United Stales
Envimamanta) Protection
Agency
Office of
Emergency a
Remedial Ret
EPA/BOO/R02-85(017
Sep ember 1985
SERA
Superfund
Record of Decision:
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TECHNICAL REPORT DATA
(Pleflse refld Instructions on the reverse before completing)
1. REPORT NO. 12. 3. RECIPIENT'S ACCESSION NO.
EPA/ROD/R02-85/017
4. TITLE AND SUBTITLE IS. REPORT DATE
SUPERFUND RECORD OF DECISION September 30, 1985
Sinclair Refinery, NY 8. PERFORMING ORGANIZATION CODE
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7. AUTHORIS) - 8. PERFORMING OPGANIZATION REPORT NO.
~. PERFORMING ORGANIZATION NAME AND ADDRESS 10. PROGRAM ELEMENT NO.
I I. CONTRACT/GRANT NO.
12. SPONSORING AGENCY NAME AND ADDRESS 13.1;YPE OF REPORT AND PERIOD COVERED
U.S. Environmental Protection Agency F1nal ROD Report .
401 M Street, S.W. 14. SPONSORING AGENCY CODE
Washington, D.C. 20460 800/00
U5. SUPPLEMENTARY NOTES
.
18. ABSTRACT .
.
The former 103~acre Sinclair oil Refinery is located in the Town of Wellsville,
Allegany County, New York. The site was originally developed as an oil refiner~ during
the late 1800s and was operated by the Wellsville Refining company. Products manu-
factured at the site included lubricating oils and grease, fuel oil, naptha, gasoline,
lighter fluid and paraffin. In 1924, the Wellsville Refining Company sold the prop-
erty and plant to Sinclair Refining Company which maintained and operated the refinery ..
until 1958, when operations ceased as a result of a fire. While the refinery was in
operation, the southernmost portion of the property was used as a landfill to dispose
of approximately 230,000 yd3 of wastes. Substances deposited in the landfill con-
sisted of drummed waste, oily and tarry sludges, and hazardous waste compounds in
other forms. The landfill consists of the "Central Elevated Landfill Area" (CELA), a
9.2-acre landfilled area to the north, the 2.3-acre "South Landfill Area" (SLA) to
the south, and a l-acre sand and gravel borrow area between the two landfilled areas.
This 12.5 acre landfill sub-site is considered in this Record of Decision (ROD).
The selected remedial action for this site includes: removal and offsite disposal
of approximately 300 drums on the surface of the CELA; excavation of the 2.3-acre
SLA to a depth of approximately 20 feet to remove all waste material; filling of the
excavated area with clean fill; consolidation of the excavated SLA wastes onto the
(see separate sheet)
17. KEY WORDS AND DOCUMENT ANALYSIS
Ia. DESCRIPTORS b.IDENTIFIERS/OPEN ENDED TERMS C:. COSATI Field/Group
Record of Decision
Sinclair Refinery, NY
Contaminated Media: soil
Key contaminants: VOCs, heavy metals,
arsenic, chromium, phenols
IS. DISTRISUTION STATEMENT 19. SECURITY CLASS (This Repor,) 21. NO. OF PAGES
None 125
20. SECURITY CLASS (TI'il fHlge) 22. PRICE
None
IPA 'Ofm 2220-1 (Rn.4-77)
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INSTRUCTIONS
1,
REPORT NUMBER
Inserllh~ I::PA r~porl number al il ap~ul on Ihe cover of Ih~ publh:alion,
LEAVE BLANK
2.
3.
RECIPIENTS ACCESSION NUMBER
Reserved fll!! use by e;a~h reporl re~ipienl,
TITLE AND SUBTITLE
Tille should in~ical~ ~lc~ly an~ brien~ Ihe subje~I ~over-.p: 0," Ihe reporl,.;and be: disrl;ay~d rrumin('nlly, s." suhlill." ifu,,,/d, 111 slII;aIi.'r
Iy~ or olhe~lse subordlnale II 10 main IIIle, When a reporlls rrepalYd In mort lhotn une vulum.:, n'",';allh(' rrllll;lry lill.., ;atld v"lunlt'
number and tnclude subliUe for Ihe s~c:inc lille, .
...
IS.
REPORT DATE
Each reporl shall cury a dale indicalinl alleasl monlh' and y('u, Indh:al(' Ih(' hasis un whh:h il was ...'le.'I,'d (qr.. JIllc' OJiUIIC', .Jtllc' oJ
IIpproNl. .tl o{ p"pllfGtion, Itr,j, -
PERFORMING ORGANIZATION COOE
Leave blank,
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7.
AUTHORCSI
Give nam~ls) in .'o)nvenlional or~r (John R, 0«, J, Ro(x." /Joe', ('I(',), Lisl ;aulhur's 'afliliilliun if il dill'('rs I' Will II", ,,,,rfunninj: ..cj:;ani.
zalion,
..
PERFORMING ORGANIZATION REPORT NUMBER
In.,1 if ~rforminl orpnization wish~s 10 assiJIIlhis number.
to
PERFORMING ORGANIZATION NAME AND ADDRESS
G~. SIr«I, city, sllle, and ZIP code, Lisl no more Ihan Iwo levels of an urj:anil.aliunal hireardlY,
10. PROGRAM ELEMENT NUMBER
Use lhe propam element number under whi~h Ihe report w;as prc:par~d, Subordin;ale nUIllbc:r, ilia)' bc: ind'hl...11I1 l'a"'IIIII,'""
11. CONTRACT/GRANT NUMBER
1n.,1 conUKI or ...anl number under which reporl win prepared.
12. SPONSORING AGENCY NAME AND ADDRESS
Include ZIP c:ocIe, '
13. TYPE OF REPORT AND PERIOD COVEREO
Indica Ie interim filii!. elr.. and if applicable, dales covered.
14. SPONSORING AGkNCY COOE
Insert appropriate code.
15. SUPPLEMENTARY NOTES
Enler informalion not included elsewhere bUI useful, such as:
To be published in, Su~sedel. Supplemenu. etc:,
1.. ABSTRACT
Include a brief (200 WtNdr or IIn) factuallummuy of Ihe mosl siJl:niti,'anl inrurm;aliun ...unlain"d III Ih., "'I'un, II I h.. r"I,..,1 nllll;Olll' a
sipificant biblio...aphy or literatwe survey, mention il her('.
Prcpared in ",uopl:'ratiun with. Translat..,n ..I. I'r"...'nl"tl al "11111,''''11\\' ..t'.
17. KEY WORDS AND DOCUMENT ANALYSIS
(a) DESCRIPTORS 0 Select from the Thcsaurus of I::naineerinll;and Scicmlilk 1erll1' Ihe prupl:'r aulhllri/"d I.'rlll, Ih;al id"ntify Ih" nlajur
concept of the research and are sufficiently s~citic and precise: 10 be used as ind,,)( enlries fur "al..lu!!II1j:.
(b) IDENTII'IERS AND OPEN.ENDED TERMS. Use idenlifien for projCC:1 nan"" eude names. equlpmenl d""j:n..lurs, el..., l!", "I>en-
ended terms written in descriptor form for Ihose subjects for which no dl:sc:riplur c~ists.
(c) C05ATI HELD GROUP -Held and &roup aWlnments are to be laken !'rom Ihe I 96S ('051\1'1 Suhj.,,,, ('alq:ury Usi. Sin",' Ih" ma.
jority of documents are multidisciplinary in nalure. the Primary l-'ield/Group assignmenUs) will be ,,,.:.-irk
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SUPERFUND RECORD OF DECISION
Sinclair Refinery, NY
Abstract - continued
CELA; RCRA capping of the consolidated wastes on the CELA; partial channelization
of the Genesee River to protect the landfill from erosion and flooding; and
erection of a fence to secure the entire Landfill area. Total capital cost for the
selected remedial alternative is estimated to be $8,759,000 with O&M costs approx-
imately $30,000 per year. A separate ROD will be prepared to address cleanup of
the refinery area once the Feasibility Study is complete.
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Record of Decision
Remedial Alternative Selection
.!ill :
Sinclair Refinery site, village of Wellsville, Rew York
Documents Reviewed:
I am basing my decision primarily on the following documents
describing the analysis of the cost-effectiveness of remedial
alternatives at the Sinclair Refinery site:
Remedial Action Master Plan, CB2M Bill, April 27, 1983.
Phase I Remedial Investigation Sinclair Refinery Site,
SMC Martin, March 14, 1985.
Fast-Track Feasibility Study of Initial Remedial Measures
for Wellsville Water Supply, SMC Martin Inc., May 1985.
Feasibility Study for the Sinclair Refinery Site Landfill,
SHC Martin, August 1985.
Staff summari,s, memoranda, letters, and recommendations.
Summary of Remedial Action Alternative Selection - Sinclair
Refinery Site.
Description of Selected Remedy:
Removal and off-site disposal of approximately 300 drums
on the surface of the central Elevated Landfill Area.
Excavation of the wastes from the 2.3-acre South Landfill
Area.
l.
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Consolidation of the excavated South Landfill Area
wastes onto the Central Elevated Landfill Area.
RCRA capping of the consolidated wastes on the Central
Elevated Landfill Area.
Partial Genesee River Channelization to protect the landfill
from erosion and flood inundation from the Genesee River.
Erection of a fence to secure the entire Landfill 8ite.
Declarations.
.,
Con8istent with the Comprehensive Environmental Re8ponse,
Compensation and Liability Act of 1980 (CERCLA), and the National
Contingency Plan (40 CPR Part 300), I have determined that the
selected strategy for the Sinclair Refinery site landfill is a
c08t-effective remedy, and that it effectively mitigates and
minimizes existing and potential damage to, and provides adequate
protection of public health, welfare and the environment.
I have also determined that the action being taken i8 appropriate
when balanced against the availability of Trust Pund monies for'
use at other sites.
The Region has consulted with the State of New York in selecting
the recommended remedial action for this site. The State concurs
that this is the most appropriate remedial measure for the
Sinclair Refinery site landfill.
Date
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Summary of Remedial Alternatives Selection
Sinclair Refinery Site
Site Location and Description
.Site Location
~.
The former 103-acre Sinclair Oil Refinery, located in Allegany
county, New York in the Town of Wellsville, southeast of the
Village of Wellsville, is bounded on the west by Brooklyn Street,
on the north by a residential area, and on the south and east by
the Genesee River. The population of Wellsville, estimated to
be 6,000 residents, is served by an aging water treatment plant
built in 1921. The intake of the treatment plant 1s located
approximately one-half mile downstream of the northern-most
extremity of the Sinclair Refinery site (see Figures 1 and 2).
.Site Description
For the purposes of this project, the Sinclair Refinery site is
considered as-two sub-sitesl the refinery portion of the site,
consisting of approximately 90 acres where the original refinery;
operations took place, now utilized as a light industrial park and
aqricultural and technical colleqe CampuBJ and the 12.5-acre
landfill portion, which accepted wastes from the refinery operation.
The fenced landfill is located along the Genesee River in the
southeastern part of, the site. The landfill sub-site consists
of the -Central Elevated Landfill Area- (CELA), a 9.2-acre landfilled
area to the north, the 2.3-acre -South Landfill Area- (SLA) to the
south, and a 1-acre sand and qravel borrow area between the two
landfilled areas (see Figure 3). The 12.5 acre landfill sub-site
is. considered in this Record of Decision (ROD). Upon completion
of a Feasibility Study for the refinery portion of the site, a
separate ROD will be prepared.
c.
Layers of fill and black-stained material are visible in the 10
foot high, several hundred foot long segment of the landfill that
was sUbjected to erosion by the Genesee River (see site History
section of this ROD). Standing water between the landfill and
the protective dike constructed in 1983 often has an oily sheen
on the su~tace.
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Sinclair Refinery, Vicinity Map
Figure 1
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The landfill, -wooded and covered with vegetation, has approximately
300 rusted and corroding 55-gallon drums located in several
locations on the surface. The majority of these drums are empty.
It is believed that hundreds of drums are buried in the landfill.
A small pool of oil, probably the remains of a lagoon, is located
on the top of the landfill. A chainlink fence partially
restricts access to the landfill from the roadway. Access from
the river bank is unrestricted.
~
The village of Wellsville lies within the Genesee River Basin
near the headwaters of the Genesee River. The river follows a
northern path across the entire Southwestern Plateau and the Erie-
Ontario Plain before it empties into Lake Ontario at Rochester,
New York. The Sinclair Refinery site, located on the floodplain
deposits of the river, has the west bank of the river a8 its
4astern boundary.
.Hydrology and Surface Drainage
The hydrology of the site is dominated by the northward-flowing.
Genesee River, which has been modified in this area in recent
years by flood control measures implemented by the U.S. Army
corps of Engineers. After severe flooding in 1972, the river
underwent channelization, bank stabilization, and diversion.
Several checK dams have also been constructed. A dike built in
1983 to prevent erosion of the landfill further modified stream
flow patterns. Dyke Cree~, a tributary, enters the Genesee
River approximately 1.25 miles downstream from the landfill
site.
Surface drainage in the landfill area appears to be dominated by
overland flow. The surface material on the CBLA is relatively
impermeable, indicated by standing water and marshy areas on
the top of the landfill. These conditions are the result of an
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8Hydrology --
Figure 4 presents a generalized geologic cross-section through
the site. The site is directly underlain by unconsolidated
deposits consisting of sands, silts, clays, and gravels. The
near-surface deposits are Holocene channel and overbank deposits
of the Genesee River. The coarser grained sands and gravels
tend to be well-sorted and are present as lenses and thin, discon-
tinuous sheets separated by layers of finer-grained deposits.
Alluvial deposits are at least 10 to 2S feet thick over much of
the site. .
1/
Beneath the alluvial sediments lie glacial deposits of the
Pleistocene age. Although the glacial and alluvial deposits are
difficult to distinguish from one another, based on field
observations, it is believed that the clay unit encountered in
several boreholes represents a glacio-lacustrine deposit. The
thickness of the clay substratum appears to pinch out to the
west ranging from at least 35 feet along South Brooklyn Avenue
to over 60 feet along the Genesee River.
During the deglaciation of the northward-sloping Genesee River
Valley, northward-receding ice masses blocked the drainage of
meltwater, forming large lakes. These lakes were the sites for
accumulations of great thicknesses of fine grained (clay and
silt) lacustrine depgsits. A general upward decreasing grain
size at this location suggests that an ancient or buried river
channel once existed west of the Genesee River (SMC Martin).
The glacial deposits are underlain by bedrock of Devonian age.
Although no site-specific data has been acquired on the nature of
this bedrock, regional data indicate that it is composed of
sandstones, shales, and conglomerates. Seismic data collected for
this investigation indicat. that the depth to bedrock varies from
approximately 70 feet near South Brooklyn Avenue to over 250 feet
in the southeastern corner of the site. This slope in the bedrock
surface reflects either a deeper pre-glacial Genesee River or a
deepening of the valley by advancing glaciers (SMC Martin).
Geomorphol.gically, this area is within the Allegany Plateau
Physiographic Province, characterized by a deeply incised dendritic
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The upperme~t~quifer, an unconfined water table aquifer, is
found at relatively shallow depths beneath the site. In the
landfill area, the depths to the water table surface were measured
in the range of 3 to 17 feet, with the depth-to-water at most
locations in the elevated portions of the landfill greater than
10 feet. Water from this aquifer discharges into the Genesee
River. The average ground-water flow velocity in the uppermost
aquifer is approximately 0.91 ft/day. Velocities tend to be
lower in the central portion of the site and higher at wells
adjacent to the Genesee River. At this rate, it is estimated
that it would take about 1.2 years for ground water flowing from
the central portion of the landfill to reach the Genesee River.
Fluctuations in the water levels observed over a three and one-half
month period averaged 1.14 feet. Fluctuations were observed to
be greater in those wells installed closest to the river,
particularly in the landfill area where maximum fluctuation were
observed on the north side. These fluctuatj~ns are apparently
related to river stage, with high water tables corresponding to
high river stages, and with low water levels occurring together
in the river and the aquifer, illustrating that the Genesee
River is a significant hydrologic boundary (SMC Martin). .
Figure 5 illustrates water level elevations and ground water
flow direction.
Topography at the site is relatively flat, with a steep drop to
the river on the east, and a steep climb into the hills to the
west. The local relief ranges from approximately 1,500 to 2,100
feet above mean sea level. The landfill exhibits greater topographic
diversity where the topography has been altered by landfilling
and earthmoving operations.
The water table in the landfill area is significantly influenced
by the local topography and the nature of the landfilled material.
The variable thicknesses and permeabilities of the wastes deposited
in this area have apparently altered the natural ground-water
flow patterns. Ground water in the southern part of the landfill
area flows in a northerly-ealterly direction towards the river.
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-10-
In the northern~ortion of the landfill area, there appears to be
perched water or mounding of the grOQnd water at a topographic
high. The water observed at this location may not be directly
connected hydraulically to the uppermost aquifer. Instead, it may
represent water pooled in a basin with a relatively impermeable
bottom of oil- or sludge-infiltrated soil. A depressed water
table is indicated south of this area and west of the dike pool.
This area lies in a topographic low between landfilled areas to
the north and south. Ground water in this area apparently flows
from the-topographically high landfilled areas into the depression.
(SMC Martin).
~
8Landfilled Waste Characteristics
,/
Seismic and resistivity surveys conducted in the landfill area
identified geophysically anomalous zones which were most likely
related to surface and subsurface ~ontamination. Seismic velocities
of the surface material in the landfill ranged from about 700 to
2,300 ft/sec. The wide velocity range for this layer is apparently
due to the variation of the fill material. Velocity inversion'
across the center of the landfill, and the presence of a near
surface layer with a seismic velocity of 2,000 to 3,000 ft/sec
are considered anomalies. A possible interpretation of these
conditions is that the water table is significantly displaced.
Water level observations indicate that this is probably the
condition across a portion of the landfill. The anomaly of the
seismic inversion may have resulted from localized cementing of
the overburden material. Subsurface drilling and test pit excava-
tions suggest this inversion is caused by sludgy or tarry material
deposited in the landfill, which may have permeated the natural
soils (SMC Martin).
A magnetometric survey conducted in the landfill area located
several zones of anomalous magnetic conditions. The magnetic
anomalies coincided well with areas where waste drums were exposed
at the surface, and indicated locations where other drums may have
been buried. Text pit excavations performed at several of these
magnetic anomaly locations uncovered buried metallic debris and drums.
Q
Pill in the-landfill is highly variable and encountered at varying
depths down to about 20 feet (see Figure 6). This fill is
generically de8cribed as .variable petrochemical waste material
intermixed with soil,. including oil, tars, sludges, and hazardous
waste-containing drums. While the chemical nature of the waste
material has not been estimated in the field descriptions of the
material, it is estimated from visual observation that the fill
material in the landfill is about 50 percent soil and 50 percent
-------
- -- J-
l[(.[NO
'U1nhlftr. 8f' L
. PttA\( U YO RIIII(; W'll
IIOft,In
. - PM"SI I "UCO( II 80""'r.
~. p""S( D 80A'''CO
, "Ulif"
~ . ...."S( PllfU'"
-------
'\,
TYPES OF WASTES DEPOSITED IN THE SINCLAIR REFINERY LANDFILL
. Cloth fi~r~ used for straining oil from the contact plant
. Sludges from an oil separator emanating from the light oil and
fuels plant (disposed of in a pond within the landfill site)
. Tank sludges from the solvent plant
. .Off-specification. products.
. Sludge dumptruck loads of oil-soaked soil and sludges (daily)
"
. Pullers Earth (used for filtering) burned and then disposed
. Approximately 500 gallons of tank sludges (weekly)
. Acid spills (disposed of in pond within the landfill site)
. Cinders and ash from the coal-fired boiler plant
. Tetraethyl lead
. Pesticides
. Waste oil
. Heavy metals
Table 1
... n."" .._-
.. .._0.__0 ---- -- -- ".'.-.."- ..---- ..,
-------
-14-
By 1958, when bhe refinery terminated its operations, the lagoon
consisted.~f only a small pool of standing liquid in the center,
surrounded by the drier, dark stained surface of the basin.
Portions of the northern and eastern edges of the lagoon,
trenches and pits were filled in.
Activities on the landfill continued long after the closure of
refinery operations. Bvidence from 1964, 1970, 1974, and 1982
aerial photograph8 indicate that lagoon dredging, trench back-
filling, additional landfilling, and general regrading occurred
throughout this period. Additional landfilling appears to be
most extensive in the 2.3-acre SLA between the years 1970 and
1974. By 1982, the landfill had been graded alm08t flat, and a
surficial covering of clay or silt covered portion8 of it. At
that time, the lagoon had been largely filled, a linear area of
dark standing liquid in the center of the landfill being the
only remT~ant of the lagoon.
Damaging Genesee River floods have occurred in the Village of
Wellsville five times since 1913. The most recent flood, caused.
by Tropical Storm Agnes in 1972, damaged and destroyed bridges
crossing the Genesee River in the Village and caused over $12
million damage, overall. .
Prom 1973 to 1976, the U.S. Army Corps of Bngineers (COB) undertoo~
a flood control project in the Village, constructing levees along
both banks of the Genesee River through the Village to a point
immediately north of the CBLA. This flood control work was
intended to rectify deficiencies in initial flood protection work
undertaken in the 1950s.
As can be seen by Pigure 7, the Gene8ee River has had a hi8tory
of systemically meandering in the vicinity of the landfill,
shifting a8 much as 8everal hundred feet in 80me place8 from
1958-1982. As the meanders migrated further downstream, the
increasing meandor amplitude resulted in increased river bank
erosion. .
The Genesee River began eroding a portion of the landfill as a
result of-thi8 lateral movement of the river-bed and heavy rains
in October T981. Analytical results from the site indicated the
presence of PCBs, ar8enic, mercury, and lead. In a8.ociation with
the period of high water in the river, organic taste and odor
problems were observed with the drinking water. Test results
from the Village of Wellsville's vater treatment plant, the
intake of which is located approximately 1 mile downstream of the
landfill, indicated low levels of aliphatic hydrocarbons (10 ug/1
-------
j'
..
I, ~
~1
Rf
~:
11
~
t
"t
.~
I
I
~
Ii
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r:,
t
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:rr.
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1&
If
J.
.~
,I'
iit
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",#:;
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't ..
"11
. .(
;"!
~~a
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r
'.
..-;;;;;f-~~
I
...
,~rGrIlD
L £11I1I8U"'"
IE..-'
,... ---
.... .----
.----
..,. ------
....
m:z3
EtD
.818 .. ace.. ,...
.... .. ....... IOU-"..
...'.U8 C-"'~...
........ ..... 1'''''
--
(~
." ',;.. '~.d
~~,
............
It ..c.n-I.'" .....
... .... ....... ';',.
..... =..-- ...... --
... "- .... -- .....-: :. t. ....
== =... _...".,........ ....
.
.
..,."
.... :,;
-~ ~/- I _eo.
~.. /" r ... .00' ""1 --'..
~[t:?';:'" r~ ..0'::::: .::~:::..
:%'.~ /V l~, - ....- .....
~/ 7d f t\ . ............ -~. ."-"":00.,"_'...
)1' . ,'~ ''- . 'uo',' ...... ........
" ,,~.,
_..,..
.,..- ~--'.
'--- \.
.....
C..AIIIIIL
. .. PilI.!!!!
'IATUIIU: 115
."O"lL !-I'(
Sl~~~~;~",~, .'.108-
I' U o.
c: .-;=>
,.."IUI'.
- CO:~.~I."c'........
..~ .. . ~.-J
Fig'Urc 7
-
-------
-16-
Pollowing t~ l~ndfill bank erosion and citizen water taste and
odor complaints, the Allegany County Health Department and New
York State Department of Transportation investigated the site in
conjunction with an investigation by the Wew York State Department
of Environmental Conservation (NYSDEC), in the fall of 1981. In
June 1982, the EPA Pield Investigation Team visited the site and
collected samples. .
A Technical Assistance Team investigation performed in October
1982 resulted in the Region's request for an immediate removal
action to stabilize the eroding bank of the landfill. Punding
for this action was denied by the Assistant Administrator for
Solid Waste and Emergency Response in January 1983. At that
time, the potentially responsible party indicated a willingness
to remove drums from the Genesee River that had washed from the
eroding landfill, and to stabilize the bank. Although in January
1983, the PRP removed approximately 10 drums from the river, it
changed its positon regarding stabilizing the eroding landfill.
To prevent the imminent threat of further erosion of the landfill
during potential high water conditions that Spring, in March
1983, the State used its own funds to construct a temporary
diversion of the Genesee River by excavating a channel that could
accommodate a two-year frequency flood.
d
In July 1983, EPA and NYSDEC entered into a a Cooperative Agreemen
to undertake a Remed~al Investigation (RI) and Peasibility Study (~~,
at the Sinclair Refinery site. SMC Martin was selected by NYSDEC
to perform the required work.
The RI was broken into two phases. Phase I was performed to
provide a detailed characterization of the landfill portion of
the site and reconnaissance assessment of the refinery portion
of the site. The ongoing Phase II RI provided additional data
on the landfill portion of the site, and will provide a more
focused investigation of those areas on the refinery portion of
the site where additional data requirements were identified.
Originally, only an PS for the landfill portion of the lite was
covered by the Cooperative Agreement. Because of the petroleum
exclusion-provision contained in CERCLA, the PS for the gO-acre
refinery Rortion of the site could not be performed unless
Whazardous substancesW were found on this segment of the site.
Since hazardous substances were detected at the refinery portion
of the site during the Phase I RI, upon completion of the Phase
II RI, an PS will be conducted at the refinery portion of the
site.
'. ... ..-...........,'--... ,-
-. . .- _.._- ..... .-. -.. '._-~'"
- ...... u-.....-.... ,"~.. -'" .
-------
':..
-17-
In an action -runded by the Potentially Responsible Party in
November 1983, the heiqht of the dike constructed in March 1983
was raised and it was strenqthened with rip-rap.
In December 1983, partial fencinq was constructed to limit access
to the landfill from the roadway.
In March 1985, the Cooperative Aqreement was amended to perform
the Phase II RI and an PS for the refinery portion of the site.
\:,
In May 1985, based upon the data collected at the villaqe's Water
Treatment Plant as part of the RI, and in response to concerns
reqarding the threat to the water supply from the Sinclair Refinery
site, SMC Martin completed a focused PS evaluating initial
remedial measures to protect the Wellsville Water Treatment
Plant. The recommended measure involves relocatinq the water
supply'. intake to a point upstream of the site (see .Authorization
to Proceed with an Initial Remedial Measure at the Sinclair
Refinery site, Wellsville, NY - Action Memorandum. for specific.
details).
In August 1985, SMC Martin completed a draft PS for the landfill
portion of the site.
Current Site status
There are seven potential routes of exposure associated with the
landfill portion of the Sinclair Refinery site, includinq
subsurface and surface soil, surfical drums, pools and surface
water, river sediments, and flora and fauna. pigure 8 indicates
the samplinq locations for all media from the Phase I and II RIs.
.Soil
As can be seen from Tables 2 and 3, the landfill 80il samples, as
well as soil samples from the bottom of shallow pools adjacent
to the Genesee River, exhibit high levels of base neutrals and
volatile organics, most notably 10,000,000 ppb docosane, 1,400,000
ppb1,3,~ trimethylbenzene, and 870,000 ppb heptadecane. Metals
are al.o-~resent, but at considerably lower concentration.. The
most noteworthy concentrations are 1670 ppm lead and
1020 ppm copper.
-------
~. '.. . .... ""'. ,"181,
,. c -, IIIN8.... ~ ................ 1-"""'1&18
: ~.: -'I '-...... ...... ".o.."
, - ~, ....., ....,..., ,....,......
~ .i ....- .. .... - -..-. -...
'1...--:;;;-..... ........ -.:;..:::.-. ..
. .
~7;)0
. ,~
-j
;j
.f
~
I ,
:tf'~"
h
to:! .
.~ 'u
~~''':';
'.
,...\,... LANDrlLl 5111.
.'.1.....,1 ......
fEASIBll"Y STUDY
sa""U-G LOCATlOtIS
...-... ~
~.f~'~~,:~::,- 1Jti~
c
-------
(
, >
IANG I! 01' (1J'uUl'" AT . OftS
",IOI.n I'OU.tnAJIT tu8O'\Ml1I)S
SUB!o1IlJ'An SOIL SAII",I!S
I
...., '.rl..- "I" 8erl..-
La." AI t AUI II.' 'Ut ..,..r AI I Aua Jut 'III
18-'.. .. 1...1..: U II lIJI8'u .f 1...1..: II n
JlLdlLi "Allies (".) I&UU c,..'
\ ..... 1t0 n)
....... ..... "'01 ... ...., lID lID
.r.."lc".,"."." I ND ......<1.1 .....1. l1-nUI) 4.1-'0.1(11)
."o.o'.ra ... """ (I ., ...,U'" lID ::=1.'(1)
. .., ........ ...... 110008 n) """'400(4) CA"'" ....n(1) I.un
....,.... ........ """'71 1 11 ......ltOOUa) ....-.- 11-4" II) ,.",-".I(1)
1.I.l.1-.........r.."." NO ......UOU) ..".. ,. '-fOUl) ,'.8-IOIIC II)
.....c'I.'..""... ......nOOOII' lID .... 1-1I40UI) I.'-II'UI)
....... ....noooe I) ...... 1I0el) .crC.WJ """1'" ",.J6en
.te'.' I. ,-ule II) 4.'~J6.'UI)
JdIC/NI!1I1UL D1Ucr..... e,..) ... ..... ........ II C I) 18-1.IU)
. n ... ....U4) , .
ac...,"'." NO IIHI 1..111.. . ..,.7(2)
..,'r.c... NO ....<1 "" If-'ll UI) JS.'-&lUII)
.....1.........." ... ""4 .,CI)
,..,.«"'I..r.."." lID ....<1 f1.STJCJU C,..)
'..ul.'".... lID ",,0
U..n."." ... ..,. 'CI) .,'rl. .' II»
Uoon.. ... ..<'0 .-"C .....IOCI) ...
..,."..... "U e u .."CS) ,-pc: .. ...
,.......r... ..1..OCt) ...e J) 4.4'.DOII ... lID
"n.. 18-<11 ,,<1 4.4'-00' "'.O'U' ...
4..'-DOT ........ OIC It ...
ACI8 8n11&C1'MU.I C,..) .-.......,.. ........ItU' NO
..'...1'.. ..1'.'. ....04(1' "O.IIU)
1.4-.,....,1,....1 lID "2'( U ..'rl. ........0'7 U' ...
,..... .. 18-<1 ....1. .....,.. ... lID
..,..c...r "'.OI(2) NO
nAIIIIIU I NIJICII.ICI C".) ..,10.".. ....... ....IOU) NO
T.u' .,..... ....."CII "",.85CI) na. C,..)
t.u' r....er"l.
,.....1.. "4.40(" .....U. pa-IO" NO lID
tn-UII lID .... < 2
pa-un lID ND- (J
f("8- UU NO NO
,i pm- u.. NO HD
pa- I U4 NO NO
pm-IUO NO ND
If.
lIOn:
.,,'.r '8 ,.r..t'.'.' ,.....,.. ,.. ..... .r co....'.."o.. ...,.... ... ...... o. ...".. .. ."c' ... ........
... ........ .. .....,.,.... I'."',
.. .
Table 2
-------
VOLATILE ORGANIC
COMPOUNDS fppb)
1, 1, 3-Trlmethy1benzene
Cyc10bexane I I
Metbycyc10Keune
4-Metby1-1-Pentano1
2-Metby1-1-Pentene
3,4,4-Trlmetbyl-4-Pentene
Metby1 Etby1 Ketone (ME!)
1,2,3-Tri8etbylcyc1obexane
l-Etbyl-4-Metbylcyclobexane
1,1,3-Trimetbylcyc1obexane
2,2,-Di8etbyl-3-Rexene
TOTAL XYLENES
BASB/RDJt"RAL EXTRAC'l'ABLES fpDb)
Docoune
Elcoune
Heptadecane
Hexadecane
4-Metby 1benaa1dbyde
Octadecane
Pentadecane
1,3,5-Trimetby1benzene
4-Metbyl-4-Bydrozyl-
2-Pentanone
NON-PRIORITY POLLUTANTS
bndfill
WASTE
ND
4,800
10,000
2,500
5,900
8,700
110
ND ~
ND
ND
ND
50,000
110,000
13,000
120,000
78,000
11,000
79,000
60,000
1,400,000
ND
SUBSURFACE
SOIL
ND
1,200
15,000
1,100
1,200
13,000
78
100
250
250
1,200
42,000
,
I
10,000,000
350,000
. 99,000
110,000
ND
200,000
120,000
820,000
110,000
ND - Not Detected
(2.5 - Detected but below quantifiable limit (nU8ber following 8(8)
. I
j
Table?
Cont in,
-------
,;
O'
1
A
"
.:f
'~
(
~
i
('
/
v
8ANO! 01' CDIIaJllUTiONS
..101m 1'OLLIJfAN1' mlll'OOJIIS
IDDUII SOD. SAlft.ES
MJ ..... An.
"J....' Au. .. te..., III ..."Wo,,'
.. La..,.11 .,,'.w._4 S..,.. Poo' ......, III - I.w'...
...,.. .... ....., III - I....... ca' ,._".81. I.... ... '001. I......
... ,......... I.... ... ...1. I...h. M.a... O. S......: 1 6 ~
...... .f ....,..: 1 6 J
I IEDLJ C,...
WIll .Tn.1 _Mllet Crr') I
....-, Ie Ie. Nt
....... .. Ie NO ... ..... II-Un) !t-1tU. 1.'.UU.
.'.HO'- .. .... Sf I) NO ....,.11- Ie .....'um II)
'.2-'lc'.ow.,w.,," .. II) NO c."'- Ie .. II)
'.'-'I.".W.'w",,, .. NO NO c'w_l. '.'-60n) .,."C6. 1.'-l.U.
...,.,...... .. ~600(2) NO ..,..w 1.'-ItC" 16-226(6. 1.I-UII)
...,,1... ..'ow... ..,oell) ~"on. .. ,... .. '-0(1) '''-1''016. I.I-UU.
1.1.2.1-...w..'.ow...'.,, " ~UOII) NO ....c..., "'.16(2. 1.1-1.416. Nt
...w..........,.... .. NO NO .tc... ,.'-JS(1) 1.4-11(6. U-UU)
....... .. ~I,,(I. NO .....1. Nt .. ..
.u..w Ie .. ..
8&1111"""'" IlnUCl'A8LII ....... Ie .. "".41(1.
.... 4'-U'(1.) 11-11'(6) II-"U)
........... .. .. lID
"...I...."w..." ..I.IU) Ie NO IESTIC'''' C,..)
"..01'."..".."." .. Ie lID
"..oc.)"w... .. Ie .. ....... ~In) .. NO
'.2-'.."ow.'."." .. Ie Ie .-IIC ..,.6U) Ie ..
..,-............... Ie .. NO ,-ue: ND-<' Ie Ie
'.4-'.."".""." .. Ie NO a-lac: ND-
-------
NON-PRIORITY POLLUTANT S
l.8ncIfill
VOLATILE ORGAN IC
COMPOPNDS IpPb)
1,1,3-Triaethyfbenzene .
Cyclohexane
Methycyclohexane
4-Methyl-l-Pentanol
2-Methyl-l-Pentene
3,4,4-Triaethyl-4-Pentene
Methyl Ethyl letone (M£I)
1,2,3-Trimethylcyclohexane
I-Ethyl-4-Methylcyclohexane
1,1,3-Trlmethylcyclohexane
2,2,-OI8ethyl-3-Rexene
TOTAL XYL EN ES
SURFACE
SOIL
NO
14,000
34,000
4,900
23,000
2,300
ND
ND
ND
ND
ND
3,600
I
I
BASE/Nm"lRAL £X'1'RAC'rABLES Ippb)
DoCOAne
£lcosane
Beptadecane
Bexadecane
4-Methylbenzaldhyde
Octadecane
Pentadecane
1, 3, 5-Triaethylbenzene
4-Methyl-4-Hydroxyl-
2-Pentanone
90,000
83,000
870,000
370,000
NO
740,000
170,000
81,000
34,000
ND - Rot Detected
<2.5 - Detected but below quantifiable limit (number following 8(8)
Table
, I I t
-------
-23-
.Ground water
~
Based upon an interpretation of ground-vater elevations in the
CEL~~ it appears that most of the landfilled waste might be
above the vater table, though it is probable that the vaste
itself has displaced the vater table. This is attributable to a
relatively impermeable sludge layer at the base of the vaste.
As a result, the vaste is not vater-saturated and does not
generate excessive amounts of leachate. At the SLA, a sludgy
barrier layer does not exist a8 in the case of the CELA. As a
result, the vaste is considerably closer to the ground vater at
the SLA, as compared to the CELA.
Infiltration rates vere observed to be highest in the SL~ at
average rates of 0.223 in/hr (fallinq head conditions) and 1.06
in/hr (constant head conditions). Significantly lover
infiltration capacities were observed in the CELA, vith average
infiltration rates of 0.26 in/hr (falling head conditions) and
0.17 in/hr (constant head conditions), suggesting a relatively
impermeable landfill cover. As a result, rather than percolating
through the waste to yield contaminated ground vater, most of the
rainwater falling on top of the CELA travels over the surface of
the landfill either pooling in depressions atop the landfill or
infiltrating the surface elsewhere. Given the low infiltration
capacities and the relatively impermeable nature of the CELA
cover, it seems likely that pooled water in these depressions
more likely evaporates than infiltrates the surface. Because of
the low permeability of the CELA, significnt levels of contamination
were not found in the ground vater. In the SLA, because of the
higher permeability of the cover material and the buried wastes,
as compared to the CELA, more precipitation passes through the
landfill, however, overall leachate generation associated with
the landfill appears to be lOw, as vell. Table 4 summarizes the
range of contaminants found in the ground water. The most notable
concentrations found include 23,000 ppb 4-methy-4-hydroxyl-2-pentanone,
6,000 ppb bis (2-ethyl hexyl) phthalate, and 3,000 ppb fluorene
beneath t~e Landfill site. Insignificant levels of contamination
were found in landfill perimeter wells.
'.'.:' !....
-------
90LATILI OIICAinC
-'OJI.muIlDS '-bl
I. I. 1-7rlcblorOltha...
lenle...
Chi or obe... a..
I.J-Olchloroprope...
1.I.Z.Z-,.trachlorOlt.a...
Eth,lbe...a..
Toluene
Vinyl Chlorld8
Ir08odlchlor08at.a...1
Chloro(or. ,
Neth,l.... Chloride
Benlo(A)Anthrace...
YetrachlorOlthflane
Pyre..
Ph.nanthre...
1,1,3-7rI..thflb1nre..
c,cloha.a...
Reth,qcloh......
4-Reth,l-l-Pentanol
Z-Methfl-l-Penta..
J,4,4-Trl88th,I-4-,..ta..
Neth,l !th,l 8aton. IIIE8)
I,Z,J-7rI88th,lCYCloh.....
l-Ethfl-4-Neth,lcycloh.....
1,I,J-7rI..thylcycloha.ana
Z,Z,-DI88th,I-J-ee.a...
YOTAL In.DES
8A8E/8IUftAL IIftACrAlLI8
fDDbI
8IaI2-Eth,1 118.,1)
'lourantha...
'loure...
lIapthale...
Phenanthra..
Pyr...
Ac.napllthe...
Arthaea...
lenlolA) AIIthrace...
If'nro IA) "rana
I..nlo III rloura~a...
Ol-R-oet,lphthalate
2-Nathylnaphthale...
DoCIIDU...
81CIID88ne
.eptadecall8
....d8call8
4-118th,lbell8a1A7de
Octad8ca-
hntad8call8
I,J,5-TrI..thflbenr.1I8
4-Nathpl-4-Iydro.,1-
2-"'ntanona
GlllUte lAm SAJI'UI
17
..5
12
<2.5
12
<3.'
5.0
<5.0
110
liD
liD
liD
liD
liD
liD
2S
It
7t
<5
'.5
n.5
liD
liD
liD
110
110
<11
pbtltalate .,000
2.3
03,000
110
10
110
110
110
110
110
NO
1,000
28
<2.5
t
27.'
<2.5
110
15.1
II
2.5
2J,000
- IIOt Detect.d
- Detect.d but belo. quantifiable 11.lt (nU8ber follo.ln9 8(8'
.,
---BDL&....1»a1-
'IOtal
Tot 81
Total
Total
Total
Total
Total
Total
Total
Total
Total
'IOta 1
An.nlc
l.r,l1lU8
Cad.. U8
Chr08l..
Coppe r
L.ad
Mercur,
Nlc'eI
selenl..
Thalli..
line
&11.,.r
-DJ2'JCID8S Ipl8l
.,.'-000
.,4'-00E
.,.'-OD'l'
Ol.ldrln
a-EndoauUan
8ndoaulfanaulfate
Indrln
Indrln AI8hyd8
..pt.chlor Erpoalde
Aldrin
a-IRC
-IRC
lepta chi or
.caa '-1
I'Q-U21
KII-un
KII-IOU
KII-UU
KII- 12..
KII-U54
K11-1210
CBIIIIIU .. "P.lHJLICli '1'181
'IOtal c,anlde
'IOtal ae_arable "'anoUn
I ,
12
<.005
liD
<.005
.on
5
liD
120
liD
NO
2,140
.020
<.010
.011
I
I
lID
110
110
110
110
110
110
110
110
80
110
lID
80
lID
lID
lID
lID
110
110
110
-------
-25-
"
The -Hydrologic Evaluation of Landfill Performance- (HELP)
computer proqrem, a two-dimensional hydrologic model of water
movement ~cross, into, through, and out of landfills, provided Q
rough approximation of the leachate which may be generated at
the Landfill site under average conditions. The model predicted
that for conditions present in the CELA, less than one percent
of the annual precipitation (50 gallons per day (gpd», will
leach through the waste and upper aquifer, and through the clay
substratum, with virtually none leaching through the waste and
laterally draining from the aquifer into the Genesee River.
Eighty-nine percent of the annual precipitation will be consumed
as evapotranspiration and runoff, with the remaining 10 percent
accumulating in the CELA soil/waste matrix. Por the SLA, the
HELP model predicted that roughly 2 percent (100 gpd) of the
annual precipitation will percolate from the surface, through
the waste and upper aquifer, and through the clay substratum.
Roughly 66 percent of the annual precipitation will be lost to
evapotr~nspiration and runoff. Thirty-one percent will laterally
drain to the Genesee River via the upper aquifer, with very
little being 'stored in the SLA.
As predicted by the HELP model and confirmed by the failure to
find contamination in perimeter wells and wells in the clay
beneath the landfill, overall leachate generation appears to be
extremely low at this time.
.Drums
Buried drums may also be potential sources of ground-water
contamination at the Landfill site. A variety of hazardous
waste compounds, including metals and volatile organics, were
observed in samples from exposed drums on the landfill surface.
Table 5 describes the condition and contents of sampled drums.
Table 6, summarizing the levels of contamination found, shows
5,700 ppb methylene chloride, 7,300 ppb nitrobenzene, 31,500 ppb
chromium, and 35,900 ppb zinc.
.Pools
Elevated levels of lead and arsenic in the pools atop the landfill
and in t~ main drainage swale (see Table 7) suggest that surface
water runoff may transport the metals to these local depressions
and possibly to the Genesee River. A significant rise in river
stage or a severe storm event would conceivably transport such
pooled contaminants into the Genesee River.
. . .',.. ...-"--,,..--' .....
. .._. ... \'...-......_..-
.- ",.., ...... "-'" ....- ..
. ..---- --:..'
. ~ . ......, ..
-... . ...- - ".
-------
.DL..l.ui1
D-l
D-2
D-3
D-4
D-5
D-6
D-7
D-B
D-9
D-IO
DRUM WASTE SAMPLE DESCRIPTIONS AND DRUM CONDITION NOTES
Description/Note~'
Dru~ is completely crushed and about 50\ exposed
at the-surface. The area appears to be regraded.
The drum material appears to be intermixed soil
and orange, black and gray waste. The orange
discoloration may be from rusting. The waste
appears to be weathered.
Drum is completely ~rushed and exposed at the
surface. The waste material consisted of black
solids, gray fibrous solids, and discolored soil
1 i ke mater ia1.
Drum is partially exposed at the surface, com-
pletely rusted and somewhat crushed. Both ends of
the drum are open. The material inside the drum
is dark brown in color with a waxy texture. The
material is homogeneous in both texture'and
color.
Drum is 60% exposed at the surface, rusted and
ruptured on both ends. The material inside
consists of two phases: the first phase is a
discolored soil-like material while the second is
light brown in color with a waxy texture.
Drum is 60% exposed at the surface, rusted and
open on one. end. The dominant material inside is
brown in color with a soil-like texture. A large
cloth rag covered with a bright red resin material.
is also in the drum.
, :
Drum is lying on surface and intact except for a
small six-inch diameter hole in one side. The
material inside consists of a homogeneous black
crystalline solid.
Drum is piled among other drums and is 50% rusted
through. Material inside is hard and white in
~olor with a fluffy porous texture.
~he bucket is 50\ exposed to the surface with the
o~n end facing up. Material in bucket is hard..,
and homogeneous with a gray graphite like color.
Drum is 60\ exposed on surface and partially
crushed with one end open. Material is
grayish-white in color with a dry, fluffy
powder-like texture. Material contains many
septum like plugs.
small
Drum is lying on surface, rusted throughout and
ruptured. Material inside is blackish brown in
color with a crystalline solid texture similar to
that found in D-6, perhaps in a different state of
weathering.
Table 5
-------
...~.. ., s......:
ya..ATIU .-AIIleI C"'.
.......
c,...........
.,..u,...
'.I-"c"'W""'"
'.1-"........,...
I.I-"c"'."""'"
.....-I.I.","'w,,",""
'.J-"."...,......
...,........
....,.... ........
,.'.I.I.-.....c""""'"
..............,....
.......
'.'.'-.wl...........
1.1.1-'.'"''.'''''''
'.'~'I......,....
..." ,,,..1..
,AS. 188ft.... unAft."" C"'.
.....I.'.."w",,,
..-.-...,.,........
......,.,..'.1...
'.1-'.""" .,.......
ra..u."'"
....u..
...................
..,........
...w"",'"
"..........
"w...
In. .....AftA8L1!8 C",.
I.f-"..",'"''''
,.....
nAIII... . - lIS I",.
"
T.... .,.....
T.... ......w.,..
,....11..
;.
o oJ
IANGI 01' CllHaJl'ftATIOHS
...olln I'UU.UfANT UIIIIUINDS
DIU. WAin IAllft.I!S
..- .....
...,1.. h-.""
.. ...,...
~.R .t .88....' 10
1&1&1 e ..,.
...
... ......., ...
- ......c ......e,,.' e..
... ...,11'- ""'" .au.
- .....- ........teu
- ...-.- ....u,ooe.. '
- .. '-fJtIl.' I
c.,,..
- .... ' .1-I6Ofe I.'
- ......, --a.te..
,,51..ell ...,j, a .f-n.e I.'
- ......- "1.1111
- .u... ...
... ...111- liD
... .... ,-n908I1.1
...
"U80n. IIISTI MIII!II e...1
.
...... lID
.-IIC ......4ell
,-PC --..01111
18-1.4'" '-PC "".,un
18-u..en ,-18C .......4111
..,..U' .......... ...
..cu. .....- ......" u.
- ....... ......1 .IUI
--en f.f'-I8f "'" ..UI
..CI ........ ",,'.In'
"(I .-.......... """". U I
..,...en ,-.......... -
"I.un .......... ..a,... ......a. ,nl
..a ..n. ...... .........UI
......' .....,.. ........" n I
..,......w .....nnl
..,....... ....... ,,....01111
. ....,.... ItHI
.."CI'
1181
ta-a." ....(1
"'..acu ",IU' ,..e4
fg-lln ......(4
"'.fI41 ...1141 ....<2
10-114' .... (I
10-11'. ...... (I
10-126' .... <2
" ,
I
....:
.....w .. ,.W...,.... '01...1.. ... ,.... ., c.,.,,""I'" ........ ... ","w ., ...,a.. .. ....,
... ........ ... ........ .. ,,,,"1..'1' I'.""
Table 6
-------
IAHGI! 011 OI,u1:.nUT.OIIS
N....,TY fIUIJ.UTAHT mwPOO""
solun ..nl SAIIIU.s
.....~ .1 I......:
L...,... A... -
S..., ... '00.'
,
N....~ a' S....,,:
L...,... A.... -
I..., ,.. l8W
,
W1I ATILI Cl8lijNICI (",.
I&I&J (",.
,......
,........"..
,...o..c...,....,...
,.....,....
c..o,........
."0'.'.'"
"',...c".",.",,,
......-'.I-'.c'..,..",,,
..., ........
..'.2.1-...,..,......,...
','c"""",..,,
.......
NH.SlU
NO
II)
NO
ND
NO
NO
III
NH1.1
--<,..
..
....<,)
.......,
",.,'c
)..., ....
....t-
ch....
ea,..,
....
....c...,
......
.....t-
lI..or
'h" t.
....
III
""(5)
III
",.1(1)
"".1(21
....U(4)
..UOU)
--IU)
..u( It
..
"IUt
..
....11(5.
1Id.1 "....11
DlhCl'.LB (",.
.....,..,...
..I-..c".,.'.".,.
..4-'.c'..,"."."
II.......
....,......
...,........
--.."........",.....
.......,....
..
..
..
..
..
..
..
..
rP.STlCIDIS ("..
2.4-'."",.".",
......
..
....SU.
.-uc
,-Ue:
'-Ue:
,-lie:
4.4'-DDD
t.4'-a..:.
t.4'-DOT
,-."..."..
...,..
...,.. .1'."..
,.,......,
,.,...,.., .......
...... .1112.
..
"'.10(2)
..
""'.01(1t
"'..'Ut
..
..
"'.l1ut
..
..
"'.Ol( It
At.. UIhft'&8lB C"..
nMllIU . """1£1 C_.
m.
T.... .,.....
T.... ......,....
,..... ...
--<10
-------
-30-
.Surface Wi~-er-
As can be seen by Table 8, only low levels of contamina~ion have
been detected in the Genesee River. Table 9 shovs that there
does no~ appear ~o be significant levels of contamination in the
Genesee River sediments. Wi~h the exception of lov levels of
non-priority pollu~ant base/neutral extractables, all of the
average concen~ra~ions of detec~ed po11u~ant8 found in ~he
8ediment8 are fairly consi8~en~ vi~h the average background
levels.
u
.:.ti!:
The only compound detec~ed from the chemical analyses of
air samples was methylene chloride at 3.6 mg/m3 (see Table 10).
Because ~his volatile organic compound is u8ed widely in analytical
laboratories, because it vas t~j only compound reported, and
because of the low levels de~ected, it is deemed insignifican~ in
terms of charac~erizing air contamination at the site.
.Public Health Threat
The 1.2 million gallon per day village of Welleville Wa~er Treatment
plant, the intake of which is located less than a mile downstream
of the Sinclair Refinery site landfill, is the primary drinking
water source for the 6,000 residents of the village., The plant's
existing facili~ies, while functional, are greatly in need of
rehabilita~ion, and are not capable of completely removing the
organic and inorganic compounds potentially discharging into the
Genesee River from the Sinclair Refinery site.
Samples taken from the water ~reatment plant's finished vater
(eee Table 11) through November 1984 have, on occasion, shown low
levels of trihalomethanes, heavy metals, and base/neu~ral
extractables, all vi~hin acceptable criteria levels. Phenol vas
a1so found on several occasions above the New York S~ate Department
of Health's (NYSDOB'S) aes~hetic guidelines. In December 1984,
8amples showed previously undetec~ed compounds: 6.4 ppb benzene
(above NYSDOB'S 5 ppb chronic exposure cri~eria) and 4.8 ppb
tetr.chl~roethylene (below NYSDOB'8 50 ppb chronic exposure
criteria);
.'
~...:......' ~.
-------
NON-PRIORITY POLLUTANTS
landfill
?;
'1
"
~I
"
f
',VOLAlflLB ORGAN IC
COMPOUNDS ippb'
1,1,3-Ifrlmetbylbenzene
Cycloheaane 'I
Methycycldheune
4-Methyl-l-Pentanol
2-Methyl-l-Pentene
3,4,4-Trimethyl-4-Pentene
Metbyl Ethyl letone (MEI)
1,2,3-TriNethylcyclohexane
l-Ethyl-4-Methylcyclohexane
1,1,3-Triaethylcyclohexane
2,2 ,-Di.ethy l-3-Reaene
TOTAL XYLEMES
SURFACE
WATEit
~~
;,
ND
25
31
ND
28
ND
ND
ND
ND
ND
ND
100
f
,
I.:
," ~
i
J.
BASB/NFJJTRAL ErrRACTABLES 'pDb'
Do co sane
Eicosane
Heptadecane
He_decane
4-Methylbenaa1dbyde
Octadecane
Pentadecane
1,3,5-Ifri.ethylbenzene
4-Methyl-4-Hydroxyl-
2-Pentanone
9.8
ND
33
19
ND
22
1.1
15
ND
.~
"
"J
.
..,
ND - Bot Detected
(2.5 - Detected but below quantifiable limit (nuaber following 8(8)
,~
'..
.!--
'I'
q
'!i
I:
.-!.
('
:j
7 '
led
,
-------
.....,...... . Ie
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..t-..c...."'",,, Ie ..
II ...... . ..
..,........ . .
..u.~...... . --'...tl
M-.............,...... . Ie
,........... . .
.&8:11 UIUft'.... C,,~I
1.4~'.....,.,..... . .
,..... . .
ft.&llillb . .......1£1 e".1
T.... ........ .. --UCII
T.... ...........
,........ --'.(11 "
1InII: ........ ........... ......... ... ..... ..
.......
...... 01 1...1..:
,:
YOUI' ILl OIlUlllc:I .,,~I
" '
~......
~.-......
....041 c,."""""
.._1...
c'."'~"""
......,...
"~'''''..8W8''''''
.....-..I-"c......'.'"
...,.~......
..1.1.2-'"."..""",,,
..1.........,....
.......
'. :
. ,
:~. :~
~:i
t.:
C,'
(.
1l.U1II...,..AL ~.UII ....1
,:.,
,J
.;. ~:
~,~
4'
.~ :;
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"
,,'
..".
,:!;;
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, ,
~.~ !:
. ';'",
. \',:
',I;:
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'1:
"
e ',;
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, .
!. ~.
'/
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.~
I.... W....
I... ..-
.
I.... W....
a.- ..-
u
.
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.
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InD unl S.&llft.~ .
II... w.... I.... .....
I.,. ..- -MLfla-
M8.... .. 1...1..: . U
8I&I c".1
....-, Ie lID
.n.... Ie ....,UI
...,.11. Ie Ie
c.".- 88-,UI Ie
....... . ...
..,... ....e'I "
.. h.. Ie "
...c.., ... U II ...1.1..1
...... ...11 Cli ...UClI
..18.1. . .
...... ..,ell "" e II
."I!.. Ie Ie
.... 88-ue s. ...l6nl
fl!STle.DII e".1
.-He "...2UI "'0. IOU II
'-lie Ie .......un.
I-lie ....IClI "'.OJC'.
,-IIC .. Ie
..4'-- Ie Ie
4.t'-D18 . ND
t.4'-181' 118 Ie
.-.......... . Ie
...... Ie Ie
....1. .....,.. ..... ..21 II .....NUI
.."...... "'..1C41 "".OU II
..,....... ....... . ""'.01 U I
ma
II' .......... ..
.............. ...,.... ... ...... .. ...,... ,. ..... ... ........ ... ........ .. ......".~..
,I I
-------
SEIIJIII'.HT SAllJ'LES mLLECI'ED ".l'1 111' C;8f!SI!£ I,va
If-Iter 01 hulL
I......
I.yew
I.......
.
YCLATILI! OIGANICS
All C08I,o..'. NO fo~ ...pl...
IASE/NI!II1UL I!lTIACfAaLI!S
AI I C08I,o..'. NO , o~ ...,-...
ACID IITIACfAaLI!S
All 1081,0..'. NO fo~ ...,1...
CrANIDIS AND PlDlCLICS (,,11'
.
,
f
)
i.
!
i
Total c,..... 1.'1-1.'(7,
Tot.1 ~..o..r.IIJ.
'''.01 lea ""'(2)
IETALS (,,11'
Total ..t 1.0., ..<2
Tota' .r.... C '.4-2111'
TOh' ber,lIl- "<2(1'
TOhl u..l- ..1.UI)
TOhl clI~08II- , .4-IU.,
Total co,..~ , . '-41( ..
Total h.. '.'-4U.,
TOhl ..rc.~, "'.I(J'
Total .iehl 0.'0-12("
Total ..1..1- "<2
Total "hew ..nu.
Total tllllll- .....U
Total at.. 11-1"(1'
PESTICIDIS (ppll'
1I.,hc.lo~ ""..1(1'
Pa. (,,11)
P(1I-I221 ....
-------
.:-
Air S"DI.L~.u:
h~: ~ {JI.1JUst::
Tt.. of Coll.otlo.
YCLATILI OEANICS,C..'-')
I '
I
...."... .'Iorl'.
'.
NlllPiIOlln YCLATD.. GlGANICS
0." ..t'" .,.,1 ,.to.. ... .".... ...1,... - .11 ooapo.." NO for .1. ...p""
:,,1.
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- AS.-]._-
91/111 M
~O:~J.U'~J
, 0 ....
J.6
0.27
All SAlU'LiS
-- . AS~~, .
91JillJL
10'lJ-.llUL.
',o.t S..c"
0.41
0.29
. AI.: J.
!tll.J1/ .4
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0.21
1.1
, 1.1
-------
,"J.M,' O. .nJ.~ au.r.
"TU ftUTWJIT ft.urr
.8IAI' O' NUlL IAJU IAllft.PID
.. ........ ... ........ .. .. .. .....,.. .. .....,.. ........ ........ .....,.. 'a...,.. 'a...,..
I..n I..." I..." I.... I..n ..." I..." W..., I..." I.,." I.." I.... I.... I.,." ,....
11111111 101111 II 11/11'11 11110/11 ...ItJl1/a IJ/I1/.. III Oil .. IJiM/.. "/U/.. "/U/.. UHf/.. 11115/.. 111141.. U/II/.. IU1U.J1
1lLUD.1 _81118 ,.."
....... .. . - . .. .. .. .. .. .. .. .. . ... ......
,.-....."..
...... lID . - It .. lID .. II .. .1 ... It _II." .. I..U."
,,,..f... .. .. - .. .. ... .. ...... ,. .. . ...C.. It -".n .., .. ..... It
,.....,... .. . - .. .. lID lID .. .. .. .....1. .. .. .. ..
..a....f- .. . - It .. .. .. '.1 .. .4 I.' '.1 . . ..
..,....'1.".. I
,I
....... .. ,. - II .. .. .. II .. II '.8 II .., .. '.1
."...-1.'-'1.'1.- I
....,18.. .. . - .. .. .. .. . .. . 8.1 _U." " .. '.8
." ....."... .
..",... .. . - .. .. .. .. .. .. .. .. . . _Cl.I' ..
....,18..
.,a..... . . - .. .. .. .. .. .. .. .. .. .. 18 ..
,.,,,...1.,,..
..., I... .. . - .. .. .. .. .. .. .. .. .. . '.1 ..
,.1.... .. . - .. .. .. ' .. .. .. .. .. .. . _Cl.I' _".1'
81111...... munM" I.."
.....,..... U . - .. .. .. .. .. .. . . .. .. . .
..."........ .. .. - .. .. .. .. .. .. .. J.I '.1 .., .. '.1
AClI arunM"
All....... . ,. .11 _,1...
ft.... - ..-.118 '....
y...1 "-.,,.'1.
.....11.. .. .. - .. .. .. .. .. .. .. .. II .. 1.1 II
18T&I C..'I
y.,.1 .'".1- .. . - .. .. .. .. . .. .. . .. . . ..
T.,.I .."." .. . - .. .. .. . . U , II , .. I ,
T...I .a.,.1 .. . - .. .. .. .. . .. .. .. . .. . ..
T.,.I .1.. .. . - .. .. .. II ., .. .. " II .. . n
Mnlfl- I""
I-lit . .. - . . .. 1.11 1.11 .. . .. . . .. ..
M.
All.......,. . .. ... _.1...
--.m IILU&I -_118 C....
~.I"..... .. . - .. .. .. . .. .. . '. _UI' .. . 18."1'
...,18.. .. . - .. .. .. .. .. .. . .. . . _UI. ..
--_m IAIII-..a 1IftACr--
~ All....... .. .. ... -.1...
.. - .., ..,..,..
I; _I , - ..,- ..,....... I"" 1'.,..,,- 1..11' - c..,_a..., ... a....I1......
-,
.. ..... .., k ,...,"a.. ke.... U. ......"..... ... ... 1-. '\e
11
1 "
-------
..
-35-
While the trthalomethanes found in the plant's finished water are
likely to be the result of chlorination of natural orqanics in
the raw water, and several of the heavy metals appear to be
artifacts of the treatment system, the benzene, nitrobenzene,
trans-1,2-dichlorethylene, and possibly the phenol, miqht be
attributable to releases from the Sinclair Refinery site.
Althouqh levels of contamination found in the water supply do not
indicate qross contamination, because of the presence of hazardous
substances in the landfill, possibly disposed of in an unsecure
manner, and because a possible link between the site an~ the downstream
water supply's low level of contamination miqht exist, it was
determined that the implementation of an initial remedial protective
measure to protect the public until the implementation of a
lonq-term remedial measure, would be prudent. The initial remedial
measure, althouqh protectinq public health, will not protect the
environment from releases from the landfill.
-Biota Threat
-
Chemical analyses performed on species most likely to be consumed
by humans, fish, have not indicated any potential threats.
Bioloqical screeninq has indicated potent1al bioaccumul~tion of
at least two priority pollutant metals in tissue from other
animals analyzed (see Table 12). The animal population in the
landfill area, therefore, is considered a potential receptor by
virtue of direct contact and/or inqestion of the hazardous waste
constituents. Predators of these lower species should also be
considered potential receptors, by virtue of the potential for
bioconcentration.
Several bare spots exist on top of the landfill area where surface
contamination has apparently prevented veqetative qrowth. A
review of color infrared photoqraphs of the entire site, however,
do not reveal.overall stressed veqetation as would be indicated
by relative loss of infrared reflectance.
. .
-------
....... .. -AI. CllllC8mAn- III .....m - ..-.m llGUI.aa. n'.L lOa. -.aa
. - ..... ..... - (8....... "..,........t
8...1- .. 8tatl_"
j . I: j . I:
Id1&a 11'-'8&1 MAW Ia:JUa 11'-'11, .AlIW
(....... ... (...u.. Itt e...u.. ftt (....... lit
. ~.... .nJ (1.1 nJ .17' (I.. n.
; ,I
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'''1 e".t .7., .... I" ."1 .... I"
........ --... ,....... .. ... ft .w. I. ... .'''1111 .w. e... ,..... '-llt. I. .... .....,
.11.. II" --........... ., ........ ... ...... au. ..... 'M ...w ....,w... ....... ....
.............. ..w. ..... 'M ...w "'law.... .......
- "'11... "''''1.. - C.. ...........
I'.U- ft
j . , . . I . . J
......
..r... ......... ....w .........
Ia:Iib "'-1", MIW "II '''''211 "II .....". Ilm1 -=m .... ..-1" ...
el'."" II' (I...... II)
.1" .17' " '1 II III .u. . ..a.
."1 .- III .1 It ... . . lie
I." I." . II .1 II' .Ia . lie
' . .. ..,......
:. ., ...........
altall.... j
j . I: . . I . .
.........
I..... ......
........ ....-., ...... ...,.....
Ia:J1&a .....- jlJJIl .DI-u. '88-11 Ilm1 ~ ..,.. .8-Itt ...
.1...... lit el...... II)
.It. .17' al, as 1.1 aN .J7 .Ut "It
.. 1.11 .111 lal It II .11 .1' . IIr
.. '.11 ..11 III J.' ... as .11 . IIr
. . ., ......... ,. 12
IIr . ... ...........
I , ..-- ~'--"'-"I'" ......,
-------
-37-
.Overall Threat Potential
With subst&nces deposited in the landfill consisting of drummed
waste, oily and tarry sludges, and hazardous waste compounds in
other forms, the landfilled areas of the site are potential
sources of contamination. Although the landfill as a whole must
be considered as a potential source of contamination by virtue
of its contents, the landfill may be only a .passive. source of
contamination in that it does not appear to be generating a
substantial volume of leachate.
Although the subsurface and surface soils and waste are highly
contaminated, ground-water analyses suggest these contaminants
are not extremely mobile and are not migrating readily from the
landfill area. Also, river water samples collected adjacent to
the landfill do not reveal gross degradation of water quality.
Although a relatively .passive- contaminant source, the landfill
as a whole must be considered a serious potential source of
contamination by virtue of the hazardous substances deposited in
the area. Buried drums in the landfill may be considered as
potential point sources of contamination of the ground water,
the Genesee River, and other media. Chemical analyses of the
drums sampled for the Phase I RI reveal a variety of hazardous
waste compounds, many of which are carcinogenic. Geophysical
studies suggest that many more drums may be buried in the
landfill. The condition and content of these buried or near-
surface drums have not been ascertained.
.
Because the landfill area is partially fenced, direct human
contact is restricted. The most significant threat from the
landfill would be from flooding or failure of the landfill slopes.
Failure of the landfill into the Genesee River would have a
serious negative impact on public health and the environment.
Although gross contamination of the air medium has not occurred,
the potential for localized, and perhaps harmful, organic compound
vaporization does exist. Drum waste samples and surface soil/sediment
samples from pools atop the landfill have shown total volatile
organics concentrations exceeding 2,000 ppb at several locations
in the landfill area. Volatilization of these compounds should
be considered as a potential contaminant migration mechanism, and
thus a potential threat to the local population.
-------
-38-
Enforcement -
In 1969, the Sinclair Refining Company merged with the Atlantic
Richfield Company (ARCO), identified aa a potentially responsible
party. EP~ began discussions with ARCO in August 1982. On
January 6, 1983, NYSDEC and EPA met with ARCO to discuss measures
to prevent further erosion of the landfill by the Genesee River.
As a result of that meeting,-on January 21, 1983, ARCO removed
drums that had washed out of the landfill. EPA met with ARCO
again on January 31 and Pebruary 7, 1983 to discuss, further,
erosion control remedial measures. The RI and PS were also
discussed at the Pebruary 7th meeting. Because ARCO had not
committed to further measures needed to prevent additional
landfill materials from entering the Genesee River, or to any
other cleanup activities at the site, a notice letter was sent
on March 7, 1983. That letter discussed NYSDEC's and EPA's
intent to conduct the RI, PS, and initial remedial measures to
prevent further erosion of the landfill. The State subsequently
expended its own funds to construct a dike as a temporary protective
measure. After further negotiations with NYSDEC, ARCO contributed
the funds to strenqthen and raise the dike and to reimburse the
state for its prior dike-related expenditures.
It is EPA's and NYSDEC's intention to offer the implementation
of the remedy to ARCO. If it appears that ARCO is not willing
to implement the remedy, or if these negotiations are fruitless,
then EPA may consider the issuance of a CERCLA S106 Administrative
Order for the implementation of the remedial action, or EPA may
initiate a cost recovery lawsuit at a later date.
Alternatives Evaluation
The primary objective of the FS was to evaluate remedial
alternatives to identify a cost-effective approach consistent
with the goals and objectives of CERCLA. A cost-effective
remedial alternative a. defined in the NCP (40 CPR 300.68j) is
-the lowest cost alternative that is technologically feasible
and reliable and which effectively mitigates and minimizes damage
to and provides adequate protection of the public health, welfare,
or the en~ironment.- The NCP outline. procedures and criteria
to be used in selecting the most cost-effective alternative.
.. .. _. .~...,. ',.'. ':' .... .
. '. .
"':'" ....,. - #~--~;~.~~~';"~~io:"«.;:':':":- ~'''' .;.~ ~:.' ; .:-t-'~,,;,;>,..
-...i>:," _...~.. .
.. .
'P"'-""--
-------
-39-
The first step 1S to evaluate public health and environmental
effects and welfare concerns associated with the problem. Criteria
to be considered are outlined in 40 CPR Section 300.68(e) of the NCP
and include such factors as actual or potential direct contact
with hazardous material, degree of contamination of drinking
water, and extent of isolation and/or migration of the contaminant.
The next step is to develop a limited list of possible remedial
alternatives which could be implemented. The no-action alternative
should be included on the list.
The third step in the process is to provide an initial screening
of the remaining alternatives. The cost, relative effectiveness
in minimizing threats, and engineering feasibility are reviewed
here. The no-action alternative should be included for further
evaluation when response actions may cause greater environmental
or health damage than no-action responses. A no-action alternative
should also be included if it is appropriate relative to the extent
of the existihg threat or if response actions provide no greater.
protection.
Prom the evaluation of the data and information on the nature and
the extent of the contamination associated with the Sinclair
Refinery site landfill, the following objectives were established
1 .
maintenance o~ a safe, uncontaminated drinking water
supply for the village of Wellsville
2.
protection of Genesee River water quality and associated
uses (potable water supply, fishing, recreation) from
contaminant releases
3.
protection of local ground water, which discharges to the
Genesee River, from contaminant migration
4.
prevention of direct contact between humans and animals
with contaminated site materials, including soil and leachate
s.
avoidance of site inundation from increased river flow
ass~c~ated with a 100-year storm event
6.
-------
-40-
Remedial respanse criteria for the landfill were divided into
criteria for ground and surface water and criteria for subsurface
and surface soil.
Water-related remedial response criteria were based upon published
State ground-water standards and ambient water quality criteria
for potable water supplies_for the constituents found in ground-
and surface-water samples at the site (see Table 13). In general
terms, contaminated ground water beneath the landfill site and
surface water within the site and the Genesee River will be
controlled such that perimeter monitoring wells or river samples
show total organics concentrations of 100 ppb or less.
Soils criteria were calculated based upon State ambient water
quality criteria, compound solubilities in water, and 80il/water
partition coefficients. ~hese calculations generated the soil
concentration of an organic compound causing a ground-water
concentration meeting the ambient limit. Table 14 lists, for
each organic contaminant found in the soils medium, its water
solubility, partition coefficient, and 8ubsurface soils criteri~.
Subsurface and surface soils at the site will be controlled in
such a manner that contaminant levels in excess of the listed
criteria do not runoff or otherwise contact plant or animal
life.
with these objecti~es and response criteria in mind, a list of
feasible remedial technologies was developed (see Table 15).
Technologies identified as having the potential to meet the
remedial response objectives were subjected to a two-step
evaluation process. The first step consisted of an initial
screening of candidate remedial technologies based upon cost,
environmental impacts, and engineering considerations. The
second step consisted of a more thorough evaluation of specific
alternatives.
/
-. . ... --..
. ... "'---"""'-"'" II"
~.-.'- -'-------~~'~'.-F1' ~
.4'.'~.~,!
-------
"'8JWU14
REMEDIAL CRITERIA '0. CROUND WATER AND SURFACE WATER
criter1a(l)
'DDbl
..J!gtu (. )
Priority Volatila Or9anic.
-benzene
-chlorobenzene
-tr8n8-l,2-dichloroathylena
-1, 1,2, 2-tatrachloroethana
-toluene
-vinyl chlorida
-l,l,l-trichloroathana
Priority 8a.e/Nautral Extractablea
-fluoranthena
-bia-(2-ethyl hexyl) phthalate
-fluorena
-D-n-octyl phthalate
-2-.ethyl napthalane
-napth81ene
-phananthrene
-pyrene
Priority Acid Extractabla.
-2,4-di.ethylphenol
Cyanide. and Phenolica
Total Cyanida
-Total recoverable phanol.
Priority lIatal.
er.enic
copper
nickel
.eleniua
.Uvar
zinc
Priority pe.ticida.
-chlordana
-toxaphene
-endrin
-heptachlor and heptachlor apoxide
-4,.'-DDD and 4,4'-DO£ .
PC8.
lIonprlority Volatile Or9anlc.
-cyclohe.ane
-..thylcyclObe.ane
-.athyl-l-pantena
-),4,4-trl..thyl-4-pantana
-xylene
liD
5
(50)
,0.3
10
1
(50)
It
C
F
E
A
E
F
0.2()
0.6
(50)
(50)
(50)
10
(50) (3)
0.2
C(b)
8(a), C
F
,
,
I
F
C(b)
1
It, I
5(2)
1
C
1<, I
5
4.0
1.1
1.0
0.1
'0
C, D
8(b), C
8(b), C
8(a), C
C
C
0.004
0.001
0.002
0.001
0.001
leb), C, D
I(b), C
I(a), C, D
lea,b), c, D
8(C), D
E
.0095
(50)
(50]
(50]
(5(\)
(50)
,
.
,
,
,
Nonpriority ".e/Nautr.l
-doeo.ana
-eico.ane
-haptadacana
-haxadecana
-octadecane
-P' '.cana
-. -i.athylbenzane
. -4-hydroxyl-2-pantanona
Extra=ablea
(50]
(50]
(50]
(50)
(50)
(50)
(50)
(50)
,
r
r
,
r
r
,
r
..cel
Aabient Water Quality C~it.ria fpevi..d: .ay 198.)
New York State Depart.ent of Environmental con.ervation
NO - lIot datactabla
- - sua of the.e coepound concentration. ahall notaxcaad
100 ppb.
(50] - Li.it derivad u.lng Depart.ent of Haalth ,enaral or,anic
che.ical fUidaline (50 ppb). '
(1)
12)
(3)
critaria repr..ent. tha ao.t .trln,ent 11.it. vlthin the Nav
York Stata Critaria for Huaan and Aquatic CIa.. Watar..
rrae cyanida. I
Thi. critarion al.o applia. to tha .ua of benz(a)anthracana,
benlofluoranthana, benlo(a)pyrana, chry.ene, fluoranthane,
Indano(1,2,3-cd)pyrana, .athylbenl(a)anthracena, and pyrane.
Alpha nu..ric deai,nationa froe NYSDEC Aabiant Watar Quality
criteria docuaantad a. follOW. I
(.)
A.
Or9anolaptic (aquatic lifa concarn) - V.a KA30CD/IO flow to
calculata 30-4ay avara,a affluant 11.it.
critarion baaad on aquatic conca me a. date rained by other
a,enciaa aa follow.1
a) Internation.l Joint coaai..ion (IJC)
b) EPA
c) 40 CFR Part 129, Aabiant .atar Quality Critaria
To.icity to aquatic life - U.a 1lA1CD/10 flow to calculate
...i8\18 daily affluent li.ite.
,i.h flaah con.uaption - V.e IIA)OCD/I0flOW to calculate )0-d8Y
avara,e effluant li.it.
Cancar rlak calculation. (huaan haalth concern.) - U.e IIA)OCD/IO
flow to calcualte 30-day avara,a effluant 1i.it.
DOH ,anaral or9anic fUidallne for protection of huaan health -
U.a 1lA30CD/10 flow to calculata 30-day avara,e effluent li.it.
crltarion ba.ad on huaan health concern. a. detarainad by other
a,encie., a. follow.: (U.e IIA)OCD/IO flow to calculata )0-d8Y
avara,a affluant li.it a.capt for nitrate vhere an 1lA7CD/lO flov
to calculate a .axi.ua daily effluant li.it viII be u.ed.)
a) EPA
b) World .ealth Or9anilation (WHO)
c) lIational Aca4e.y of scianca. (liAS)
or;anoleptic (huaan bealth concerna) -U.e IIA)OCD/IO flow to
calculate )O-4ay avera;e effluent li.it.
I.
C.
D.
E.
,.
G.
I.
It.
CIa.. GA ,round-vatar quality .tandar4 froe 6NYCRR Part 70),
ba.a4 on be.t u.e a. .ourca of potebla vatar .upply.
Table
f-.
t
,:
11
! .
"
;j
. t.,
t.,
(.
.,'
'.
r..
, ,
~ f
,I
-------
REMEDIAL CRITERIA FOR IOItS
lolubUU:y in parU Uori
co!!!~ounc! Water '~e!!\1 Coefficient Criteria tcc~}
Priority Volatila Orvanic.
~anlane '700 120 24
chl oro~nlene 500 143 36
~na-l,2-dichloroethylane 600 130 325
l,l,2,2-tetrechloroethena 150 356 5
toluene 500 143 '72
vinyl chlorida 1.1 .,043 207
Priority aa.e/Meutral Ertract~la.
fluoranthena 0.215 ',062 t1
Priority Acid Extractabla.
2,4-di.ethylphenol
cyanidea and Phanolic.
'rotal cyanide
'rotal recover~la phanol. U 31'7 111
priority Metal.
ar.anic fI/A fI/A 15,000
copp.r ff/A II/A ',700
nickal fI/A II/A 26,300
.elaniua ilIA ff/A liD
.Uvar MIA M/A 600
linc II/A II/A 53,000
;~'rior1ty Pe.ticide.
chlordana 0.056 21,306 "
toxaphene
andrin an~ heptachlor
heptachlor
epoxide
4,4'-DDD 0.16 11,'60 0.6
.,.'-DDE 0.0013 161,'714 8.'
PCla 0.04 25,137. 12.1
Konpriority Volatile orianic.
cyclohexane U 538 1.345
.ethylcyclohexane 14 1.000 2.500
.ethyl-l-pentene 71 UI 115
),4,4-tri.ethyl-4-pente~e
xylene 175 255 637
Nonpriority aa.e/Neutral Extractabla.
doco.ane
aico.ane
heptadacana
haxadacana
octadacane
pantadacane
l,3,5-tri=ethylbenlene
.Uoxane
4-hydroxyl-. .ethyl-2 pentenona
hexadecanoic acid
0.001
0.004
0.007
0.002
'72,.,10
'0,'13
66,165
133,171
181.150
227,401
167 ,163
332,145
Table 14
..' ".'" ..,. ... ,-,".. .., ~
. .-... ............-._. -".. ,; .'n...~_.'''''~'''''''' ~._-
. -'''-'-'''-
-------
SUMMARY OF AVAILABLE REMEDIAL TECHNOLOGIES
A.
-
Source Control Measures
B.
a. Wo action
b. Surface grading and revegetation
c. Collection and treatment of contaminated
d. Excavation and disposal
e. Excavation to on-site secure landfill
f. In-8itu treatment of wastes
1. incineration
2. solidification
3. biological destruction
g. Installation of impermeable barriers
1. slurry walls
2. surface cap
3. complete encapsulation
h. Landfill bank stabilization
Off-Site Migration Control Measures
a. Wo action
b. Ground-water controls
1. 8lurry walls
2. pumping
c. Ground-water recovery and treatment
d. Dredging of contaminated river sediments
e. River rechannelization (flood protection)
surface runoff
-------
-44-
Because of the-meandering tendencies and the signifcant flood
potential of the~enesee River, any remedial containment measure
implemented at the Landfill site might be subject to flood
inundation and erosion unless protected by a bank stabilization
or channelization measure. Therefore, technologies to protect
the landfill river bank from flooding were considered in the
development of alternatives.
From the list of available remedial technologies applicable source
control and off-site migration control remedial measures were
formulated and were sUbjected to an initial screening in terms of
cost, environmental impacts, and engineering considerations.
Source control measures evaluated included:
4.
s.
6.
No ac1:.t on
collection of contaminated runoff with on-site treatment
collection of contaminated runoff with publically-Owned
Treatment Works (POTW) treatment
collection of leachate with on-site treatment
Collection of leachate with POTW treatment
Waste and contaminated soil exc.vation and disposal at
existing secure landfill
7. Waste and contaminated soil excavation and disposal at a
new secure landfill
8. Waste and dontaminated soil excavation and on-site disposal
9. Waste and contaminated soil excavation and incineration
followed by residue disposal on-site
10. Waste and contaminated soil excavation, followed by
solidification and on-site disposal
11. Waste and contaminated soil excavation, followed by
biological destruction and on-site disposal
12. In-situ waste and contaminated soil solidification
13. In-situ waste and contaminated s01id biological destruction
14. Surface grading and revegetation, CELA and SLA
15. Surface grading and revegetation, SLA relocated to CELA
16. Installation of perimeter slurry walls, CELA and SLA
17. .Installation of slurry walls, SLA relocated to CELA
18. Installation of RCRA surface cap, CELA and SLA
19. ~~stallation of RCRA surface cap, SLA relocated to CELA
20. Landfill bank stabilization with modified slopes
21. Landfill bank stabilization with exi8ting slopes
22. Landfill bank stabilization with structures
1 .
2.
3.
.. .... ." .'
-------
-45-
Off-site mitigative controls evaluated inc~uded:
1. No action
2. Installation of upgradient slurry walls
3. Installation of upgradient pumping system
4. Ground water recovery, on-site treatment
5. Ground water recovery, treatment at POTW
6. Dredging of contaminated sediment, disposal in on-site
secure landfill
7. Dredging of contaminated sediment, off-site disposal at
existing secure landfill
8. Dredging of 'contaminated sediment, off-site disposal in
new secure landfill
9. River flow control with open channels
10. River flow control with dikes
11. River flow control with enclosed channels
12. River flow controls with groins
13. River flow control with check dams
Tables 16 and 17 summarize the initial screening of remedial
technologies, listing summary conclusions of their public
health/environmental impacts, feasibility and costs. Costs are
not listed for those technologies rejected on the basis of
insignificant add~tional public health or environmental protecti~ .
poor technical executability, or poor reliability. Technologies
rejected on a strictly non-cost basis include:
.Collection of leachate/on-site treatment
.Collection of leachate/POTW treatment
.solidification of waste/soil
.Biological destruction of waste/soil
.In-situ solidification of waste/soil
.In=situ bio-destruction of waste/soil
.upgradient slurry walls
.--..- -- ..
. .---- '." :....:. .:.."(" --"t'~'
"";'&1. ..t~ .....:~.:
-------
('
1IJIIM'l at IRJrIM. IDEBUtG at RDEDDL B(JItII.mJ!S
I'F.ASm D.1ft ~1IIGNmJIZ
RllLIC 8r.N." 'n:aot1CM. ams
--.wn:;y IJIIInnuurIN. 1IIfIIWY" _.-..an.1ft II!WW1IftR D.. rPI l1li. DR D.1'ft' 1r.urr.u.lNRJAL 0 .. lit
A. SI8Z
-------
lUlU! or IIrr... DraUIG " RDImIAL 'J!XJIIUI;JP3
1EJ.UID.J'ft --'OP-tIICNlMZ
DLIC IIIIIL'IIV TEOINIQL cmrs
.......1r.Y IIIIrIlOllll!tftN. AlfJlW"PmIII DIR.IIJ8I'IM II. I'I'Y ElEaJ'lMII. I'I'Y "IMII.I'I'Y fmPI'DL/NHW.. 0 . 10
I
A. .... CI8IIa...... (QlntJIUId)
Ld.5 Biological dtauc- SiCJdficant 8d11iUaal _..abl8 Not eJ8aItabl8, 8Jt reliabl.8 IIat OOaalat8d
tiC8\ at vate 8nII ~Cltec:UC8\ cbt to wut.e I
8)11, 41p)88l in ~ble -.- illpcU dw'8CtedaiC8
on-lli t8 .CIII8
I..Ul
A...l Irt-llitu ..Udtfic:a- 1Jait.s 8dlBtJaal _..abl8 Not eJ8aJt8ble, RIt reliabl.e IIat OOaalatect
tiC8\ at .... 8nd ~ot.ectJcn cbt to wute
..u dw'8Cteria1C8
A...2 Irt-lli tu biological IJaited 8dlBUaal "..ubie Not aeaJt8ble, RIt reliable IIat OOaal8ted
d!aructiC8\ at ~atKUcn Ale to wute
vat. 8nd 8DU ~bl. --- dw'8Ct.ria1C8
Upc::U
"f.lCe) lurfeae ,,8dlng IJ81ted 8dIB Uaal 1Ipl..abl8 18aabl8 8111ab18 .1,006,0001. 30,000
8nd r..taUcn, ~CIt.8ct1cn
OILA 8nd &A
A. f.l Cb) Surf.. gr8dlng IJ81ted 8dIB Uaal _..able 18aItab18 8I1111b18 82,000,000/' 30,000
8nd r.egetaUC8\, &A ~CIt.8ct1-
relocated to OILA
A.f.2(.) 1nIta11at1- at 1J81t8d 8CIII1 tlaal _..abl8 18aItab18 leUabl8 81,000,000/f 30,000
..d8lter8l_ry ~CIt.8ct1-
vall8, OILA 8nd &A
A. f.Z(b) 1nIta11at1- at IJ81ted 8dd1t1aal 1Ipl..abl8 18aUb18 811iab18 P,OOO,OOOI' 30,000
8l_ay -.118, !LA ~ot.ec:ti-
relocated to OILA
A.f.3(.) 1nIta11at1- at Llldted 8&I1Uaal 1Ipl-ubl8 1IIIa*abl. 8111ab1. ",-,0001. 30,000
IDA ...fACII cap, ~CIt.8ct1-
C!LA 8IId &A
..f.JCb) 1nIta118t1- at IJ81ted 8&I1Uaa1 1Ipl..abl8 18aatabl. 8111ab18 ",000,000/ 30,000
IDA ..f.. cap, &A ~CIt.8ct1as
relocated to aJ.A
"t.l r.-.Ul tanII L181ted adlBUaa1 1Ip1881t8b1.e l8aItable Reliable ",000,000/' 1,000
a.abil1a.Uan witb p-otectias
"'4fi8d 8lop. Po88ib1e Idrer- i8pc::U \6
T6
-------
/
IIJIIINT or DlI7UL ID!8tDG at RIXDUL mJIII,mllS
I'EASmn.rn ClllD-OP-fIIGIImJIZ
IUUdC BDl.'" ft'XJINlQL 0J6"I'S
--.,...rt:Y .,nnnBI'IN.. 1IIIf'InIn''' __..-JIftIBD. rn nPnrrM ft..1Pr RI!I.URD.WY '~ITM./AIMW.. 0 . IU
~. IGGT .\1'01 IMIGIIIIII
CDr'-a. -
I." .tIt acUCII 188ent1811y lID protACt1C11 ~.-abl. I8G1tab1. IIIIt nll8bl. ,0 /. 30,000
1Qu1b1. --- UpcU
I.b.l 1nItA118t1C11 ~ lMi9'1fiCllllt ecMitianal QUHUaable, . I8G1tab1. Qul8t1aabl. IIIIt O8laal8t8c1
upgradient ai-II prote«iea e.. cmpued - to mting
ofall. to lID acUea)
Jo881b1. --. t8pcU
1.b.2 tnat.a118t1C11 of ln8i9'1fiCllllt ecMitianal oueat1C818ble, l8aatable Qulaiaab1. IIat O8laalat.ed
\IpJIadiant IUlPng prote«iea - to a1 ting
,.It- PQ88ibl. ..,.. t8pcU and 58adtUng
LOo1 aCUIIII"'~ ln8i9'1fiCllllt ecMitianal ~8ft,Ib1. I8G1tab1. II.Uabl. . 2,000,000/' 150,000
~8IJ, --III.. protec:tJea
:.......
LOo2 ~CUIIII vate~ ln8i9'1fiaaa ecMiUanal 1Ip1881t8b1., 18GItab18 1111 UbI. . . 1,000,000/' 150,000
naJ¥8IJ, u88l88lt protec:tJea w/faI!1I oonalu",
at JOBr
L4.1 lkedlJing of C1CIM8- In8ifldfioaa ecMitianal 1Ip18ft,1b1. lIIaIt_hl. 1II118bl. IIIIt O8laalat.ed .
1...t.8d 8d1.881t, prot8d:iea
dilp0881 in ..iii..
-~. 188dfUI
8.4.2(8) Ikaclging of eDIt'" Jn8ifldfloaa adII1t1anal 1Ip18ft,1b1. I8C111t8b1. III1Ub1. IIat O8laalat8d
t81n1t.8d _di88*, protec:tJea
'1f f-mte di"", at
.!ldlttl.~.
1"
Lcl.2(b) Ikaclging of ClIft- In8ifldfioaa ecMitianal ()Jnt1aabl., O8ltiaab1. 1111iab1. M O8laal8t.ecJ
t81nIt8cJ _di8eM, prot8d:iea - to a1Ung - to lilting
IIff-a1te ...... Ia
raw .018. 181dUI
8...1 ... DOl aliUal Lbdt.ecJ adIIi tlanal 1Ipl..abl. 1Itaatab1. 11111"'. t1t,OOO,OOO/' 1,000
'11th ... cNma1. pot8d:iea
IbUible -.. t8pcU
8...2 ~.. 001 aliUal LIalt.e4 add1 tlanal 1Ipl..ub1. i!.Qub1. ...U.ab1. 510,000,000/' 1,000
with ... protecticn
IbUible _et. Upd:8 'Table 16
-------
TECHNOLOGY SCREENING SUMMARY
'.
-- .---------- ..---- ------ ---.----- -~-_.._---_..- -- ---- ....--..-------
lANaolll BANI( STABILIZATION RIVER FLOW CONTROL
-- C-'" -...- --~.-' ---- - ------ -- ------ ...---
1Nil'ltCt1. .,.. ,........... ... ,.....,,-.- ......r..-L .....u to""''- "..,.. t."1 .... I""
. ,....... U''''.'''' _""'''.,
.- -- ----.-. -- ._-- .--.--.---.- ----.- ---...--- --"--
5~
n .... .... ....".. ,... en. ....to" ,.. ....1.-...... .,.. ... r'''''''''' ...r........" ...
... ... ..... C..... ,.,tI_C88II.' ...,."..,....- c-te.,...."'. ."._tt."'''''''.
U c.,..,
'
-.-------.-. ---- .------- ~---- ,----- ~_.-
~ ~
C ........ ...t. ...t. ...,.......,........ te.. ...... ",, !... 1_. .... ,'\ . ".1' ...... .... .,.. '''' ..-
! .... . ""'1""'" .. ....- ......... ,.-- . ........,t.. It... ..., ...1. ...t. "" .... ....
a: ...-....,....,.",
w i ..- . ............
... . ----..--- ---
a: ---- -- .-..------
.., II
~ ........ 1."""- ..,...., .....,.,. .........U'" .....e..-."" .......e ........1- '''''''''.'''''' ",'_'1 .......1- ,...-"- ......
a- .. ........... """'''-' ..... ...... ..... ...... ... ,,"'-' ....."'- .,. ........... ....."-
z 51
1:
~ ---' ~. -.------ ------.
... .
I! .......' .. - c...'''' I. ... ....... I... ,..,1...,.- c..tl... ..... C818t'''' .... --...,.,. II" CIII8"'" .....
.....-..- ..... c........,.-...... ~......_...- c-",,,".""- t. 'hi tII....II. ~.....II."'" «'--.....-...- c-...............
...-
--
~! ~,t..""'- ........"......- .........,n.-el ...._ur......' ""_"0-' ",..M'I' .,......" ...._.n.....'
I . ...,.".... ..... .. ............... ....... "'M" ..,.... . .......
:>- ,.............-. ,......... ....-. ,..,....., ....-.
.... I ..........." ,......'" ...... .
.!: ......... ...... ..... ........ ..........." ..... ........
~~ -. ....... .... .... If -_......, .... ... ............ "--",,,,,,.
........1L.8IoI M)M-'I.'" ..- ......-. .. .-
~
lz ............ .... ..,..... .... .... ..... .. ...,......
I -,,-"1 '" &81"""''' ......,.. ... Cae"''''''' .-... ...,....
li "'- ..,.... "'" . .....- ..........
... ..... .... .... ........ .... ..-
I ....'..
........ ... .... .-... .... .......,.. .... .......," """-' ...-...
-'00 "'_"' ..........,..... .......,
.. --..-
-
,......... "........ "''''',''
c l .............. ~.......,- "","."M8
a .
~
5 il
~
8 Ii ..... 8'''.' "".'
Table
-------
-50-
-Landfiil bank stabilization with existing slope
-Landfill bank stabilization with a structure
-upgradient pumping system
-Dredging sediments/on-site disposal
-Dredging sediments/off-site secure landfill
-Dredging sediments/new off-site secure landfill
-River flow control with enclosed channels
-River flow control with groins
-River flow control with check dams
A number of technologies were rejected because of their high cos~-
to-benefit ratio. That is, these technologies had costs generally
several times or an order-of-maqnitude qreater than other
technologies (or combinations of technologies) that achieved
similar public health and environmental protection. Technologies
rejected on this basis include:
-collection of ~unoff/on-site treatment
-collection of runoff/POTW treatment
-Excavation/off-site secure landfill
-Excavation/new off-site secure landfill
-Bxcavation/incineration/on-site secure landfill for waste/soil
-Surface qradinq/SLA relocated to CBLA
-Slurry walls/SLA relocated to CBLA
-Gro~nd water recovery/on-site treatment
-Ground water recovery/POTW treatment
-------
-51-
Colle~ion and treatment of contaminated runoff and ground water
were rejected since their order-of-magnitude installed costs were
comparable to that associated with surface grading, revegetation,
and slurry wall installation, yet had significantly greater
operation and maintenance costs. Excavation and redisposal of
waste8 in off-8ite 8ecure landfills was rejected primarily due
to significant (order-of-magnitude) cost a8 compared to Resource
Conservation and Recovery Act (RCRA) capping and 8lurry wall
installation to the limiting clay aquaclude. Construction of a
new off-site landfill was also rejected becau8e siting problems
were considered to have the potential for long implementation
delays.
It should be noted that rejection of all off-site disposal
technologies in the screening process makes it impossible to
consider a remediation alternative -specifying off-8ite storage,
destruction, treatment, or secure disposal of hazardous subtances
at a facility approved under RCRA.- The 8creening make8 it clear;
however, that off-site disposal of Landfill site wa8tes is both'
extraordinarily costly.
The RI and follow-up work indicate that leachate generation and
contaminant migration via the ground water to the Genesee River
appear not to be a significant pathway. Thus, those technologies
remaining are not s~ecifically related to leachate or ground-water
control. Purthermore, since no ground water plume of contamination
is identified at this time, it is believed that off-8ite contaminant
migration is primarily a function of surface runoff caused by
periodic rainfall and Genesee River flooding. Therefore,
technologies that 8tress this pathway of contamination, such as
surface treatments and river contro18, appear most appropriate
for further consideration.
, .
Table 18 provides a listing of those technologies that survived
the 8creening process. The8e technologie8 were combined to
generate alternative remedial systems (see Table 19). These
systems were then evaluated in order to recommend a cost-effective
remedial 'alternative.
The narrowed list of remedial alternative was furthered evaluated
according to the following criteria. fea8ibility to site-specific
conditions, reliability, operational requirements, implementation
-------
~
TECHNOLOGIES SURVIVING INITIAL SCREENING
A.
SOURCE CONTROL MEASURES
No action
Surface grading and revegetation, CELA and
SLA
Installation of perimeter slurry walls, CELA
and S LA
Installation of RCRA surface cap, CELA and
SLA
Installation of RCRA surface cap, SLA
relocated CELA
Landfill bank stabilization with modified
slopes
B.
MIGRATION MANAGEMENT CONTROL MEASURES
No action
River flow control with open channels
River flow control with dikes
-------
aERIDlkL kCTIOR ALTEaRATIVII
klternative
.u.ber
UBIPk policy aeference
110 action
It
klternative a.ceeding applicable
public health/environ.ental
crlteria
III
klternative attaining applicable
public health/environ.ental
critarh
",
IV
klternative attaining applicable
public health/environ.ental
criteria
V
klternative attaining applicable
public health/anviron.ental
criteria
c'
j
\
.'
;}'
"I
kltarnatiye attaining applicable
public health/environ.ental
criteria .
.
, '
.'
klternativa attainin9 applicable
public health/environ.ent criterie.
i
VII
."#.
..
klternativa .ini.iain9 conta.inant
.i9ratiOn an4 protectin9 public
bealth/environ.ent but not
attaining applicable criteria
.,'
9111
",
,,"
./
;
,,':
~ ;1
, :1
;:1
~
co.ponent Technoloqiea
110 action
Inatallatioo of peri.eter
alurr, .alla, CILk and ILk,
loatallation of aCak aurface
cap, CILk a04 ILk. ai"er '
flow control ~ith open channela
Ifull channel~aatiool.
10atailatiOo of peri.eter
alurr, ..lla, CELk an4 ILk.
10atalla~00 of a cia, ca.
CILA an4 ILk. aiwer flow
control with 4i-ea (partial
channeliaationl.
InatallatiOo of aca. aurface
cap, CILk a04 IL..
aiver flow eootrol with opeo
chanaela (full chaonaliaatiJDI.
Inatallation of aca. aurface
cap, CIL. a04 ILk.
aivar flow control with open
chaooela (partial ehaaoeliaatioal.
aaloeatioO of ILk oato CILk.
laatallation of acak aurfaca
cap. CILk.
aiver flow eoatrol with opea
chaaaaia (partial cbaaaaliaatioal.
Inatallation of cia, clap, CILk
aad ILk.
aivar flow eoatrol with di-ea
(partial chaaneliaatiool.
laatallatioo of cia, cap, CILk
aa4 ILk.
Lan4fill baa- atabiliaatioa with
8Odifie4 alopea.
Ta b 1 e
-------
-54-
According to the NCP, a total cost estimate must also be considered
for remedial actions and must include both construction and annual
operation and maintenance costs. These costs are estimated for
the alternatives under consideration. A present worth value
analysis was used to convert the annual operation and maintenance
costs to an equivalent single value. These costs were considered
over a 20-year period at a .10 percent discount rate and 5 percent
inflation. .
.Alternative I
No Action, Alternative I, would involve no remedial actions on
any of the affected media at the Lanfill site, and no controls on
runoff, bank erosion, flooding, or leachate generation. Access to
the Landfill site would be completely controlled by the erection
of a chain-link fence around the landfill perimeter. Existing
perimeter ground-water monitoring wells would be utilized for
long-term mq~itoring.
The only operation and maintenance requirements associated with.
this alternative are those associated with periodic inspection
and repair of the perimeter fence and regular sampling and analysis
of ground water from perimeter wells.
Because the soil cover of the landfill and the buried wastes are
relatively impermeable, rather than perolocating through the waste
to yield contaminated ground water, most rainfall travels over the
surface of the landfill, carrying surface contamination along
with it, either running off into the Genesee River or pooling at
low points on the landfill. Onder no action, a rise in river
stage or a severe storm could allow transport of these pooled
contaminants into the Genesee River. In addition, failure of
the dike currently protecting the CELA could allow the release
of waste materials from the landfill into the river.
..
-------
-55-
Although no action is feasible and has minimal operational
requirements, it offers little protection to public health and
the environment. This alternative would only control direct
access to the Landfill site. It would do nothing to control
continued runoff of contaminated soils, bank erosion or flooding.
.Alternative II
Alternative II, slurry walls, RCRA cap, and full river
channelization, combines two source control measures with a
migration management technology, yielding maximum public health
and environmental benefits. This alternative would eliminate
runoff of contaminated surface soils, prevent bank erosion and
Landfill site flooding, and fully isolate contaminated subsurface
waste, soils and ground water from the surrounding environment.
The entire Landfill site perimeter would also be fenced.
This alternative includes the installation of low permeability
3-foot wide bentonite clay/soil slurry wall around both the CELA'
and SLA to an average depth of 35+ feet beneath the CELA and 20+"
feet beneath the SLA. The slurry-wall would be cut approximately
five feet. into the clay aquaclude so as to provide a continuous
ground-water containment system.
The RCRA cap, incorporating a 2-foot clay liner, geofabric,
1-foot witness layer for leak detection, 1.5 feet of sandy soil,
and 6 inches of top soil, would be designed to prevent essentially
all infiltration of rainwater into the landfills. Overlaying
the perimeter slurry walls, the cap would provide continuous
impermeable barriers around all sides of the CELA and SLA. The
cover would be placed after removal of exposed drums and all
vegetation, and the filling of depressions with clean soil.
Two leachate/groundwater .umps would maintain a hydraulic gradient
into the landfill., assuring the containment of contamination
within the slurry walls. The pumped liquid will be stored on the
Landfill site until sufficient volume is collected to remove by
tank truck for dispoal, or will be treated on-site or at a waste
water treatment plant.
'..
-------
-56-
This alternative also includes full channelization of the Genesee
River from the extreme southern tip of the Landfill site, 3,000
linear feet to the existing flood control structures below the
northern tip of the Landfill site. This relocation widens and
moves the river channel away from the Landfill site, provides
stable riprap banks along both sides, and eliminates the threats
of landfill erosion and flood" inundation (100-year flood protection).
Por full river channelization, 3S acres would be disturbed by
construction activities, requiring temporary sedimentation and
erosion control measures.
Because of the extensive channelization and the slurry wall
construction requirements associated with this alternative,
three construction seasons will probably be required.
Construction of shallow slurry walls and river channelization are
both feasible and reliable. Because of the full river channelization
away from the landfill along its entire reach, and the RCRA cap
and slurry wall, this is the most redundant, most protective
remedial alternative.
8Alternative III
Alternative III, clay cap*,slurry walls, and partial river
channelization, is similar to Alternative II in that it
utilizes fencing, surface grading/revegetation, slurry walls and
internal hydrualic control, however the surface regrading involves
a far less extensive capping than required by RCRA. Also, the
Genesee River controls are less extensive and cl08er to the edges
of the CELA and SLA than full channelization. Partial channelization
of the Genesee River would extend roughly from the southern tip
of the SLA to the existing flood control structures below the
northern tip of the CELA. This relocation would widen the river
*Generally, a clay cap utilizes 2 feet of clay and 6 inches of
top soil. But because the frost line is located 4 feet below the
ground surface in this area, to prevent freeze-thaw heaving,
which could have a detrimental impact on the integrity of the
surface seal, 3 feet of clay, 1-foot of soil, and 6 inches of top
soil were utilized for the clay cap.
-------
-57-
in two stages and move the river channel away from the Landfill
site, providing stable riprap banks along both sides and
eliminating the threats of landfill erosion and flood inundation
C100-year flood protection). The cap, under Alternative III
would not provide the level of protection from rainfall
infiltration that a RCRA cap would, however, this alternative
would provide slurry wall protection and would severely limit
rainfall infiltration, particularly in the currently uncapped
SLA. The cap, overlaying the perimeter slurry walls, would
provide continuous, relatively impermeable barriers around all
sides of the CBLA and SLA. .
To accommodate partial river channelization, placement of the
slurry walls and cap will require relocation of waste material at
some points along the perimeter. Also, excavation and handling
of hazardous materials will be required at the northern and
southern ends of the Landfill site.
Por partial river channelization, 28 acres would be disturbed by
construction activities, requiring temporary sedimentation and
erosion control measures.
Because only partial channelization is called for, two to
three construction seasons should be sufficient to implement
this alternative.
This alternative addresses all aspects of the Landfill site
problem and controls all pathways of contamination, providing
somewhat less protection to public health and the environment
than Alternative II due to the les8 redundant nature of the cap
and the less extensive control over the Genesee River. It still,
however, meets all Landfill site remediation criteria, and is
feasible and reliable.
.~. .
".:J" ".;;'" ."-" ".. . ';;:..".. .-
. .: ~;'~'~'.:"...'=;.:. . '~.-.
. "\....:' ..-:. .
.'
',. . ...~'., ;.
.' :.... .
,","w" .." ..,.-------...
.; r":t..- ...... :...-,-:..~..~ .: ...-..
-------
-58-
8Alternative IV
Alternative IV, RCRA cap and full river channelization,
combines a single source control measure (RCRA cap) and a single
migration management measure (full 100-year flood protection
river channelization). Its significant difference from
Alternatives II and III is the lack of slurry vall perimeter
controls. Elimination of slurry walls viii not produce the
effectiveness of this alternative, however, since, at this time,
ground water movement appears to be an insignificant pathway of
contaminant migration. RCRA capping will eliminate any surface
water infiltration and subsequent leachate generation, particularly
in the SLA.
The full channelization away from the landfill along its entire
river reach provides maximum protection from flooding. The RCRA
cap provides maximum protection from infiltration.
Because of the extensive construction requirement associated
with full channelization, three construction 8ea80n8 will probably
be required.
This alternative attains applicable public health and environmental
criteria, addressing the critical aspects of the Landfill site
problem, contaminant'migration via surface runoff, bank erosion
and flooding, but it does not control movement of ground water
under the Landfill site. The required technologies are both feasible
and reliable.
8Alternative V
Alterntive v, RCRA cap and partial river channelization, combines
a single source control measure and a single migration management
measure. Its significant difference from Alternative IV is the
use of partial river channelization instead of full river
channelization.
Under partial river channelization, excavation and handling of
hazardous-m~terials will be required at the northern and southern
-------
-59-
Two to three cons-truction seasons would be required to. implement
this alternative.
This alternative addresses the critical aspects of the Landfill
site problem, contaminant migration via 8urface runoff, bank
erosion, and flooding. It doe8 not, however, control the
movement of ground water under the site, and it provides less
flood protection than full channelization. The required
technologie8 are both feasible and reliable.
8Alternative VI
Alternative VI, consolidations of SLA wa8te on the CBLA,
RCRA Cap, and partial river channelization, involves two 80urce
control mea8ure8, excavation and RCRA capping, and a migration
management technology, 100-year flood protection via partial river
channelization.
Becau8e the SLA would be excavated and replaced with clean fill
under this alternative, partial river channelization of the
Gene8ee River would only have to extend roughly from the borrow
pit area south of the CELA to the existing flood control
8tructures, requiring about 1000-linear feet less riprap than
the partial river channeliztion described under Alternative III.
Bven though more cover material will be required to accommodate
the increased height of the CELA, resulting from the addition of
the waste excavated from the SLA, because capping of the SLA will
no longer be required, an overall 8avings of cover material as
compared to all the other alternatives will be realized.
Excavation of the 2.3-acre landfill to a depth of 25 feet is
technically feasible and reliable, however, it poses some risk
to the on-8ite worker8 and the local population. Bowever, with
the utilization of proper health and safety measures during
excavatin this shortterm exposure risk will be minimized.
P100ding and erosion ~uring the operation are also of concern.
Because the, waste will not be removed from the site, the risk to
the public associated with hauling hazardous waste from the site
would be elt.~nat.d.
. . .
- .
.. ... .'-- -.
,. -.._...~..t;.:...;, .~:"
.... "....' . "",- ';:',-.:.. ~~~
.,-".'~ "~;' : 'r- :l'\..,i':"~'~~.~~--
"'. .' ~ . ..,-.. .
,'., ,
..
-------
-60-
Because of the excavation and construction re~uirements associated
wit~. thi8 alternative, two to three construction seasons would
probably be required.
This alternative addresses the critical aspects of the Landfill
site problem, contaminant migration via 8urface runoff, bank
erosion, and flooding. The required technologie8 are both
feasible and reliable.
-Alternative VII
Alternative VII, clay cap and partial river channelization,
includes one source control technology, grading with clay capping,
and one migration management technology, 100-year flood protection
via partial river channelization.
Under partial river channelization, excavation and handling of
hazardous mater~als will be required at the, northern and
southern ends of the Landfill site.
Two to three construction seasons would probably be required to
implement this alternative.
This alternative addresses the critical aspects of the Landfill
site problem, contaminant migration via surface runoff, bank
erosion, and flooding, 'but provides significantly less
protection than the alternatives employing RCRA caps and/or full
river channelization. It also employs feasible and reliable
technologies.
-Alterantive VIII
Alternative VIII, clay cap and bank stabilization, involves
the application of two source control technologies, grading with
clay capping as in Alternative III, and stabilization of the
existing Landfill site banks with riprap and dikes, without
river channelization, but providing 100-year flood protection.
This alternative allows the Genesee River to remain in it.
established channel. This bank 8tabilization and flood control
technology is the least protective of the options considered. It
does nothing to control Gene8ee River flood water. other than
protecting the Landfill site from inundation. This leaves the
banks vulnerable to possible flood damage and erosion.
-------
-61-
Under this alternative, riprap will protect the existing dike
embankment, but not the river channel bank at all points along
the Landfill site-river interface. This alternative has only a
fair potential for success since it is vulnerable to uncontrolled
Genesee River flood waters.
por bank stabilization, a total of 15 acres would be disturbed by
construction activities, requiring temporary sedimentation and
erosion control measures. One to two construction seasons should
be sufficient to implement this alternative.
This alternative provides public health and environmental protection
but may not meet all applicable cri~eria. This alternative
addresses the critical aspects of the Landfill Site problem:
contaminant migration via surface runoff, bank erosion, and
flooding, but does not effectively controlling the river since
it includes no channelization work. The technologies employ~d
under this alternative are both feasible and reliable.
Tables 20 and 21 summarize the screening of alternatives. Table
22 shows the various costs associated with the alternatives
considered in the final evaluation.
, .
Com~unity Relations
Throughout the RI, PS,'and focused PS for an initial remedial
measure, all data and reports have been submitted to interested
citizens, elected officials, the PRP, and the local library,
which serves as a public repository.
The public has expressed significant concern regarding the
potential threat from the Sinclair Refinery site. In addition to
the potential acute effects that may be associated with flood
conditions, residents are concerned with the long-term chronic
effects of exposure to chemicals that may be released from the
lite. The Welllville Rod and Gun Club hat ettablithed the health
of the community as the foremost concern in their attempts to
activate the community. The first public meeting, sponsored by
the Rod and Gun Club, included a public panel discussion with BPA
and NYSDBC fn.Pebruary 1983 to addre8s the community's concerns.
The primary concern expressed at this and subsequent meeting was
the threat to the water supply from the site.
-------
~
~ cost O£qsI. ",,,n rOl ,""Ill sm 1(lI(DI. .uI_n,1S
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JlNf'fttc:al1
r..,I.I"', .. sn.-speclflc CelldlUOIII r.-i 500cI r.- Goo' Ii-' ~ ~
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,.
!
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Ijood
Fair
poor
Benefici a 1
Adverse
High
ttoderate
low
- ~Iternatl.e Is well suited to meeting crlterl. under consideration.
- Alternative is suited to meeting criteria under consideration.
- ~Iternatl.e not well suited to meeting criteria under consideration.
- ~Iternatlve effectl.ely contributes 10 he.lth and safety or environment.
Alternative negatively impacts health and ~afety or environment.
In.olves sophisticated mech,nlcal equipment and logistical requirements.
- Invol.es commonly utilized mechanical equipment and logistical requirements.
- little or no mechanical equipment required. .
. :
~';f.
0; ,
~.
",
-------
At URMATI¥[
I. !to ActiO'!
II. Slurry Valls
RCRA Cap I
Fu11 ChlnneHuUOft
III. Slurr, Valls
Sur"ce Gradtno:
(C18, Cap)
'arttll Chlnnel-
hltlon
I'. r.CRA Cap
F~II Chlnneltlatton
Y.
lieU C.p
'arttal Channel-
batlon
'I.
Reloc.U.,.. 0' SLA
to 'CUA; ItCH Clp
on C[lA; Partial
channe1111tton upto
C£LA
'II. Surface Gradtng
(CI'f Clp)
Partt. Channel-
tutlon
'III. Surf.ce Grading
(CI., Clp)
'ank Stabtlt,atton
(Gilles)
~'.I. ~.~, Or-!~~Flll 51'[ R(~DIAl Al'(RNA'IV~~
PU8L1C
H[Al TH C~.!~NS
Conttnued exposure exists
to rltnfal1-lnd flood-
Induced .19rltlon of
cont.lnants.
[It.lnat.s ,.lelses vtl
III -.dll. Public risk
elt.lnlted.
[11.lnltes relelses vii
all .edla. Publtc risk
ell.lnlted.
[It.lnates relelses wt.
surflce runoff Ind bank
e~ton. Public risk
.Inl.hed.
[It.lnltes relelses vi.
surilCe runoff Ind bank
erosion. Public risk
.Inh,hed,
(11.ln.tes releases wll
surf.ce runoff .nd bank
erosion. Public risk
.Inl.lud.
l"VIRONM£"'Al
~~~"-L
nClIIlCAl
CONCIA!lL
Continued .Igr.tton 0'
cont..ln.nts to r.enes...
River. Not disruptive 0'
ellstlng pl.nd Ind wild-
life.
[11.lnates rele.ses to 'roven
r.enese~ River, Hlghl, tech~logy
dlsruptlye of esta-
blished ~llnt Ind wild-
life o~ llndflll Stte.
[II-Inates rele.ses to ProVeft
Ge~~sfte A~ver. Hlghl, technolog,
dlsruptlwe of esta-
blished pllnt Ind"wlld-
life on l.ndftll Site.
11o groundwlter controls Proven
Hlghl, dlsrupttv. of technol~
estlbllshed plant .nd
wildlife on llndflll Site.
No groundw.ter controls ProYeft
Htghl, dlsruptlw. of techno log,
established pl.nt .nd
wlldllf. on llndflll
Site.
RPduce the l.ndflll 'roVen
site b, .bout 2 .cres; techno log,
No groundwlter controls.
Highl, disrupt lye of
established pl,nt Ind
wildlife on llndfl11 Stte.
Controls r.lelses vii sur- No aroundwlter controls Proven
flee runoff Ind b.nk Highl, dtsruptlye of techno log,
erosion. Public risk estlbllsh~~ p1.nt and
.Inl.lled. wildlife on L.ndflll
Site.
Controls rel.a"s via 110 groundwlter controls 'roven
surflce runoff Ind ~an. No rlyer fl~lng technolog,
Rtst of f.~sure ellsts controls. Highl, dls-
during sever. flood events ru~ttv. of est.bllshed
pl.nt and wildlife on
landfl11 Site.
'.
-------
,URRal' 0. ESTI"aTED TOTAL .IOJECT COlTS
CAPITAL a".UAL 'IESI.T IIOIT8 To"aL
aL"I..a,,"1 COS"s 0'" COSTS O. 0. 0'" COS'" . ,'.S.." .0IT..
I .0 actio. . '0,000 UO,Ooo ,,",000 . "',000
II It.rrr ..11. ,", "0,000 "0,000 un,ooo ,12,00,000
.c.a Cap
..tt c.a..otl.atlon
111 It8ur .0118 810,101,000 UO, 000 fUJ,OOO.,: ,",221,000
CUr cop
.artlot c.a..atl.atlon
IV .caa Cap , ,,0'6,000 UO, 000 U",oOo , ,,"0,000
..11 c.a..atl.atlo.
V ac.. cap , ,,501,000 SJO,OOO ,J..,ooO , ,,'00,000
.artlat c.a..atl.atlo. '
VI a.tocata lLA to CILA ",15,,000 UO, 000 81...000 . ',15 J, 000
acaa C.p,
.ortlat Cba..atl..tlon
.11 ctar Cap . ,,10,,000 UO,OOO 81",000 , ,,10J,OoO
.artlat cba..atl..tlo.
.111 ctar C.p . 1,650,000 810,000 81",000 , "0,,,000
.a.1I It...IU.a-
tlo.
. 20 r.ar pta..la. p.rlod, '0' dl.cou.t rata
0'. I. aa....d to ..catato appro.I..tatr 5. par ra.r
o..r tha ta..tb 0' tho pt..nl.. parlod.
"
"
~
Table
-------
-65-
Oue to concerns expressed, at this meeting, the NYSDOB
performed a cancer study to dete.mine whether there was an
increased cancer risk from consuming the Village's water. The
results of this study indicated that the overall cancer incidence
in the Village for the studied period is essentially the same as
. that for other New York Villages having similar population
densities.
After publicly releasing the draft Phase I RI, a public
meeting was held on May 6, 1985. This meeting was attended by
approximately 100 people.' On April 1, 1985 a public workshop
was held to answer additional questions, and to take comments.
These meetings were announced via direct mailings and press
releases. The public comment period ended on April 15, 1985.
After publicly releasing the draft PS for the landfill portion
of the site, a September 3, 19~5 meeting was held to brief the
public on the findings and to solicit public comment. The
meeting, which was announced via press release and direct mailing,
was attended by 15 people. A three week public comment period'
ended on September 16, 1985.
A responsiveness summary is attached (see Attachment 1). This
document summarizes the comments on the PS and includes meeting
notification documents. .
Consistency With Other Environmental Laws
The recommended remedial alternative complies with all substantive
requirements of RCRA, the Clean water Act, and the Clean Air Act.
The alternative will also comply with all applicable COE permit
requirements, as well.
Recommended Alternative
According to 40 CPR part300.68(j), cOlt-effectiveness is
described as the lowest cost alternative that is technically
feasible and reliable and which effectively mitigates and minimizes
damag. to and provides adequate protection of pUblic health,
welfare; and the environment. Eight alternatives including no
-------
-66-
Alternative I, the no-action alternative, vas found to provide
inadequate-pretection of public health and the environment. The
primary concern. a..ociated vith no Action vouLd be the continued
discharge of contaminated surface runoff and leachate into the
Gene.ee River, and the threat of failure of the landfill into the
river.
Becau.e there doe. not appear to be .ignificant lateral movement
of ground vater through the vaste .atrix of the CBLA and SLA,
and becau.e an adequate .urface .eal vill .ignificantly reduce
infiltration and the resultant generation of leachate, slurry
wall grouDd-vater controls do Dot appear to be neces.ary
to protect public health and the environment. Accordingly, both
.lurry vall alternative., Alternative II and Alternative III,
vere deleted from consideration.
Partial river channelization eliminate. the erosion and flood
inundation threat to the landfill by providing .table riprap
banks along both sides of the river along the full length of the
landfill. The added protection provided by full river
channelization's larger buffer between the river and the vaste, .
and .everal hundred more footage of riprap up.tream of the SLA
is not significant enough to warrant the $500,000 increase in
cost over partial river channelization. Accordingly, Alternative
IV was deleted from consideration.
Alternative VIII, employing measures to protect the e.tablished
channel, has only a fair potential for success because it
would be vulnerable to uncontrolled Genesee River flood waters.
por this rea. on this alternative wa. dropped from consideration.
The primary .urface- and ground-vater problem. a.sociated with the
Landfill .ite are tho.e due to runoff and infiltration. Accordingly,
an adequate surface seal vill be required to prevent further
relea.e. to the environment. Tvo .urface .eal alternative. vere
evaluated. RCRA capping, incorporating a 2-foot clay liner, 1-
foot drainage layer, a geotextile filter fabric, 1.5 feet of soil
and 0.5 feet of top .oil and clay capping, utililing 3 feet of
clay, 1 ~oot of .andy .oil, and 0.5 feet of top .oil.
-------
-67-
While clay capping will probably perform an adequate job of
preventing surface runoff and infiltration, because of the
thickness requirements of the clay cap so as to accommodate
the 4-foot froet~ine, a RCRA cap would coat only $200,000
more than a clay cap. But for thia insignificant increase in
capital coat, a RCRA cap Wbuld allow aignificantly greater
protection by providing a drainage layer and filter fabric.
would also require le.. long-term maintenance expenditure..
It
Becau.e of the increa.ed level of protection provide by a .mall
increa.e in co.t as.ociated with RCRA capping, Alternative VII,
employing a clay cap, va. deleted from further consideration.
Becau.e of the impervious nature of the .oil. underlying the
CKLA, the ground-vater table beneath this portion of the
Landfill site is depressed. The waste in the SLA, however, i.
con.iderably clo.er to the ground water becau.e of the greater
permeability of the underlying soil.. A. a result of the
conditione at the SLA, a greater potential existe for releases
to the ground vater fro. the SLA than from the CBLA. Re10c~ion
of the waetes in the SLA to the CBLA under Alternative VI would,
therefore, enhance the .ource control measure by providing an
added degree of protection again.t releases to the ground water.
Under Alternative V (RCRA cap and partial channelization), the
bank. of the Genesee River would be channelized from the existing
flood control 8tructure north of the CBLA to a point immediately
south of the SLA. Under Alternative VI (relocation of the SLA
to the CELA, RCRA cap,. and partial river channelization), because
the SLA would be excavated, the channelization would start from
the borrow pit area south of the CBLA, requiring significantly
les. riprap than the partial channelization provided by
Alternative V. In addition, Alternative VI would require less
cover material then Alternative V .ince the va.te from the SLA
would be consolidated on the CBLA. A8 an added benefit of the
decreased surface area requiring capping, Alternative VI would
provide a slightly increa.ed level of protection from .urface
runoff and infiltration as compared to the RCRA cap provided by
Alternative V.
-------
-68-
Under Alte~native VI, excavation of the SLA and placement of
clean fill wo~d cost $1.5 million. However, under Alterna-
tive VI, the co.t. a..ociated with le.. cover material and the
abbreviated partial channelilation requirements would require
$1.25 million le.. than for Alternative V, making Alternative VI
only $250,000 more expensive than Alternative V.
Since Alternative VI provides an increa.ed level of protection
from surface water infiltration and runoff a. compared to
Alternative V, and .ince the level of confidence as.ociated with
relocating the SLA i. greater than leaving it in place, Alternative
VI, relocating the SLA to the CBLA,. RCRA cap, and partial river
channelization is more cost-effective and i., therefore,
recommended for implementation at the Landfill .ite.
The recommended remedial alternative consi.ts of the following
activities:
8Drums
To facilitate the necessary compaction and grading operation on .
the CELA, approximately 300 drums located on its surface will be
removed and disposed of off-site.
Excavation
The 2.3-acre SLA wi~l be excavated to a sufficient depth to
remove all of waste material (approximately 20 feet). The
excavated WAstes will be placed on top of the cleared and grubbed
CELA. Clean fill from an off-site source will be used to fill
the excavated SL'.
. Con.ideration was given to on-.ite incineration of the excavated
SLA wastes, h~vever, because of the .mall quantity of material
that will require incineration, it is not believed to be as cost-
effective as relocation to the CELA.
:' .-...
-------
-69-
Channelization
Approximately' 2,900 linear feet (28 acres) of property along
both ban~s of~he Genesee River from the COB's sheet pile veir
immediately downstream of the CBLA to the borrov pit area
vill have to be cleared, grubbed, and graded. In addition, the
impoundment located betveen the recently constructed dike and
the exposed southern face of the CBLA vill have to be drained
and filled. Bxcavation and on-site dispoaal of vaste material
may be required at the south end of the CBLA and incidentally
during excavation in the existing channel. A manufactured
geotextile filter fabric viii then be placed along both river
banks, followed by a layer of aand to .erve aa a protective
buffer, folloved by riprap. The riprap viii extend from the
channel bottom to three feet above the 100-year flood elevation
on the west side of the channel adjacent to the landfill for the
entire length of the landfill-river interface. The rip rap on
the ea.tern bank vill extend from the channel bottom to the
100-year flood elevation. Pigures 9 and 10 illustrate the
proposed channelization.
Surface Seal
Pigure 11 shows the surface seal that vill be installed fOlloving
the removal of all exposed drums and vegetation, and the placement,
compaction, and grading of the vaste excavated from the SLA.
Approximately two feet'of low permeability (maximum of 1 x 10
centimeters per second compacted clay would be applied across
the entire CBLA and SLA vastea. A one-foot drainage layer
followed by a geotextile filter fabric would be placed on the
clay layer. One foot of aoil folloved by 6 inchea of seeded top
soil vill cover the top of the landfill.
A chain link fence, encompassing the entire Landfill site, vill
be installed to prevent access to the aite.
Table 23 repre8ent8 coat eatimatea for the recommen4e4 actiona.
The total require4 amount for the design ($500,000) and the
construction ($8,759,000) of this measure is $9,259,000, of which
BPA vill fund $8,383,100.
,.
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Relocation af SLA to CELA,
RCPA cap, and partial river
channellz..!:lon
Figure
-------
~- . -_....~ -. ~
'- .I/~~:'~,. I- -_u_.- ----....
:;,,:,"../i -. ~~ - -.- _. - . -..
.... .': ~-=. ';~':~'.j" ."'~m
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I'
TYPICAL DETAILS AND
C HANNE L PROFILE
, 0 \.-.-
............
~"'"'''''''''''' .... ,I).. ~1." "h.'IM '
n' . D'"..''''''' OIl ,..~.,".."""U~ (0-..
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Figure
III8C\.AlIi LAIIOFILL Sl1[
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10
-------
"
COYER
\
IAItT" fIll
DRAINAGE
$'.
SWALE
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UNDISTUR8ED
,SOIL
WASTI
MATUIAL
.
,
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.
TYPICAL
CROSS
SEC TION
OF RCRA
CAP
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Figure
11
,- .........
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-------
I
I
COST ES Tn'.].. TES
ALT£R~;ATIVE VI
RCRA CAP, PARTIAL RIVER CHA~~ELIZATION UPTO CELA
CAPITAL CDSTS
: :..;, r:..:::.:':';:~::> :'0
C:::!.A,
£L !:~~:T
.
,.
Mobilization
Clearing and Grubbing
Surf icial Drum Removal an,d Disposal
Fil~ing and.Grading (lOO,O~O c~ @ 9.50/cy)
Draln and Flll Impoundment Be~lnd Dike
~CRA ,Cap (48,800 sy @ $26.20/sy)
FenClng
?artiai River Channelization upto CELA
Hazardous Waste Relocation from SLA to CELA
Clea~ fill to backfill and 1evel SLA
subtotal
Contingency (20')
Total Installed Cost(2)
Engineering, A~inistrative, Legal,
etc. (25')
- .
~
- .
'"'
oJ.
-.
Fe
,..
oJ,
E.
.
. .
Total Ca pi tal Co st '
JJum AI.
O&!'. COS':'S
EL E~~~T
A.
B.
Monitoring Well Sampling and Analysis
Cap and Fence ~~intenance
Total Annual O.H
CAPITAL COSTS
33,000
55,000
40,000
950,000
380,000
1,278,000
60,000
1,995,000
948,000 .
100,000
$ 5,839,000
1,168,000
$
$ 7,007,000
1, 752,000
$ 8,759,000
ANNU AI. COSTS
$25,000
5.000
$30,000
Table 23
. -' - .
., -.. -' -"~"..:- .;.'::~:.;..-:'. .:. :~:.~~;.,;~: .z,,~~:~:;,,"~:..~lr
-------
-74-
The peasibility study planned for the refinery portion of the
Sinclair Refinery lite il Icheduled for completion in November
1986. So that implemention of the lurface lealing recommended for
the Landfill lite will not preclude the Refinery lite PS
conlideration of relocating contaminated loill from the
Refinery lite to the Landfill lite, a phaled approach will be
employed in conltructing the lurface leal and channelisation at
the Landfill lite. The Genelee River channelisation design and
conltruction, and the SLA excavation delign and implementation
will proceed aa aOOn aa poaaible. However, the CBLA aurface
aeal will not be designed until the Refinery site PS hal
conaidered all remedial alternativel, and a remedial solution.
hal been selected. Should it be neceaaary, to protect the excavated
SLA waltea and the CBLA aurface from erolion and lurface runoff
in the interi., a temporary 1-~00t clay cover would be conltructed.
Operation and Maintenance
operation and maintenance requirements associated with this
alternative are minimal ($30,000). The cap, river banks, and
fence will require periodic attention and maintenance. Regular
sampling and analysis of ground water from on-lite and perimeter
wells will be required, as well.
Schedule
Action
-RA approves ROD
-Amend cooperative Agreement for Design
-Solicit Design Proposals (State)
-Award Contract for Delign (State)
-Start Design
-Complete Delign
-Amend cooperative Agreement for
Conltruction
-Solicit Conltruction Propolals (State)
-Award Con.ract for Conltruction (State)
-start Conltruction
-co.plete Conltruction
~
september 30, 1985
September 30, 1985
October 31, 1985
January 31, 1985
April 1, 1986
September 30, 1986
October 31, 1986
Dece.ber 1, 1986
April 1, 1987
May 1, 1987
May 31, 19 89
-------
-75-
Future Actiona
Upon completion of the RI/PS for the refinery portion of the
aite, a Record of Deciaion will be prepared to recommend a remedial
solution for this portion of the project.
The need for Landfill site ground-water control, and the incorporation
of such control in the remedial meaaure for the refinery portion
of the site, will be evaluated in detail during the PS for the
Refinery aite.
...~ --..."..- .-. .,.... -" -".. .. -,or
.. III '" .' ,-, .
. -. ...~.- ...
-------
. I
Responsiveness Summary
-------
N.,w York State Dep.:rtment of Environmental Conservation
SO Wolf Road, Albany, New York 12233-0001
~~. ~::,.
~
~
~
Henrv G, Williams
Co'mmissiol'ler
March 22. 1985
Dear Concerned Citizen:
Work has been continuing on the Sinclair Refinery Superfund Site. The
Phase I Remedial Investigation has been completed and the Draft Phase I Report
hits been distributed and copies have been placed in the prOJict's Document
Depository located in the Wensville Public Library.
April 7 ~ 1985
DISCUSSION OPPORTUNITY
1 - 4 PM and 6 - 9 PM
Wellsville Public Libral1'
PI~asc stop in ~nytlm~ bet\V~en 1 Sind 4 or 6 and 9 PM er. April 1.
Representatives from the Departn':ent of Environmental Conseryntion (DEC), SMC
Martin, DEC's consultp.r.t and t~~ Env:ronmentAI Protection Agenc~l (EPA) wB! be
aya.Hable to discuss thp. draft Phase I Report with you. They will explain fJnj'
difficult to understand parts of the Heport, answer your questions and take.
}'(Jur comments.
Thp. Phase I investigation studip.c soil types, wHter JC"Tels, weather and a
v~uiety of other factors that help to detel.rpine the extent of contamination end
predict future contaminant movement. This Phase 1 st'-1dy 81so included thE:
analysis of a large number of soil, sediment, waste and water samples each of
wtjch has been analyzed for 145 different compound~. A large number of
biological samples (fish. frogs. insects. mice. etc.) were also analyzed to
determine if thp.y showed any signs of contamination. The Report presents the
results of the investigation, identifies the extent of m~gr8tion of contaminants
and documents the environment21 imoEtct of the site.- The enclosed Exee\itive- ' -
Summary of the Draft Phase I Report provides a much more detailed description
of what the Report includes. The complete Report consists or two volumes
which have been placed in the WeUsville Library. \fe would like to gather your
comments on the Report before it is finalized. THE COMMENT PERIOD ON THE
PHASE I INVESTIGATION REPORT WJI.L E~D ON APRIL .15. 1985. We
encourage you to write. call or give us your comn1ents during our discussion.
sessions.
(OVER)
.or', ",
~...... ~. ""'~.\":. -"'...""~':'~"::..~:.
-------
May 61 1985
PUBLIC MEETING
..
i
I
C;
~.
7 : 00 PM
Wel1sville Public I.ibrary
-
ON MAY 6 WE WILL HOLD A PUBLIC MEETING TO PRESENT AND DISCUSS:
FAST TRACK FEASIBILITY STUDY - DRAFT REPORT
The Fast Track Feasibility Study is an investigation of WeUsville's public
water supply and an evaluation of alternative methods of insuring that it is not
contaminated by the Sinclah' Refinery Site. The draft report will review the
findings of the study, describe the alternatives that were looked at and
recommend n remedial alternative.
HEALTH ASSESSMENT
The New York State Department of Health (DOH) has investignted the
incidence of cancer in Wellsville as compared to other similar areas.
FUTURE REMEDIAL ACTIVITIES
Additional investigation and feasibility studies are in progress.
FINAL PHASE I INVESTIGATION REPORT
Following toe close of the comment period on April 15. 1985 the Phase I
Investigation Report will be finalized.
We look forward to meeting with you during both the discussions on the
Draft Phase I Investigation Report (April 1, 1985) and the public meeting on
the Fast Track Feasbility Study. Health Asseument. Future Remedial Activities,
and the Final Phase I Investigation Report (May 6. 1985). Please let us know
before the close of the comment period on April 15. 1985 if you have any
questions or comments on the Draft Phase I Investigation Report but are unable
to participate in- the discussion sessions. We have a toU-free telephone- numher'
1-800-342-9296 or contact Dr. Vasudevan at 518/457-4343.
Sincerely.
/J /"
/';..,. - .. . /"0#" - . ~..,i-.
, -.. -"- :..~~ ~s:<~....
Bruce Bentl~y ..~
Citizen Participation Specialist
Ene.
. .. ... ...
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ST,\TE OF NEW y~ KK -w
'DEPARTMENT OF HEALTH ~~ OFFICE
CORNING TOweR
.
CAV..' AXELAOO. M.D.
C_u-
OF
THE GOVERNOR NELSONA. ROCKEFELLER EMPIRESTATE P\.AZA
April 29. 1985 .
'.
[
~~
PUBLIC
HEALTH
. ALBANY. N.Y. 12201
UNOA A. IIANOOLI'H. M.O.. M.".H.
lIiteaet
,
2
WlWAM F. LEAVY
1-- ~""-...
Dear'Concerned Citizen:
The Cancer Surveillance Program in' the' Bureau of Cancer Epidemiology has
completed the investigation of cancer incidence in Wellsv111e which you
requested. The complete report is attached.
In summary. overall cancer incidence. in the Village of Wellsville for
1973-1982 is essentially the same as the rate for other minor civil divisions
in New York State (exclusive of New York City) having a similar population
density. In published studies of drinking water and cancer. the cancer sites
usually associated with exposure to tr1halomethanes (chem'cals formed during
water chlorination such as chloroform) or polychlorinated biphenyls (PCBs) are
colon. rectum. bladder. liver and malignant melanoma of the skin. None of
these sites were found to be significantly increased in Wellsville. The small
deviations seen between the observed number of people with cancer and the
number expected based on the population standard rates are within the range
which occur by c~ance when comparing a single community with a large
population. Thus. the pattern of cancer occurrence in Wellsville does not
support the hypothesis of an association with chemicals in the public drinking
water. This conclusion is consistent with the results of the water quality
testing. which showed the levels of trihalomethanes to be well below the
maximum contaminant level considered acceptable for protection of the public
health. No PCB's were detected in the samples.
There was an excess of leukemia cases in Wellsville ~n which exceeded the
limits expected by chance. that is. it was statistically significant.
However. the lack of an excess of leukemia in women and the absence of
childhood cases make an association with drinking water very unlikely. This
pattern is more suggestive of an occupatiQnal or lifestyle exposure which puts
men at an increased risk. Six of the ten men with leukemia had worked in .
occupations with a potential exposure to leukemogenic agents such as benzene.
petroleum products and organic solvents. However, only two of these six men
had acute myeloid leukemia. the type which is usually associated with
occupational benzene exposure. and there was no increase in aplastic anemia
deaths. a precursor condition of acute myeloid leukemia. The sampling results
on wellsville's water supply through December 1984 -indicate that on one..
occasion benzene was detected in treated water at a level above the Department
of Health's guideline. It was not detected at other sampling times. The
resulting low average level of benzene in Wellsville's drinking water
contributes only a negligible amount to the total daily intake from al1
sources of benzene exposure. It is unlikely that exposure to these low levels
of benzene in the drinking water accounts for the excess cases of leukemia in'
Wellsville men.
. -'....:-...-.
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-2-
The State Health Department has already begun further study of leukemia in
Wellsville. An intervjew study of the leukemia patients and their families to
obtain more detailed information on occupational history as well as other
leukemia risk factors, such as exposure to radiation and family history of
cancer, will be conducted.
Sincerely yours,
s ~ '" :r: ~uJ, $
Susan J. Standfast,'M.D.
Assistant to the Director
Division of Epidemiology
"
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SINCLAIR REFINERY SITE
WELLSVILLE. NEW YORK
PUBLIC INFORMATION MEETING
MAY 6. 1985
~~i'!!Q~
1-
Introduction
2-
Phase I Remedial Investigation
3-
Investigation of Cancer Incidence
in Wellsville. New York.
4-
Fast-Track Feasibility Study
of the Wellsville Water Supply
.
5-
Federal Superfund Procedure
6-
Future Remedial Activities at
Sinclair Refinery Site
,.
~
'"
!j
.
..
By:
Mr. John W. Willson. NYSDEC
By: Mr. Daniel E. Erdman.
. SMC Martin. Inc.
By:
Dr. Susan Standfast. NYSDOH
By: Mr. Stuart Rosenthal,
SMC Martin. Inc.
By: Mr. George Pavlou. USEPA
By:
Dr. Chittibabu Vasudevan. NYSDEC
- . .
. .
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New York State Department of Environmental Conservation
50 Wolf Road, Albany, New York 12233.0001
'I\.;
(cntc~~i~ .
...... ....... .-".......,
Henry G WilliaMS
Commissioner
AUG 2 ( 19~~
Jear :oncerned ~it'zen:
RE:
Draft Report On Feasibility Study for
The Sinc1air La~dfill Site.
Village of wellsville, Allegany County
Enclosea is a copy of the Executive Summary of the Draft Report on the
~~asinility StudY for the Sinclair Landfill Site. Copies of the report are
av ai lab 1 e at the document depos i tOf.y ) tl the Wel1 s'..i 1l! Pub 1 i c Library located at
155 N. ~ain Street, ~ellsville, New York.
Tnere will D~a Public Information Meeting concerning the report on Tuesday,
5eptember 3, 1985, 7:00 p.m. at the Wellsville Public Library, 155 N. Main
2:re~~, wellsville, New YJrk. Representatives of the New York State Department
OT Environmental Conservation (NYSDEC). SMC Martin, inc., the Department's
consJ1tant. ana the United States Environmental Protection Agency (EPA) will be .
available to aiscuss the report and to receive and answer comments. .
Please submit your comments on the draft report to me at the above address
on or before September 16. 1985. All comments received before the September 16,
i985 close of business will be addressed in the responsiveness summary report.
The EPA will prepare a Record of Decision (ROD) in connection with the
suDject matter ~hich will review: the draft report, the comments received on or
before September 16, 1985. and the responsiveness summary report which will be
prepared by NYSDEC. The ROD will explain the sel!ction of the Remedio\l Measure
for the Sinclair Landfill Site.
If you have any Questions on this matter, please contact me at 518/457-4343
or leave a recorded message for Dr. Vasudevan by calling our toll free telephone
number 1-Suu-342-9296.
Sincerely,
nr:'
. I /1;
. ~abu Vasude an,
Project Engineer
Bureau of Western Remedial Action
Division of Solid and Hazardous Waste
tnclosure
-------
~ . I v"', I~'"
THIS LETTER WAS SENT TO THE ATTACHED LIST
, 'J',
Dear:
Re:
Sinclair Refinery Site, Wellsville, Allegany County
Responsiveness Summary on Feasibility Study for the
~inclair Landfill Site.
Enclosed is a copy of the summary of the Responsiveness 'Summary Report
addressing comments received from the public on the Draft Report on Feasibility
Study for the Sinclair Landfill Site. Additional Copies of the Responsiveness
Summary Report are available at the doc~ent depository in the Wellsville Public
Library located at 155 North Hain Street, Wellsville, New York.
The United States Environmental Protection Agency (USEPA) is expected to
write the Record of Decision (ROD) by September 30, 1985. The ROD will explain
the selection of Remedial Measures for the Sinclair Landfill Site.
If you have any questions on these matters, please contact,
Chittibabu Vasudevan, Ph.D., P.E., of my staff, at (518) 457-4343 or leave a
recorded message for Dr. Vasudevan by calling ~ur toll free number, '
1-800-342-9296.
Si ncele ly ,
..1. .h.....
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Norman H. NosenchuCk, P.E.
Director
Division of Solid and Hazardous Waste
Enclosure
cc:
G. Pavlou, USEPA, Region II, w/enc.~
J. Singerman, USEPA, Region II, w/enc.
N. Kim, NYSDOH, Albany, w/enc.
L. Voilanti, NYSDOH, Buffalo, w/enc~
G. Johnson, NYSDOL, New York, w/enc.
S. Rosenthal, SMC Martin, w/enc.
1.- . ..:._..:.,,:~~-;. '.: ;'.
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LIST OF ADDRESSES
Mr. Andrew B. Puch
ARCO Petroleum Products Co.
400 E. Sibley Boulevard
Harvey, IL 60426
Mr. A.F. Pope
ARCO Petroleum Products Co.
515 South Flower Street
Los Angeles, CA 90071
Mr. Alan Knauf
Harris, Beach, Wilcox, Rubin and Levey
Attorneys and Counselors at Law
2 State Street
Rochester, NY 14614
Dr. Albert Vanderlinde
President
Alfred University
S. Brooklyn Avenue
ROn, Box 402
Wellsv;lle, NY 14895
Mr. Wayne Ackart, P.E.
Lozier Engineers
600 Terinton Hill
Fairport, NY 14450
Lewis Steele, Esq.
Seeger, Steele and Galez;owski
Attorneys and Counselors at Law
300 Delaware Avenue
Buffalo, NY 14202
The Honorable Richard Wesley
New York State Assemblyman
P.O. Box 38
Geneseo, NY 14454
The Honorable Daniel
U.S. Senator
111 W. Huron Street
Buffalo, NY 14202
P. Moynihan
Ms. Jane O'Bannon
Office of U.S. Senator D'Amato
Federal Building - Room 620
Buffalo, NY 14202
-1- -
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Ms. Susan Goetschius
Olean Times Herald
25 E. Pearl Street
Wellsville, NY 14895
Ms. Debbie Howitt -
WLSV Wellsville Radio
76~ North Main Street
Wellsville, NY 14895
Ms. Judy Burt
Wellsville Daily Reporter
159 North Main Street
Wellsville, NY 14895
The Honorable Robert Gardner
Mayor
City Hall
Railroad Avenue
Wellsville, NY 14895
Mr. David Dorrance
Allegany County Department of Health
Court House
Belmont, NY 14813
Mr. Donald MacFarquhar, P.E.
Department of Public Works
Village of Wellsville
156 North Main Street
Wellsville, NY 14895
Mr. Jan Bastian
Wellsville Rod and Gun Club
3784 Main Street
Scio, NY 14880
Mr. Roy Campbell
445 Broad St reet
Salamanca, NY 14779
Sinclair Documents
Library - 155 North Main Street
Wellsville, NY 14895
Ms. Peggy Monachi no
Office of Congressman
Lundine
101 North Union Street
Room 505
Olean, NY 14760
-2
- . ... ..". '.. ..
. .
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, :~;i~~
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.
Division 01 Solid and Hazardous Waste
RESPONSIVENESS SUMMARY
. Responses to Public Comments:
on Draft Report "Feasibility
Study for. the Sinclair Refinery
Site-Landfill, Wellsville,
New York"
..
September 1985
.,r,'e~'\, ',",1'; ~> ',::.-,;.J(::tt'/n-I'":"J oCEnvironrnental Conservation
-,
i
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RESPONSIVENESS SUMMARY
TABLE OF CONTENTS
o
Introduction to the Problem
Page No.
1
4
16
o
Summary
Responses to Public Comments
o
o
Reponses to letters from:
Mr. Donald A: MacFarquhar, Department of
Public Works, Village of Wellsville
21
Mr. Arthur F. Pope, Atlantic Richfield Company
-------
INTRODUCTION TO THE PROBLEM
The Vtllage of Wellsville is situated along the Genesee ~iver
at its confluence with Dyke Creek, Allegany County, in the southwestern
portion of New York State. The former Sinclair Refinery, now an
uncontrolled hazardous waste site, consists of 90-acres plus a 12-acre
landfill located along the west bank of the Genesee River approximately
one mile upstream from Wellsville.
The Genesee River is the primary drinking water source for the
Village of Wellsville. The water supply intake for the Wellsville
Water Treatment Plant ;s located approximately one-quarter (i) mile
downstream from the northernmost edge of the Sinclair Refinery Site..-
The water supply system serves approximately 6,000 people, producing
approximately one (1) million gallons per day (MGD).
In recent years, complaints of oily tastes and odor in the drinking
,
water have occasionally been reported by Wellsville residents, although
records of such complaints have not been kept. These complaints, along
with visible bank erosion of the landfill, particularly during heavy
rains in October of 1981. brought the Sinclair Site to public
recognition as a potential source of contamination to the Village's
drinking water.
In view of the threat of exposure created by the Wellsville water
intake's' close proximity downstream of the Sinclair Site. the New York
State Department of Environmental Conservation (NYSDEC), in
January 1985, authorized their consultant, SHe Martin, to prepare a
fast-track feasibility study of feasible Initial Remedial Measures
(IRM), in accordance with NCP guidelines and the IRM Report was
distributed in May 1985.
-------
The NYSDEC received comments from elected officials,
representatives of the Village of Wellsville, interested citizens and
the Atlantic Richfield Company (ARCO).
Most of the comments were
related to the relocation of the water intake or continuous operation
of the granular activated ca~bon units.
Comments and responses were
presented in a Responsiveness Summary Report, August 1985. The
Environmental Protection Agency (EPA) staff informed the public at
the September 3, 1985 Public Meeting that relocation of the intake
to a location upstream of the Landfill Site is recommended as an Interim
Remedial Measure for the Wellsville Water Supply, to the EPA's Regional
Administrator.
In 1984 and 1985, a Remedial Investigation was conducted in
accordance with National Contingency Plan guidelines, in order to
determine the nature and extent of the environmental contamination.
A Draft Remedial Investigation Report was published in March 1985.
Additional investigative work continued in 1985.
The Remedial Investigation identified several factors of importance
to the consideration of remedial measures:
1- A clay unit, 35 to 60 feet thick, underlies the Landfill Site
at a depth generally less than 25 feet from the ground surface.
2- Contaminants present in the greatest quantities in the landfill
areas include priority and non-priority volatile organics,
base/neutral extractable organics and metals.
3- Although wastes and soils show significant quantities of
specific contaminants, ground and surface waters beneath the
Landfill Site remain relatively uncontaminated. A pathway
of significant contaminant migration between the waste/soil
and the groundwater does not appear to exist.
. ..
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4- Contamination in river sediments downstream (north) of the
. La~dfill Site is comparable to contamination at a sampling
location upstream.
5- A potential pathway of contaminant migration exists between
flood-induced landfill bank erosion and overland storm runoff
and contaminant discharges to the Genesee River.
6- Approximately 300 drums of waste material lie in various stages
of decomposition on the surface of the Landfill Site. Chemical
analyses of the samples taken from the waste drums indicate
that very few contaminants were present in the drummed
~aterial.
7- The CELA was calculated to contain approximately 206,500 cubic
yards (cy) (248,000 tons) of waste and the SLA was calculated
to contain approximately 22,500 (cy) (27,000 tons). Maximum
waste thicknesses measured were .20 feet in the CELA and 18
feet in the SLA.
8- A leachate generation model predicted that leachate migrating
from the CELA (vertical and lateral) would be negligible and
leachate migrating from the SLA would total approximately
1,700 gallons/day.
Additional Remedial Investigation (RI) is in progress at the
refinery portion of the Sinclair Site. Application to EPA was submitted
in September 1985 requesting additional funding to complete the
investigation at the refinery. After the completion of the
investigation at the refinery, if it is demonstrated that the refinery
portion is contaminated, a Feasibility Study (FS) will be conducted
to evaluate remedial technologies to identify cost-effective remedial
measure(s) for the refinery portion of the Sinclair Site. The progress
-
of the RI/FS for the refinery portion depends on the funding
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SUMMARY
In accordance with the National Contingency Plan (NCP). the
Feasibility Study for the landfill portion of the Sinclair Refinery
Site evaluated several remedial technologies to provide a cost-effective
Remedial Measure for the central elevated and southern landfill sites.
Remedial response criteria for the Landfill Site were dev~loped
for ground and surface waters and surface and subsurface soils.
Water
criteria coincide with criteria for raw drinking water supplies as
established by the New Yor~ State Department of Health. Soils criteria.
were derived from background soil concentration levels or a partition
coefficient analysis.
Thirty remedial technologies were considered and screened as to
.
their technical feasibi1i~y. environmental/public health effects and
order-of-magnitude costs. These technologies were either source control
measures or migration management measures. as listed on Table 1.
The technology screening resulted in the rejection of groundwater/
leachate control. on-site treatment and river sediment removal as either
not technically feasible or resulting in insignificant benefitS.
Techn~logies such as runoff collection and groundwater recovery were
rejected because their costs were generally 3-10 times greater than
other technologies that achieved comparable public health. and
environmental benefits.
Those technologies that survived the screening
process are listed in Table 2.
-4-
..
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The most promising remedial technologies were formulated into
remedial actlon alternatives in accordance with the United States
Environmental Protection Agency's (USEPA) policy. This policy specifi~s
that alternatives considered should cover a spectrum ranging froln No
Action to those minimizing threats but not attaining all relevant
standards, those attaining relevant standards, and those exceeding
relevant standards.
Following a Public Meeting on September 3, 1985,
three (3) additional alternatives were developed and evaluated. These
three (3) alternati~s are briefly described in Table 3. Table 4 lists
the altern~tives utilizing the available remedial technologies in
response to this policy.
A detailed evaluation of these alternatives was carried out based
on a non-cost and cost basis.
Non-cost criteria included reliability.
operational comple~ity, short and long-term health and safety impacts,
short and long-term environmental impacts, feasi~ility to site specific
conditions, and implementation time. The non-cost decision matrix
for landfill site remedial alternatives is presented in Table 5. The
non-cost evaluation indicated that all alternatives, except No Action.
would have adverse short-term impacts on the local population and plant
and wildlife due to the extensive construction requirements and the
associated traffic, noise. dust and destruction of habitants.
Conversely, all alternatives (except No Action) would have beneficial
long-term impacts on the local population and environment. with the
exception of plant and wildlife on the Landfill Site itself.
Differences among alternatives were strictly a matter of degree.
" "
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The non-cost analysis indicated a wider disparity among
alternatives for technical criteria than for environmental criteria.
Again with the exception of No Action,-a1ternatives were well suited
for application to the Landfill Site.
Based on the evaluation of
alternatives performed by SMC Martin, Inc., Consultant to the New York
. State Department of Environmental Conservation, Alternative No. II,
appears to have the highest potential for success, with Alternatives
No. III and IV close behind.
(Cost criteria included capital
(installed) cost, annual operatian and maintenance cost and present
worth). All had low operational requirements, although those requiring
water level maintenance within slurry walls (Nos. II and III), and.
that requiring dike maintenance (No. V), having marginally higer needs.
Implementation times varied from a low of 18-24 months for Alternative
No. V to 30-36 mdnths for Alternative No. II.
Because of the extremely low operating and maintenance costs
associated with all alternatives, this item was not a significant factor
in the cost analysis. Capital costs varied from just $90,000 for No
- Action (fence), to $7,650,000 for the next most expensive alternative
(No. V), to $11,490,000 for the most expensive alternative (No. II).
Table 6 summarizes both the non-cost and cost analysis.
-The NYSDEC has analyzed all alternatives in detail. The NYSDEC
is recommending the selection of Alternative VIII - Relocation of SLA
to the CELA, RCRA Cap and Partial Channelization upto the CELA for
the following reasons:
o The NYSDEC feels that Partial Channelization provides stable
adequate rip-rap banks along both sides and eliminates the
threats of landfill erosion and flood inundation.
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o Relocation of the contents of the SLA to CELA and filling and
regrading SLA with clean fill would enhance the source control
measure by reducing the landfill area.
o Relocation of the contents of the SLA to CELA eliminates/reduces
leachate generation currently calculated to be 1,700 gallons
per day.
o Relocation of the contents of the SLA to CELA provides a greater
distance of separation between the SLA wastes and the
groundwater.
Also, the soil beneath the CElA is less pervious
than the soil beneath the SLA, adding better protection against
migration of SLA contaminants to the groundwater.
o The RCRA Cap, which incorporates clay liner, geofabric and
drainage layer for leak detection, is designed to minimize
infi1tration,of rain water and snow melt into the landfills.
;
: I
- j
Because there does not appear to be significant lateral movement
of groundwater through the waste matrix of the CELA and SLA at this
time and because an adequate surface seal will significantly reduce
infiltration and the resultant generation of leachate, groundwater
control may not significantly improve the protection to the public
health ~nd the environment provided by the recommended alternative.
However, during the Feasibility Study for the refinery portion of the
Sinclair Site, the need for groundwater control will be studied 1n
more detail.
If such need is demonstrated, a cost-effective groundwater
control at the Landfill Site will be considered as a remedial measure.
This alternative poses greater short-term risk of contaminated dust
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.
.
., ;
exposure to on-site personnel and local population than other
alternatives. However. with proper health and safety measures during
the construction. the short-term risk to the on-site personnel and
the population in the immediate vicinity will be minimized.
It is expected that the EPA will write a Record of Decision
selecting a cost-effective remedy for the landfill Site by
September 30. 1985. The public will be notified of the selection of
the remedy after it is made by the EPA.
-8-
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A.
B.
TABLE 1
SUMMARY OF AVAILABLE REMEDIAL TECHNOIDGIES
SOURCE CONTROL MEASURES
a.
b.
No action
Collection ot conta.inated .urtace runott
1. on-.ite treatment
2. treatment at publicly-owned treatment works
Collection ot leachate
1. on-.ite treataent
2. treatment at publicly-owned treatment work.
Excavation and di.po.al
1. ott-.ite
2. on-.i~e .ecure landtill
3. incineration and on-.ite di.po.al
4. .oliditication and on-.ite diapo.al
5. biological ~aatruction and on-aite dispoaal
In-aitu treat.ant ot wasta.
1. lo11d1t1cat1on
2. biological daatruction
Installation ot imparmeable barrier.
1. .urtace grading and revegetation
2. .lurry wall.
3. aurtac. cap
4. complete encapaulation
Landtill bank .tabilization
c.
d.
e.
t.
g.
OFF-SITE (MIGRA~ION MANAGEMENT) CONTROL MEASURES
a.
b.
No action -
Ground-water barrier.
1. alurry vall. .
2 . pumping
Ground-vater racovary
1. on-.ita traat.ant
2. treatment at publicly-owned treatmant worka
Dradging ot conta.inated river .adi.ent.
-l~ on-.ita di.po.al
2. ott-.ita diapoaal
Rivar tlov control (flood protaction)
1. open channel.
2 . dika.
c.
d.
a.
-9-
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( PO'l'W)
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A.
TABLE 2
~CHNOLOGIES SURVIVING INITIAL SCREENING
A.a
SOURCE CONTROL MEASURES
A.t.lea)
A.t.2(a)
A.t.3(a)
A.t.3(b)
A.g.l
B.
No action
Surtace-qradinc; and revegetation, CELA and
SLA
Inatallation ot perimeter .lurry walla, CELA
and SLA
Inatallation ot RCRA .urtace cap, CELA and
SLA
Inatallation ot RCRA .urtace cap, SLA
relocated CELA
Landtill bank .tabilization with 80ditied
.lope.
B.a
MIGRATION MANAGEMENT CONTROL MEASURES
B.e.l
8.e.2
,No action
River tlow control with open channel.
River tlow control with dike.
- 1 0;:-
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TA'S..~ 1
-~...-
ADDITIONAL ALTERNATIVES - Vll, VIII, IX
Alternative Vll - 'RCRA Cap, Partial River Channelization
This alternative cmmbines a source control measure with a migration
management technology to produce a system attaining applicable public
health/environmental criteria. This alternative provides a clay liner, geofabric, and
leak detection layed on the surface of the Central Elevated LandfiU Area (CELA)
and the Southern LandflU Area (SLA). .
, The other feature of this alternative is the partial channelization of the
Genesee River from a point roughly opposite the southern tip of the SLA to the
existing ftood control structures below the northern tip of the landfUl site. This
feature widens the river in two stages and moves the river channel away from the
landflU site. For a schematic description of this river channeUzation, please refer
to Figure 3-12 and Appendix C-3-3 of the Feasibility Study report, dated August
1985.
RCRA Ca the CELA, Partial River
NYS DEC IS RECOMMENDING THIS ALTERNATIVE. Like alternative Vll, this
alternative combines a source control measure with a migration management .
technology, producing a system attaining applicable public health/environmental
criteria. The contents of the SLA would be excavated and placed on top of the
contents of the CELA. The area of the SLA would be ftUed and regraded with
clean fill from off-site. The surface of the combined landfill in the CELA would be
graded, covered with a RCRA cap and revegetated: The RCRA cap woul~ be of
the same characteristics as for alternative VII (clay liner, geofabric, and leak
detection) .
The other feature of this alternative is the partial channelization of the
Genesee River from the borrow pit area (south of the CBLA) to the existing ftood
control structures below the northern tip of the landfUl site. As ~ the case of
Alternative VII, this feature widens the river and moves the river channel away
from the landfill site. For schematic description of this river channelization, please
refer to Figure 3-12 and Appendix C-3-3 of the Feasibility Study report dated
August 1985.
RCRA Ca , the CELA, Full
This alternative combines a source control measure with a migration
management teclmology, producing a system attaining applicable public
health/environmental criteria. The source control measure Is Identical to that for
Alternative VII; excavation and placement of the contents of the SLA on top of the
CELA, filling the SLA with clean flU material and capping the CELA with a RCRA
cap and revegetation.
However, the migration management technology, for this alternative, Full
Channelizatton Is more redundant than Partial Channelization. As opposed to Partial
. Chsnnelization, Full ChanneUzation maintains. uniform width of 160 feet from the
borrow pit area (south of CELA) to the existing flood structures below the northern
tip of the landftU site. As in the case of other two Alternatives (VII. VIII). this
. feature moves the, river channel away from..the landfill site. For schematic
description of this river wcx-k. please refer to Figure 3-1 and Appendix C-3-2 of
the Feasibility Study report dated August 1985.
-,,-
-------
TABLE 4
REMEDIAL ACTIOII ALTERNATIVES
Alternative CoaDOnent Technoloaies
lIuaber USEPA PoliCY Reference
I No Action A.a No Action
'8.a No Action
.
II Alternative exceeding applicable A.f.2(a) Installation of periaeter I
public health/environaental slurry valls, CELA and SLA
criteria A.f.3(a) Installation of RCRA .urface
cap, CELA and SLA
8.e.l River flow control vith open
channel. (full channelization)
III Alternative attaining applicable A.f.l(a) Surface grading and revegetation
public healtb/environaental (includes clay'cap), CELA and SLA
I criteria A.f.2(a) Installation of perlaetar
~
N .lurry vall., CELA and SLA
I 8.e.2 River flow control vith
dike. (partial channelization)
IV Alternative attaining applicable A.f.3(a) Installation of RCRA .urface
publio health/environaental cap, CELA and SLA
criteria ' 8.e.l River flow control vith open
channel. (full channelization)
V Alternative ainiaizing contaainant A.f.l(a) Surface grading and revegetation
aigration and protecting public (includes clay oap), CELA and SLA
health/environaent but not A.g.l Landfill bank .tabilization
attaining applicable criteria vith aodified .lope.
VI Alternative ainiaizing contaainant A.f.l(a) Surface grading and revegetation
aigration and protecting public (include. clay cap), CBU and SLA
health/environaent but not 8.e.2 River flov control with
-------
~
.'
'-
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.'
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ii
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. .
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I
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I
t
: f
I
.
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:
.,
.
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",
;.
.: f
tl
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'.
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'''i
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,~
~,
It,
.;J
II.
~
Alternative
Number
VII
VIII
IX
TABLE 4 (CONTINUED)
REMEDIAL ACTION ALTERNATIVES
USEPA Policy Reference
Alterna~ive attaining applicable
public. health/environmental criteria
Alternative attaining applicable
public health/environmental
criteria
Alternative attaining applicable
public health/environmental
criteri a
A.f.3(a)
B.e.2
A.f.3(b)
B.e.2
A.f.3(b)
B.e.1
Component Technologies
Installation of RCRA surface
cap, CElA and SlA
River flow control with open
Channels (partial channelization)
,
Installation of RCRA surface cap,
SlA relocated to CElA
River flow control with open
channels (partial channelization)
Installation of RCRA surface cap,
SlA relocated to tELA.
River flow control with
-------
TABLE 5
... COST OECISIIII MA,a.. r. LAIIIIFILL snr IOO.M. ..lrMAn.s
.malA . II III II , II .. 'II VIIW!
-,c1lft'CII:
fe'I"lllt, t8 Slt..s,eclfle C8Rdltl811 load Good Good Good 1M 1M ... ~
""I"IIt, - .... fal,"" fllrJ84!M .
'ot..UII f.r lueelll Good fa I "'Good hlr/Good hi, . fal,
ILlY" 0' CoIIff.tIIC.,
o.o.."rat" r."'Or8lAC. I. 'oor r.oocl r100Cl Good fair"'" load load load
11811.r a.. luU..,
Operltl..1 ""'Irtllllltl LOll LOII/MDderlt. Low/MDcI.rui LOll LOIIlIWtrlt. L.. L.. Low
IapI...tIU.. fI.. I-tlls) - ".]0 Z4-]o
Desltn/Conltructl.. 4-1 JO.36 Z4-JO ]0-36 .1.Z4 14-]0 ,
AcIllIY_nt 0' IHlflell' 4-1 JO-26 Z4-]0 ]0-36 II.Z4 14-]0 24.]0 14-]0
Itsultl
, , ~I.-..-t and "'''e ""Itll;
-'
~ Short I... 18fIICti IC8IIStnlCtl.
,
relit'" - MY.,..
L.I' PoptlllC. (""'1"1, 10M Adv.n, Adven. Adwen. SIII"U, "w.,., Adv... "'.n.
I""'" ,It., 511"U, "'.rs. S""'U, Aft.,.1 SItIJllU, "'.rsl
..,.lltl....t-La". 10M SIl",U, Adw.n' 5II1"tl, Adw.rs, 511,lItl, Adv.rs, S"pU, Aft.,.,
. 18II1IIwlll. I" v'e'.',,)
"""11 '.rsH8I1 10M Poss"I, Adv.n. '0""11, AdWln. 'oll'bl, Adw.rs. 'OSl''', Aft.,., 'ossl'l, Mw... Possl'I, Aft,n. 'osslb', ....-
L.II 'I..t lad MII.llf. .... Ad.erSt AdwerSt A'"erle Adw.rs, "'.rs, Aft.rs. Advene
£allr888eIt-lt-LI". .... SlItI.U, Adv.n. SII!!"tI, Adwers, S'II"tl, After~' 10M S""'''r HIers. 51II11U, Adv.,.. SlIptl, Adveno.
L-. ,... I...e'l - IHllleI.1 """elal I...,tctll 1_lIdll
L8Cl1 PopuIIC. Aft'"' 1..lIclll lelleffct.1 1_lIct.1
'...la'I~I'-La". A.w,rs. I_ffelll leneflcl.. lelleflclal leNftelal ....ftelal 1...1I,lal Ientile I.,
. o,erl"'" '.n-I 110ft. 'osslbl, ".n. 'o"lbl, Uw.rs, IIoIIe 110M 10M 10M 'one
L.al ....., .... MU"". SII",U, Adwen. A'werSt A'wen. Adven. "WI'" . Adw.rs. Advln.
Adw.rs.
£al1.......t-at-L.". . Adw,rs. leNlleI.1 lellellelll le..llelll I_flctal 1...lIe'll I...flelll IetIIffelll
L8Cl1 L"" ... Adw.rse I_flctll 111II1Iel.1 I_flctll '-flcla' ...flclal . I...flct., IllIIffct.1
,
~
I
.
. I
j
'Jood
Fair
Poor
Beneficial
Adverse
High
'1oderate
low
- Alternative is well suited to meeting criteria under consideration.
Alternative is suited to meeting criteria under consideration.
- Alternative not well suited to ~eeting criteria under consideration.
- Alternative effectively contributes to health and safety or environment.
- Alternative negatively impacts ~ealth and \afety or environment.
Involves sophisticated mechanical equipment and logistical requirements.
Involves commonly ut3 1 mechanical equipment and logistical requirements,
-------
TABLE 6
Al T(IIIATlYt
I. 110 Actl....
CAPIT:S' Wi'::\..1H
MTIII StIIWIY or lAllor1L1! SIT[ 1[~DIAl AlT(RNATlvrS
.
II. Slur" IIllIs 11.4. U.OU
AeRA elp
rull ehinne"'ltl..
III. Slurry II.I's 10.703 II.'"
Surfue 'rld'",=
(ell, Clp)
P.rtlll Chlanel-
h.tloa
". RCIA c.p ,.- 1.490
full C~'nnell,.tl..
I ,. Surf.ce firldlng 7.150 8.044
..... ([I., e'f)
c.n 81n' Stlbl ".tl..
I (Ones)
'I. Sur'lce Gridlng
(CI'f e.p)
'.rt'. e.....I-
IlitlOII
1.-
11.703
'II. ICIA ClP
Pertlll a...,-
I uti...
8.506
1.900
"II. Ie loeltl.,. 0' SlA
- to CUA; IeIA CIII
on C[lA; 'Irtl.1
c~lnnell'ltlOll .,to
eUA
8.759
1.153
,...
leloelt_... ., SlA ? 254
to C(lA;~1A CIII
011 C(lAifull c""'l-
lutlOll upto [(LA
9.648
Continued .',r.tlOII 0'
cont.'nlnts to lir.lesre
River. lIot .'sruptlve 0'
e.lstlng pllnd .nd wIld-
life.
n I.hlltes relelSn to 'row. "'ghest cost
r.eaese~ "fer. H'ghl, technology IlternJt've.
d'srupt',e 0' estl- Sreetnt publIc
bllshed ~I.nt Ind .lld- hellth bene"ts.
I"e 011 lind' III SIte.
(It.'nltes relelses to.- 'ro," SltghU, lower
Gno!s... A!'er. Highl, technolOV level 0' confidence
disruptive of estl- thin AlternJtlve
bllshed pllnt Ind wlld- ID. II.
lIfe on llndflll SIte.
[I,.,..tes rele.ses "~I 110 groundwlter controls 'rowen ~ .ppl'clt'on
surflce runoff .ad IIIn' Highl, dlsruptlfe of technology la "ew 0' 11e1 0'
eros'OII. Public rls1 estlbllshed pllnt lad ,roundwlter cont--
.'nl.lled. wIldlife on llnd,'11 S'te. Inlat .'gr.t,on.
Controls relelSn ,I. 110 groundwlter controls Prowen lowest cost Ind
surflce runoff Ind Nn" No river fiNdIng technology lowest level 0'
Itst of ..ppsure e.'sts controls. Hlghl, dls- confIdence of .1'
durIng s..ere flood events ruptlve of estlbl'shed clpplnt/chennel-
pllnt Ind wIldlife on "It'on .Item-
llndflll SIte. Itlfes.
COIItrols relelses ,I. sur- 110 !,roundwlter controls 'rowen CCllllper.ble to
'.ee runoff Ind bin' Hlghl, dlsruptl,e of technology Alterftltlve ID. IV
erosIon. Publ'c rls' estlbl'shed pllnt .nd wIth lower lewel
.'n'.',ed. wIldlIfe on l.ndflll 0' COII"dence.
Site.
110 ,roundwlter controls 'row" Sltghtl, lower
HIgIII, disruptive of technology lewel 0' conftdenc..
estlbllshed pllnt Ind thin AlternJtl,e
wlldl'fe OR l.ndflll ID. I'.
Site.
Reduce tile l.ndfll1 'rowen SlIgIItI, hIgher
site b, .bout 2 lern; tecllnoi. I"el 0' confidence
110 groundwlter controls. thin Alternlt"e
HlglIl, dlsruptl,e of ID. VII.
estlbllshed pllnt Ind
.lldllfe OIl llndflll SIte.
Reduce the l.ndftl1 'rowen SlIghtl, higher
site b"lbout 2 leres. technoi. lewel 0' eonftdence
110 groundwlter controls. thin AlternlU'e
Highl, disruptive of 110. VIII. .
est.bll,h~ pllnt Ind
wildlife on llndflll Site.
PUIlIC
H£Al TN C_[IIS
484
Continued elPDSure ellsts
to r,'.fl'l-Ind flood-
Induced .'grltlon 0'
cont.'nents.
[I'.'netes relelsPS "I
III 8ed11. 'ubllc rls'
ell.'nlted.
[1,....tn relelses ,'.
III ..,... Publl~ r's'
ell.'nlted.
[1..,..tes rele.ses v"
lurflce runoff Ind bln1
erosIon. Public rls'
.,,,'.lIed.
[11.ln.tes relelses ,..
lurllce runoff Ind IIInll
eros'oa. Public rls'
.'n'.lIed.
[11.,..tes relleses .'1
lurf.ce runoff .nd bin'
erosl,... 'ubllc rls'
.Inl.',ed.
DlVIIIOK"AL
CCJfC(RIIS
OTH£I CCltDTS
nC_ICAl
C_EAIIS
lowest cost
-------
1. Corrment:
Response:
2. Corrment:
Response:
RESPONSES TO PUBLIC COMMENTS
ON
FEASIBILITY STUDY FOR SINClAIh lANDFIll SITE
WEllSVIllE, NEW YORK
Who will be responsible for monitoring and
maintaining the remedial structures (RCRA
cap, rip-rap, channels, etc.)?
During the first year after the remedial
measures' imp1e~entation 90 percent (90S)
of the maintenance and monitoring costs will
be borne by the EPA and 10 percent (10S) by"
the NYSDEC. After the first year, long-term
monitoring and maintenance costs will be borne
by the State of New York or some other
responsible entity capau1e of performing this
work and beari~g these costs.
What additional sampling is planned?
Additional sampling at the Refinery, off-site
tank farm and upstream of the site for
background characterization are planned.
The sampling includes surface water,
groundwater and surface and subsurface soil.
The work will begin immediately after funding
becomes available.
-------
-'
3. Comment:
What is the landfill?
Who was responsible
Response:
for the materials placed on the landfill?
At the Sinclair Site, the southernmost portion
of the property was used as a waste dump for
a variety of materials. Landfill activities
occurred throughout operational history of
the refinery, spanning greater than 58 years.
The larger landfilled area (9.2-acres) is
referred to a the Central Elevated Landfill
Area (CELA) and the area to the south
(2.3-acres) is called the South Landfill Area
. (SLA). These two (2) landfill areas are
seperated by an area reportedly used as a
borrow source.
Landfill activities apparently
continued long after the closure of refinery
operations. Aerial photographic evidence
from 1964, 1970, 1974 and 1982 indicated that
lagoon dredging, trench backfilling, additional
landfilling, and general regrading occurred
throughout this period. Additional landfilling
appears to be most extensive in the south
landfill area between the years 1970 and 1974.
How many chemicals were detected and at what
concentration levels?
4. Comment:
~7-
.. ... ~. ,'''''''''''' . .
".',' ...,..... --.--."
-," . "'"
-------
Response:
There were 62 chemicals identified at the
Landfill Site in waste, surface soil,
subsurface soil, groundwater or surface water.
For complete list and concentrations at which
they were found, please refer to Tables 1-3
to 1-5 of the Feasibility Study Report, dated
August 1985.
5.
Comment:
Were the same chemicals found at the landfill
Response:
as at the Refinery Site?
The Remedial Investigation at the refinery.
portion of the site is not complete.
However, .
based on the information available at this
time, most of the chemicals found at the
Landfill Site were also detected at the.
refinery.
6. Conrnent:
How far upstream were water samples taken?
Was contamination found?
Response:
Limited upstream water samples were taken
in the vicinity of Weidric Bridge, about
one-half mile upstream of the Landfill Site.
Analyses of these limited water samples,
indicate presence of no contaminants other
than phenol.
It is likely that abandoned
oil we1lfie1ds upstream may be source(s) of
the phenol. Additional background and upstream
sampling are planned.
-18-
. "......
-------
7.
Comment:
~\!sponse :
B.
Conrnent:
Response:
9.
Conment:
Response:
"":' .-- -:',',
Is public access to the river bank by the
landfill restricted?
Public access through the landfill to the
river bank is restricted by a fence.
However,
the river bank may be accessed through the
Genesee River.
Why were only six (6) alternatives developed
and evaluated while it is Possible to develop
more alternatives?
Three (3) additional alternatives were
developed and evaluated.
Please refer to
summary of the ResponSiveness Report for
detai 15.
The surface soil was not considered as a
pathway of contamination.
As reported on Page 1-45 and 1-46, the
concentrations of several chemicals are
excessively high in samples collected from
exposed waste drums and in Soil/sediment
samples collected from shallow pools atop
the CELA. Surface runoff of these contaminants
to the Genesee River is a major pathway of
contamination. However, since the Landfill
Site is fenced off, direct human contact with
the surface contamination is limited.
-19-
'.
. .,
..' . _.
. .
. ..' .._._---.._-~
'. ....
"'. ". . .......
. '. ~
..,., . .'
-------
10.
Comment:
Partial channelization of Genesee River as
proposed in Alternative VIII should be
carefully designed to control the flooding
Response:
and erosion of the RCRA capped CElA.
When remedial measures for the landfill Site
are designed, all necessary measures will
be taken to provide adequate protection to
prevent the flooding and erosion of the RCRA
capped landfill.
-20-
-------
I ..w:s~
I hue,,'
!'I.:'fC""'C
: CallCnni31 ..
I ........-. .-,...~
~....
, . .
... '1-,.:--. ...... .'
.' ",""',-. . ..
~
~
Nt\w York State Department of L'.tlronmental Conservation
50 Wolf Road, Albany, New York 12233.0001
Henry G. Willilms
Commillioner
Mr. Donald A. ~acFarquhar, P.E.
Director of Public Works
Village of Wellsville
Municipal 9uilding
156 North Main Street
P.O. Box 591
Wellsville. New York 14895
IrP 2~ 1985
Dear Mr. MacFarquhar:
Feasibility Study of the Landfill
Site-Sinclair Refinery Site,
Wellsville, New York
Thank you for your September 6, 1985 letter offering comments on the
subject report.
Re:
As I discussed with you in person on September 11, 1985 in Albany,
New York, the New York State Department of Environmental Conservation (NYSDEC)
developed and evaluated three additional alternatives. These three alternatives
are briefly described in Enclosure 1. Please refer to Mr. Bruce Bentley's
September 19, 1985 letter to you for more details of these alternatives.
.
In response to the Environmental Protection Agency's (EPA) request and in
the interest of securing the funding for Remedial Design during the 1985 Federal
fiscal year, after detail evaluation of all alternatives, the NYSDEC recommended
Alternative VIII-Relocation of SLA to CELA, ~CRA Cap and partial channelization
up to the borrow pit area, south of the CELA for the following reasons:
- The NYSDEC feels that partial channelization provides stable and ade-
quate rip-rap banks along both sides and eliminates the threats of land-
fill erosion and flood inundation.
Relocation of the contents of the SLA to tELA and filling and regrading
SLA with clean fill would enhance the source control measure by reducing
the landfill area.
- Relocation of the contents of the SLA to CELA eliminates/reduces
leachate generation currently calculated to be 1,100 gallons per day.
- Relocation of the contents of the SLA to CELA provides a greater
distance of separation between the SLA wastes and the groundwater.
Also, the soil ~eneath the CELA is less pervious than the soil ~eneath
the SLA, adding better protection against migration of SLA contaminants
to the groundwater.
-21-
. .
-(. -1""'--..... ....-........1.. .~..«. ..;.::.,.:~.",:~:!,,''':.J'';:~~'''~''.'.' .:.-.~...'...~~~!-!.I..t'-"'1I".~-:t:'~~.. -
'....~:....-:~."'....~..-:o~.~..:.. .:.~ ~~.'.~' 'r:.' '. ~':':I ~:.' ..... ~- ~~ -
- . .- - ;:::.'."':r"~".~":!'.'~:!' .-:--~ -.:. .' """"." ~--;s...",,!, ':'..1JIt!), '~''''''..~
-------
.Mr. Donald A. MacFarqu~ar
Page 2
o
- The RCRA CaPr which incorporates clay liner. geofabric and drainage
layer for leak detection. is designed to prevent essentially all
infiltration of rain water into the landfills. The NYSDEC feels that
clay caps with geotextile and lateral drainage layers have a lower
potent ia 1 for fa 11 ure .. .
~s. you pointed out in your letter. there is little leachate formation and a very
slow groundwater migration rate. However. during the Feasibility Study for the
refinery portion of the site. need for groundwater control at the landfill site
will be studied; if such ne,d is demonstrated. a cost-ef~ective groundwater
control at the landfill site will he considered as a remedial measure.
It is expected that the EPA will write a Record of Decision selecting a
cost-effective remedy for the landfill site by September 30. 1985. You will be
notified of the selection of the remedy after it is made by the EPA. If you have
any questions. please contact me at (518) 457-4343.
Sincerely.
..,.,.
~ab: ..ude.an,
Project Engineer
Bureau of Western Remedial Action
Division of Solid and Hazardous ~aste
Enc1 osure
cc: w/enc.: G. Pavlou. USEPA-Region 11
J. Singerman. USEPA-Region II
S. Rosenthal. SHC Martin
.- -22-
..
. . ... ~.." ~ : .~.: .':.'." . . . .
.. '~"'''' .-...
. ;:~ t
-------
ENCLOSURE 1
-
ADDITIONAL ALTERNATIVES - VII, VIII, IX
Alternative VII - RCRA Cap, Partial River Channelization
This alternative combines a source control measure with a migration
management technology to produce a system attaining applicable public
health/environmental cdteria. This alternative provides a clay liner, geofabric, and
leak detection layed on the surface of the Central Elevated Landfill Area (CELA)
and the Southern LandftU Area (SLA). .
The other feature of this alternative is the partial channeUzation of the .
Genesee River from a point roughly opposite the southern tip of the SLA to the
existing flood control structures below the northern tip ot the landftU site. This
feature widens the river in two stages -and moves the river channel away from the
landfill site. For a schematic description of this river channeUzation, please refer
to Figure 3-12 and Appendix C-3-3 of the Feasibility Study report, dated August
1985.
Alternative \'111 - Relocation of SLA to CELA, RCRA Cap the CELA, Partial River
Channelization
NYS DEC IS RECOMMENDING THIS ALTERNATIVE. Like alternative VII, this
alternative combines a source control measure with a migration management
technology, producing a system attaining appUcable public health/environmental-'
criteria. The contents of the SLA would be excavated and placed on top of the
contents of the CELA. The area of the SLA would be ftUed and regraded with
clean fill from off-site. The surface of the combined landfill in the CELA would be
graded, covered with a RCRA cap and revegetated. The RCRA cap would be of
the same characteristics as for alternative VII (clay liner, geofabric, and leak
detection) .
The other feature of this alternative is the partial channelization of the
Genesee River from the borrow pit area (south of the CELA) to the existing flood
control structures below the northern tip of the landfill site. As in the case of
Alternative VII, this feature widens the river and moves the river channel away
from the landfill site. For schematic description of this river chann~Uzation, please
refer to Figure 3-12 and Appendix C-3-3 of the Feasibility Study report dated
August 1985.
Alternative IX - Relocation of SLA to CELA, RCRA Cap, the CELA, Full
C hannel1zatton
This alternative combines a source control measure with a millf!'ation
management technology, producing a system attaining applicable public
health/environmental criteria. The source control measure Is Identical to that for
Alternative VII; excavation and placement of the contents of the SLA on top of the
CELA, ftUing the SLA with clean flU materia1 and capping the CELA with a RCRA
cap and revegetation.
However, the migration management technology, for this alternative, Full
Channelization is more redundant than Partial Channelization. As opposed to Partial
ChanneUzation, Full ChanneUzation maintmns a uniform width of 160 feet from the
. borrow pit area (south of CELA) to' the existing flood structures below the northern
tip of the landftU lite. AI in the case ot other two Alternatives (VII, VIII), this
feature moves the river channel away from the landnn site. For schematic
. description of this river work, please refer to Figure 3-1 and Appendix C-3-2 of
the Feasibility Study report dated August 1985.
~
-23-
. ~. . .
. -~~
-------
ROBERT G GARDNER
Mayor
(716) 593"881
RAL,PH C. RUGABER
Trustee
WM G. HENDRICK
Trust..
JOHN A. MEL.ARO. JR.
Trustee
TIMOTHY J. COLLIGAN
Trustee
(,
JANICE A. GIVENS
ClerIC - Treasurer. Registrar
(716) 593-1121
SUE E. BARNHART
Deputy ClerIC - Treas.. Registrar
DONALD A. MacFAROUHAR
Dorector 01 PubliC. WorkS
(716) 593-1850
JUDITH M. SERVEY
JuSllCe
(716) 593-2055
ANNE M. BRADDOCK
AHorney
(716) 593-2636
W. JOSEPH EMBSER. JR.
Attorney
(116) 593-1900
STEPHEN L. MARGESON
ell'el 01 Pohce
(716) 593-5600
MICHAEL P. FINN
Water ancl Lignt Dep\.
(716) 593"950
THOMAS R, BRADDOCK
Zoning Ollicer
(716) 593-225<1
KENNETH T. SMITH
Assessor
(716) 593-225.
WILLIAM D. DORNEY
BUlld.ng InSDlcto'
(7' 6) 593-225.
VILLAGE OF WELLSVILLE
MUNICIPAL BUILDING IS8 NORTH MAIN
..., 0ffIc. ... 5"
WELLSVILLE. NEW YORK
I 48SU5
September 6, 1985
Dr. Chittibabu Vasudevan
New York State
Department of Environmental
50 Wolf Road
Albany, N.Y. 12233-0001
Conservation
Dear Dr. Vasudevan:
We have reviewed SMC Martins rer.0rt "Feasibility
Study for the Sinclair Landfill Site' and wish to
offer our comments. We agree that options II and IV
included in Table E-4, Matrix Summary of Landfill
Site Remediation Alternatives are technically
acceptable and cost effective and will, when combined
with a new water intake, provide an environmentally
sound solutio~ to the problems of the Sinclair -.
Landfill Site.
It is our feeling that the greatest potential
for the migration of pDllutants from this site will
occur in a flood environment and consequently
feel that full channalization allowing for right
bank ov.erflow is an important element of an acceptable
solution.
The report concludes that there is little
leachate formation and a very slow ground water
migration rate. Addition of the RCRA Cap should
further minimize infiltration and ground ~ater migration.
Slurry walls add another measure of insurance
against off site ground water' migration but they do
not appear to be absolutely necessary given the
present low migration rates. If slurry walls are
not included what is the future potential for leachate
discharge from the site and how would it be handled1
Yours trul~
,d£l~ ..~
D.A. MaC~q r, P.E.
Director of Public Works
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New York State Deplrtment of Environmental Con.ervatlon
50 Wolf Road, Albany, New York 12233.0001
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Henry G. Williams
CommiSSioner
Mr. Arthu~ F. Pope
Manager, Environment and Health
ARCO Petroleum Products Company
515 South Flower Street
Box 2679 - T.A.
Los Angeles, CA 90051
Dear Mr. Pope:
SEP 2 5 191~
Feasibility Study of the Landfill Site
Sinclair Refinery Site, Wellsville, New York
Thank you for your September 13, 1985 letter received by this
office via telecopier on September 17, 1985.
RE:
Enclosed are the Department's responses to your comments on the
subject study. The responses are numbered in accordance with the
numbering of your letter and enclosure of September 13.
If you have any questions, please contact me at 518-457-4343.
Sincere:y, . ~11 ,iiJ
~u v~ evan, Ph.D., P.E.
Senior Sanitary Engineer
Bureau of Western Remedial Action
Division of Solid and Hazardous Waste
Enclosure
cc: w/incoming and w/enclosure
G. Pavlou, USEPA, Region II
J. Singerman, USEPA, Region II
S. Rosenthal, SMC Martin Inc.
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RESPONSES TO ARCO'S COMMENTS CONCERNING
DRAFT - FEASIBILITY STUDY FOR
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- SINCLAIR LANDFILL SITE, WELLSVILLE, NEW YORK
RESPONSES TO GENERAL COMMENTS
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1. Relocation of the Wellsville's raw water intake to upstream of
the site addresses the public health threat to the public water
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supply. The relocation of raw water intake does not address the
threat of surface water contamination. The environmental
contamination and other health concerns from the Landfill Site
are assessed by the Feasibility Study Report which evaluates several
remedial technologies and alternatives in order to identify
cost-effective remedial measure(s) for the Landfill Site.
2. The primary objective of the Remedial Investigation (RI) at the
Landfill Site was to characterize the nature and extent of the
contamination present at the Landfill Site; the objective of the
Feasibility Study (FS) is to evaluate remedial technologies and
alternatives to identify cost-effective remedial measure(s) to
protect the public health and environment from the contamination.
"
At the Sinclair Site, the southernmost portion of the property
was used as a waste dump for a variety of materials. Landfill
activities occurred throughout operational history of the refinery,
spanning greater than 58 years. The larger landfilled area
(9.2-acres) is referred to as the Central Elevated Landfill Area
(CELA) and the area to the south (2.3-acres) is called the South
Landfill Area (SLA). These two (2) landfill areas are seperated
by an area reportedly used as a borrow source. Landfill activities
apparently continued 10ng after the closure of refinery opeations.
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Aerial photographic evidence from 1964. 1970. 1974 and 1982
indicated that lagoon dredging. trench backfilling, additional
landfi1ling and general regrading occurred throughout this period.
Additional landfilling appears to be most extensive in the south
landfill area between the years 1970 and 1974. Adequate
investigation of disposal activity and subsequent land use after
1958 has been conducted to aid in desi9ning the remedy for the
Landfill Site.
RESPONSES TO SPECIFIC COMMENTS
I. Executive Summary
1. Because lateral and vertical movement of groundwater through
the waste matrix of the CELA is limited and lateral drainage
from SLA to the Genesee River via the upper aquifer is
approximately 1.600 gallons/day. it is concluded that a pathway
of significant contaminant migration between the waste/soil
,
and the groundwater does not appear to exist at this time.
The last sentence of Point 3 on Page £-2 should read:
"A pathway of significant contaminant migration between the
waste/soil and the groundwater does not appear to exist."
However. during the Feasibility Study for the refinery portion.
of the site. need for groundwater control at the Landfill Site
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will be studied; if such need is demonstrated. a cost-effective
groundwater control at the Landfill Site will be considered
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as a remedial measure.
2. Please add the following sentence to Point 6 on
Page E-2 "Chemical analyses of the samples taken from the waste
drums indicate that very few contaminants were present in the
drummed material."
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II.
Introduction
1. Table 1-1 on Pages 1-9 reports that approximately
SOO_gallons/week, ~ 500 gallons/day, of tank sludges were
deposited in the Sinclair Refinery Landfill. This information
is based on interviews with former employees of the Sinclair
Refinery.
2. The objective of the FS is to identify cost-effective remedial
measure(s) to remediate the landfill Site. The extent of
the remedial measure partly depends on the magnitude of the
contamination. Highest concentrations are indicative of the
magnitude of the contamination and hence these are presented.
3. The terms, significant, minor amounts, high concentrations,
excessively high, are to be simply viewed as qualitative.
Generally these terms are used with reference to background
concentration values of the contaminants. The statement on
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Page 1-27 liThe concentrations of most of the metals in the
surface water and groundwater were either not detected or
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had concentrations under 30 ppb (with the anomalous exception
of zinc which was 4,100 ppb in one groundwater sample, possibly
due to contact with the galvanized steel well casing)." should
be replaced by:
-The concentrations of most of the metals
in the surface water and groundwater were either not detected
or had concentrations under 0.32 ppm (with the anomalous
exception of zinc which was 2.64 ppm in one groundwater sample
possibly due to contact with the galvanized steel well
casing)." The above statement summarizes the data presented
in Table 1-5 for metals in groundwater and surface water.
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4. This FS Report was prepared in accordance with the
E~vironmental Protection Agency's (EPA) Guidance on Feasibility
Studies under CERlA, April 1985. This guidance calls for
the presentation of site background, nature and extent of
the problems prior to the presentation of criteria and
standards. The FS Report follows the EPA's guidance.
S. The FS Report does refer to the results from analyses of air
samples collected during the RI and suggests that contamination
of the air medium has not occurred (Page 1-46). Page 1-47
of the report refers to the biological tests. Details c.
the bilogical t~sts may be found in the Phase I Remedial -.'
Investigation Report, dated March 1985.
6. The comment refers to the risk assessment of human exposure
of the chemicals. The objective of the FS Report is to
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identify cost-effective remedial measures. The remedial
criteria were developed to be consistent with the objective
of remediating the landfill Site.
7. The New York State Department of Health (NYSDOH) has
established 5 ug/l of benzene as maximum allowable limit in
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potable water. The non-detectable criteria for benzene is
in accordance with class GA groundwater quality standard from
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6 NYCRR, Part 703, based on best use as source of potable
water supply.
8. An example of the mathematical method to calculate soil
criteria is provided in Enclosure 1.
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9. The long-term Environmental/Public Health impact as outlined
on Page 2-5 was utilized to evaluate each remedial
alternative's (which is a combination of complementing
technologies) effectiveness to meet the remedial criteria
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and objectives as outlined in Section 1.6 in addition to the
environmental and health issues associated with the
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implementation of the remedial alternative.
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ENCLOSURE 1
AN EXAMPLE OF THE MATHEMATICAL METHOD
TO CALCULATE SOIL CRITERIA
Reference: Kenaga, E. E., and Goring, C.A.I., "Relationship Between
Water SOlubility, Soil Sorption, Octanol - Water Partitioning, and
Concentration of Chemiclas in Biota." Special Technical Publication
707-ASTM, pp: 78-115,1980
Definition: The "soil sorption coefficient- (Koc) or "partition
coefficient" is the concentration of chemical sorbed by the soil
expressed on a soil organic carbon basis divided by the concentration
of chemical in soil water.
o There is abundant evidence that neutral organic substances are sorbed
principally by soil organic matter and that distribution coefficients
are useful for judging their relative susceptibility for leaching.
o Despite the complexity of the sorption process in soil, a good
relationship has been found between the organic matter of soils and
their capacity to sorb most organic chemicals.
o Variability in sorption coefficients expressed on the basis of the
organic carbon content of soil can be expected more for ionic organic
chemicals than for non-ionic organic chemicals.
o Despite the above-mentioned limitations in soil sorption coefficients
based on the organic content of soil, they represent the best way
currently avaiTable for comparing the sorption characteristics of
chemicals and development of soil criteria in the absence of any
documented soil criteria.
o The relationship:
10g Koc . 3.64 - 0.55 (10gS)-------(1)
Where S. water solubility of the chemical (ppm)
correlation coefficient "r" . - 0.84
n- number of compounds used. 106
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The 95 percent confidence limit for the calculated value is ~ 1.24
orders of magnitude
Cs . kot x f x Cw-------(2)
Where Cs . soil criteria in pbb
Cw . surface water/groundwater criteria in ppb
.
f . organic carbon in the soil expressed as a fraction
o Organic carbon content is assumed for the site as 1/20
Note:
log is the 10grithm to the base of 10.
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Enclosure 1
(Continued)
Given Data~
Example 1:
Chemical: 4.4' - ODD
Water Solubility (S) . 0.160 ppm
Water Criteria (Cw) . 0.001 ppb
Organic Carbon Content. 0.05
Substituting the S value in Equation 1, Koc is calculated to be
11,960; subsituting Koc, f and Cw in Equation 2, Cs is calculated
to be 0.6 ppb.
Example 2:
Chemical: 4,4' - DOE
S = 0.0013 ppm
Cw = 0.001 ppb
Using the same procedure as for Example 1,
Koc . 168,784
Cs . 8.4 ppb
Observation:
o Inverse relationship between water solubility and partition
coefficient. .
o An organic chemical with higher solubility is more leachable
from the soil than a low soluble organic compound.
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ARCO Petroleum Product. Comp.ny
S1S South Flower 9Ir..'
MIlling Addr...: Box 2671 . T.A.
LOl Angel... C.llforni. i0051
T".pho". 21! .813511
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September 13, 198'
Dr. Chittibabu Vasudevan
New York Sute
Department of Environmental Conservation
'0 Wolfe Road
Albany, NY 12233-0001
Dear Dr. Vasudevan:
A nached are ARCO Petroleum Products Company comments on the draft report
entitled, "Feasibility Study for Sinclair Landfill Site, Wel1svUte, New York."
Our major concern with this Study is that it does not consider the impact of the
potential relocation of the City's drinking water intake on the proposed remedial
measures. With relocation of the intake, the app~rent drivinl force to take
extensive remedial action at' the landfill is signficiantly reduced.
A second general concern is that the state continues to associate aU the waste
types, volumes and contaminants found in the landfll1 with past refinery
operations and neglects over twenty flve years 01 disposal, and industrial and
other use of the property by as yet unidentified parties after the refinery
closed. We have also attached a number of specific comments for your
considera tion.
If you have any questions, please contact Mr.. David Smith of my staff at
(21 J) ,.86-191'.
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Sincerely,
G~- ~~'-
Manaaer, Environ~~al th
AFP/mr
CCI
D. A. Smith
AP 3319
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- ARCO Petroleum Products Company
Comments on The Draft Feasibility StudY for Sinclair Landfill Site
WelJsville, New York
General Comments
1.
The draft report does not consider the impact of the potential relocation 01 the
WeUsville's drink1ng water intake to upstream of the site. The report neither
identifys it as a potential remedial measure nor considers the possible reduction in
the nature of remedial action needed. The impact of relocation of the intake should
be incorporated if'lto the final report.
Neither the RI or FS attempts to identify materials disposed' in the landfills after
the closure of the refinery in 19'8. All the waste types, volumes and contaminants
are erroneously associated solely with p~st refinery operations. Twenty seven years.
0'1 disposal activity and uses of the property by others have been overlooked ,by
these reports. The final RifFS rc~.~orts should include a comprehensive investi~ation
of disposal acti'~ity and s'JbseQuent land use after !.2.H:.
2.
Specific Comments
I.
Executive Summary
1.
Statements in the third and eighth point 01 the Executive Summary
appear to contradict one another. Point three states: "A pathway 01
contaminant migration between the waste/soil and ,he cround water does
not appear to exist." Point eight Itates ". . . . leachate migrating frorn
the SLA would total approximately 1700 gallons/day." How can 1700
gallons/day migrate if there is no pathway? Please clarify.
Point 6 should reflect the conclusion on paRes 1-29 thru 1-30 tha t '/ery
few contaminants were present in the drumrned rnaterial.
2.
II.
Introduction
1.
Neither the Remedial Investigation aU) or Feasibility Study (FS) supports
the findings in Table .1-1 that '00 gallons/day of .tank siudses, and
several dum p truck loads dally of oil-soaked soil 4!nd sludges were
disposed at the landfill. The reported volurnes should be deleted.
In describing the nature and extent of the landfill's probrem in Section
1.' the worlt case scenario has been presented, (i.e., highest detected
concentrations are reported). We believe it is misleading to only define
the extent/nature of a problem thru the worst case. There is 00
direction in either the National Contlgency Plan or EPA's "Guidance on
Feasibillty Studies under CERCLA, April 198'" that suggests such an
approach is necessary or advisable. The report in some cases
exa~gerates the problems by at l~st 2 or 3 tilD.!!..Jorexalnplea
2.
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'Comments on The Draft FeasibBity Study
\\'el1sviUe, New York
Page 2
Media
ARSENIC CONCENTRA TrONS. ppb
Actual
Ranae in RI
Averaae
Draft FS
Subsurface Soils
Surface Soils
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3.
Throughout the description 01 the landfiH problems in Section 1.'
qualitative Staternents without adequate basis or criteria are used to
evaJuate contamination. For eQmpJe:
a.
. Pale 1-23. "Priority pollutant's are present in significant.
quanti ties." "'ha t is significant and why?
Page 1-2'. "Four media displayed retatively minor amounts of . . ."
What is minor and why? .
b.
c.
Pale 1-27 "... had concentrations under 30 ppb..." Why i$ 30
ppb im portant?
Page 1-)'1 "... cOIn pounds detected in high conCentrations..."
What is high and why are they c:onsidered important?
d.
e.
Page 1-.' ".. selected metals are excessively hiteh..." wha t i~
excessively hiah, and is it important?
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The dIscussion of Airborne Contaminant Transport in Subsection 1.'.'
makes no reference to the ehree air quality samples taken directly over
the landfill. Similarly, the di:scussion makes no reference to the
biological tests of the animaJ population in the area. Subsection J .,.,
should be revised to include the findin_s from both t_hese tUts.
For a given chemicaJ (i.e., arsenic) the same enironmental crheria and
nandArds are to be used for aU three pathways into the human bod}' Ci.e.,
skin absorption, injestion, or inhatation). This is inconsistent with the
draft EPA January 24, 1'8' document entitled, "Public Health Process,
Procedural Manual". This document clearly indic.ues that when
evaluating the h~;lards/risks to the public for a liven Chemc1al, different
criteria for the three exposure pathWilYS .re~roprilte and necessary.
The FS should evaluate and use. when .~ ro riate different criteria f r
the three eXPOsure ,athways.
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Comments on The Draft Feasibility Study
Wellsvi11e, New York
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7.
Table 1-10, page 1-49 presents the criteria for groundwater and $urface
water. The nondectectable (NO) criteria for benzene is inconsistant with
the '.Oug/l guideline used in reporting river water benzene analysis to
the public, and referred to in the April 29, 19U final report entitled,
"Cancer Incident in Wellsville, N. Y. Final Report'.
8.
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