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.1.0 EXECUTIVE SUMMARY This document is a Remedial Action Master Plan (RAMP) for the Skinner Landfill site located near West Chester, Ohio. A RAMP is a plan for undertaking remedial investigation acti- vities and remedial actions in response to a hazardous sub- stance release, or a substantial threat of release, into the environment. It is based upon the National Oil and Hazard- ous Substances Contingency Plan (NCP) promulgated by the Environmental Protection Agency (EPA) on July 16, 1982 (47 FR 31180-31243). This document is based on readily available existing data. No new data were generated during preparation of this RAMP. 1.1 PURPOSE The specific purpose of this RAMP is to define the scope of emedial investigation activities or remedial actions for the Skinner Landfill site along with a schedule of imple- mentation. The RAMP provides cost estimates for each pro- posed activity and identifies data limitations, community relations strategies, and possible problems that may be en- countered during project implementation. 1.2 SITE DESCRIPTION Skinner Landfill is a 70-acre unpermitted sanitary landfill located 1 mile northeast of the Town of West Chester, Ohio. " The surrounding area is primarily agricultural and wooded lands with a subdivision to the west. The site is owned by Mrs. Elsa Skinner. The site is not visible from the access point off of Cincinnati-Dayton Road. ' 3 PROBLEM STATEMENT Industrial chemicals from the Chem-Dyne reportedly been dumped in an old lagoon area in the landfill^ The dumped material consists of drums . broken.. drums and frgg standing liquid. The lagoon area was covered with soil from the landfill in 1976 and 'the limits of the old chemical dump are not presently known. .Samples of these chemicals were found to contain toxic concentrations of hazardous chemical substances. Groundwater contamination is a. possibility- Leachate has been reported seeping from the bank in the area of the old lagoon. Two streams flowing toward the Town of West Chester traverse the base of the landfill. Surface water contamination is a possibility. Numerous storage tanks and 55-gallon drums are scattered throughout the landfill. The contents of these tanks and drums are unknown. During the site visit, instrument read- 1-1 EXHIBIT 1

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.1.0 EXECUTIVE SUMMARY

This document is a Remedial Action Master Plan (RAMP) forthe Skinner Landfill site located near West Chester, Ohio.A RAMP is a plan for undertaking remedial investigation acti-vities and remedial actions in response to a hazardous sub-stance release, or a substantial threat of release, into theenvironment. It is based upon the National Oil and Hazard-ous Substances Contingency Plan (NCP) promulgated by theEnvironmental Protection Agency (EPA) on July 16, 1982 (47 FR31180-31243).

This document is based on readily available existing data.No new data were generated during preparation of this RAMP.

1.1 PURPOSE

The specific purpose of this RAMP is to define the scope ofemedial investigation activities or remedial actions forthe Skinner Landfill site along with a schedule of imple-mentation. The RAMP provides cost estimates for each pro-posed activity and identifies data limitations, communityrelations strategies, and possible problems that may be en-countered during project implementation.

1.2 SITE DESCRIPTION

Skinner Landfill is a 70-acre unpermitted sanitary landfilllocated 1 mile northeast of the Town of West Chester, Ohio. "The surrounding area is primarily agricultural and woodedlands with a subdivision to the west. The site is owned byMrs. Elsa Skinner. The site is not visible from the accesspoint off of Cincinnati-Dayton Road.

' 3 PROBLEM STATEMENT

Industrial chemicals from the Chem-Dynereportedly been dumped in an old lagoon area in the landfill^The dumped material consists of drums . broken.. drums and frggstanding liquid. The lagoon area was covered with soil fromthe landfill in 1976 and 'the limits of the old chemical dumpare not presently known. .Samples of these chemicals werefound to contain toxic concentrations of hazardous chemicalsubstances. Groundwater contamination is a. possibility-

Leachate has been reported seeping from the bank in the areaof the old lagoon. Two streams flowing toward the Town ofWest Chester traverse the base of the landfill. Surfacewater contamination is a possibility.

Numerous storage tanks and 55-gallon drums are scatteredthroughout the landfill. The contents of these tanks anddrums are unknown. During the site visit, instrument read-

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^

ings in two of the tanks registered high cancen^xi-inn* OfIt is not known if there are buried drums in

areas other than the lagoon area.

Six standing water ponds lie along the western boundary ofthe landfill. Based on visual inspection, these ponds donot appear to be contaminated. Trucks have been seen back-ing up to these ponds indicating possible dumping.

1 . 4 LIMITATIONS

Limitations considered particularly relevant to the SkinnerLandfill site follow.

1.4.1 Data Limitations

The extent of the original lagoon (where chemicaldumping occurred) is not defined.

Results of the laboratory analyses of samplesknown to have been collected were not readilyavailable at the time of RAMP preparation.

Borings drilled in the lagoon area were too shallowfor geologic analysis of sub.surface conditions andsoil materials.' Boring elevations and locationswere not recorded.

The contents of the scattered drums and storagetanks onsite are unknown.

The extent of seepage from these drums and tanksinto the surface soils is unknown.

No data were readily available to determine thewater quality and potential sediment contaminationfor the six water ponds onsite and the two inter-mittent streams flowing around the base of thelandfill.

Only limited sample data were available for privatewells in the area.

Due to the size and complexity of the site layout,current aerial photography is needed for analysisof possible problem areas at the site.

Due to the possibility of channelized groundwaterflow, contaminated groundwater may be restrictedto narrow zones. Additional monitoring wells areneeded for further analysis.

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o Topographic data are limited to USGS quadranglemaps of the area. These maps have a 10-foot con-tour interval where a smaller contour interval isneeded for analysis of surface drainage and runoff.

1.4.2 Study Limitations '•

o The RAMP does not recommend specific remedialactions due to a lack of information necessary toconduct a feasibility study for them.

o Costs provided are Order-of-Magnitude only. Thistype of estimate is defined by the American Associ-ation of Cost Engineers as follows: "An approximateestimate made without detailed engineering data.Examples include: an estimate from cost-capacitycurves, an estimate using scale-up or scale-downfactors, and an approximate ratio estimate. It isexpected that an estimate of this type will beaccurate within +50 percent and -30 percent."

o The RAMP is basically a planning document withtasks and subtasks suggested as minimum efforts toaccomplish its objectives. ;

o The RAMP budget and development schedule did notpermit a complete and exhaustive consideration ofall remedial planning activities.

1.5 INITIAL REMEDIAL MEASURES

The purpose of initial remedial measures (IRM's) at the SkinnerLandfill site is to reduce imminent hazards to public healthassociated with the presence of hazardous wastes containedonsite.

The IRM's identified for the Skinner Landfill site are:

o Installing a gate and placement of warning signso Warning to people living in site areao Issuance of an advisory notice

1.6 REMEDIAL INVESTIGATION/FEASIBILITY STUDY

Before alternatives for remedial actions can be analyzed,sufficient information must be available to evaluate them.Gathering of this information will be completed in a remedialinvestigation/feasibility study (RI/FS).

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2.0 DATA EVALUATION

2.1 OBJECTIVE

This section presents available technical data and nontech-nical information on the Skinner Landfill site and its immed-iate surroundings. It also summarizes potential impactsresulting from the landfill site contamination based on avail-able information. Evaluation of readily available existingdata determines data limitations and the need for remedialinvestigations and measures.

2.2 BACKGROUND

2.2.1 Site Description

The Skinner Landfill is a sanitary landfill located approxi-mately 1 mile northeast of the Town of West Chester in UnionTownship, Butler County, Ohio (Figure 2-1). See Figure 2-2for a location map of the landfill site. The landfill isapproximately 50 feet higher than the surrounding terrainand consists of 50 to 70 acres of land; the boundaries arenot clearly distinguishable by visual inspection. The initialowners of the landfill were Mr. and Mrs. Albert Skinner andtheir sons; the present owner is Elsa Skinner, wife of AlbertSkinner. The property is bounded on the north and east bywooded land, the south by wooded and agricultural land, andon the west by the Cincinnati-Dayton Road and scattered single-family residences.

The entire site, including the presently used landfill area,is scattered with debris such as tires, wood, aerosol cans,numerous large tanks, engines, washers, and dryers.

Access to the site is obtained from the Cincinnati-DaytonRoad. There is a complex pattern of trailways leading intoand through the landfill. One residence is located in thelandfill area itself. Refer to the site map (Figure 2-3)for a general layout of the area, and to the Site Visit Memo-randum (Appendix A) for a summary of observations made duringthe RAMP site visit.

The site is hidden from the public community by the surround-ing trees and other vegetation which appears to be normaland healthy. Trails leading to the six water ponds suggestpossible dumping activities or usage of the water. Two inter-mittent drainages traverse the base of the landfill flowingsouthwest through the Town of West Chester where they meetto form the East Fork of Mill Creek.

2.2.2 Site History

From photo analysis, it appears that the land was originallyused in the 1930's for the extraction of sand and gravel._

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During the next several decades the Skinners acceptedgeneral immtripaT refuse . As early as 1964 hazardous wastewas reportedly ar?f!epfred at- -Hi** land-Fi^j and cyanide wasconfirmed to have been disposed of at the sire. in 1976,toxic chemicals from the Chem-Dyne Corp. were reportedlyplaced in the landfill.

The ite was never permitted as a municipal landfill and ispresently unpermitted. Application for a permit was madebut never approved because the area had previously been zonedas a rural residential area. Because the landfill was notpermitted, regular inspections were not rondiigted. Therefore,records concerning the landfill operation are scarce.

In 1977, the landfill operators were charged by Ohio EPAwith improperly disposing of hazardous waste material at thesite.. Approximately 100 drums, allegedly containing indus-trial and chemical wastes, were photographed onsite. In asubsequent court case in which the Ohio EPA attempted toforce the land owners to remove the drums, the presidingjudge ruled that the Ohio EPA failed to present sufficientevidence that the drums posed a danger. The same judge didprohibit the landowners from. using the facility for futuredisposal or storage of industrial wastes of any nature exceptunder legal permit.

Another business activity was conducted onsite by John Skinner, |son of the landfill owners. Beginning in the early 1960's, jJohn Skinner worked for the Chem-Dyne Corporation (now in jreceivership) , cleaning, washing and repairing Chem-Dyne ;equipment used to haul chemical wastes. This activity appar- {ently began under the auspices of William Kovacs, a vicepresident of Chem-Dyne Corp. It is unknown when this busi-ness began or ended; however, in the court case referred toabove, which was tried in October 1978, the presiding judgeallowed this activity to continue.

2.2.3 Remedial Actions to Date

To date there have been no remedial actions taken to rectifythe problems at the Skinner Landfill site.

2.2.4 Chronology

A chronology of the Skinner Landfill site is presented inAppendix B.

2.3 HAZARDOUS MATERIALS CHARACTERIZATION

2.3.1 Generators and Transporters

The possible generators and possible transporters ofhazardous material to the Skinner Landfill and identified in

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a report entitled "Skinner Landfill - Responsible PartySearch" written in April 1983 under EPA Contract No.68-01-6543.

2.3.2 Materials - Quantitative

Miscellaneous sampling of the materials at the SkinnerLandfill has taken place to identify and quantify possiblehazardous wastes present (Table 2-1).

The results from the analyses of many of these samples werenonexistent in the reference materials available for thepreparation of this RAMP.

During a heated confrontation with authorities in May 1976,the Skinners reported the following materials to be buriedin the landfill:

Nerve gasMustard gasIncendiary bombsPhosphorusFlame throwersCyanide ashOther explosive devices

A military unit was brought to the landfill under a searchwarrant and found no explosive devices. Cyanide ash, phos-phorus, and several flame throwers with canisters were theonly items from this list that were found onsite.

During the excavation of the lagoon area in 1976, sevensamples were taken from 55-gallon drums and liquid ooze inthe pit. Table 2-2 summarizes the results of the laboratoryanalysis of these samples.

2.3.3 Materials - Qualitative

From the ooze samples taken on May 11, 1976, the chemicalsidentified by the Gas Chromotograph - Mass Spectrophotometerprocess were:

o Trichloropropaneo Dichlorobenzeneo 1,3 Hexachlorobutadiene (Aldrin Component)o Naphthaleneo Hexachlorocyclopentadiene (C-56)o Methyl Napthalene (Two Isomers)o Iso-Butyl Benzolateo HexachloroNor-Bornadine (Endrin Intermediate)o Octachloro-cyclo-penteneo Heptachlor-nor-boreneo Hexachlorbenzene

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rTable 2-1

SUMMARY OF SAMPLING EVENTS AT SKINNER LANDFILL01-5V73.0

SamplingDate

April 26, 1976

May 3, 1976

May 11, 1976

July 29, 1976

July 25, 1977

July 27, 1982

Description of Materials______Sampled_________

Surface puddles in lagoonarea

Groundwater - privatewells in the vicinity ofthe landfill

7 samples - pit ooze andbarrel liquid in lagoonarea

5 borings

Leachate puddle and streamsamples in lagoon area

4 monitoring wells instal-led for Mitre Program on7/19/82

SamplingAgency

Ohio EPA

Ohio Depart-ment ofHealth

Ohio EPA

B.C. Nuttingfor AlbertSkinner

Ohio EPA

FIT/E&E

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Table 2-2QUANTIIAIIVE RESULTS OF LABORATORY ANALYSIS

PIT OOZE AND BARREL LIQUIDSKINNER LANDFILL

Collection Date: 11, 1976

(All results in mg/l)

CyanideCadmiumChromium (total)Lead (total)Mercury (total)ZincCopperPhenol

-SAMPLE MIMBCT,_*13752

«„

Cyanide9.1

Identification of samples

%%'-%S&JLit*l«*«»«>'13752 - i^rr^^ (°ran*« C°1°D#13753 , "covered from pit

<"£ : aar7eeil Z*™ **"rrel recovered from ptt

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o Chlordeneo Methyl Benzyl Phenoneo Octachlor penta fulvalene

The contents of the barrels sampled were found to includethe following in varying amounts:

o Cyanideo Cadmiumo Chromiumo - Leado Mercuryo Zinco Coppero Phenol

2.4 ENVIRONMENTAL SETTING

2.4.1 Physiography and Topography

Butler County is in the Central Till Plains section of theCentral Lowland physiographic province. The topography ofthe county has been greatly influenced by Wisconsinanglaciation. Glacial erosion modified the bedrock, and thepresent surface relief generally conforms to this modifiedbedrock topography. The resulting physiographic featuresinclude gently rolling glacial uplands, glacial terraces andoutwash plains.

The Skinner property is presently characterized by hummockyterrain resulting from sand and gravel mining. The site issituated on an elongated hill about 50 feet above the sur-rounding terrain (Figure 2-2).

2.4.2 Geology

Butler County lies over a gentle dome known as the Cincinnatiarch. Bedrock under the county is primarily shale and lime-stone of Ordovician age. The bedrock structure has beeneroded and buried under deposits from Wisconsinan glaciation.

The Town of West Chester appears to be situated over anarrow, preqlacial bedrock valley (St. John, 1981). Thisvalley, which trends northeast-southwest, is filled withclay, sand and gravel. The Skinner property appears to belocated on areas covered by several feet of sand and graveland other areas where glacial till is thin over shale andlimestone.

Topographic and Soil Conservation Services maps indicatethat sand and gravel have been mined on the Skinner property.Wells near the site (wells 11, 12, 13 in Figure 2-4 and Tab-le 2-3) encountered shale bedrock at depths of 6, 8 and 20 feet,

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FIGURE 2-4: LOCATION OF KNOWN RESIDENTIAL WELLS

HAS BEEN REDACTED – ONE PAGE

CONTAINS POTENTIAL PERSONALLY-IDENTIFYING INFORMATION (PII)

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Table 2-3RESIDENTIAL WELL LOGS

sampled 5/3/761. 0-5' topsoll5-17' sand and clay17-60' rockStatic level - 15 feetWater at 15 feet3 gpm

2. 0-35.5' clay35.5-1C4J limestoneStaticTevel - 38 feet

3. 0-40' clay40-75' gravel75-90' gray^shale

4. 0-42' clay42-80' gravel80-96' clay96-130' gray shale130-150' gray limestoneStatic level - 110 feetCasting set Into shale

5. 0-10' clay10-30' gravel ,42-50' gravel *Static level - 26 feet

6.

3-16' yellow clay16-20' sand and clay20-31' gravel and clay31-34' sandstone fyStatic level - 17 feet

7.

8.

9.

10.

f

11.

12.

0-46' sandy clay46-50' sand and gravel10 gpm

0-7' topsoll7-75* sand and grave\water at 55'

Presbyterian Church0-18 clay18-22 sand22-59 clayStatic level - 10 feet

0-5' clay5-20' creek gravel20-45' clay45-52' creek gravel52-54 sandstone {?p

0-6' clay6-56' shale

0-6' clay8-100' shale

13. 0-20' clay20-75' rockStatic level - 30 feet

14.

Sampled 5/3/76Source: Hosier/1982

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Two borings near the lagoon (B-5 and B-S in Figure 2-5 andAppendix C) encountered shale at depths of 14.5 and 15 feet.Elevations of several borings drilled near the lagoon werenot available for constructing profiles; however, it appearsthat a continuous clay layer under the lagoon does not exist.These borings encountered layers of silt, clay, and sand andgravel, typically found in glaciated areas.

2.4.3 Hydrology

Surface drainage from Butler County reaches the Ohio Rivervia the Great Miami River, Mill Creek, and Muddy and LittleMuddy Creeks. Runoff from the Skinner site drains to thesouthwest into the East Fork of Mill Creek. Mill Creekflows south-southwest through Cincinnati before reaching theOhio River.

Because of excavations for sand and gravel and regrading forlandfill operations, the surface drainage patterns are greatlychanged from their natural patterns. There are bodies ofponded water along the western side of the site. Two inter-mittent streams flow southwest along the base of the land-fill through the Town of West Chester where they meet toform the East Fork of Mill Creek.

During a site visit inspection by Joe Moore, Ken Harsh andJim Pennine of the Ohio EPA on July 25, 1977, leachate wasobserved seeping from the vicinity of the buried lagoon.The inspectors also observed drums filled with a white,semisolid material stacked near the creek. Some of thedrums were leaking and draining into a nearby creek. Watersamples were taken of the stream and leachate seep and asample of the white solid material was also collected.Published results from the laboratory analysis of theleachate puddle were available (Table 2-4) ; however, noother data were available regarding the other samples taken.

2.4.4 Geohydrology

Groundwater supplies in Butler County are primarily obtainedfrom wells established in glacial drift. The underlyingshale and limestone have low yields of brackish and highlymineralized water (Klair and Thompson, 1948). Wells in WestChester appear to be exceptions to this norm. Nine of thir-teen well logs from the town indicate that the wells arecompleted in rock. Static water levels in these wells aregenerally above the top of rock.

Unconsolidated fill in the buried valley under West Chesterconstitutes a high yielding aquifer that is used by manylocal residents. Groundwater movement is probably to the

along the strike of the buried valley discussedin Section 2.4.2 (St. John, 1981).

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APPROXIMATE LOCATIONOf OLD INCINERATOR

TOWNSHIP /V.SCHOOL / 7

FLOW

APPROXIMATEAREA OF OLDLAGOON

•APPROXIMATELOCATION OFSON-IN-LAWSRESIDENCE

LEGEND

— —— LANDFILL BOUNDARY

5 STANDING WATER PONDS

A BORINGS DRILLED BY ATEC FOR E&E

• BORINGS DRILLED BY H. C. NUTTINGFOR ALBERT SKINNER

1000

500SCALE IN FEET

FIGURE 2-5APPROXIMATE LOCATION OF BORINGSDRILLED IN LAGOON AREASKINNER LANDFILL

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Table 2-4LEACHATE PUDDLE

Sample Date: July 25, 1977

Compound

ChlorideCadmiumChromiumCopper "LeadMercuryZincPhenols

Concentration(mg/1)

9,60059812026055

§ 1240§ 2

Arsenic levels could not be verified because of interferenceby dilution.

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Table 2-5GROUNDHATER ANALYSES (mg/1)

SKINNER LANDFILL

LOCATION:

DATE:

Silver (Ag)Aluminum (Al)Barium (Ba)Beryllium (Be)*Chromium (Cr)Cobalt (Co)*Copper (Cu)Iron (Fe)Manganese (Mn)*Nickel (Ni)Vanadium (V)*Zinc (Zn)*Arsenic (As)*Cadmium (Cd)*Mercury (Hg)*Lead (Pb): Selenium (Se)Antimony (Sb)Tin (Sn)Thallium (Te)CyanideCalcium CarbonateSulfateChloridePhenols

Hell B-507/27/82

v'o.03o")0.530.35ND

•io.'oss1"0.31ND8.718

0.41ND

0.41ND

• 0.0641ND

o-H*36.011

NDNDNDND

Hell B-607/27/82

.0.01216

0.48ND

0.0450.190.065

557.60.30ND

0.390.0180.032

0.000330.023"NDNDNDNDND

Blank07/27/82

NDNDNDNDNDNDND

0.220.035

NDND

0.040ND

0.001NDNDNDNDNDNDND

DouglasResidence05/03/76

< 0.20

< 0.03

< 0.03< 0.03

< 0.1 .

0.27< 0.01< 0.01< 0.005< 0.01

< .013748142< 2

HancockResidence05/03/76

.020

< 0.03

< 0.030.14

< 0.1

0.70< 0.01< 0.01

< 0.005< 0.01

< .013665210

< 2

EPA HaterQuality

. Criteria

0.05—1

—0.50————13.4——0.050.0100.0020.0500.01————

:—~—

6%wi,

ND*

Not detected.Priority pollutant.No criteria set.

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APPROXIMATE LOCATIONOF OLD INCINERATOR

TOWNSHIPSCHOOL

SKINNERRESIDENCE

APPROXIMATEAREA OF OLDLAGOON

APPROXIMATELOCATION OFSON-IN-LAWSRESIDENCE

LEGEND

— — LANDFILL BOUNDARY

j| STANDING WATER PONDS

•• TANKS1000

500SCALE IN FEET

FIGURE 2-6APPROXIMATE LOCATION OF BULKTANKS CONTAINING DETECTED ORGANICSSKINNER LANDFILL

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inated. Leachate from the landfill may also be reaching thestreams. These streams feed Mill Creek, which flows to theOhio River through Cincinnati, and provide recharge to theshallow, unconsolidated aquifer used by some residents ofWest Chester.

Incomplete combustion of some of the materials on the sitecould cause a public health hazard in the event of a fire.It appears that the Skinners are no longer burning materialon their property, but the possibility of accidental firesshould be considered.

2.5.2 Environment

Pollutants from the Skinner Landfill could affect terrestrialand aquatic life on and off the site. Runoff from rainfallor snowmelt could transport contaminants to the ponds onsiteand to the streams surrounding the site. Many of the haz-ardous materials that may be on the site can bioaccumulatein the food chain. They may not be at toxic concentrationsin the water, but could be found in the tissues of receptororganisms in concentrations high enough to cause toxicity.This could lead to human health concerns if the organisms,such as fish, are eaten.

Other wildlife of concern could include resident and migratingbirds, as well as larger animals, such as deer. Bioaccumu-lation of hazardous materials can lead to reproductive fail-ure or acute or chronic toxicity.

2.5.3 Socioeconomics

The presence of hazardous wastes near homes that depend on apotable aquifer and in a growing residential area may affectthe socioeconomic balance of the area. The newer subdivisionsin the area are home to a transient community dependent uponselling their homes when their companies transfer them. Theknowledge that a hazardous waste site is in the area maycause a decline in area growth and reduced property values.

2.6 DATA LIMITATIONS

Data used in the preparation of this RAMP were taken fromavailable known sources, including, but not limited to, thefollowing:

o EPA fileso Other state and local fileso Site visit inspectiono General conversations with persons at the site

and/or conversations with personnel having know-ledge of the site.

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IThe data compiled from the above are limited in the followingregard:

o The lagoon area containing known toxic wastes isnot clearly identifiable in the existing documents.Therefore/ the area of buried drums where sampleswere taken in 1976 is only approximate (Figure 2-7).

o There were 55-gallon drums (estimate 250) and storagetanks (estimate 60) visible throughout the entiresite. There is no information as to the materials(if any) stored in these drums. During the initialRAMP site visit, two of the tanks tested showedhigh levels of organics. There is no informationas to what is buried (drums, split drums, tanks)in the landfill.

o The extent of seepage from these drums and tanksonto the surface soils is unknown.

o There are two intermittent streams traversing thebase of the landfill area. Results were not avail-able for water chemistry or organic analysis ofany samples taken. Possible groundwater contami-nation is the major concern regarding the SkinnerLandfill site.

o Nine borings have been drilled near the old lagoonarea. These were relatively shallow borings andmore information is needed for geologic analysis.The exact locations and elevations of these nineborings cannot be determined from the existinginformation.

o There is no record of any soil samples taken inthe area of the chemical dump or any other portionof the landfill area.

o Only limited sample data were readily availablefor private wells in the area.

o Current aerial photography is needed for analysisof materials and possible problem areas at thesite.

o Topographic data are limited to USGS quadranglemaps of the area. These maps have a 10-footcontour interval while a smaller contour intervalis needed for analysis of surface drainage andrunoff.

o No water quality or sediment data were readilyavailable for the six ponds.

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