND (0.0051) UJ 2.1 J ND (0.0051) alpha-bhc ND (0.056) ND (0.056) ND (0.075) ND (0.019) UJ ND (0.021) ND (0.019) alpha-chlordane ND (0.06) ND (0.06) ND (0.08) ND (0.02) UJ ND (0.022) ND (0.02) beta-bhc ND (0.055) ND (0.055) ND (0.073) 3.2 J J delta-bhc ND (0.11) ND (0.11) ND (0.15) 0.76 J ND (0.04) ND (0.036) Dieldrin ND (0.064) ND (0.064) ND (0.085) 3 J 0.91 J ND (0.021) Endosulfan I ND (0.06) ND (0.06) ND (0.08) ND (0.02) UJ ND (0.022) ND (0.02) Endosulfan II ND (0.12) ND (0.12) ND (0.16) ND (0.04) UJ ND (0.044) ND (0.04) Endosulfan sulfate ND (0.12) ND (0.12) ND (0.16) ND (0.04) UJ ND (0.044) ND (0.04) Endrin ND (0.12) ND (0.12) ND (0.16) 2.2 J ND (0.044) ND (0.04) Endrin aldehyde ND (0.18) ND (0.18) ND (0.24) 0.43 J ND (0.067) ND (0.061) Endrin ketone 25 J 42 J ND (0.085) ND (0.021) UJ ND (0.024) ND (0.021) gamma-bhc (Lindane) ND (0.031) ND (0.031) ND (0.042) ND (0.01) UJ ND (0.012) ND (0.01) gamma-chlordane ND (0.03) ND (0.03) ND (0.04) ND (0.01) UJ ND (0.011) ND (0.01) Heptachlor ND (0.083) ND (0.083) ND (0.11) ND (0.028) UJ ND (0.031) ND (0.028) Heptachlor epoxide ND (0.064) ND (0.064) ND (0.085) ND (0.021) UJ ND (0.024) ND (0.021) Methoxychlor ND (0.32) ND (0.32) ND (0.43) ND (0.11) UJ ND (0.12) ND (0.11) Toxaphene ND (3) ND (3) ND (4) ND (1) UJ ND (1.1) ND (1) Haley & Aldrich, Inc. 10/23/2006

16 Page 5 of 6 TABLE 7 SUMMARY OF AND LNAPL ANALYTICAL RESULTS TREMONT BFOU TREMONT CITY, OHIO chemical_name B-7 11/20/2003 B-7 (FD) 11/20/2003 C-3 10/29/2003 C-3 11/13/2003 D-7 12/1/2003 F-7 LNAPL 10/28/2003 Semi-Volatile Organic Compounds (UG/L) 2,2-oxybis(1-Chloropropane) ND (22) ND (20) ND (20) UJ ND (5) ND (4) ND (8) UJ 2,4,5-Trichlorophenol ND (28) ND (25) ND (25) ND (6) ND (6) ND (10) 2,4,6-Trichlorophenol ND (29) ND (26) ND (26) ND (7) ND (6) ND (10) 2,4-Dichlorophenol ND (22) ND (20) ND (20) ND (5) ND (4) ND (8) 2,4-Dimethylphenol ND (22) ND (20) ND (20) ND (5) 560 ND (8) 2,4-Dinitrophenol ND (59) UJ ND (53) UJ ND (53) UJ ND (13) ND (12) UJ ND (21) UJ 2,4-Dinitrotoluene ND (22) ND (20) ND (20) ND (5) ND (4) ND (8) 2,6-Dinitrotoluene ND (22) ND (20) ND (20) ND (5) ND (4) ND (8) 2-Chloronaphthalene ND (22) ND (20) ND (20) ND (5) ND (4) ND (8) 2-Chlorophenol ND (22) ND (20) ND (20) ND (5) ND (4) ND (8) 2-Methylnaphthalene 550 J 390 J J ND (4) Methylphenol 880 J 700 J ND (20) J Nitroaniline ND (44) ND (40) ND (40) ND (10) ND (9) ND (16) 2-Nitrophenol ND (22) ND (20) ND (20) ND (5) ND (4) ND (8) 3,3-Dichlorobenzidine ND (22) UJ ND (20) UJ ND (20) ND (5) ND (4) UJ ND (8) 3-Nitroaniline ND (44) ND (40) ND (40) ND (10) ND (9) ND (16) 4,6-Dinitro-2-methylphenol ND (44) ND (40) ND (40) ND (10) ND (9) ND (16) 4-Bromophenyl phenyl ether ND (22) ND (20) ND (20) ND (5) ND (4) ND (8) 4-Chloro-3-methylphenol ND (22) ND (20) ND (20) ND (5) 770 ND (8) 4-Chloroaniline ND (22) ND (20) ND (20) ND (5) ND (4) ND (8) 4-Chlorophenyl phenyl ether ND (22) ND (20) ND (20) ND (5) ND (4) ND (8) 4-Methylphenol ND (23) Nitroaniline ND (44) ND (40) ND (40) ND (10) ND (9) ND (16) 4-Nitrophenol ND (44) UJ ND (40) UJ ND (40) UJ ND (10) ND (9) UJ ND (16) UJ Acenaphthene ND (22) ND (20) ND (20) ND (5) ND (4) ND (8) Acenaphthylene ND (22) ND (20) ND (20) ND (5) ND (4) ND (8) Acetophenone ND (20) 270 ND (4) 63 Anthracene ND (22) ND (20) ND (20) ND (5) ND (4) ND (8) Atrazine ND (22) ND (20) ND (20) ND (5) ND (4) UJ ND (8) Benzaldehyde ND (26) ND (7) ND (6) ND (10) Benzo(a)anthracene ND (22) ND (20) ND (20) ND (5) ND (4) 20 J Benzo(a)pyrene ND (22) ND (20) ND (20) ND (5) ND (4) ND (8) Benzo(b)fluoranthene ND (22) ND (20) ND (20) ND (5) ND (4) ND (8) Benzo(g,h,i)perylene ND (22) ND (20) ND (20) ND (5) ND (4) ND (8) Benzo(k)fluoranthene ND (22) ND (20) ND (20) ND (5) ND (4) ND (8) Biphenyl ND (22) ND (20) 1200 ND (5) ND (4) 16 J bis(2-chloroethoxy)methane ND (22) ND (20) ND (20) ND (5) ND (4) ND (8) bis(2-chloroethyl)ether ND (22) ND (20) ND (20) ND (5) ND (4) ND (8) bis(2-ethylhexyl)phthalate ND (5) Butyl benzylphthalate ND (5) 360 J 610 Caprolactam ND (22) ND (20) ND (20) ND (5) ND (4) ND (8) Carbazole ND (22) ND (20) ND (20) ND (5) ND (4) 32 J Chrysene ND (22) ND (20) ND (20) ND (5) ND (4) ND (8) Dibenzo(a,h)anthracene ND (22) ND (20) ND (20) ND (5) ND (4) ND (8) Dibenzofuran ND (22) ND (20) ND (20) ND (5) ND (4) ND (8) Diethyl phthalate ND (22) ND (20) ND (20) ND (5) Dimethyl phthalate J 80 J Di-n-butylphthalate ND (22) ND (20) 490 J ND (5) ND (4) 160 Di-n-octyl phthalate ND (22) ND (20) ND (20) ND (5) ND (4) 9 J Fluoranthene ND (22) ND (20) ND (20) ND (5) ND (4) ND (8) Fluorene ND (22) ND (20) ND (20) ND (5) ND (4) 15 J Hexachlorobenzene ND (22) ND (20) ND (20) ND (5) ND (4) ND (8) Hexachlorobutadiene ND (23) ND (21) ND (21) ND (5) ND (5) ND (8) Hexachlorocyclopentadiene ND (22) ND (20) ND (20) ND (5) ND (4) ND (8) Hexachloroethane ND (22) ND (20) ND (20) ND (5) ND (4) ND (8) Indeno(1,2,3-cd)pyrene ND (22) ND (20) ND (20) ND (5) ND (4) ND (8) Isophorone ND (22) ND (20) ND (4) ND (8) Naphthalene J 930 J Nitrobenzene ND (22) ND (20) ND (20) ND (5) ND (4) ND (8) N-Nitrosodi-n-propylamine ND (22) ND (20) ND (20) ND (5) ND (4) ND (8) N-Nitrosodiphenylamine ND (22) ND (20) 1800 ND (5) ND (4) 48 Pentachlorophenol ND (44) ND (40) ND (40) ND (10) ND (9) ND (16) Phenanthrene ND (22) ND (20) ND (20) ND (5) ND (4) 33 J Phenol ND (20) Pyrene ND (22) ND (20) ND (20) ND (5) ND (4) ND (8) Haley & Aldrich, Inc. 10/23/2006

17 Page 6 of 6 TABLE 7 SUMMARY OF AND LNAPL ANALYTICAL RESULTS TREMONT BFOU TREMONT CITY, OHIO chemical_name B-7 11/20/2003 B-7 (FD) 11/20/2003 C-3 10/29/2003 C-3 11/13/2003 D-7 12/1/2003 F-7 LNAPL 10/28/2003 Volatile Organic Compounds (UG/L) 1,1,1-Trichloroethane ND (0.10) ND (0.10) ND (0.10) 1,1,2,2-Tetrachloroethane ND (0.10) ND (0.10) ND (0.053) ND (0.10) UJ ND (1.00) ND (0.10) 1,1,2-Trichloroethane ND (0.10) ND (0.10) ND (0.060) ND (0.10) ND (1.00) ND (0.10) 1,1-Dichloroethane 5600 J J ,1-Dichloroethene ND (0.10) ND (0.10) ND (0.064) 57 J 39 J ND (0.10) 1,2,4-Trichlorobenzene ND (0.10) ND (0.10) 3000 J ND (0.10) ND (1.70) ND (0.10) 1,2-Dibromo-3-chloropropane (DBCP) ND (0.25) ND (0.25) ND (0.25) ND (0.25) ND (1.00) ND (0.25) 1,2-Dibromoethane ND (0.10) ND (0.10) ND (0.017) ND (0.10) ND (1.00) ND (0.10) 1,2-Dichlorobenzene ND (0.10) ND (0.10) 1200 J ND (0.10) ND (1.40) ND (0.10) 1,2-Dichloroethane ND (0.10) ND (0.10) ND (0.038) 98 J 110 J ND (0.10) 1,2-Dichloropropane ND (0.10) ND (0.10) ND (0.052) ND (0.10) 27 J ND (0.10) 1,3-Dichlorobenzene ND (0.10) ND (0.10) 860 J ND (0.10) ND (1.50) ND (0.10) 1,4-Dichlorobenzene ND (0.10) ND (0.10) 870 J ND (0.10) ND (1.20) ND (0.10) 2-Butanone Hexanone J J ND (0.27) J ND (4.00) ND (0.27) 4-Methyl-2-pentanone Acetone J Benzene ND (0.10) ND (0.10) 1200 J J Bromodichloromethane ND (0.10) ND (0.10) ND (0.050) ND (0.10) ND (1.00) ND (0.10) Bromoform ND (0.10) ND (0.10) ND (0.068) ND (0.10) UJ ND (1.00) ND (0.10) Bromomethane ND (0.10) ND (0.10) ND (0.088) ND (0.10) ND (1.00) ND (0.10) Carbon disulfide ND (0.10) ND (0.10) ND (0.072) 33 J 61 J ND (0.10) Carbon tetrachloride ND (0.10) ND (0.10) ND (0.028) ND (0.10) ND (1.00) ND (0.10) Chlorobenzene ND (0.10) ND (0.10) 320 J ND (0.10) ND (1.20) ND (0.10) Chloroethane ND (0.12) ND (0.12) ND (0.12) 450 J 160 ND (0.12) Chloroform (Trichloromethane) ND (0.10) ND (0.10) ND (0.025) 130 ND (1.00) ND (0.10) Chloromethane ND (0.13) UJ ND (0.13) UJ ND (0.13) 280 ND (1.00) ND (0.13) cis-1,2-dichloroethene ND (0.10) ND (0.10) ND (0.025) J 3600 cis-1,3-dichloropropene ND (0.10) ND (0.10) ND (0.057) ND (0.10) ND (1.00) ND (0.10) Cyclohexane ND (0.10) ND (0.10) ND (0.041) ND (0.10) 450 ND (0.10) Dibromochloromethane ND (0.10) ND (0.10) ND (0.021) ND (0.10) ND (1.00) ND (0.10) Dichlorodifluoromethane (CFC-12) ND (0.10) UJ ND (0.10) UJ ND (0.060) ND (0.10) UJ ND (1.00) ND (0.10) Ethylbenzene 3300 J 3500 J J 4600 Isopropylbenzene ND (0.10) ND (0.10) 1800 J 110 J 260 ND (0.10) Methyl acetate ND (0.15) ND (0.15) ND (0.15) UJ ND (0.15) UJ 760 ND (0.15) Methyl cyclohexane ND (0.10) ND (0.10) ND (0.055) ND (0.10) 400 ND (0.10) Methyl Tert Butyl Ether ND (0.10) ND (0.10) ND (0.081) ND (0.10) ND (1.00) ND (0.10) Methylene chloride m-xylene J J o-xylene 3600 J 3900 J Styrene ND (0.10) ND (0.10) 5700 J ND (0.10) ND (1.10) 690 J Tetrachloroethene ND (0.10) 1300 J 1500 J ND (0.10) Toluene trans-1,2-dichloroethene ND (0.10) ND (0.10) ND (0.027) 40 J ND (1.00) ND (0.10) trans-1,3-dichloropropene ND (0.10) ND (0.10) ND (0.082) ND (0.10) ND (1.00) ND (0.10) Trichloroethene 2000 J 3000 J 3700 J J Trichlorofluoromethane (CFC-11) ND (0.10) ND (0.10) ND (0.10) UJ Trifluorotrichloroethane (Freon 113) ND (0.10) ND (0.10) ND (0.10) 30 J ND (1.00) ND (0.10) Vinyl chloride ND (0.10) ND (0.10) ND (0.063) 68 J ND (1.00) ND (0.10) Xylene (total) J J J Notes and Abbreviations: 1. ND ( ) - The compound was not detected. MDL in parenthesis. 2. J - An estimated value. 3. UJ - An estimated reporting limit. 4. R - Data was rejected, unable to verify. Haley & Aldrich, Inc. 10/23/2006

18 4HA United States Office of Directive No FS Environmental Protection Solid Waste and EPA 540/F-96/008 Agency Emergency Response PB July 1996 User s Guide to the VOCs in Soils Presumptive Remedy Office of Emergency and Remedial Response User s Guide In order to expedite remedy selection at similar types of sites, EPA recommends the use of presumptive remedies preferred technologies for common categories of sites, based on historical patterns of remedy selection and EPA's scientific and engineering evaluation of performance data on technology implementation. This User s Guide recommends the soil vapor extraction (SVE) technology as the preferred presumptive remedy for sites where volatile organic components (VOCs) are present in soil and treatment is warranted, although the thermal resorption and incineration technologies maybe selected as presumptive remedies at sites where conditions are appropriate. Presumptive remedies are expected to be used at all appropriate sites except under unusual site-specific circumstances. This guide is based on the VOCs in Soils Presumptive Remedy Guidance, Presumptive Remedies: Site Characterization and Technology Selection for CERCLA Sites with Volatile Organic Compounds in Soils, OSWER FS. Please refer to that guidance for a more detailed description of how the presumptive remedy can be applied at sites where volatile organic components (VOCs) are present in soil. This User s Guide is intended to aid the site manager. It: Explains the benefits of using the presumptive remedy approach; Highlights how to decide if the presumptive remedy approach can be applied to your site; Explains which presumptive remedy approach to select for your site (the preferred presumptive remedial alternative for sites with VOCs in the soils is soil vapor extraction (SVE)); Describes how to write the feasibility study (FS) or engineering evaluation/cost analysis (EE/CA) for a presumptive remedy; and Outlines administrative record requirements. Time and cost savings can be realized by following the presumptive remedy approach during a remedial investigation/feasibility study (RI/FS). First, since a preferred cleanup technology can be identified prior to or early in the RI, technology-specific remedial design data can be collected and analyzed sooner. In addition, use of the presumptive remedy approach eliminates the need to: Identify potential treatment technologies Screen technologies in your site-specific FS or EE/CA. In addition, the steps of assembling technologies into alternatives and reducing alternatives are streamlined since the number of technologies under consideration have been minimized. Figure 1 presents the presumptive remedy technologies for VOCs in soils and important features of each. Figure 1. Presumptive Remedies for VOCs in Soils Soil Vapor Extraction (SVE): The preferred presumptive remedy In-situ process Removes contaminants from vadose zone soils by inducing air flow through the soil Highly cost effective alternative Vapor treatment may be required Thermal Resorption Soil excavation required Uses direct or indirect heat to vaporize VOCs from soil Vapor treatment may be required Incineration Soil excavation required Employs thermal decomposition via oxidation Destroys the organic fraction of the waste Vapor treatment may be required 1

19 In order to determine if you can use the presumptive remedy approach at your site, you need to answer the following questions. Regardless of the status of your RI or removal evaluation, these questions can be addressed once you establish the nature of any VOC and non-voc waste contained in the soil, where treatment is warranted. Are VOCs present in soil or sludge? VOCs include halogenated and non-halogenated organics such as trichloroethylene, carbon tetrachloride, acetone and benzene. A complete a list of typical VOCs is found in the master VOCs presumptive remedy guidance referenced on page 1. If your site does not have VOCs in the soil, then this User s Guide is not applicable for use in remedy selection at the site. Are non-vocs present that will preclude the use of the presumptive remedy guidance? For sites with a mixture of VOCs and other contaminants in soil, the presumptive remedies should be considered only if they also can also be effective in removing the non-voc contaminants, or can be used in combination with other remedies. For combination remedies, this presumptive remedy approach can be used to select the VOC portion of the remedy. For example, sites with VOCs and metals commingled in soil may be effectively remediated by employing SVE to remove VOCs and fixation or solidification to address the metal contamination. The presumptive remedy approach can still be used for the selection of the SVE remedy whereas a traditional FS analysis would be necessary for the treatment of metals. In conclusion, if VOCs are present in soils and non-vocs do not preclude a VOC remedy, you may also select the presumptive remedy for the VOC component of the site. Have all key stakeholders been notified? Please keep in mind that it is important to notify the community, (especially any community working groups) the State, and any PRPs that a presumptive remedy is being considered at your site. It is important to get their buy-in early in the cleanup process. This notification should begin as early as possible and can continue to occur throughout the RI/FS in the form of fact sheets and agenda items during public meetings. Early discussions about the rationale for presumptive remedies creates confidence in both the technology and remedy selection process. Once a candidate presumptive remedy site has been identifiied and a response action involving treatment is warranted under the NCP, you can decide which of the 3 VOCs in soils presumptive remedy technologies to select. Once you have determined that your site is a candidate for a presumptive remedy, SVE should be analyzed first since it is the preferred presumptive remedial alternative. In most cases, SVE is extremely cost effective and can be implemented in-situ. The SVE Checklist (Figure 2) can help you decide if SVE is appropriate at your site. 1 The questions posed in the SVE Checklist provide a preliminary first-cut assessment of basic site characteristics that relate to potential SVE treatment effectiveness. Your site is a strong candidate for SVE if you answer yes to all of these questions. At this point, you may wish to assume SVE as the preferred technology for VOC remedial action at your site. Therefore, you may immediately proceed to an SVE Pilot Study and a Presumptive Feasibility Study (see p. 3). For the purposes of this User's Guide, the terms "Presumptive FS or EE/CA" refer to the FS or EE/CA developed at sites where the presumptive remedy is applied. The SVE Checklist is not a definitive screening test for SVE. So, even if you answer no to one or more of these questions, SVE may still be an appropriate presumptive technology for your site, but greater technical analysis may be warranted. Considerations such as best professional judgment and community opinion should guide your decision to proceed with an SVE Pilot Study to confirm the appropriateness of the SVE technology at your site. If SVE is determined to be ineffective based on site-specific circumstances, thermal desorption is the next technology that should be assessed for use at your site. Thermal Desorption is the primary VOC presumptive remedy at sites where soil excavation is required to remediate a non-voc contaminant. At some sites, public perception is that incineration can be disruptive to a community, and it has been ruled out due to that perception. Be aware of this if you prove incineration as a remedy. For a complete discussion of the characteristics that affect the use of SVE, thermal resorption and incineration technologies, refer to Tables 3 and 4 of the master VOC presumptive remedy guidance. Site Characteristics 2 Soil Permeability > 10-6 cm 2 Soil Moisture Content < 50%? Figure 2. SVE Checklist VOC Vapor Pressure > 0.5mm Hg? Dimensionless Henry's constants > 0.01? Soil/Air Filled Porosity < 40%? Low organic carbon content? I Yes, I No II 1 If you are scoping an RI or a removal evaluation, the information requested in Figure 2 should be identified as a presumptive remedy data need" along with common data needs for an RI/FS. As you develop the RI/FS Work Plan, you should establish site-specific data quality objectives for each set of RI data needs. All presumptive remedy data needs should be collected during the first round of environmental data collection of the RI if not before. 2 See Table 4 of the VOCs in Soils Presumptive Remedy Guidance for a description for each of the terms listed in Figure 2. 2

20 After determining that your site can use a VOCs in soils presumptive remedy, the next step is to prepare a presumptive FS or EE/CA. Note that for non-time-critical removals, you can prepare an EE/CA. Regardless of the status of your RI or removal evaluation, the Presumptive FS or EE/CA for the soil remedy should begin immediately. As highlighted on page 1, the presumptive remedy approach allows you to streamline and focus the FS or EE/CA by eliminating the technology screening step because EPA has already conducted this step on a generic basis in the document Feasibility Study Analysis for VOCs in Soils Sites. Basically, only the No- Action alternative and presumptive remedy alternative require further consideration. If SVE is appropriate, the other presumptive technologies (thermal desorption incineration) may be eliminated from further consideration. To tailor the Presumptive FS to the specific conditions at your site, you may first need to refine the presumptive remedy alternative, as necessary. For example, if off gas treatment is required, the technology for off gas treatment is not selected presumptively and should be addressed in the FS. As shown in Figure 3, the presumptive technology should be matched with an appropriate mix of conventional and innovative vapor treatment technologies. The final step of the Presumptive FS would consist of analyzing the No-Action and Presumptive Remedy alternatives against the nine NCP evaluation criteria. An example format for critical elements of a Presumptive FS is provided in Figure 4. Please note that it is advisable to expand the Introduction Chapter of your Presumptive FS or EE/CA to include a brief discussion of the presumptive remedy approach and justification for using this approach at your site. You may wish to consider technologies that enhance the performance of the presumptive remedy based on sitespecific conditions. For example, SVE enhancements include bioventing, capping, hot air injection, steam injection, and subsurface mining. Additionally, you may consider using a phased approach to designing and implementing an SVE system similar to EPA s suggested phased approach to characterizing and remediating contaminated groundwater sites. In order to maximize engineering flexibility during remedial design and remedial action, it is not always necessary to address potential enhancements in your Presumptive FS. Only where: (a) there is a high degree of confidence that the enhancement is essential for cost-effective remediation; or, (b) the addition of the enhancement significantly changes the cost or scope of the base SVE alternative, should such enhancements be included in the Presumptive FS. For more information on whether to include enhancements in your FS and determining what would require changes to a ROD, see Guide to Addressing Pre-ROD and Post-ROD changes," OSWER FS-4, April I Figure 3. Example of a Possible SVE Alternative Refinement Alternative 1- No Action Alternative 2- SVE with No Off Gas Treatment Alternative 3- SVE with Off Gas Treatment (e.g., activated carbon, catalytic oxidation, flameless thermal oxidation, resin adsorption, etc.) Alternative 4- SVE with Off Gas Treatment and Capping I. II. III. IV. Figure 4. Example Format For Critical Elements of A Presumptive FS Introduction A. Background to the Site B. Introduction to the Presumptive Remedy Approach C. Determination to use the Presumptive Remedy Approach Description of the No Action Alternative, the Presumptive Remedy Alternatives, and ARARs Detailed (Nine Criteria) Analysis of the No Action Alternative and the Presumptive Remedy Alternative Description of the Preferred Alternative A. Rationale for the Preferred Alternative You must compile an administrative record in accordance with the Final Guidance on Administrative Records for Selecting CERCLA Response Actions, OSWER Directive A.1. The administrative record must contain both EPA guidance and site-specific information documenting the selection of the VOCs in soils presumptive remedy. Other required EPA guidance documents include Presumptive Remedies: Policies and Procedures, OSWER FS Presumptive Remedies: Site Characterization and Technology Selection for CERCLA Sites with VOCs in Soils, OSWER FS Feasibility Study Analysis for VOCs in Soils Sites, OSWER [Note The administrative record file index should include a notice specifying the location of and times when public access is available to the generic file of backup materials used in developing this document. The generic file contains background materials such as technical references and previous feasibility studies. Each EPA Regional office has a copy of this file.] Guide to Principal Threat and Low Level Threat Wastes, OSWER FS 3

21 Tab: G - Basis of Disposal Cost Breakdown of Drummed Waste Page 1 of 3 Disposal Cost for Drummed Wastes Pricing is base on quote from Waste Management Haxardous liquids are incinerated. Hazardous waste solids and Non-Hazardous Waste is landfilled. The "bottom Line" numbers are carried over into Tab F. WasteT pe Abrasive slurry Adhesive Adhesive Adhesive Adhesive Adhesive Air Fresheners Aluminum Oxide/Slud e Ammonia Anti-foamer Asbestos Asbestos/Resin Asbestos/Water Asbestos/Water Caustic Caustic Dirt Wash Caustic sludge Cement Glue Cement Glue Coal Extract Contaminated grease Deodorant Deodorant Detergent Detergent Diamataceous Earth Drawing compound Epoxy Waste Epoxy Waste Ethyl-alcohol Fat FaVSand Fatty Acid Food Flavoring Glue Sludge Glue Sludge Glue Sludge Glue Sludge Glue Sludge Glue Sludge GI cerine Gravel/dirt/slud e Grease Grease Grease Grease Grease/Sludge Hexane/Paint Sludge Ink Sludge Ink Sludge Ink Sludge Lacquer Sludge Latex Latex Based Adhesives Latex Coating Latex Glue Latex Glue Latex/Grease Latex/Grease Latex/Grease Linear Material Lube Sludge Lube Sludge Machine rease Mineral Spirits Neoprene/Water Non-Chlor-Polyol Oil Oil Sludge Oil/Sludge Oil/slud e Oil/Water Oil/Water Oil/Water/Rubber Paint & Ink Sludge Paint Filters Paint Resins Paint Scrap Paint Sludge Paint Sludge Paint Sludge Paint Sludge Paint Sludge Paint Sludge Paint Sludge Drum Haz Quanti N-Haz 4 N-Haz 96 N-Haz 67 N-Haz 45 N-Haz 20 N-Haz 19 N-Haz N-Haz 2 Haz 18 Haz 1 N-Haz 6 Haz 22 Haz 394 Haz 8 Haz 22 Haz 1 Haz 35 Haz 480 N-Haz 139 N-Haz 367 N-Haz 10 N-Haz 623 N-Haz N-Haz 975 N-Haz 854 N-Haz 83 N-Haz 14 N-Haz 4 Haz 2 Haz 1 Haz 150 N-Haz 22 N-Haz 635 Haz 14 N-Haz 90 N-Haz 11 N-Haz 6 N-Haz 3 N-Haz 3 N-Haz N-Haz N-Haz N-Haz 263 N-Haz 204 N-Haz 4 N-Haz 3 N-Haz 2 N-Haz 451 Haz 289 N-Haz 81 N-Haz 1 N-Haz 13 Haz 14 N-Haz 438 N-Haz 98 N-Haz 5287 N-Haz 384 N-Haz 1228 N-Haz 491 N-Haz N-Haz 122 Haz 309 N-Haz 89 N-Haz N-Haz Haz 277 N-Haz 2 N-Haz 3 N-Haz N-Haz 24 N-Haz 1 N-Haz 24 N-Haz 30 N-Haz 69 N-Haz 1644 N-Haz 9 N-Haz 5 Haz 897 N-Haz 7422 Haz 1376 Haz 1176 Haz 932 Haz 750 Haz 585 Haz 393 Haz Qty per Waste $ $ $ Laboratory Non-Hazardous Waste Hazardous Waste Anal sis Disposal Costs Trans Costs Disposal Costs Trans Costs $ $ $ $ $ $ $ $ $ $ $ $ 4, $ $ $ 10, $ 6, $ $ 10, $ 32, , , , , $ 6, , , , , , , $ 1, $ 28, $ $ 15, , , , , , , , , , , , , , , , , $ 14, , $ 1, , , $ 12, , $ 9, , $ , $ 2, $ , $

22 Tab: G - Basis of Disposal Cost Breakdown of Drummed Waste Page 2 of 3 Disposal Cost for Drummed Wastes Pricing is base on quote from Waste Management Haxardous liquids are incinerated. Hazardous waste solids and Non-Hazardous Waste is landfilled. The "bottom Line" numbers are carried over into Tab F. Drum Haz Qty per Cost/ Cost/ Cost/ Laboratory Non-Hazardous Waste Hazardous Waste WasteT pe Quanti N-Haz Waste Drum Overpack Ton Anal sis Disposal Costs Trans Costs Disposal Costs Trans Costs Paint Sludge 348 Haz Paint Sludge 186 Haz Paint Sludge 151 Haz Paint Sludge 133 Haz Paint Sludge 123 Haz Paint Sludge 105 Haz Paint Sludge 81 Haz Paint Sludge 77 Haz Paint Sludge 63 Haz Paint Sludge 58 Haz Paint Sludge 49 Haz Paint Sludge 48 Haz Paint Sludge 42 Haz Ink Sludge 289 Haz Paint Sludge 40 Haz Paint Sludge 17 Haz Paint Sludge 16 Haz Paint Sludge 15 Haz Paint Sludge 15 Haz Paint Sludge 7 Haz Paint sludge 3 Haz Paint Sludge Haz Paint sludge Haz Paint Sludge Haz Paint Sludge Haz Paint Sludge 1 Haz $ 5, 730, $ 290, Paint Sludge/Water 33 N-Haz Paint Waste 77 N-Haz 1, Phosphate 1 N-Haz Phosphoric Sludges 93 Haz 83, , Poly Styrene 45 Haz 24, Polyester Resin 486 N-Haz Polyester Resin 230 N-Haz Polyester Resin 101 N-Haz Polyester Resin 63 N-Haz 15, , Polyol 249 N-Haz Polyol 58 N-Haz 5, , Polyol Resin 7362 Haz 38, ,392, , Polyol/Paint Sludge 585 N-Haz Polyol/Paint Sludge 474 Haz 344, , Polystyrene 3 Haz Poly-styrene 2 Haz 2, Polyurethane 35 Haz Polyurethane 14 Haz Polyurethane Haz 27, , Polyvinyl Adhesive 260 Haz 84, , Powdered Cleanser 434 N-Haz 7, , QC Samples 66 N-Haz 1, Resin 256 Haz Resin 219 Haz Resin 155 Haz Resin 139 Haz Resin 69 Haz Resin 62 Haz Resin 59 Haz Resin 51 Haz Resin 40 Haz Resin 32 Haz Resin 29 Haz Resin 21 Haz Resin 17 Haz Resin 16 Haz Resin 11 Haz Resin 10 Haz Resin 3 Haz Resin Haz Resin Haz Resin Haz Resin 399 Haz 517, $ 31, Resin/Glue 467 Haz 151, $ 9, Resin/Solvent Sludge 53 Haz 17, $ 1, Rubber Cement 261 N-Haz Rubber Cement 85 N-Haz $ 6, , Rubber/Latex 65 N-Haz $ 1, Rubber/Solvent 2 Haz $ $ Separator Sludge 76 N-Haz $ $ 1, $ Silicone N-Haz $ $ $ Silicone/Sludge 2 N-Haz $ $ $ Sludge 285 N-Haz Sludge 15 N-Haz 5, , Soap and Shampoo 542 N-Haz 9, , Sodium Silicate 2 N-Haz Solid Fats 67 N-Haz 1, Solid Paint Sludge 65 N-Haz 1, g Solid Polystyrene 21 Haz 15, $ Solid Trash 96 N-Haz 1, $

23 Tab: G - Basis of Disposal Cost Breakdown of Drummed Waste Page 3 of 3 Disposal Cost for Drummed Wastes Pricing is base on quote from Waste Management Haxardous liquids are incinerated. Hazardous waste solids and Non-Hazardous Waste is landfilled. The "bottom Line" numbers are carried over into Tab F. Drum Haz Waste T pe Quanti N-Haz Solvent Sludge 10 Haz Solvent Sludge 1 Haz Sta-sol 31 N-Haz Still Bottoms 943 Haz Still Bottoms 43 Haz Still Bottoms 9 Haz Still Bottoms 2 Haz Styrene Monomer 58 Haz Sulfuric Sludge 62 Haz Toothpaste 1811 N-Haz Toothpaste 399 N-Haz Waste Sand Mix N-Haz Water Based Glue 21 N-Haz Water Based latex 32 N-Haz Water/Latex 434 N-Haz Water/Latex 265 N-Haz Water/Sludge 2 N-Haz Wax 323 N-Haz Wax/Water 364 N-Haz Wax/Water 11 N-Haz X lene Sludge Haz Still Bottoms (Cubic yard boxes) 120 Haz Still Bottoms (Cubic ard boxes 3 Haz Still Bottoms (Cubic yard boxes) Haz Paint Slud e allets 42 N-Haz Total Hazardous Drums: 23,965 46% Total Non-Hazardous Drums: 27,927 54% Total Drum Count: 51,892 Laboratory Non-Hazardous Waste Hazardous Waste Anal sis Dis osal Costs Trans Costs Disposal Costs Trans Costs 2, $ , $ 19, $ 1, , $ 1, , , , , , , , , , , , $ 159, $ 10,894, $ 575,973.33

24 J LIQUID WASTE, 3106 Sn yder- Domer Rood, Springfield, Ohio (513) H CELL B 1 Started D9ce",ber 22, 1976 Fini.shed Februar-y INC Total Drur.s Buried ~ i "f-0016 Delco cem,v Grease B4 drums S-0019?ranklin Glue Paint Sludge 168 drums H-0021 Frip.idaire Paint Scrap 7) drums,'-0025 Inland Paint Sludge 675 drums Inland Poloy "esin 252 drums.1_0027 Inland Layt.ex Glue 1)2 dr-ums,)-0030 Inland Asbestos &Water 107 drums P-0042 Procter & Gamble Detergent 14 drums P-0043 Procter Pc Gamble Fatty Acid 21 drums P-0044 Procter & Gamble Tooth Paste 113 drums T-0052 u-0053 St. Regis Horthington Cyl Paint & Ink Sludge Paint Sludge 121 drums 220 drums o TOTAL D:'im.~S CELL B 1 1,980 drums - I.;. i -;.,,--..'...-"..

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