United States Environmental Protection Agency Office of Emergency and Remedial Response EPA/ROO/R02-89/097 September 1989 $EPA Superfund Record of Decision ------- REPORT DOCUMENTATION 1" REPORT NO. . I ~ 3. RecIpient'. Acceulon No. PA(aE EPA/ROD/R02-89/097 4. Title and Subtitle 5. Report Date SUPERFUND RECORD OF DECISION 09/29/89 Marathon Battery, NY 6. Third Remedial Action - Final ,. Author(a) B. Perfonning Organization Rept. No. II. Perfonnlng Orgalnlzatlon Name and Addre.. 10. ProjectlTaaklWork Unit No. 11. Conttact(C) or Gnnt(G) No. (C) (G) 1~ SpmwII'Ing Org8nlz8tlon Name and Addre.. 13. Type of Report & Period Covered U.S. Environmental Protection Agency 800/000 401 M Street, S.W. Washington, b.c. 20460 14. 15. Supplementary NoIe8 16. Abatract (Umlt: 200 worda) The Marathon Battery site is a former battery manufacturing plant in Cold Spring, Putnam County, New York. The site is composed of three study areas: Area I, which consists of East Foundry Cove Marsh and Constitution Marsh; Area II, which encompasses the former plant, presently a book storage warehouse, the surrounding grounds, and a vault with cadmium contaminated sediment dredged from East Foundry Cove; and Area III, which includes East Foundry Cove (48 acres), West Foundry Cove and the Hudson River in the vicinity' of Cold Spring pier and a sewer outfall. Contamination in Area III 'emanates from plant wastewater that was discharged v1a the city sewer system into the Hudson River at Cold Spring Pier or, in some instances, through a storm sewer into East Foundry Cove. A Record of Decision (ROD) was signed for Area I in September 1986 with cleanup activities to includes dredging the East Foundry Cove Marsh. The second ROD for this site was signed in September 1988 and included decontamination of the battery plant and soil excavation in Area II. This 1989 ROD represents the third and final operable unit for the site and. addresses sediment contamination in Area III. The primary contaminants of concern affecting sediment at the site are metals including cadmium and nickel. The selected remedial action for the site includes dredging of approximately 55,000 n1' ~~A~~,,~_---""--' ~ .. !':pn;mpnt' in E.::!!':t" tf'nnt-in"orl nn noxt- n::>t"To\ 17. Document Analyala L Deacriptora Record of Decision - Marathon Battery, NY Third Remedial Action - Final Contaminated Media: sediment Key Contaminants: metals (cadmium, nickel) . b. klentifteraiOpen-Ended Terma c. COSA 11 ReIdIGroup 18. AvailabiUly Statement 1 II. Security CIa.. (Thla Report) 21. No. 01 Page. None 58 20. Security Cia.. (Thl. Page) ~ Price Nnno 212 (4-77) 50272-101 (See ANSl-Z3I1.18) s..tMtrucll"". on Re".,... (Formerly NTlS-35) ------- EPA/ROD/R02-89/097 Marathon Battery, NY 16. Abstract (Continued) ,Foundry Cove to a depth of one foot, followed by onsite chemical fixation and offsite lisposal; sampling and analysis of the area adjacent to and under Cold Spring pier and dredging approximately 900 cubic yards of cadmium-contaminated sediment from this area followed by treatment with East Foundry Cove sediment; sediment monitoring and performance of a hydrological study of Area III to determine if West Foundry Cove is a depositional area and in need of remediation; and long-term sediment monitoring. The estimated present worth cost for this selected remedy is $48,499,500, which includes ------- ~ Name: Location: HRS Score: NPL Rank: ROD Date signed: Remedy: Capital Cost: o & M/Year: Present Worth Cost: LEAD EPA Remedial Primary contact: Secondary contact: Main PRPs: .PRP Contact: WASTE Type: Medium: origin: . Est. quantity: ROD PACT SHEET Marathon Battery Company Cold Spring, N.Y. #656 9/29/89 Dredging, fixation, and off-site disposal. $25.6 million (dredging and facility construction) $21.4 million (1st year--facility operation) $132,700 (years 2-30--maintenance & monitoring) $48.5 million Pamela Tames, (212) 264-1036 Douglas Tomchuck, (212) 264-7508 Marathon Battery Co., Gould, and U.S. Army Jeff Civins, (512) 495-8400 Cadmium, nickel, and cobalt Sediments Nickel-cadmium battery facility. 56,000 cubic yards -,'."'."..'C' ,"'. ------- DAlC: SEP 26 1989 . . UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION II .1 SUB.ECT: Record of Decision for the Marathon Battery Company Site FROM: Stephen D. LUftig, Director Emergency and-Remedial Response Division William J. Muszynski, P.E. Acting Regional Administrator SCfj TO: The Marathon Battery Company site is located in the Village of Cold Spring, Putnam County, New York. My staff has prepared the attached Record of Decision (ROD) for the Area III portion of the site, which includes East Foundry Cove, West Foundry Cove, and the Hudson River in the vicinity of the Cold Spring pier and sewer outfall. I have concurred on the ROD, and I am forwarding it to you for your signature. RODs for the Area I (Constitution Marsh and East Foundry Cove Marsh) and the Area II (the former battery plant and surrounding grounds, the adjacent residential yards, and the vault containing contaminated sediments from prior dredging activities in Foundry Cove) portions of the site were signed in September 1986 and September 1988, respectively. The remedy selected for Area I involves continued monitoring for Constitution Marsh, and dredging of the cadmium-contaminated sediments in East Foundry Cove Marsh, followed by chemical fixa- tion and off-site disposal. The remedy selected for Area II involves decontamination of the interior of the former battery plant building and its contents, excavation, chemical fixation, and off-site disposal of the vault and the cadmium-contaminated soils on the plant grounds and the adj acent residential yards, and excavation, enhanced volatilization, and replacement of the volatile organic-contaminated soils on the plant grounds. The design of the remedy selected for Area I was completed in April 1989. The design of the remedy selected for Area II is currently be~ng negotiated with the potentially responsible parties (PRPs). The remedial investigation and feasibility study (RI/FS) for Area III was prepared by EPA's contractor, Ebasco Services, Inc. Pamela Tames is the EPA Remedial Project Manaqer for this project. As you will recall, you were briefed on the findings of the RI/FS and the Proposed Plan for Area III on June 20, 1989. The public comment period, which began with the release of the RI/FS report and the Proposed Plan on June 28, 1989 and July 10, 1989, respec- tively, ended on August 21, 1989. Comments that were expressed at the July 19, 1989 public meetinq, as well as those that were expressed in letters that were received during the public comment period indicate that the general public supports those alternatives which will remove the cadmium-contaminated sediments from Area III. II8JION II FORM 132C)a1 (818&) ------- -2- The attached ROD, which was prepared based upon input from the New York state Department of Environmental Conservation (NYSDEC), the New York state Department of Health, Environmental Impacts Branch, Water Management Division, Air and Waste Management Division, the Office of Regional Counsel, and the Agency for Toxic Substances and Disease Registry, reflects the recommendations of the Emergency and Remedial Response Division to address the contamination problems associated with Area III. NYSDEC's conCUrrence letter for the Proposed Plan is attached. NYSDEC'sconcurrence letter for the ROD will be forthcoming. The major components of the selected remedy can be summarized as follows: . .- . . Dredging of cadmium-contaminated sediments from East Foundry Cove to a depth of one foot, thickening of the dredged sediments, on-site fixation, and disposal off- site... . . - . . Collection, analysis, and evaluation of supplemental sediment samples adjacent to and beneath the Cold Spring pier and the sewer outfall to ascertain the extent of cadmium-contaminated sediments that present a threat to human health and the environment. The supplemental . sampling will also be used to determine the amount of dredging necessary in the Hudson River adjacent to the pier arid the Cold Spring sewer outfall. If the sediments underlying the Cold Spring pier are also determined to present a threat to public health and the environment, dredging of those contaminated sediments, fixation, and off-site disposal will be performed. post-dredging sampling and restoration to the original contours, as necessary, in the areas that are dredged. Replanting, as necessary. . Monitoring and a hydrologic study of Area III to as- certain whether West Foundry Cove is a depositional area. If sediment transport presents a threat to the environment, further action may be necessary in this area. ------- -3- Since the PRPs contend that they were released from liability in an earlier co~rt case, they declined to unde~take the desiqn for Area I. Since the Area III desiqn is beinq considered a revision and supplement to the Area ~ desiqn, the PRPs will not be offered the oPportunity to undertake the Area III desiqn work. Upon completion of the Area III desiqn, the PRPs will be otfered the oPportunity to implement the remedial action tor both areas. To incorporate the Area III remedy into a consolidated desiqn will take approximately nine months. Since funds tor the implementation ot the remedy will not be available upon completion ot the consoli- dated desiqn, it is unknown when the remedy will be implemented. My statf and I are available to discuss the particulars of this site with you at your convenience. Attachment " . '.~. . , .. - - '" "," " ,.' . . ------- DBCLARATIOB POR THE RECORD OP DBCISION I S:ID BAMB AHD LOCATION Marathon Battery Company, Cold Spring, Putnam County, New York. 8'1'ATBKBRT OF BASIS AHD PURPOSB This decision document presents the selected remedial action for the Area III portion of the Marathon Battery Company site. The selected remedy was developed in accordance with the Comprehen- sive Environmental Response, Compensation, and Liability Act, as amended by the Superfund Amendments and Reauthorization Act (CERCLA), and to the extent applicable, the National Contingency Plan (NCP). .. . . The attached index identifies the documents Administrative Record for Area III. The Administrative Record are the basis for the action. that comprise. the documents in the selected remedial The State of New York concurs with the selected remedy. ASSBSSMENT OF ~ SITB Actual or threatened releases of hazardous substances from this site, if not addressed by implementing the response action selected in this Record of Decision, may present a current or potential threat to)public health, welfare, or the environment. DESCRIPTION OF THE SBLECTBD REMEDY This operable unit is the third planned for the site. . The remedy selected for the first operable unit in East Foundry Cove Marsh involves dredging, chemical fixation, and off-site disposal of the cadmium-contaminated sediments, and no action for Constitution Marsh (Area I). The remedy selected for the second operable unit (Area II) involves decontamination of the interior of the former battery plant building and its contents, excavation, chemical fixation, and off-site disposal of the vault and the cadmium- contaminated soils on the plant grounds and adjacent residential yards, and enhanced volatilization and replacement of the volatile organic-contaminated soils. The third operable unit includes East Foundry Cove, West Foundry Cove, and the Hudson River in the vicinity of the Cold Spring pier and sewer outfall (Area III). This action addresses the elevated levels of cadmium that are present in Area III sediments. The major components of the selected remedy, which will address the cadmium-contaminated ------- Dredging of cadmium-contaminated sediments. from. East Foundry Cove to a depth of one foot, thickening of the dredged sediments, on-site fixation, and disposal off- site. . . .. Collection, analysis, and evaluation of supplemental sediment and beach samples adjacent to and beneath. the Cold Spring pier and the sewer outfall to ascertain the extent of cadmium contamination that presents a threat to human health and the environment. The supplemental sampling will also be used to determine the amount of dredging necessary in the Hudson River adjacent to the pier and the Cold Spring sewer outfall. If the sediments underlying the Cold Spring pier are also determined to present a threat to public health and the environment, dredging of those contaminated sediments, thickening, fixation, and off-site disposal will be performed. . Post-dredging sampling and restoration to the original contours, as necessary, in the areas that are dredged. Replanting, as necessary. . Monitoring and a hydrologic study of Area III to ascer- tain whether West Foundry Cove is a depositional area. If contaminated sediment transport presents a threat to the environment, further action may be necessary in this area. Long-term monitoring of East Foundry Cove, West Foundry Cove, and the Cold Spring Pier Area. The data compiled for East Foundry Cove indicate that over 95 percent of the cadmium contamination is located in the upper layer (1 foot) (30 centimeters (em» of the sediments. Due to the nature of the dredging process, dredging to a specific action level (e. g. , . 10, 100, or 250 milligrams per kilogram (mg/kg) of cadmium) within this narrow range of depth would be technically difficult, since these concentrations vary in the sediments by only a few inches of depth. By dredging the upper layer (1 foot) of contaminated sediments, 95 percent of the cadmium contamination will be removed. Similarly, the data compiled for the Hudson River in the Cold Spring Pier area indicate that most of the contamination is located in the upper layer (1 toot) of the sediments. However, little is known about the sediments beneath the Cold Spring pier. Therefore, more than one foot of sediment may have to be dredged. As a result, it is anticipated that the cadmium concentrations will not exceed 10 mg/kg in nearly all of the dredged areas. ------- DECLaRATION consistent with CERCLA and the NCP, I have determined that the selected remedy is protective of human health and the environment, attains federal- and state requirements that are applicable or relevant and appropriate to this remedial action, and is cost- effective. This remedy satisfies the statutory preference for remedies that employ treatment that reduces toxicity, mobility, or volume as a principal element and utilizes permanent solutions and alternative treatment technologies to the maximum extent practicable. . Because this remedy includes a comprehensive long-term monitoring program, the five-year review will not apply after completion of the remedial action. f- ;)7-11 Date 3 ------- RBCORD OP DBCISIOIf SUJIK1Ry HARATHON BATTERY COMPANY SITE - AREA III COLD SPRING I PUTNAM COUNTY I NEW YORK UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION II ------- TABLE OF CONTENTS site Location and Description... .~... .. . . . . . . . . . . . Site History and Enforcement Activities"....... community Relations History......~............. Scope and Role of Operable Unit................ site Characteristics........................... Summary of Site Risks.......................... Documentation of Significant Changes............ Description of Alternatives......... ............ Summary of the Comprehensive Analysis of Al ternati ves. . . . . . ~ . . . . . . . . . . . . . . . .' ~ ~ . . .'. . . . . . . Selected Remedy.. .'. . . . . . . . . . . . . . . . .. '. . . . . . . . . . . . Remediation Goals............................... Statutory Determinations............. .0. . . . . . . . . References. . . . . . . . . . . . . .' . . . . . . . . . . . ... it". . . . . . . . . bsm 1 2 6 7 7 11 14 15 22 29 31 31 33 ATTACHMENTS A - Figures B - Tables C - Administrative Record Index D - NYSDEC Letter of Concurrence E - Responsiveness Summary ~ ------- . RECORD OF DECISION \ MARATHON BATTERY COMPANY SITE NEW YORK 8ITB LOCATIO. AND DESCRIPTION SITE LOCATION The Marathon Battery Company site is situated in the Village of Cold Spring in Putnam County, New York. It is across the Hudson River and slightly north ot the United States Military Academy at West Point, and approximately 65 kilometers (40 miles) north of New York City. The site is located within the incorporated boundaries of Philipstown (Figure 1). SITE DESCRIPTION The site is comprised of three study areas: Area I, which consists of East Foundry Cove Marsh and Constitution Marsh; Area II, which encompasses the former nickel-cadmium battery plant, presently a book storage warehouse, the surrounding grounds, a vault with cadmium contaminated sediments dredged from East Foundry Cove in the 1970s, and adjacent residential yards; and Area III, which includes East Foundry Cove, West Foundry Cove and the Hudson River in the vicinity of the Cold Spring pier (Figure 2). This Record of Decision CROD).. addresses the Area III portion of the site. .. Foundry Cove, a shallow bay and cattail marsh on the east bank of the Hudson River across from West Point, is composed ot east and west components. East Foundry Cove is partially isolated from West Foundry Cove and the Hudson River by a railroad bed to the west. The 20 hectare (ha) (48 acre) East Foundry Cove consists of approximately 5 ha (12 acres) of marsh to which the plant's outfall discharged, and 15 ha (36 acres) of tidal flat and Cove. The exchange of water between East Foundry Cove and West Foundry Cove during flood and ebh tides is through a 10 meter Cm) (33 foot) passage under a Metro-North railroad trestle and a channel system which connects Foundry Cove to Constitution Marsh, a 117 ha (281 acre) AUdubon Society Sanctuary to the south. Located to the north of the site is the residential/business district of Cold Spring. The eastern boundary of the site includes the Old Foundry, a national historic site. Water depths in West Foundry Cove and the HUdson River in the vicinity ot the Cold Spring pier range from 0 to about 6 m (20 feet ------- shore. The main channel of the Hudson River in this area averages between 20 and 80 m (65 to 262 ft) in depth. The Cold Spring Pier Area is in an eddy zone created by the pier at the south end of this area and encompasses an area of 110 m (361 ft) taken from the pier. Similarly, West Foundry Cove is in an eddy area created by Constitution Island. These slow flow eddy areas have a significantly higher deposition of contaminants. Water circulation between Foundry Cove and the Hudson River is mainly influenced by a tide of 1 to 1.5 m (3.3 to 5 ft), exposing a considerable portion of the East Foundry Cove bottom at low tide. Because of the shallow water depths in the Cove, almost one third of the Cove bottom is covered with aquatic plant growth and is considered an emergent wetland. SITH HISTORY AND BNPORCBMENT ACTIVITIES The source of contaminants found throughout Area III emanates from wastewater that was discharged by the former battery manufacturing plant, where nickel-cadmium batteries were manufactured from 1952- 1979. The plant I s wastewater treatment system originally consisted of a lift station and piping for transfer of all process wastewater into the Cold spring sewer system for discharge directly into the Hudson River at the Cold spring pier. In addition, a by-pass valve was installed so that when the lift station was shut down or overloaded, a direct gravity discharge could be made into the Kemble Avenue storm sewer for discharge into East Foundry Cove. The battery manufacturing facility was designed and constructed in 1952 by the U.S. Army Corps of Engineers (USACE) for the U.S. Army Signal Corps. Initial operation of the facility was contracted by the Signal Corps to Sonotone corporation. The first batteries manufactured were used in the NIKE Missile Program, and other missile programs. In 1957, the facility began production of aircraft batteries for military jet fighters. In september 1962, Sonotone Corporation purchased the plant and its equipment from the United States. In 1963, thirty-five thousand square feet of production area were added and production of nickel-cadmium batteries for commercial customers was initiated. In December 1967, Sonotone became a wholly-owned subsidiary of Clevite, Incorporated (Clevite) which operated the facility for slightly over 18 months. In July 1969, Clevite merged with Gould, Incorporated (Gould): however, Gould was required to divest itself of the plant due to its ownership of other battery facilities. As a result, the plant appears to have been operated by Gould for only one week. In July 1969, the plant was sold to Business Funds, Incorporated, which subsequently changed its name to Marathon Battery Company. Production increased to near capacity in Cold Spring, and expansion of the assembly operations was undertaken in Waco, Texas. ------- Eventually, all operations were transferred to the Texas plant. The last manufacturing operations were performed in the Cold Spring facility during March 1979. The facility, with the equipment removed, was purchased in November 1980 by Merchandise Dynamics, Incorporated (Merchandise Dynamics) for use as a book storage and distribution facility. Merchandise Dynamics has filed for Chapter 7 bankruptcy. On September 22, 1970, a complaint was filed (70 Civ. 4110) in the U.S. District Court for the Southern District of New York, by the United States against Marathon Battery Company At Al for violation of Sections 407, 413, and 441 of Title 33 of the United States Code (Refuse Act). The complaint sought preliminary and permanent injunctive relief, enjoining and restraining the "discharge or deposit of any alkali, or any salt of nickel, cadmium or cobalt...directly or indirectly into Foundry Cove or the Hudson River" and ordered Marathon Battery Company and the other defendants to remove the "deposited salts, and any other refuse or debris deposited in Foundry Cove." A Final JUdgment was filed in 1972, which required Marathon Battery Company, Sonotone, Clevite, and Gould to remove contaminated sediments to a concentration of 900 milligrams per kilogram (mg/kg) from the outfall area adjacent to the discharge pipe, the channel leading to the main body of Foundry Cove, and a portion of Foundry Cove. Marathon Battery Company, Sonotone, Clevite, and Gould, participated in the limited cleanup of Foundry Cove. In response to a report filed with the Court on behalf of the defendants, the United States filed a Satisfaction of Judgment, stating that "the defendants...are deemed to have complied with the terms of the Final Judgment, as amended, with respect to the removal of the deposits of cadmium from Foundry Cove and are relieved from any further obligation with respect thereto." (REI, 1983). The Army was not named as a cO-defendant in the United States' suit. Marathon Battery Company, Sonotone Corporation, Clevite, and Gould alleged that the Army had participated in damaging Foundry Cove by engineering and approving the plant design and by constructing the plant. Between November 1972 and July 1973, dredging was conducted. The dredged sediments were mixed with 0.5' limestone and were buried in an asphalt and clay-lined underground vault on the plant property. A fence was placed around the vault. The surface of the vault was to be aaintained in perpetuity by the property owner and monitoring was to be conducted by the New York State Department of Environmental Conservation (NYSDEC). Studies conducted trom 1976 to 1980 by NYSDEC, the United States ------- Environmental. Protection Agency (EPA), and New York University indicated, however, the East Foundry Cove was still contaminated, much of it at concentrations greater than 900 mg/kg (900 parts per million (ppm»~ In October 1981, the Marathon Battery Company site was included on the Interim National Priorities List. Subsequently, EPA and the state of New York signed a cooperative Agreement to undertake a remedial investigation and feasibility study (RI/FS) at the MaratHon Battery Company site. In 1983, in response to an informal complaint regarding possible employee illnesses associated with cadmium exposure, the Occupa- tional Safety and Health Administration (OSHA) took air samples during routine and maintenance work in the warehouse. These data showed that exposure levels of cadmium, lead, and nickel were below OSHA's permissible exposure limits. Based upon these sample results, OSHA concluded that, although there was evidence of heavy metal contaminated dust in the facility, the only potential exposure was to workers involved in maintenance operations. OSHA advised that these employees should wear respiratory equipment while performing dust-producing activities. In 1984, in order to investigate the feasibility of remediating the. site, NYSDEC contracted with Acres International Corporation (Acres) of Buffalo, New York, to perform a Remedial Investigation and Feasibility Study (RI/FS). Area II sampling efforts in the summer of 1985 identified contamination both inside the building in the dust (cadmium and nickel concentrations as high as 120,000 mg/kg and 130,000 mg/kg, respectively) and outside in the sur- rounding soils. In August 1985, a draft RI/FS report was prepared by Acres. Because the FS contained insufficient information to evaluate effectively the effects of remedial alternatives under considera- tion, the USACE was tasked to expand upon the study by further evaluating the technically feasible means of remediating Foundry Cove and constitution Marsh. The USACE completed this technical assistance in February 1986. In March 1986, following a contractual dispute with Acres, NYSDEC requested that EPA assume the lead responsibility for the project. EPA I S contractor, Ebasco Services, Inc. (Ebasco), completed a supplemental RI/FS for the East Foundry Cove Marsh/Constitution Marsh portion of the site (Area I) in August 1986. On september 30, 1986, a ROD was signed for this portion of the site. The selected remedy includes dredging of the contaminated sediments from East Foundry Cove Marsh followed by chemical fixation of these sediments and off-site disposal, as well as a no action alternative for Constitution Marsh. ------- An analysis of the data from the former battery facility by the Agency for Toxic Substances and Disease Registry (ATSDR) in late June 1986 led to the recommendation that the facility be closed immediately to all personnel not in personal protective equipment, until the cadmium levels were below occupational standards and guidelines. On July 3, 1986, EPA advised OSHA of the levels of cadmiua detected in the warehouse, referring the project for immediate action. In July 1986, OSHA performed an investigation of the warehouse. Air and wipe samples were collected. Results from the air sampling showed levels of cadmium in the employees' breathing zone to be below OSHA's occupational exposure criteria. Because of the proximity of the local residences to the former battery facility, on July 9-10, 1986, the EPA Technical Assistance Team (TAT) collected twenty-two surface soil samples from the yards of residences on Consti tution Avenue and the Boulevard. TAT inspected the warehouse and took soil and air samples around the perlaeter of the facility. Results from this investigation showed no detectable levels of cadmium in the air, and concentrations ranging to 600 mg/kg in the soil. Supplemental field activities for Area II were initiated in late 1987, and were completed in April 1988. A ROD for this operable unit was signed on September 30, 1988. The selected remedy includes decontamination of the interior of the former battery plant building and its contents, excavation and chemical fixation of the vault and cadmium-contaminated soils on the plant grounds and nearby residential yards, enhanced volatil ization of the volatile organic-contaminated soils, and off-site disposal of the treated waste. No action was selected for the groundwater underlying the site. In February 1988, in response to the notification by the Cold Sprinq fire department, EPA conducted an investigation of the sprinkler system within the battery facility. EPA, concerned that a fire could result in a release of dust to the environment, inspected the facility and verified that the sprinkler system was inoperable. Demand letters for past costs by EPA and NYSDEC were sent to the Potentially Responsible Parties (PRPs) in September 1988. Marathon and Gould have refused to pay any costs associated with Areas I and III, contending that they were released from liability in the federal district court case, 70 Civ. 4110, as discussed above. Marathon Battery Company, Gould, and Merchandise Dynamics, were issued a unilateral order in March 1989 to decontaminate the former battery facility and its contents, as called for in the ROD for Area II. Recently, Merchandise Dynamics, was found to be in noncompliance with the order due to its unauthorized removal of ------- . books from the facility. ENSR, the contractor for Marathon and Gould, bas commenced work in compliance with the Order. Negotiations with the PRPs for the design and construction of the remaining portions of the Area II remedy are currently ongoing. Marathon Battery company, Gould, and the USACE have cooperated in supplying information and meeting with the Agency to comment on the proposed remedial alternative. BXGBLXGKTS OP ooMMUHITY PARTXCIPATXON The governmental effort to ensure significant community involvement in Cold spring has been extensive. A comprehensive public relations strategy was developed by EPA to keep concerned parties cognizant of CERCLA activities at the site. The EPA maintains three public information repositories in Cold Spring. They are located at the Cold spring Village Hall, Philipstown Town Hall, and The Preservation and Revitalization of the Cold Spring Area office (PROCO). Other repositories are. maintained at NYSDEC offices in Albany and EPA offices in New York city. A community group, Concerned ci tizens Action to Remove Toxins (CCART), received a Technical Assistance Grant (TAG) for $50,000 on February 2, 1989 to hire a technical advisor to assist in explaining to the public the results of the studies. The public is also kept informed through frequent public meetings. The RifFS report and proposed Plan were released for public comment on June 28, 1989 and July 11, 1989, respectively. The notice of availability of these documents was published in the citizen Reaister on July 13, 1989. A public meeting was held on July 19, 1989 to discuss the results of the RIfFS, the preferred alternative for the Area III portion of the site, and to solicit public comments. A more detailed discussion of the outcome of this public meeting as well as the questions and concerns raised by the public during the public comment period, can be found in the Reponsive- ness summary, which is part of this ROD. The public comment period was originally scheduled to close on August 1, 1989, but was extended to August 21, 1989 at the request of the PRPs and the general public. 8ooP. AND ROLB OP OPBRABLB UNIT As stated, the site has been divided into three areas, addressed as separate operable units. EPA has already selected remedies for Areas I and II. The design of Area I is currently being completed, and the performance of the design and the remedy for Area II is the ------- subject of negotiations with the PRPs. The third operable unit addresses the contaminated sediments in East Foundry Cove, West Foundry Cove, and the Cold Spring Pier Area. This area of the site poses a threat to\the environment and human health due to risks from the possible ingestion of fish, blue crabs, and cadmium-contaminated suspended sediments in the surface water during water sports. The purpose of this response is to prevent potential exposure to the contaminat~d sediments. SUMKARY OP SIT. CBARACTBRI8TIC8 The ~/FS was prepared by EPA's contractor, !basco, in May 1989. Surface and subsurface soils, sediment and surface water were sampled during the RI. In addition, fish were sampled and bio- assays were performed using contaminated sediment. All media were found to be contaminated to various degrees. Cadmium contamination in the sediments of East and West Foundry Coves and the Pier Area is of greater concern than cobalt and nickel contamination because cadmium is more toxic. Nickel concentrations in surficial sediments are generally of the same order of magnitude and vary in parallel with cadmium concentrations. East Foundry Cove is contaminated to a greater extent than West Foundry Cove or the Pier Area. Surface water cadmium, cobalt, and nickel concentrations are not affected by sediment-bound contamination. No differences could be found from background Hudson River metal concentrations or from wet weather storm events during the RI/FS. The sediment is predominantly a silt sized particle with substantial quantities of clay. No RCRA listed wastes were found on-site. SEDIMENTS Sixty sediment samples from East Foundry Cove, two hundred eight sediment samples from throughout the Cold Spring Pier Area, and eighty-nine samples from West Foundry Cove were analyzed and evaluated for Area III. In addition, sediment samples were collected from the Hudson River within an area extending from Wappingers Falls to Croton Bay to determine whether additional cadmium deposition areas existed. All samples were analyzed for cadmium, cobalt, and nickel. Table 1 shows the range of cadmium contamination in Area III. East Foundry Cove sediment samples were collected at nineteen locations by Acres in 1985 at three regular intervals down to a depth of 50 centimeters (em) (19.7 in) (see Table 2). As part of the bioassay tests performed by Ebasco in 1988, nine sediment samples were collected in the East Foundry Cove and analyzed (see Table 3 and Figure 3). Al though these samples were analyzed under special analytical service procedures and not subjected to EPA's quality assurance and quality control process, they confirm the ------- resul ts of the Acres samples. In addition, as part of the remedial design for Area I, Malcolm Pirnie collected thirty-one confirmatory sediment samples in May 1989 (see Table 4 and Figure 4). Only the data points located within East Foundry Cove were used to determine the extent of contamination. These data show that cadmium contamination ranges from 0.28 mg/kg to 2700 mg/kg with a mean of 179.25 mg/kg and a median of 5.6 mg/kg for all depths. The mean for each sampled depth is 439.4 mg/kg (0- 10 em), 50.5 mg/kg (10-25 em), and 2.1 mg/kg (25-50 em). The major portion of the contamination is found in the upper layer of the sediment. In fact, at the 10-25 em depth, only six samples exhibited cadmium contamination at levels greater than 3.8 mg/kg. Nickel concentrations ranged from 47.9 to 1369 mg/kg, and cobalt from 14.5 to 75.7 89/kg. In the Hudson River in the area of the Cold spring Pier, samples from eighty-five locations, covering about 465 acres, were collected at reqular intervals down to a depth of 137 em (53.94 inches). Cadmium contamination ranges from 1.2 mg/kg to 1,030 mg/kg, with a mean of 12.6 mg/kg and a median of 3.9 mg/kg for all depths. It should be noted that only 6 of the 208 samples showed levels of cadmium above 20 mg/kg. Cobalt and nickel contamination ranged from 7.5 mg/kg to 70 mg/kg and 15 mg/kg to 193 mg/kg, respectively. The vast majority of the contamination was found in the upper layers of the sediment. At depths below 50 em (19.7 inches), the highest level of cadmium found was 8.1 mg/kg. The sediment underlying the Cold spring pier will be sampled and analyzed during the Area III design phase. In West Foundry Cove, forty-three locations were sampled at regular intervals down to a depth of 94 em (37 inches). Cadmium contamination ranged from 1.1 mg/kg to 569 mg/kg with a mean of 43.9 mg/kg and a median of 4.2 mg/kg for all depths. Cobalt and nickel contamination ranged from 5.9 mg/kg to 33 mg/kg and 16 mg/kg to 381 mg/kg, respectively. The contamination in West Foundry Cove appears to be evenly dispersed vertically throughout the sediment. West Foundry Cove is believed to act as a depositional area. In order to determine the impact of tidal flow on cadmium deposition in backwater cove areas of the Hudson River, sediment samples were collected from seven locations up river from the Village of Cold spring. At each location, samples were recovered at two depths (0-10 and 40-50 em) and analyzed for cadmium, cobalt, and nickel. Cadmium concentrations ranged from 1.3 to 6.4 mg/kg, cobalt ranged from 10 to 17 mg/kg, and nickel from 22 to 40 mg/kg. These concentrations of metals are consistent with metal concentrations found elsewhere in the Hudson River, and are not considered site-related contamination. . In addition, sediment samples were also collected down river from the Village of Cold spring at nineteen locations along the river ------- banks and ten locations in mid-channel. Fifty samples were recovered from two depths (0-10 and 40-50 em), where possible, and were analyzed for cadmium, cobalt and nickel. Cadmium concentrations ranged from 1.3 to 29 mg/kg; cobalt concentrations ranged from 5.2 to 20 mg/kg, and nickel concentrations ranged from 16 to 47 mg/kg. These values are consistent with normal background levels found in the Hudson River and not considered to be site- related. Sediaent samples from all three subareas were collected for analysis to investigate whether the .ediments contain compounds which may not be compatible with the treatment alternatives considered as part of the FS. The results of this analysis, which are presented in Table 5, indicate that no significant contamination by other inorqanic elements is present in area sedi..nts. The majority of organic compounds detected are polycyclic aromatic hydrocarbons (PABs) and are believed to be the result of petroleum products spilled in the Hudson River by boat, barge, shipping traffic, and land-based runoff, not from site- specific discharges. GRAIN SIZE ANALYSIS Sediaent grain size samples were collected in the Pier Area and West Foundry Cove to aid in determining what effect dredging may have on down river transport of resuspended sediments. The percent by weight of gravel (> 2 millimeters (mm», sand (2- 0.062 mm), silt (0.062-.002 mm) and clay « 0.002 mm) in the sixty samples that were collected was calculated. The results show that sil t is the most abundant fraction in the maj ori ty of sediment samples, followed by clay, sand, then gravel. The ranges, means, and standard deviations of the fraction weight percentages are as follows: Standard Ranoe Hun Deviation Silt: 51.89 - 88.48t 65.93 + 5.60 t Clay: 6.73 - 34.36' 24.88 + 6.24 t Sand: 4.19 - 15.42t 8.00 + 2.57 t Gravel: 0 - 26.01t 1.17 + 4.35 t During dredging operations, certain amounts of the dredged sediment may be introduced into the water column. Due to the nature of the sediaents, sediment transport will be evaluated during design of the remedial action with the qoal to minimize resuspension of sediments. ------- SURFACE WATER Surface water .amples were collected from five locations during August and September 1987, during dry and wet weather, and during ebbing and flowing tides. Fifty-seven samples were analyzed for cadmium, cobalt, nickel, total suspended solids, and several for hardness. The concentrations of cadmium, cobalt, and nickel are generally less than 4 micrograms per liter (ug/1) except in six cases. The highest level was 67 milligrams per liter (mq/l). lIe Fish samples were collected at four locations. All fish were analyzed for cadmium, cobalt, and nickel, and showed below detection limit results (less than 1.0 mg/kq) for all three metals, no matter where the fish were collected. Although only Fundulus were to be collected, all fish caught were saved for analysis. Interference from matrix effects prohibited the laboratory from attaininq a detection limit lower than 1.0 mq/kg. The Acres' study (1985) also sampled Foundry Cove finfish for metal contamination. Resul ts revealed elevated levels of cadmium in muscle tissues of fish up to 0.320 uq/q while fish sampled from outside the Cove never exceeded 0.1 uq/q. ~ Soil samples were taken from beneath the Village of Cold spring's storm sewer. To evaluate the possibility that the corrosive nature of the wastewater from the battery plant may have deteriorated the storm sewer line on Main Street to the point where wastewater might have also entered the underlying ground, six locations were sampled at two foot intervals down to a depth of sixteen feet. Samples were analyzed for cadmium, cobalt, and nickel. The hiqhest concentration of cadmium was 3.8 mg/kg and the mean for all samples was 1.4 mg/kg. In addition, the results for cobalt and nickel also did not indicate significant concentration in the soil. Three samples were also collected from the sand on the beach near the COld spring Pier. Two samples were collected at 0-6 inches and one sample was collected at 12-18 inches in depth. All samples were analyzed for cadmium, cobalt and nickel (see Table 6). cadmium concentrations ranqed from 2 mg/kq to 12 mq/kg with a mean of 7. 3 mq/kg. Cobal t ranqed from 3.9 mq/kq to 8 . 9 mg/kq, and nickel from 10 mg/kg to 33 mg/kq. 10 ------- 8UKM1Ry 0. SIT. RISKS A public health evaluation was performed usinq the basic methodoloqy described in the Superfund Public Health Evaluation Manual, incorporatinq data from the site investiqation and previous studies. The information cited in this ROD is expanded upon in Chapter 6 of the supplemental RI/FS. Based upon the results of the remedial investiqation, the Pier Area and East and West Foundry Cove sediments were determined to be contaminated with cadmium, cobalt, and nickel. Contamination was also detected in area crabs and fish. Based on environmental features and the surroundinq location of these areas and orqanisms, alonq with possible activities and concerns of nearby residents, the followinq exposure pathways were considered: - Inqestion of fish cauqht in the Foundry Cove/Pier Area - Inqestion of Blue Crabs cauqht in Foundry Cove - Inqestion of contaminated surface water/suspended sediments durinq water sport activities CONTAMINANT IDENTIFICATION Due to the aquatic nature of East and West Foundry Coves and the Pier Area, the media of concern are limited to surface water and sediments. The analytical results of surface water samples collected from Area III and the Hudson River were qenerally below 5.0 uq/1 for cadmium. This is below the applicable standard of 10.0 uq/1 for cadmium in drinkinq water. In addition, most of the metals in Hudson River waters are bound to resuspended particulate sediments. Therefore, surface water is not considered a medium of concern unless it contains resuspended sediments. Cadmium and nickel are considered the contaminants of concern in the sediment found in East Foundry Cove, West Foundry Cove, and the Pier Area. These metals were chosen because they were detected at elevated concentrations, were found in qreater than 25 percent of the samples analyzed, were present in the effluent from the former battery manufacturinq process, and are known to cause adverse human health effects (EPA, 1981: EPA, 1983). Renal dysfunction is the most typical and severe effect of chronic low- level cadmium exposure. Cobalt, althouqh present in the media of concern, was detected on- site at concentrations below cadmium and nickel, and is also recognized as an essential nutrient. Therefore, cobalt was not evaluated as a contaminant of concern in the risk assessment, but it should be noted that remediation of cadmium and nickel will 11 ------- reduce cobalt concentrations. Levels of cadmium and nickel vary widely over the study areas included in Area III. In West Foundry Cove, cadmium sediment concentration ranged from 1.1 to 569 mg/kg with a mean of 43.9 mg/kg. Nickel concentrations ranged from 16 to 381 mg/kg with a mean of 65.3 mg/kg. Cadmium concentrations in the pier Area ranged from 1.2 to 1,030 mg/kg with a mean of 12.6 mg/kg. All samples except six contained 20 mg/kg of cadmium or less. Nickel levels detected were between 150 and 1,260 mg/kg with a mean of 36.8 mg/kg. East Foundry Cove exhibited cadmium concentrations between 0.28 mg/kg to 2700 mg/kg with a mean of 179.25. The Spring 1989 sampling, by Malcolm Pirnie, although not considered in the risk assessment, is consistent with the earlier sampling data. EXPOSURE ASSESSMENT As previously stated, three exposure pathways were evaluated in the risk assessment. They consist of the ingestion of blue crabs, ingestion of fish, and the ingestion of suspended sediments. For each intake route, potential health impacts were evaluated using site and contaminant-specific models. Latin hypercube sampling" (LHS) was then used to determined the range of uncertainty for the input variables. Since only site-specific values should be considered in the risk assessment, actual fish" and water contamination values could not be used since both area fish and Hudson River water are exposed to additional sources of contamination. Therefore, to obtain the site-specific fish and water data necessary for the risk assessment, the site sediment contamination data was modelled to aquatic species consumed by man or suspended in the water column. The potentially exposed population that was evaluated consisted of adults who crab, fish, and swim in the Foundry Cove area. The cumulative frequency figures for children do not vary from the adul t figures. Therefore, all presented results apply to both adults and children. Exposure via these pathways was assumed to be limited to a 3 month fishing/crabbing/swimming season, with a minimum use of 1 day per year, maximum use of 91 days per year, and a median of 24 days. TOXICITY ASSESSMENT Since ingestion is the only contaminant pathway considered, and ingested cadmium and nickel are not considered carcinogens, only reference doses (RfDS) are used in the risk assessment. RfDs have been developed by EPA for indicating the potential for adverse health effects from exposure to chemicals exhibiting noncarcinogenic effects. RfDs, which are expressed in units of mg/kq/day, are estimates of lifetime daily exposure levels for humans, indicatinq sensitive individuals. Estimated intakes of chemicals from environmental media (e.q., the amount of a chemical ------- -, ingested from contaminated drinking water) can be compared to the RfD. RfDs are derived from human epidemioloqical studies or animal studies to which uncertainty factors have been applied (e.g., to account for tQe use of animal data to predict effects on humans). These uncertainty factors help ensure that \ the RfDs will not underestimate the potential for adverse noncarcinogenic effects to occur. The RfD for cadmium is 1.0E-03 mq/kq/day for inqested food and 5.0E-04 mq/kq/day for water. The acceptable intake tor nickel is 2.0£-02 mq/kg/day. The normal dietary intake for cadmium can range trom 7.1E-05 to 1.4£-04 mq/kq/day and trom 4.3E-04 to 8.5E-03 for nickel. When the normal dietary intake is added to the chronic daily intake for each of the contaminant pathways, the resulting fiqure will show whether the RfD has been exceeded. The data show that the blue crab and sediment ingestion pathways are of little concern because they have little probability of exceeding an acceptable intake. The fish pathway remains as the critical exposure pathway for the area. For all exposure pathways, the acceptable intake of nickel might be exceeded approximately 15' of the time. Working backwards, it is possible to calculate acceptable sediment concentrations which are protective of human health~ In Area III, the resultant fiqure is 220 mq/kq for cadmium. A similar analysis was not conducted for nickel due to its lesser toxicity and bioaccumulation rate. In addition, any recommended remedial action for cadmium would also apply to nickel. . Potential concern for noncarcinogenic effects of a single contaminant in a single medium is expressed as the hazard quotient (HQ) (or the ratio of the estimated intake derived from the contaminant concentration in a given medium to the contaminant's reference dose). By adding the HQs for all contaminants within a medium or across all aedia to which a given population may reasonably be exposed, the Hazard Index (HI) can be generated. The HI provides a useful reference point tor gauging the potential significance of multiple contaminant exposures wi thin a single mediua or across media. ENVIRONM!;NTAL RISKS Sediaent bioassays were conducted on four freshwater estuarine species (CeriodaDhnia dubia. Selanastrum caDricornutum. Cranaog ~ and PimeDhales Dromales) to determine the concentra- tions of cadmium, nickel, and cobalt in sediment which adversely aftect aquatic organisms. Thirteen sediment samples were collected from Foundry Cove and the Pier Area and one from Wappingers Falls (reference location) and used in the bioassay tests. Samples were recovered from the top 6 inches of sediment. Based on the resul ts ------- of those tests, it was concluded that a level between 10 and 255 mq/kg of cadmium in the sediment would protect the environment. Research performed for EPA (JRB, 1984) established sediment criteria for cadmium based upon limiting concentrations in water to levels below EPA Ambient Water Quality criteria. Preliminary results have shown that sediment cadmium toxicity decreases with increasing organic content. Therefore, for a total organic carbon (TOC) concentration of 5', the chronic sediment cadmium criterion was found to be 38.5 mg/kg, and at a TOC of 10', the chronic level was found to be 77 mg/kg. Ebasco's field results showing an average TOC value of 9.4' for this area would imply that a cadmium concentration somewhere in the range of 73 mg/kg would be required to prevent chronic exposure. The proportion of cadmium found in the sediment to that in aqueous solution in the marsh, however, will depend not only on TOC, but on other site-specific factors, including water chemistry, pH, oxidation/reduction potential, and temperature. Therefore, the model for partitioning based upon simplifying assumptions will only approximate site-specific cadmium criteria (ERT, 1986). NYSDEC feels that even at 10 mg/kg of cadmium in sediments there may be adverse ecological impacts. The shortnosed sturgeon (AciDenser brevirostrum), an endangered species since 1967, occurs in the Hudson River from Troy to Piermont, a range of 125 miles which includes the site. Because it is a bottom feeder, and benthic organisms accumulate cadmium, exposure to si te contamination is possible. However, since critical life stages (e.g., juveniles and larvae) and over- wintering individuals do not congregate in the Foundry Cove area, it is expected that the site contamination may not have a significant effect on these fish. DOCUKBHTATION OP SIGNIPICAHT CHANGES Based upon the requirements of CERCLA section 117 (b), EPA has determined that significant changes have not been made to the selected remedy from the time that it was proposed in the Proposed Plan until final adoption of the remedy in the ROD. D.SCRIPTION OP ALTERNATIVES As previously stated in the summary of site risks, the contami- nants which pose a significant health and environmental threat are cadmium and nickel in sediments. Because cadmium occurs in the sediments in equal or greater concentrations than nickel, and because cadmium is more toxic than nickel, nickel was not evaluated for all the alternatives. Remedial objectives which control cadmium will effectively deal with the lesser health and environmental problems posed by nickel and will also reduce cobalt concentrations. . Based on the results of. the site investigation, and the public 14 ." '. -"., . "," .' .., ..- '''','''" ;. . .~ : . ,.,' " -...' -,,' - . . . . "1 ", , . ------- health and environmental evaluations, the remedial objectives are: Reduce cadmium in sediments to protect aquatic organisms and. protect human health. - Reduce the transport of suspended sediments from East and West Foundry Coves and the Pier Area. For the rs, Area III Cove, West Foundry actions, including disposal oprions, redeposition, were was divided into three subareas: Ea~t Foundry Cove, and the Pier Area. Six alternative no action, contaminant removal/treatment/ and acid extraction and disposal and/or evaluated for each subarea. These alternatives are described below: EAST FOUNDRY COVE Alternative EFC-l: No Action The Superfund program requires that the "no-action" alternative be considered at every site. Under this alternative, EPA would take no further action to reduce the levels of. sediment contamination in this subarea. Human access to East Foundry Cove would be restricted. A fence would be erected along the shoreline, preventing access to the cove by land. Signs would be posted instructing people to avoid contact with cove sediments, and to avoid consuming fish caught in the cove. Maintenance for this area would include a yearly ecological survey and a water and sediment sampling program for a period of 30 years. The present worth cost to implement this remedy is $1,241,700, and the remedy can be completed in 3 months. This alternative complies with action-specific ARARs. Because this alternative would result in contaminants remaining on-site, CERCLA requires that the site be reviewed every five years. If justified by the review, remedial actions may be implemented at a later time to remove or treat wastes. Alternative EFC-2: Containment Under this al ternati ve, containment of contaminated sediments would be accomplished by constructing a mUlti-layer cap. The cap would consist. of a geotextile layer, an Armorform (TM) layer or its equivalent, and a foot of sand. This alternative would be executed . in accordance with federal and New York State dredging and flood hazard area construction practice requirements. Also, during construction of the cap, silt curtains would be utilized to meet Clean Water Act Section 401 certification water quality standard requirements. 15 , '" ------- This alternative, with a present worth cost of $16.5 million, would take approximately 28 months to implement. Alternative BPC-31 Dredaina. Thickenina. On-site Fixation. Off-site DisDosal Under this alternative, contaminated sediments would be dredged to . a depth of one foot and thickened. During design, further analysis of the environmental effects of the contamination will be done to ascertain the precise areal extent of the dredging necessary to protect the environment. The data compiled for East Foundry Cove, to date, indicate that over 95' of the cadmium-contamination is located in the upper layer (1 foot) of the sediments. Due to the nature of the dredging process, dredging to a specific action level (e.g., 10, 100, or 250 mg/kg of cadmium) would be technically difficult, since these concentrations vary in the sediments by only a few inches. Therefore, expectations are that by dredging the upper layer of the sediments, 95' of the cadmium contamination would be removed. Approximately 55,000 cubic yards (cy) of sediment would be removed if the entire Cove needed to be dredged to a depth of 1 foot.", During dredging, the goal will be to minimize transport and suspension of contaminated sediments. silt curtains will be utilized during dredging to contain resuspended sediments. " Treatment of the dredged sediment would consist of three maj or components: thickening, fixation and clarification. During the thickening process theclreclged sediment is dewatered. Then the thickened sediment is fixated. Transportable treatment equipment would be situated on-site to fixate the contaminated sediments. Fixation chemically binds the contaminants within the sediments, and would render the sediments non-hazardous. The dredge water would be clarified to. remove remaining suspended solids. The clarified water would be tested before being discharged into the Cove and the sol ids would be added to the thickened sediments. FOllowing treatment, the fixated material would be transported to an off-site sanitary landfill. This technoloqy is commercially available, and has been selected for use in Areas I and II of the si te. Following dredging, the Cove would be resampled to determine the effectiveness of the dredging operation in meeting its cleanup goals. The sampling data will become part of the environmental baseline study and will be used as a basis for comparison during monitoring. A hydrologic analysis of the Cove and Marsh would also be under- taken. To preserve its estuary structure and function, the Cove bottom would be restored, as necessary, using as a basis for design the data generated by the hydrologic analyses. To achieve this goal, consideration would be given to the selection of fill material that would be conducive to binding any remaining cadmium in the sediments. The extent of revegetation would also be determined at this time . Monitoring would be conducted to ------- ascertain the degree of restoration of the Cove. This alternative is expected to comply with all pertinent ARARs, as follows: as with EFC-2, the use of silt curtains during construction would meet Clean Water Act Section 401 certification water quality standard requirements; the treated discharge water would meet the federal and New York water quality criteria and mixing zone requirements imposed under the SPDES permit program; and the off-site disposal process would meet the New York non- hazardous solid waste (Part 360) requirements. Since the location of the upland treatment facility to be used for remediation will remain the same for Areas I and III, the archaeological investigations required to conform with the National Historic Preservation Act (NHPA) and RCRA facility location requirements have been initiated under the Area I remedial action and will be continued to encompass Area III. Other location-specific ARARs , will be met, since this alternative greatly reduces the levels of contaminated sediments which pose a threat to human health and the environment. . The time required to implement this alternative is approximately 25 months. The estimated present worth cost is $37,042,000. For comparing costs it was assumed that fixated sediments are removed from the site via rail. Due to concerns expressed by the public that the Village of Cold Spring's narrow streets would make truck transport extremely difficult, the utilization of trucks to transport fixated sediments through the Village is not a viable option. (Other options include rail and barge.) Trucks may be utilized, however, for the movement of materials on-site, and to transfer fixated sediments unloaded from barges or trains to the ultimate disposal site. The estimated capital cost also assumes that the entire cove would require one foot of fill material (55,000 cy) for restoration. It should be noted that approximately $10 million in capital cost savings could be realized if East Foundry Cove were remediated concurrently with Area I. Alternative B70-4: Dredaina. Thickenina. Dewaterina. Off-Site Treatment. Off-Site DisDosa1 This alternative is similar to EFC-3 in all aspects except for the location of the treatment facility. Contaminated sediments would be dredged to a depth of one foot, thickened and dewatered using vacuum filtration. The dredge water would be clarified, tested and discharged into the cove. The dewatered sediments would be transported to an off-site facility for treatment and disposal. Following treatment, the sediments would be transported to an off-site sanitary landfill. Restoration of the Cove would be as described in Alternative EFC-3. In addition to the ARARs required for the dredging and thickening portions of Alternative EFC-3, this alternative would also have to ------- comply wi th RCRA standards for generators, transporters, and hazardous waste facilities (40 CFR 262, 263 and 264) since hazardous wastes would be transported off-site. This alternative could be implemented in approximately 25 months at a present worth cost of $29,170,600. The costs were developed assuming that the hazardous wastes would be transported off-site via railroad. &l~.rD.tiv. B~C-51 Dredaina. Acid Extraction. Thickenina. Dewaterina. Off-Site DisDosal Similar to Alternatives EFC-3 and EFC-4, under Alternative EFC-5, East Foundry Cove would be dredged at least one foot in depth and restored, as necessary. The contaminated sediment would be treated at an on-site acid extraction plant. Bench scale acid leaching tests were conducted during the RI to determine the appropriate extraction acids for leaching metals from the sediments. A combination of sulfuric acid and ferric sulfate was chosen. Approximately 6,400 tons of these chemicals would be required for the extraction process. The extracted metals, including cadmium, would be transported off-site to an approved RCRA treatment, storage, and disposal facility. The treated sediments would then be thickened and dewatered using vacuum filtration and transported off-site for disposal at a sanitary landfill. The treated dredge water would be tested and discharged into the cove. The ARARs discussed previously in conjunction- with dredging and thickening processes and the discharge of treated water into the Cove all apply to this alternative. In addition, it is assumed that the acid extraction facility will utilize a carbon adsorption treatment system to enable air emissions to meet New York State air emissions requirements. The time required to implement this alternative is approximately 18 months. Assuming rail transport of materials, the estimated present worth cost is $27,423,500. &l~.rD.tiv. BFC-': Dredaina. Acid Extraction. Thickenina. On- Site RedeDosition This alternative is similar to Alternative EFC-5, except that following acid extraction and thickening, the treated sediments would be neutralized and redeposited in East Foundry Cove via a pipeline. A silt curtain would also be used to prevent the .iqration of resuspended sediments as the cleaned sediment is redeposited. The metal sludges would be fixated on-site and transported off-site to a sanitary landfill. This alternative would also comply with ARARS. The time required to implement this alternative is approximately 20 months at an estimated present worth cost of $14,337,500. 18 ------- RST I'OOHDRY COVE Alt8rnative WFC-l: No Action Under the no-action al ternati ve for West Foundry Cove, warning signs would be posed instructing people to avoid the area. A public education program would also be initiated. Operation and maintenance costs include an annual ecological survey and sediment and vater sampling and analysis. This alternative could be implemented in 3 months at an approximate present worth cost of $1,000,400. Alt8rDativ8 WFC-2: Containment Containment of contaminated sediments in West Foundry Cove would be accompl ished by constructing a one foot sand cap over the contaminated sediments. The cap would cover approximately 26 acres. The time needed to implement this alternative is estimated to be 10 months. The present worth cost is $8,040,500. A long-term monitoring program similar to that for EFC-2 would be implemented. Alt8rDativ8 WFC-3: Dredaina. Thickenina. On-Site Fixation. Off- Site DisDosal The technology utilized for this remedy would be similar to that for Alternative EFC-3. Implementation, however, would be more difficult because the area to be remediated lies within the main flow of the Hudson River. Approximately 58,000 cubic yards would be dredged under this alternative. At least 26 months would be needed for implementation. The present worth cost is $60,468,200. Alt8rDativ8 WFC-4: Dredaina. Thickenina. Dewaterina. Off-Site Treatment. Off-Site DisDosal The technology utilized for this remedy would be similar to that for Alternative EFC-4. Approximately 24 months would be required to implement this alternative. The present worth cost is $38,009,500. 19 ," ------- Al~.rna~iv. WFC-S: Dredaina. Acid Extraction. Thickenina. pewaterina. Off-Site DisDosal Under this al ternati ve, West Foundry Cove \ would be dredged. Cadmium would then be removed from the sediments at an on-site acid extraction plant and the sediments would be thickened as they would be with the other dredging alternatives. Approximately 12,100 tons of ferric sulfate and sulfuric acid would be used during the extra9tion process. Used acid and the extracted cadmium would be transported off-site to an approved RCRA treatment, storage and disposal facility. The cleaned sediments would be disposed of in a sanitary landfill. The Cove would be sampled and restored, as necessary, similar to all dredging scenarios. Approximately alternative. 25 months would be needed to implement The present worth cost is $35,714,600. this Al~.rna~iv. WFC-6: Dredaina. Acid Extraction. Thickenina. On- Site RedeDosition This alternative is similar to Alternative WFC-S, except that following acid extraction, cleaned sediments would be redeposited . in West Foundry Cove. This alternative would also be more diffi- cult to implement since West Foundry Cove lies within the main flow of the Hudson River. The present worth cost is estimated to be $17,038,000. The time required for implementation is 24 months. .COLD SPRING PIER AREA Al~.rDa~iv. CSP-l: No Action Under this alternative, a fence would be erected to prevent access . to Pier Area sediments by land. Signs would be posted warning people to avoid contact with the sediments. A long-term monitoring program and a public education program similar to those for EFC-1 would be implemented. This alternative could be implemented in 1 month. worth cost is $648,100. The present Al~.rna~iv. CSP-2: containment This alternative is similar to Alternative WFC-2. 1 acre would be capped. This alternative would take approximately 3 months to implement. The present worth cost is $1,216,100. Approximately ------- Alternative CSP-3: Dredaina. ~hickenina. On-site Fixation. Off- Site DisDosal This alternative is similar to Alternative EFC-3. Approximately 900 cubic yards would be dredged from the area adjacent to and beneath the Cold Spring pier and the area would be restored, as necessary. This alternative would take about 17 months to implement. The present worth cost is $10,457,100. If this alternative is implemented concurrently with the remedy for Area I, cost savings similar to those for Alternative EFC-3 would be realized. Alternative CSP-4: Dredaina. Thickenina. ~ewaterina. Off-Site Treatment. Off-site Dis osal This alternative is similar to alternative EFC-4. Approximately 17 months could be required to implement this alternative. The present worth cost is $10,268,800. Alternative CSP-5: Dredain~. Acid Extractio~, ;~ickenina. Dewater1na. Off-Site D s os This alternative is similar to alternative EFC-5. Approximately 17'months would be required to implement this alternative. The . present worth cost is $12,068,100. Alternative CSP-S: Dredaina. Acid Extraction. Thickenina. On- Site RedeDosition This alternative is similar to Alternative EFC-6. Approximately 14 months would be required to implement this alternative. The present worth cost is $7,233,900. SUMMARY OP COMPARATrVB AHALYSrS OP ALTBRNATrVES During the detailed evaluation of remedial alternatives, alternative was assessed against nine evaluation criteria. nine criteria are summarized below: each The Short-term ettectivene.. addresses the period of time needed to achieve protection, and any adverse impacts on human health and the environment that may be posed during the construction and implementation period until cleanup goals are achieved. Long-term ettectivene.. and peraanence refer to the ability of a remedy to maintain reliable protection of human health and the environment over time once cleanup goals have been met. .eduction of toxicity, .obili ty, or volume is the anticipated performance of the treatment technologies a remedy may employ. ------- zapl_ent8bility is the technical and aclministrative feasibility.' of a remedy, including the availability of materials and services needed to implement a particular option. . Cost includes estimated capital and operation and maintenance costs, and net present worth costs. CompliaDce with Applic8ble or .elevaDt aDc! Appropriate .equir..ents (AltARs) addresses whether or not a remedy will meet all of the applicable or relevant and appropriate requirements of other Federal and state environmental statutes and/or provide a basis for invoking a waiver. OVerall protection of human health aDc! the environment addresses whether or not a remedy provides protection and describes how risks posed through each exposure pathway are eliminated, reduced, or controlled through treatment, engineering controls, or institutional controls. state Acceptance indicates whether the state concurs with, opposes, or has no comment on the preferred alternative. community Acceptance indicates whether, based upon input received during the comment period, the public concurs with, opposes, or has no comment on the preferred alternative. The comparisons of the alternatives against each of the nine evaluation criteria for each of the three subareas are summarized below. BAST POUNDRY COVE A. Short-Term Effectiveness The time to implement Alternatives EFC-2 through EFC-6 ranges from 19 to 28 months. Alternative EFC-1 could be implemented in approximately 3 months. Alternatives EFC-3 through EFC-6 involve dredging and will have short-term adverse impacts on the biota of East Foundry Cove. These short-term impacts would be confined to East Foundry Cove, and efforts to minimize these impacts would be undertaken as part of the implementation of any of these remedies. These alternatives will also be designed so as to reduce short-term impacts locally and down river due to the resuspension of contaminated sediments. The use of trains and/or barges to transport material off-site would have less adverse impacts on the local community than the use of trucks for transport. Alternatives EFC-1, EFC-2, and EFC- 6 would have the least short-term impact on the community since ------- they do not involve removal of large quantities of material from the site. Alternative EFC-4 would transport sediments off~site untreated. During the implementation of any remedy, precautions. would be undertaken to limit the exposure of on-site workers to contami- nated sediments; however normal construction hazards would be associated with the implementation of Alternatives EFC-3 through EFC-6. . B. Lana-Term Effectiveness and Permanence By removing 95 percent of ~he cadmium-contaminated sediments Alternatives EFC-3 through EFC-6 would be protective of public health and the environment. Implementation of these alternatives would result in the permanent removal of the cadmium. By containing rather than treating contaminated sediments, Alternative EFC-2 would provide reduced long-term effectiveness since the cap would require reqular monitoring and maintenance to insure its inteqrity. Failure of the cap would re-expose the contaminated sediments to the environment. Alternative EFC-l would not provide protection to human health and the environment over the long term. C. Reduction of Toxicitv. Mobilitv or Volume Dredging and fixating cadmium-contaminated sediments under Alternative EFC-3 would reduce the toxicity and mobility of the site contaminants. The volume of material would be increased by the fixation process, but this increased volume of material would be non-hazardous. Al ternati ves EFC-4, EFC-5, and EFC-6 would provide similar reductions in toxicity and mobility. Alternative EFC-4 would result in an increased volume of material but not until it is transported off-site and treated at an off-site facility. AI ternati ves EFC-5 and EFC-6 would not result in an increased volume of material at the site. Alternative EFC-2 would eliminate the .obility, but not the toxicity or volume of contaminated material. Alternative EFC-l would not eliminate the toxicity, mobility or volume of contaminated material. D. ImDlementabilitv The technOloqies utilized for Alternative EFC-3 are proven, and transportable treatment facilities are commercially available. . This is the same technology to be utilized to remediate Area I. This remedy would be implemented in coordination with the Area I remedy, expeditinq implementation and reducinq capital and contracting costs. Lacatinq a landfill with the capacity to accept the fixated .aterial or the material remaining after acid extraction could affect the implementability of Alternatives EFC-3 throuqh EFC-S. While it is expected that a landfill which would accept the ------- material could be located, the distance to a landfill, the landfill tipping fee and the proximity of a rail line or navigible waterway will greatly influence the cost of implementing these alternatives. Alternative EFC-1 is easily implemented. Alternative EFC-2 would be difficult to construct. Alternative EFC-4 would rely on the capacity of commercial fixation facilities for implementation. Alternatives EFC-5 and EFC-6 would require the fabrication of acid extraction equipment, and the large amount of acids may be difficult to transport on-site. E. ~ The direct capital costs for Alternative EFC-3, assuming train transport, are estimated to be $17,000,000. The ann~al operation and maintenance costs will be approximately $19,770,160 for the first year and $47,600 for each of the next 29 years. The present worth based on a rate of 5% is $37,042,000. While Alternative EFC- 3 is the most costly of the alternatives considered for East Foundry Cove, the cost estimates are within the range of Alternatives EFC-4 through EFC-6, and the capital costs of implementing Alternative EFC-3 would be significantly lower if implemented concurrently with the Area I remedy. F. ComDliance with ARARs Alternative EFC-3 would comply with all ARARs. Alternatives EFC- 4, EFC-5, and EFC-6 would also comply with ARARs. Alternatives EFC-1 and EFC-2 may not comply with location-specific ARAR's because all contaminants remain on-site. G. OVerall Protection of Human Health and the Environment By utilizing treatment technologies to eliminate exposure to levels of cadmium, nickel and cobalt which would pose a threat public health and the environment, Alternative EFC-3 provides overall protection since 95 percent of the contamination would be removed. Alternatives EFC-2, EFC-4, EFC-5, and EFC-6 are similarly protective. Alternative EFC-l would not provide overall protection, since exposure to contaminants above health-based levels would not be eliminated. H. state AcceDtance Because the sediment removal alternatives provide adequate protection of public health and the environment, the state of New York would concur with the selection of Alternatives EFC-3 through EFC-6, but prefers Alternative EFC-3. ------- I. Communitv AcceDtance The general public supports those alternatives which involve the removal of contaminated sediments (Alternatives EFC-J through EFC- 6). The publ~c also supports the utilization of rail as a means of transporting materials to and from the site. Marathon Battery Company and Gould, Inc. have stated that the remediation processes would have a much greater adverse impact on the area than no action. nST PoUNDRY COVE . A. Short-Term Effectiveness Implementation of Alternative WFC-l would take approximately 3 months and have little or no short-term impacts. Alternatives WFC- 2 through WFC-6 would involve disturbing sediments in the Hudson River, and would result in some downstream migration of contaminants as it would be more difficult for silt curtains to effectively contain the suspended sediments. The short-term impacts associated with implementing Alternatives WFC-2 through WFC-6 in West Foundry Cove would be similar to those associated with the East Foundry Cove alternatives. However, the volume of material is greater; thus the time to implement the remedies would be greater. B. Lana-Term Effectiveness and Permanence Alternative WFC-l does not involve any construction or require long-term maintenance; it requires only periodic monitoring. Since the present average cadmium concentrations do not pose a threat to public health or the environment, Alternative WFC-l would be effective over the long-term. Additionally, cadmium concentrations in the upper layer of sediment in West Foundry Cove are expected to decrease over time due to tidal action. By removing sediments, Alternatives WFC-J through WFC-6 would be effective in the long term and considered permanent. Alternative WFC-2 would require constant maintenance to insure the integrity of the containment cap due to the Hudson River's currents and tidal action and would be less permanent than Alternatives WFC-3 through WFC-6. During remedial design activities for East Foundry Cove, additional studies will be performed to determine if contaminated sediments from West Foundry Cove would re-contaminate East Foundry Cove and Marsh after remediation of those areas. If West Foundry Cove is found to be a source of contamination to East Foundry Cove and Marsh, a limited removal of the contaminated sediments would be evaluated and incorporated into final remedial construction plans. ------- . C. . . Reduction of Toxicitv~ Mobi1itvor Volume Alternative WFC-l provides no reduction of the toxicity, mobility or volume of contaminants in West Foundry C~ve. . OVer the long term, concentrations would decrease by downstream migration of cadmium. Dredging and treating cadmium contaminated sediments by fixation or acid extraction under Alternatives WFC-3 through WFC- 6 would reduce the toxicity and mobility of th~ site contaminant. The vo~ume of .ateria1 would be increased by the fixation process but this increased volume of material would be non-hazardous. D. ImD1ementabi1itv Alternative WFC-l is the easiest of the West Foundry Cove Remedies to implement. The ease or difficulty of implementing Alternatives WFC-2 through WFC-6 is similar to the discussion for Alternatives EFC-2 through EFC-6; however the volume, ,of material to be transported off-site would be greater" and', :1ocating adequate landfill capacity may be more difficult. '.., E. ~ The direct and indirect capital costs 'for Ait~rnative WFC-1 are estimated to be $16,400 and $4,400 respectively. The annual operation and maintenance costs would be'approximate1y $59,200 for 30 years. The present worth based on a rate of 5' is $1,000,400. The implementation costs of other alternatives range from $7.6 .i11ion to $54.28 million and do not prc?vide for significantly greater protection of public health or theenvi~onment. . F. ComD1iance with ARARs Although the no-action alternative will, not remediate the contaminated sediments, the levels of contamination, when averaged, are fairly low (43.9 mg/kg). As a result, 'Alternative WFC-l would comply with all applicable or relevant and appropriate requirements. Alternatives WFC-2 throughWFC-6 would comply as well.".' G. pvera11 Protection of Human Health and the Environment While small areas of sediment containing, elevated cadmium concen- trations occur throughout West Foundry Cove, when averaged over the Cove, cadmium concentrations are quite low, and do not pose a threat to human health or the environment. : Thus, Alternative WFC- 1 provides overall protection of human health and the environment. By utilizing treatment or containment technologies, Alternatives WFC-2 through WFC-6 would also provide overall protection of human heal th and the environment. . , ,'26 ------- H. State ACCeDtance The State concurs with a no-action alternative for West Foundry Cove based on conditions known to date. If remedial design activities show West Foundry Cove sediments as a source of recontamination of the areas to be remediated (East Foundry Cove and East Foundry Cove Marsh), then. the State recommends re- evaluatinq removal of sediments' or other remedial measures to address those sediments that are contributing to the recontamination. I. Communitv AcceDtance The qeneral public supports the no-action alternative for West Foundry Cove. COLD SPRING PIZR AREA A. Short-Term Effectiveness Alternative CSP-3 could be implemented' in about 14 months. Alternatives CSP-1 and CSP-2 could. be implemented in one to four months. Alternatives CSP-4 through ,CSP-6 could be implemented in . 14 to 17 months. ' '. . The short-term impacts associated with the implementation of Alternatives CSP-3 are similar to'those, discussed for Alternative EFC-3, except that there is less material to be treated. However, there is a greater potential for mater!al being carried down-stream, , durinq dredging operations at the pier, and measures would have to ' be taken to limit the impact, of the Cold Spring Pier Area remediation on the Hudson River. ' B. Lana-Term Effectiveness and Permanence Alternative CSP-1 does not involve major construction or maintenance, with the exception of periodic monitorinq. Cadmium concentrations in the upper layer of sediment in the Pier area of the Hudson River would be expected to decrease over time due to tidal action, provided that the sediment beneath the Pier is uncontaminated and not a source ,of cadmium contamination. Alternative CSP-2 would require constant maintenance to insure the integrity of the containment cap and would be less permanent that Alternatives CSP-3 through CSP-6. Also the lonq-term effectiveness of CSP-2 is unknown due to tidal action., ' . The discussion of lonq-term effectiveness of CSP-3 throuqh CSP-6 is sailar to the discussion for Alternative EFC-3. Durinq remedial design, the sediment adjacent to and beneath the Cold Sprinq Pier will be sampled to. determine the full' extent of 27 ------- contamination. If the sediment beneath the Pier is found to be present a threat to public health and the environment, this area will be included in the remediation. C. Reduction ~f Toxicitv. Mobilitv or Volume The discussion of reduction of toxicity, mobility, or volume for CSP-3 is similar to the discussion for Alternative EFC-3. D. ImDlementabilitv The technology utilized for Alternative CSP-3 is proven, and transportable treatment facilities are commercially available. This remedy could be implemented in coordination with Alternative EFC-3 and the Area I remedy, reducing capital costs and expediting implementation. Limitations to the implementability of Alternative CSP-3 are similar to Alternative EFC-3, although implementing this al ternati ve concurrently wi th the Area I remedy would expedite implementation and reduce capital costs. E. ~ The direct and indirect capital costs for Alternative CSP-3, utilizing train transport, are estimated to be $6,779,700 and $1,830,500, respectively. The annual operation and maintenance costs will be approximately $1,473,970 for the first year and $25,900 for each of the next 29 years. The present worth based on a rate of 5% is $10,457,100. The capital costs shown would be greatly reduced if this remedy were implemented with Alternative EFC-3 and the Area I remedy. The implementation costs of the other alternatives range from $648,100 to $12,068,100 and do not provide for significantly greater protection of public health or the environment. F. ComDliance With ARARs Alternatives CSP-3 through CSP-6 would comply with all applicable or relevant and appropriate requirements. Alternatives CSP-1 and CSP-2 may not comply with location-specific ARAR's because contaminants would remain on-site. G. OVerall Protection of Human Health and the Environment Alternative CSP-3 utilizes treatment technologies to eliminate the threat to human health and the environment posed by sediments containing elevated cadmium, nickel, and cobalt concentrations. Alternatives CSP-2 and CSP-4 through CSP-6 are similarly protective. Alternative CSP-1 would not provide overall protection, since exposure to contaminants above health-based levels would not be eliminated. ------- H. State AcceDtance Because the sediment removal alternatives provide adequate protection of public health and the environment, the State of New York would concur with the selection of Alternatives CSP-3 through CSP-6, but prefers Alternative CSP-3. I. Communitv AcceDtanc~ The Village of Cold Spring intends to replace the Cold Spring pier in the near future. Accordingly, the public would prefer Alternatives CSP-3 through CSP-6, since any contaminated sedi- ments that are present would be removed. '1'1IE SELBCTED REDDY The results of the RI/FS have shown that elevated levels of cadmium above backround are present in Area III sediments. Based upon consideration of the requirements of CERCLA, the detailed analysis of the alternatives, and public comments, both EPA and NYSDEC have selected Alternative EFC-3, dredging of the contaminated sediments from East Foundry Cove to a depth of one foot, chemical fixation and off-site disposal of those sediments, and restoration of the original contours, as necessary: Alternative WFC-1, continued monitoring, for West Foundry Cove: and Alternative CSP-3, sampling and analysis adjacent to and under Cold Spring pier with dredging of any contaminated sediments determined to be a threat to the environment, followed by chemical fixation, off-site disposal, and restoration of the original contours, as necessary. The data compiled for East Foundry Cove indicate that over 95% of the cadmium contamination is located in the upper layer (1 foot) of the sediments. Due to the nature of the dredging process, dredging to a specific action level (e.g., 10, 100, or 250 mg/kg of cadmium) would be technically difficult, since these concentrations vary in the sediments by only a few inches of depth. Therefore, expectations are that by dredqinq the upper layer of contaminated sediments, 95' of the cadmium contamination will be removed. Following remediation, it is anticipated that cadmium concentrations would not exceed 10 mg/kg in most of the dredged areas. A no-action alternative was chosen for West Foundry Cove. It was assumed that West Foundry Cove receives cadmium-contaminated sediments from East Foundry Cove and East Foundry Cove Marsh and the Cold Spring Pier Area. Once these 80urces are remediated, cadmium-free sediments would then be deposited in West Foundry Cove. Tidal action would cause the existing sediments to mix with the newly deposited sediments thereby causing the average cadmium ------- concentration in the sediments to decrease gradually below its current average concentration of 43.9 mg/kg. A hydrologic analysis of Area III will be conducted in order to evaluate sediment transport routes. . . Sediment samples at and beneath the Cold spring pier will be collected, analyzed, and evaluated to ascertain whether this area is a source of cadmium contamination.. . If, based upon this analye;is, these sediments are determined' to be a source, these . sediments will be dredged to a depth of one foot. During the dredging operation, silt curtains will be utilized to contain resuspended sediments and minimize short-term environmental impacts. ..' The dredged. sediments will be thickened on-site. The dredge water, resulting from the thickening process, will be clarified and tested to. make. sure. that it meets EPA and New York' State water quality standards before, it is discharged. into the Cove. The solids resul ting from .the clarification process' .will be added to the contaminated sediments awaiting fixation. '.' Fixation of the thickened.-sediments will take place at an on-site facility. Bench scale tests~ere performed for the Area I ROD and indicate that fixation. 'of, the contaminated sediments.' -is a, viable remedy. Pollowingtreatment, the fixated material :.willbe transported to an off-site' sanitary landfill.. For, costing purposes, it was assumed ~hat the more costly rail transport 'would be used to remove the fixated sediments from the site. . ' . . . . ' . . . . . . . . . .' . . . . . . .' . Following '..dredging, the dredged areas, ,will be resampled to. determine'the levels of cadmium remaining in the sediment: this information will be used asa baseline. study for the monitoring program. The dredged areas will be restored as necessary, pending the outcome, of the previously stated studies to preserve the estuary structure and function and to provide an added level of protection to the environment. Monitoring will be conducted to assure the success of the restoration. The capital cost for the remedy. in East Foundry Cove is $17 i 000,000. The operation and maintenance cost is estimated to be $19,770,160. The estimated capital cost for the remedy for the pier Area is $8.5 million. The operation and maintenance cost is estimated to be $1.5 million. The selected remedy for treating the contaminated sediments from Area I and Area II is chemical fixation. It was assumed that sediments from Area III could be treated at the facility con- structed on-site for Areas I and II, and a savings in capital cost could be realized. This cost saving was not reflected in. the cost estimates stated in the ROD. . .: ' ------- UJlBDIATIOH GC)~T.JI The risk assessment has concluded that, with the cadmium contamination presently remaining in East Foundry Cove and the Pier Area, a threat to human health and the environment exists. Existing conditions. at the site have been determined to pose a threat predominantly from ingestion of contaminated sediments by human and animal populations. 'The'purpose of this response action is to remove the contaminated sediments to levels consistent with state and Federal ARARs and to ensure protection of the environment from the continued exposure of contaminants from the sediments. Since no federal or state ARARs exist for sediments, the action level was determined through a site-specific risk analysis. "'. STATUTORY DETBRMINATIOHS Under its statutory authority, EPA's primary responsibility at Superfund sites is to undertake remedial actions that achieve .adequate protection of human health and the environment. In. addition, Section 121 of CERCLA establishes several other stat- . utory. requirements and preferences. These specify that when complete, the selected remedial action for this site must comply .with. applicable or relevant and appropriate environmental stand- ards established under Federal and state environmental laws unless . .astatutory waiver is justified. . The selected remedy also must be . cost-effective and utilize permanent solutions and alternative . . . .treatment . technologies or resource recovery technologies to. the maximum extent practicable. Finally, the statute includes a preference for remedies that employ treatments that permanently and significantly. reduce the. volume, toxicity, or mObility of hazardous wastes as their principal element. The following sections discuss how the selected remedy meets these statutory . requirements. . . . ComDliaDce With ADDlicable or Relevant and ADproDriate Reauirements The selected remedy of dredging of the contaminated sediments, followed by chemical fixation and off-site disposal, will comply with all action, and location-specific ARARs. Specifically, these are the Clean Water Act Section 401 water quality standard requirements, federal and New York State water quality criteria and mixing zone requirements under the SPDES permit program, NHPA and . RCRA facility location requirements, and New York State non- hazardoussoil waste (Part 360) requirements.. . ------- Cost-Bffectiveness The selected remedy is cost-effective because it has been determined to provide overall effectiveness proportional to its cost. A cost savings of almost $20 million wi~l be realized since the selected remedy would be able to utilize much of the capital equipment constructed for the remediation of Area I and the contractor procurement costs would be reduced. utili.atioD of Permanent SolutioDS and Alternative Treatment TechDoloaies to the Maximum Bztent Practicable EPA and New York state have determined that the selected remedy represents the maximum extent to which permanent solutions and treatment technologies can be utilized in a cost-effective manner for the Area III portion of the site. Of those alternatives that are protective of human health and the environment and comply with ARARs, EPA and NYSDEC have determined that the selected remedy provides the best balance of tradeoffs in terms of long-term effectiveness and permanence: reduction in toxicity, mObility, or volume achieved through treatment~ short-term effectiveness; implementability, cost, while considering the statutory preference for treatment as a principal element, and state and community acceptance. The selected remedy is as effective as the other remedial action alternatives in the short-term, offering the additional advantage of on-site treatment, which reduces potential risks to residents along transportation routes. The implementability of the selected remedy is comparable to that of the other alternatives. The selected remedy is the least costly treatment option. The selection of treatment of the contaminated sediments is consistent with program expectations for treatment to ensure the long-term effectiveness of a remedy. Since all of the alternatives are comparable with respect to long-term effectiveness, toxicity, mobility, and implementability, the major tradeoffs that provide the basis for the selection of the remedy are long-term effectiveness and cost. The selected remedy can be implemented with less risk to the area residents and at less cost than the other remedial action alternatives and is, therefore, determined to be the most appropriate solution for the contaminated sediments at the Marathon Battery Company site. Preference for Trea~ent as a PrinciDal Blement By chemically fixating the dredged sediments, the selected remedy addresses the principal threats posed by Area III through the use of treatment technologies. Therefore, the statutory preference for remedies that employ treatment as a principal element is satisfied. ------- UJ'BRBHCBS ERT, 1986. Comments of the .Mara~on :f:::r: c~~~a~Y ~ni~f~~;d. Inc. on the Sunnlemental Remed1al ;-Yesit~~~c-~ Q'~ iea:~;~~~~y Study of the Marathon Batterv Sunerf nd Sod S r na ew ork. USEPA. 1981. Health Assessment for Cadmium (Final Renort). L.D. Grant et al., Research Trianqle Park, North Carolina, No. 60018- 81/023. In Acres, 1985. ~~;P~~~iu;9~~:tei~i;'~~f~~;o~. B of 14mhient Water Quality Criteria " ------- ATTACBHEN'l' A J'IGURES " .' ------- Cold Sping . pier West Fcudy .. Cove .1 1 Nanh , kilometer w.88ndI -. NEW'tORK MMA. UIn:II ,.. ".,..em USGS .,., FaiIt, ,." Yen 1.5 CMcI. R«* Fomwr Mat8hon B8aIry Plant ..18 , Figure !.. The Marathon Battery. silC in Cold Spring, New York. ------- - .-...-- ..- ....... .-.-- ---.... FIGURE 2 <> DICK'S CASTLE HISTORIC DISTRICT IPARTIAL) IfI\lER . . . . ~~o SCALE . l lID . «- o '00 ~ ------- fRAcrn . FIGURE 3 BIOASSAY SEDIMENT L9CATIONS EAST FOUNDRY COVjE 'AND WEST FOUNDRY COVE' I . ' ,.': :. , "";!)~!\l :,:,'....JI"'JL:~L,...."",'" , . '. 1IV1,,-!tf;;;'o" "1"" .\ EAST FOUNDRY COVE E.~ I I 10 I , ~ SCALE JOG - ,.., 60 100 1 I I I I ------- . ,"; < \ \ ; TRAIN TRESTLE ., . i; . . ~ .. . . , ~ . . ~ WEST COVE . ~".~ , "~ i 55-7 55-10 ( . FOUNDRY .11tO 0 . :!~.:H / . BRO K)/ . 1:~HANNEl II S8-11 S8-81 IL ~... r", NR 1.1 . SS-/ ",~ ! NRI NR ,,' N~ "~ 'r"'~' . ! ". ".~ CONSTITUTION ~.. MARSH c:. /"r'J-\....., :,~""<,,----: , 1\. . . ~s;atJ- . ". ' ~~; " 1,1 " '. . NR ' :~-2.. I.' NR . CHANNEL . \ . , .\ . . . ..~.." ) .~.'.. ~... ,~ I . I . , ! . A~ t.EOENO . CORE SAMPLE "ATION cd CONCENTRATION OlVEN IU MOlteD ern'tAt 1 DATA LISTED BY 1° IUB-SAMPLE A~ ro, I.l,...~: 0.," ,. t a" , U.U" 11.24" NR . NO Ra:COVERY ~ I . I. I i EAST COVE F.:rGUR€. 4 SEDIMENT SAMPLING STATIONS ------- ATTACHMENT 'fABLES :- ~.. .. . .' .~(>' .. -;- " -'. . B ------- 'fULE 1 DDTBOlf BATTBRY COKPAlfY 8ITB ADA III 8BDIKBlfT CADKIUII COlfCBlfTRATIOlf8 Caq/kq) EAST FOUNDRY WEST FOUNDRY PIER AREA COVE COVE IJUKBBR 01' 8AXPLE8 57 89 208 KIlIDIUX 0.29 1.1 1.2 DXIKUH 2,700 5'9 1,030 IIBDIAlf 5.' 4.2 3.9 DU 179.3 43.9 12.' AREA I SBDIKINT CADMIUM CONCENTRATIONS (8g/Jtg) BAST ~tJ1fDRY COlf8TITOTIOlf COVE MARSH MARSH I1UKSER 01' 8AXPLE8 19 70 KIlfIXtJX 70 4 D%IKUH 11',100 940 DDIAlf 2,800 170 JIUB 27,799 178 ..) ~ <] .~ . ,. ~,:. ~ '''.~'.'~''':-('' "'~;':"": '.: ' . ...- ., .. .f' ------- 1. 2. 3. 4. 5. 6. 7. 8. 9. 10. 11. 12. 13. 14. 15. 16. 17. 18. 19. 20. 21. 0-10 em 140.0 0.29 7.0 796.0 712.0 640.0 267.0 460.0 315.0 814.0 280.0 14.0 410.0 67.0 8.5 39.0 680.0 850.0 17.0 9.8 2700.0 highest 'fABLE 2 BAS'f POtJNDRY COVE ACUS SUPLBS 10-25 em 25-50 em 142.0 0.32 0.35 38.0 14.0 0.54 131.0 4.1 2.8 3.8 1.6 0.36 0.39 NR 0.6 3.2 560.0 1.9 NR 0.43 55.0 1.9 *0.28 0.30 5.6 2.1 0.33 2.1 0.38 1.2 . 1.1 0.57 0.44 0.62 NR NR NR 2.2 2.4 NR 0.40 11.0 lowest 57 Samples, 21 Stations .. ------- '., \ 'tABLB 3 BAST POUKDRY con BIOASSAY 8BDIKBIIT SAKPLBS " Ii1 ~ EC-1 157 117 22.6 EC-2 12.7* 47.9* 23.6 EC-3 34.7 59 22.2 EC-4 2015 1369* 75.7* EC-5 3244* 1009 63.1 EC-6 407 223 23.8 EC-7 N/A N/A N/A EC-8 81.7 67.4 14.5* EC-9 246 132 23.1 EC-10 246 153 22.9 MEAN 716 353 32.4 () J Q , . ~ ,." ~ ..". ".. ------- - ~ TABLE 4- HAZARDOUS SUBSTANCE LIST ANALYSES OF SEDIMENTS SAMPLE NUMBER/LOCATION PIER AREA WEST FOUNDRY COVE FIELD BLANK COMPOUND ISL-1 ISL-~ ISL-3 ISL-4 (Ul/1) DfORGANICS (ms/ks) ALtI!INTJM 17300 21200 22400 13000 ND 1AJlI1JM ND 91 113 83 ND CADlIUM ND 16 ND 31 ND CALCIUM 2690 4020 2480 3180 ND CBIlCIUUM 41 134 43 53 5 COPPER 7.0 96 ND 43 ND IRCl 31600 33100 33200 25700 HD LEAD ND HD 38 315 ND f!ACHESIUM 6410 7600 7420 5880 HD MANGANESE 433 1100 641 576 HD MEllCURY HD 1.3 0.3 0.4 HD HIcnL ND ND' ND 198 HD POTASSIUM 2810 3020 3350 1720 HD SODItIM 384 704 497 454 HD ZINC 84 316 114 141 HD ORGANICS (ug/kS) CII.OIOFORM ND ND 10 50 HD BIlCltODICBLOIlOMETBANE ND ND 14 16 HD J)III HI> 6J 6J HI> FLUOIWmIENE 72J HD 320J HD ND PYIEHE 110J ND 490J HD HD IENZO(a)PYIlENE 550J 950 370J 470J ND BENZO (b )FLOUBANTBENE HD ND 460J HD HD CBltSENE HI> ND 350J HD ND PBDWmIRENE HD ND 290J 1m ND HOTE: J. ESTIMATED VALUE ------- . TABLE: 5 ANALYTICAL RESULTS OF BEACH SAMPLES AND SOIL SAMPLING . ALONG MAIN STREET STORM SEWER \(mc/k9) . SAMPLE LOCATION/DEPTH CADMIUM COBALT NICKEL BCH-Ol BEACH/0-6- 2.0 4.5 10.0 BCH-02 BEACH/12-1S- S.l 3.9 13.0 8CH-03 BEACH/0-6- 12.0 S.9 33.0 1-1 West of Lunn . Main/0-2' 1.5 S.7 24.0 1-2 West of Lunn . Main/2-4' 1.5 8.6 2.0 1-3 West of Lunn . Main/4-6' 1.2 7.6 19.0 1-4 West of Lunn . Main . NO RECOVERY . 1-5 West of Lunn &. Main/8-l0' 1.2 8.6 22.0 1-6 West of Lunn . Main/10-l2' 1.S 10.0 24.0 1-7 West of Lunn &. Main/12-14' 1.2 89.0 19.0 1-8 West of Lunn . Main/14-l6' 3.S 1.2 26.0 2-1 East of Depot Sq. . Main/0-2' 1.0 5.9 9.3 2-2 East of Depot Sq. &. Main/2-4' 1.1 8.6 19.0 2-3 East of Depot Sq. &. Main/4-6' 2.5 S.4 23.0 2-4 East of Depot Sq. , Main/6-S' 1.S 12.0 23.0 2-5 East of Depot Sq. . Main/S-lO' 3.3 lS.0 37.0 2-6 East of Depot Sq. & Main/10-12' 1.5 11.0 23.0 2-7 East of Depot Sq. . Main/12-14' 1.2 S.O 18.0 2-8 East of Depot Sq. &. Main/14-16' 1.4 9.6 20.0 3-1 Between Stone . Depot 0-2' 1.0 8.7 20.0 3-2 Between Stone . Depot 2-4' 1.3 9.3 22.0 3-3 Between Stone &. Depot 4-6' 1.1 8.5 24.0 3-4 Between Stone . Depot 6-S' 1.5 11.0 21.0 3-5 Between Stone . Depot 8-10' 1.5 9.7 21.0 3-6 Between Stone . Depot 10-12' 2.4 18.0 33.0 3-7 Between Stone . Depot 12-14' 1.9 12.0 26.0 3-8 Between Stone &. Depot 14-16' 2.0 13.0 2S.0 4-1 Between Stone &. Depot 0-2' 1.0 4.7 12.0 4-2 Between Stone &. Depot 2-4' . 1.2 8.8 17.0 4-3 Between Stone . Depot 4-6' 2.1 15.0 21.0 4-4 Between Stone . Depot 6-8' 1.4 11.0 22.0 4-5 Between Stone , Depot 8-10' 1.7 11.0 27.0 4-6 Between Stone &. Depot 10-12' 1.6 10.0 25.0 4-7 Between Stone . Depot 12-14' 1.4 8.5 23.0 4-8 Between Stone &. Depot 14-16' 1.2 9.2 20.0 5-1 Between Stone . Fair 0-2. 1.4 8.0 19.0 5-2 Between Stone . Fair 2-4' 1.4 8.4 21.0 5-3 Between Stone , Fair 4-6' 1.5 10.0 24.0 ------- TABLE; 5 ANALYTICAL RESULTS OF BEACH SAMPLES AND SOI~ ~~P7;:G ALONG MAIN STREET STORM E /ka) SAMPLE - LQCATION/DEPTH CADMIUM COB.\LT NICKEL 5-4 Between Stone & Fair 6-8' 1.6 11.0 24.0 5-5 Between Stone & Fair 8-10' 1.6 10.0 24.0 5-6 Between Stone & Fair 10-12' 1.7 10.0 23.0 5-7 Between Stone & Fair 12-14' 1.2 11.0 24.0 5-8 Between Stone & Fair 14-16' 1.3 9.3 20.0 6-1 Between Stone & Fair 0-2' 1.2 8.9 19.0 6-2 Between Stone & Fair 2-4' <0.22 5.1 10.0 6-3 Between Stone & Fair 4-6' 1.9 10.0 23.0 6-4 Between Stone & Fair 6-8' 1.0 6.4 16.0 6-5 Between Stone & Fair 8-10' <0.43 5.7 12.0 6-6 Between Stone & Fair 10-12' <0.24 5.7 11.0 6-7 Between Stone & Fair 12-14' 1.6 10.0 22.0 6-8 Between Stone & Fair 14-16' 1.1 6.6 16.0 7-1 Fair and Main 0-2' 1.2 11. 0 22.0 ------- TABLE G, HUDSON RIVER SEDIMENT CADMIUM CONCENTRATIONS Cadmium Concentrations (maIko) 8.91 (1) 6.09 (1) 3.60 (1) 3.21 (1) 1.94 (1) 2.6 (2) 14.1 (2) 4.7 (2) 4.4 (2) 11.5 (2) 11.8 (2) 14.0 (2) 24.2 Location Newburgh Bay (3) Bannerman's Island (3) Little Stony point (3) Can Hook (4) Iona Island (4) Stony Point (4) Yonkers Neehawken (4) N.Y. Port Authority (4) Staten Island (4) Passaic River (4) Port Newark (4) Wappingers Creek (5) /) , v (1) (2) (3) (4) (5) From Kneip and O'Connor 1979 From O.Connor and Maese 1984 Upstream from Marathon Battery Site Downstream from Marathon Battery Site Above Wappinger's Creek (Ebasco (1989) .'# I . " , :1' , . , , : ; ~ : ~ i : n . j: . ,. i Ii ' ; I' en ':', tn' : : n : '. ti-! i i - ; i 0 : t Z f I~l ~: t I ' ~ I ,- Ii; , i I; : t I . : t ------- . . ATTACHMENT C ADMINISTRATIVE RECORD INDEX ------- c, o o ATTACBMEN'l' D BYSDBC LETTBR OP CONCU1UU!:NCB w o v ------- 5EP-29-1ge9 16: 34 FRD1 NYS.~IR.~TION TO t:j-=>';:j~t::f(,1:2264rtbll::J P.~" New York State Department of Environmental Oon""8tlon . WoN Road, Albany, New 1brk 12233-7010 . . Mr. Wil1iam J. MUszynski, P.E. Acting Regional Administrator Emergency and Remedial Response Division U.S. Environmental Protection Agency Region II 26 Federa' Plaza New York. NY 1022S Dear Mr. MuszYnski: SEP 291989 .~ W 11Iom.. C. Jorang CommJuloner RE: Record of Decision (ROD) Marathon Battery Company Site '340006 Area III - East and West Foundry Cove and. The Cold Spring Pier Area . The New York State Department of Environmenta' Conservation (NYSDEC) concurs with the remedies proposed 10r ~he referenced project as described in the Proposed Remedial Action Plan dated July, 19S9 with the addition of sampling and remediation of the Cold Spring Pier, if necessary,and post dredging sampling to confirm the effectiveness of the remedial actions. The remedial action can be sunnarized as follows: .. . . * Dredging to a depth of one foot, fixation and off-site. disposal of cadmium-contaminated sediments in East Foundry Cove and the Cold. Spring Pier area.. . Post dredging sampling and restoration of dredged arias. * * Continued monitoring and hydrological study of Vest Foundry Cove to evaluate its impact on the surrounding environment. V. agreed in our te1.phone conversation of September 29, 1999, that additional bioassay work will not be necessary, and one million dollars has been allocated to this project for remedial design work in the 1989 fiscal year budget. . Should you have any questions on these issues, please call Mr. Michae' J. O'Toole, Jr., P.E., at (518) 457-5861. . Sincere1y, . .. . ~. Deputy Commissioner ------- |