United States
           Environmental Protection
           Agency
              Office of
              Emergency and
              Remedial Response
EPA/ROO/R02-89/097
September 1989
$EPA
Superfund
Record of Decision

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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)

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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

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~
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' ,"'.

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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&)

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-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.

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-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
" . '.~. .
,
.. - - '" ","
" ,.'
. .

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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

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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.

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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

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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

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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
~

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. 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

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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.

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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

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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.

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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

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.
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

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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

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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

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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.

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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

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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

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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

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-,
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

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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
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-...' -,,' - . . . .
"1 ",
, .

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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
, '"

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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

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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

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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

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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
,"

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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

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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.

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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

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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

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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.

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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.

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.
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

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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

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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.

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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

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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. . .: '

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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.. .

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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.

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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
"

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ATTACBHEN'l' A
J'IGURES
"
.'

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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.

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-
.-...--
..- ....... .-.-- ---....
FIGURE 2
<>
DICK'S
CASTLE
HISTORIC
DISTRICT
IPARTIAL)
IfI\lER
. . .
.
~~o
SCALE
.
l
lID

.
«-
o '00
~

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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

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. ,";
<
\
\
; 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
.



\

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,

.\
.
.
.
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.~.'.. ~...
,~
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

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ATTACHMENT
'fABLES
:- ~.. .. .
.' .~(>' .. -;- "
-'. .
B

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  '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'

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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
..

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'., \
'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
, . ~ ,." ~
..". "..

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-
~
   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

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.
   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

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    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

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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'
, .

, ,

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: : n
: '. ti-!
i i -
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: t Z
f I~l ~:
t I ' ~
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i I; : t
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. .
ATTACHMENT C
ADMINISTRATIVE RECORD INDEX

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c,
o
o
ATTACBMEN'l' D
BYSDBC LETTBR OP CONCU1UU!:NCB
w
o
v

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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

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