Stark C&D Disposal v. Bd. Health, No. ERAC 766132 (Ohio Env.Rev.App.Com. January 6, 2010).

The Ohio General Assembly did not intend to establish a minimum distance requirement for the modification of a C&D landfill. Instead of focusing on the distance between a landfill and private water wells, when considering a modification application local boards of health should consider the adverse effect of a landfill on public health, safety, and the environment.