ONoEFft . 0 0 0 0 0 0 4State Of Ohio Environmental Protection Agency

PO. Box 1049, 361 East Broad St..Columbus, Ohio 43216-1049(614)466-8565

Richard F Celeste,Governor

June 18, 1986

EPA Region 5 Records Ctr

Mr. Joseph R. SkeltonOffice of Law Director309 Main StreetCoshocton, Ohio 43812

Dear Mr. Skelton:

In response to your letter of May 14s-< 1386, attached, please find copies ofcorrespondence concerning proper closure of the Coshocton City Landlll. Ourfiles do not contain any Indication that this landfill has been properlyclosed. To the contrary, observations made by the Southeast District Officeof Ohio EPA are that various areas of the landfill were not closed and coveredin accordance with 3745-27-10 of the Ohio Administrative Code, since trash anddrums (whole and 1n pieces) can be seen on the surface of the site.

Sincerely,

Roger HannahsUnregulated Sites CoordinatorDivision of Solid and Hazardous Waste Management

RH:pamM87

Enclosures

cc: Jennifer Hell, Legal SectionCharles Taylor, Chief, DSHWMEd Kitchen, Enforcement Coordinator, DSHWMSteve Hamlln, SEDOM1ke Starkey, SEDOJerry Roberts. SEDO

2, 197*

Mr. Charles T' r:.-..iCity Service A? t-.-r:Municipal Liv.iiai:igCcsnoctori, uhic

Dear Mr. Turner:

It is the understanding of this office that the city ofCosnoctcn is closing its present landfill on May 9, 1979.

This letter is to infofiu you of the operator's responsi-• • • • ••? the landfill.the solid v/aste disposal regulationsProtection Agency states:

.' days after closure of a sanitaryshall complete the following

ve

ofSection

the Oh.i.'i.}"

.- ; • ' <::• i-27-10 of

1 andf \.'. .actions :

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deposited in thij sanitaryi^ndriLl shall bo covered with at least twofeet c-' well compacted cover material thatrr,oet the requirements set forth in Regulation2745-27-09 (L'l ; andTh 3 site shall be seeded with such grasses orot.hfir vegetation as will grow to form a completeinf. c'ense cover, which seeding shall be done asT'.'ny tir.es A3 necessary to ino;jL'V <.: i.c.;'liance•/Lth this requirement; andAll land surface.-: "h.,?l1 Sr "•r'.i'l-'irf t-. 'jl^oe-i ofno less than. 11 anu no yiedt«r t:iaii ^j%; aadAll land shall bo graded and drainage facilitiesshall be provided so as to direct surface v/ateroff the site, and not allow ponding of water ontil's site; andVentilation structures shall be installed andmaintained as necessary to control gas migration;andThe site shall be baited for rodents, and treatedfor other v>'~fc~'-<' if rrr-e--«5nrY; nnc.1Except for facilities receiving only waates gener-GLec on the yew. i;.t£ v.-ii i-'." t;.o facia Lrysigns stating in letters not less than three Irhigh that the facility is permanently closed shall;be posted in such a manner as to be easily visible; from .'all access rou.'..* I'.i—ii; uutw cii~ -^LJ, whichsigns shall be maintained in legible condition fornot less than two years after closure of the site;

locatei

•TMr. Charles ".-rr.J. , SMay 2, I?73Paije 2

A pint of fh^ fllt« flh.^H bo filed with the Boardo^ He;iltri h.iv'_:ui juriauicticr., Lvi^ County Recorderof the counr.y m which the facility is located,

,. ', and the Director, which plat shall accurately• locate and describe the completed site and

• - r - . ir.'*?v.l'» i :-:f>iTia don rrlcitlnq to the area, (V-.-i. 1!-.. ' .. i, (. . voluiiics, ana nature of the waste materials.' ''• " . -\::-.Oj: i.^-\ j i-. tM.u duuitsty landfill; and

'•' - (9) Ail entrances and access roads to the facility. • snail La blocked by locked gates, fencing, or

; other sturdy obstacles to prevent unauthorized. • . access, unless the site is to ba used for otncr

:.-'••_'_ ,'.': . ' than solid waste disposal.- - * --P

' • / I n addition to the aforementioned items the operator, owner /r^'or lessee is responsible cor the followiny for a period of threi:

1 ••',;."*'•:.'. 'years. • ' (See attached c o n y ) .s .V ,; -:-; '* •''.

\., •• „ 'If- this office can be of any assistance- to you please call.

Respectfully,

Scott GardnerSanitarian

SG/lh

.••' ils»- ^/i .

p.»• i"*.- —t' ^»T'' j * •^Ai.v-yv-/ .?::>"-•• .

CountySolid VJaste

Robert Secrest, MJD. May 22, 1979Health ConxoissionerCosnocton County ciealth Departnjert724 South Seventh StreetCoshocton, Ohio 43812

Dear Dr. Secrest:

On May 14, 1979, I set with Scott Gardner, Sanitarian, Cosboctcn CountyHealth Deparsnent and Mike Puatarizh of Cravat Cool for tna purpose ofdiscussing the position of the Ohio 2PA as relates to the Coshocton CityLandfill.

TSia following points were addressed:

1. The Coshocton City landfill is closed as of January 1, 1979 inaccordance with Section 3745-27-1OA (2) of the Ohio fciainistrativeCode.

2. Closure of the landfill in accordance with Section 3745-27-10 of theOhio .\doinistrative Code is the responsibility of the operator asdefined by Chapter 3745-27 of the Ohio Administrative Code. Thefarmer operator should be 30 informed, of this requiranenc in writing.

3. This facility should not be permitted to re open or otherwise operateas a solid waste disposal facility, or be licensed without firstobtaining a Pemit to Install and engineering plan approval from theDirector of the Ohio

4. Mining of coal deposits beneath or on those areas of the facility wheresolid waste must be moved or otherwise displace , will require a Pennitto Install and engineering plan approval fron the Director of theOhio c?A prior to excavation or diaplflretiBnt of those solid wastes.

If you have any question, please contact me at this office.

;5incerely,

Jerry K. RobertaSolid Vfesta ScientistOffice of Land Pollution Control

cc: Joe Speaknan, Office of Land Pollution Control, C.O.cc: Dan aedman, Office of Land Pollution Control, C.O.

State of Ohio Environmental Protection Agency James A. Rhodes, GovernorF-

Re: Co shoe ton CountySolid Waste Survey

Robert Secrest, M. D. September 11, 1979Health Consuls sionerCoshocton County Health Department724 South Seventh StreetCoshocton, Ohio 43812

Dear Dr. Secrest:

Cn September 4, 1979, an inspection was conducted o£ the proposed landfill facilitylocated in Sections 11, 12, 19, and 20 of Franklin Township, Coshocton County at theintersection of State Route 83 and Township Road 276. This inspection was conductedas part of your continued Solid Waste Disposal Survey, which was begun on March15, 1979.

During this inspection visit, I was accompanied by Steve Hamlin, duo EPA, andMike Wilson of your Health Department. We met at the site with Arnold Clark andAlan. Dusenberry, Coshocton County Commissioner, Strohm McDowell, Cravat Coal, andDick Davis of Columbus § Southern Ohio Electric.

The discussions during our visit were many and varied but the main area of concernas relates to your Solid Waste Disposal Program is the unapproved Cravat Landfilloperation.

The following violations were observed and discussed thoroughly with all present:

1. The Cravat Coal Company is operating a solid waste disposal site without planapproval. Section 3734.02 (C) of the Chio Revised Code, states, "No personshall establish a solid waste disposal site or facility after the effective dateof the regulations adopted by the Director under this Section without submittingapplication for a permit with accompanying: detail plans , specifications , andinformation regarding the facility and method of operation, and receiving apermit issued by the Director".

2. The Cravat Coal Company is presently open dumping solid waste on the propertydescribed. Section 3734.03 of the Chio Revised Code, specifically prohibitsopen A^yg of solid wastes.

3. The Cravat Coal Company is presently operating a solid waste disposal facilitywithout having obtained a solid waste disposal license in accordance withSection 3734.05 of the Revised Code.

State of Ohio Environmental Protection Agency James A. Rhodes, GovernorSoutheast District Office James F. McAvoy. Director2195 Front St..Logan, Ohio 43138 • (614) 385-8501

\

Robert Secrest, M. D.September 11, 1979Page 2

This writer reconnends to the Coshoctan County Board of Health that the aboveviolations be sited in writing to Cravat Coal Company and that they be advisedto cease disposal operations ionediately and until such time as a plan approvaland Permit to Install are granted by the Director of the Ohio EnvironmentalProtection Agency.

During tin? inspection period, the Coshoctan City Landfill was observed to bepermanently closed. Those parties responsible for closure of the facility andthose parties owning the property on which the site is located, should be advisedin writing of their obligations regarding proper closure procedures as outlinedin Section 3745-27-10 of the Chio Administrative Code. This facility cannot bere-opened and/or re-licensed unless plan approval and a Permit to Install areobtained as described in Section 3734.02 (C) of the Ohio Revised Code.

Based on these recent developments, I am delaying final evaluation of your SolidWaste Disposal Program. I will return at a later date or at your request andevaluate your efforts and progress.

Should you have questions or need assistance, please call me at this office.614-385-3501

Sincerely yours,

Jerry K. RobertsSolid Waste ScientistOffice of Land Pollution Control

JKR:dm

cc: Joe Speakman, Office of Land Pollution Control, C.O.cc: Steve Hamlin, SEDO

September 12, 1979

Department of HealthCoshocton County724 S. 7th StreetCoshocton, Ohio 43812

Attention: Mr. Mike Wilson

Dear Mr. Wilson:

As per your request to Mr. Strom McDowell of our company,please accept this letter as our written notice for the closureof the Ccshocton City Landfill due to our mining operations.

Sincerely,

CRAVAT COAL COMPANY

\Ja<nes E. CarnesAssistant Manager

JEC.-jv

COiilOC'lXJN C O U N T Y

DEPARTMENT OF HEALTH

721 S. Tih Si. — Tdqjhuno GJlM-Ui;

COSHOCTON. OHIO MX 12 <• ' j ]

September 14, 1979 ^ -fc"1"'>'J£_.''

James Z. Car::^- .Crava t Coal Cc:..;:any Inc .I I o L l o w a y , O h ^ o

Dear Mr . Games :

This letter is accompanying a copy of the procedure forclosing a'la.".---" ill. Cravat Coal operated the Coshocton CityLandfill : i-o:r. xay 9, 1979 to August 20, 1979 and the areao. t;ie lan^iill ::.ust be closed according to Regulation 3745-27. In the event you are responsible for the entire CoshoctonCity Landfill area the aforementioned Regulation applies.

' Respectfully,

Michael Wi lsonSanitarian

COSHuCTON COUNTY

DEPARTMENT OF HEALTH

72-1 S. T i l l Si. — Telephone G22-142G

CO.SHOLTON, OHIO .13812

Septe.-r.ber 14, 1979

Mr. Charles ":^\:\^i, ~c.City Service L'irectorMunicipal Bui IcingCoshocton, Cnio

2ear Mr. Turner:

Accompanyina this latter is the procedure for closing theCoshocton City Landfill. Please noce that for a period of 3years you are responsible for settling, ponding, cracking orerosion of the- rover material and maintaining any monitor wells,Also the t,jroc(j'.iure is given should any leachate be detected ontne site.

Respectfully,

Michael WilsonSanitarian

Re: Coshocton CountySolid V/aste Survey

Robert Secrest, M.D. November 1, 1979Health CommissionerCoshocton County liealth Department724 South Seventh StreetCoshocton, Ohio 43312

Hear Dr. Secrest:

Ch October 17, 1979, a follow-up survey inspection was conducted of the proposedcounty landfill facility located in Sections 11, 12, 19, and 20 of Franklin Township,Coshocton County at the intersection of State Route 83 and Township Road 276. Thefollow-up survey inspection is a result of the initial survey inspection conductedon September 4, 1979.

I was accompanied during the inspection by Steve Haolin, Jerri-Anne Garl, andDave Johe of the Ohio Environmental Protection Agency and Mike Wilson of yourHealth Departaent.

Photographs were taken and the following violations were observed:

1. The Cravat Coal Company is operating a solid waste disposal site without planapproval. Section 3734.02 (CO of the Ohio Ravised Code, states, "No personshall establish a solid waste disposal site or facility after the effective dateof the regulations adopted by the Director under this Section without submittingapplication for a permit with accompanying detail plans, specifications, and

.;. Information regarding the facility and method of operation, and receiving apermit issued by the Director'.1.

2. The Cravat Coal Company is presently open duaping solid waste on the propertydescribed. Section 3734.03 of the Ohio Revised Code, specifically prohibitsopen duaping of solid wastes.

Solid wastes were being shoved ahead and over in a 'cliffing* method alongthe course of the high wall pits. No attempt to spread and compact wastes,as described in current regulations, was evident.

3. The Claim Coal Company is presently operating a solid waste disposal facilitywithout having obtained a solid waste disposal license in accordance with Section3734.05 of the Revised Code.

As of October 12, 1979, the above cited violations nave been referred to ourOffice of Land Pollution Control Litigation Screening Conaittee for appropriateenforcement action*

State of Ohio Environmental Protection Agency James A. Rhodes, GovernorSoutheast District Office James F. McAvoy, Director2195 Front St..Logan, Ohio 43138 • (614) 385-8501

Robert Secrest, M.D.November 1, 1979Page 2

This writer again reconaeads to the Coshoctaa County Board of Health that theabove violations be cited in writing to Cravat Goal Conpany and that they beadvised to cease disposal operations immediately and until such tins as a planapproval and Permit to Install are granted by the Director of the Ohio finriajnaentalProtection Agency.

During this inspection period, we visited the old Coshocton City Landfill whichhas recently been closed. No refuse deposited at the site has yet been disturbed,but a drag line was being prepared for use while we were at the facility. Again,I must state that those parties responsible for closure of the facility andthostfparties owing the propei ty on which the site is located, should be advisedin writing of their obligations regarding proper closure procedures es outlinedin Section 3745-27-10 of the Chio Administrative Code. This facility cannot bere-opened and/or re-licensed unless plan approval and a Permit to Install areobtained as described in Section 3734.02 (C) of the Chio Revised Code.

Would you please inform this Agency of the Coshocton County Board of Health'sintentions with regard to abatement of the above violations?

Should you have questions or need assistance, please call me at this office.614-33S-8S01

Sincerely yours,

Jerry K. RobertsSolid Waste ScientistOffice of Land Pollution Control

JKR:dm

cc: Mike Shapiro, Legal Sectioncc: Joe Speatanm, Office of Land Pollution Control, C.O.cc: Steve"Hanlin, SEDO(j:|cfi}

Re: Coshocton CountyCoshocton City Landfill

Charles A. Turner, Sr. January 23, 1983City Service DirectorCity of Coshccton760 Chestnut StreetCoshocton, Ohio 43812

Dear Mr. Turner:

Thank you for your prompt reply to my inquiry aiout the Coshocton CityLandfill. The information you submitted vas guite helpful in ourinvestigation. However, there is still a gap in our understanding ofhow the landfill was closed to meet the requirements of Ohio AiministrativeCode 3745-27-10 Closure of Sanitary Landfills. Specifically, we wish toknow who was the site operator at the time of closure and, if it was aparty other than the City, is there an agreement as to who is responsiblefor the closure and continued site maintenance? Please forward thisinformation to us.

The reasons for our inquiry into closure is that we believe that the jobwhich was done was not done properly. The poor closure is believed to bea contributing factor in the production of leachate from the site. Ourmain concerns on the closure which was done include:

1. Not using impermeable cover material.

2. Improper grading of the site which allows ponding of surface water.

3. Not covering all the waste material with at least two feet of compactedcover material.

4. Lack of vegetative cover which would control erosion.

5. Ho control of leachate at the site.

Each of these concerns is actually a violation of State regulations. Therefore,we are asJcingr |Ap *ltm owner/ operator or lessee to submit a plan of actionas to hotf tte BYoper closure of the site will take place. A schedule of thework should also &• a port of the plan.

Southeast District Office2195 Front St.. Logan. Ohio 43138

Richard F. Cetoate, GovernorRobert H. Maynard, Director

Charles A. Turner, Sc.City Service DirectorCity of CoshoctonJanuary 28, 1983Page 2

It is our understanding that the City may be pursuing an independantinvestigation of this site. If this is so we would be willing tolend any assistance we are able. In either case, a meeting betweenOhio EPA, tihe City and the site operator/lessee would help usestablish our positions. A meeting the veek of February 21, 1983would be most suitable for us.

Please contact myself or Steve Hamlin at this office, (614) 385-8501to make arrangements.

Sincerely,

Patrick 8. GormanEnvironmental ScientistDivision of Hazardous Materials Management

PHG.-dni

cc: flogrer Hannahs, DHMM, C.O.