United States
Environmental Protection
Agency
Office of
Emergency and
Remedial Response
EPA/ROD/R02-90/111
September 1990
&EPA
Superfund
Record of Decision:
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REPORT DOCUMENTATION 11. REPORT NO. I ~ 3. Recipient's AcceMion No.
PAGE EPA/ROD/R02-90/i11
{ 4. TItle snd Subtitle 5, ReR.MI Dste .
DECISIQN ..
SUPERFUND RECORD OF 09/28/90
,
Solvent Savers, NY
6.
First Remedial Action - Final .
7. Author{s) 8. Perfonnlng Organization RepL No.
e. Perfonnlng OrgaJnlzation Name and Add...ss 10. ProjecllTsaklWork Unit No.
11. Contrecl{C) or Grant(G) No.
(C)
(G)
1 ~ &por.ortng Orgsnlzatlon Name snd Addre.. 13. Type 01 Reporl & Period Covered
U.S. Environmental Protection Agency 800/000
401 M Street, S.W.
washington, D.C. 20460 t4.
15. Supplementsry No..s
18. AbetrsC1 (Umlt: 200 words)
The 13-acre Solvent Savers site is a former chemical waste recovery facility in
Lincklaen, Chenango County, New York. The site is bordered by Mud Creek to the east
and by an intermittent stream to the north. Between 1967 and 1974, a variety of wastes
including solids, liquids, and sludges from a distillation process used to recover
solvents were disposed of at the facility. . Concurrently, a drum reconditioning process
was also operated on site. EPA and State investigations conducted from 1981 to 1982
revealed metals, VOCs, and other organic compounds including PCBs in onsite soil, and
metals and VOCs in the ground water. The site has been separated into five principal
source areas, which contain a total of 59,000 cubic yards of contaminated soil, 300
buried and 100 surficial drums, and 578,000,000 gallons of contaminated ground water.
In 1989, EPA required seven Potentially Responsible Parties (PRPs) to conduct an
extensive removal action, which included removing and/or treating all drums and the
associated contaminated soil. To the extent that the work is not completed by the PRPs
in a timely fashion or to the extent that any soil contamination will remain on site
following completion of that work, the remedial action documented in this ROD will be
implemented. The primary contaminants of concern affecting the soil, debris, and
(See Attached Page)
17. Document Analysis.. Descrlptore
Record of Decision - Solvent Savers, NY
First Remedial Action - Final
Contaminated Media: soil, debris, gw
Key Contaminants: VOCs (PCE, TCE), other organics (PAHs, PCBs, phenols),
b. IdentilierelOpen-Ended Terrne metals (arsenic, chromium, lead)
c. COSA TI ReIdIGroup
18. Avlllabiity Statement 19. Security Clus (This Report) 21. No. 01 Psges
None 267
20. Secwlty Clus (This Pege) n Price
Nnnp
212 (4.77)
-
50272.101
(See ANSI Z3e.18)
See InlJlruCUonlJ on Reve...
(Formerly NTISo35)
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EPA/ROD/R02-90/111
Solvent Savers, NY
First Remedial Action - Final
Abstract (Continued)
ground water are VOCs including PCE and TCE; other organics including carcinogenic and
noncarcinogenic PAHs, PCBs, and phenol; and metals including arsenic, chromium, and lead.
The selected remedial action for this site includes excavating 300 buried drums, followed
by treating and disposing of the drums and associated wastes at an offsite RCRA facility;
excavating 59,000 cubic yards of contaminated soil from two highly contaminated source
areas, followed by treating soil highly contaminated with VOCs onsite using low
temperature thermal extraction; treating approximately 1,000 cubic yards of the excavated
PCB-conta~inated soil using the same thermal process or by incinerating the soil offsite,
based on the results of a treatability study; treating soil contaminated with low levels
of VOCs using soil flushing and/or vapor extraction processes, based on the results of a
treatability study; treating any organic vapors from the soil treatment using an as yet
undetermined air pollution control system; backfilling excavated areas with treatment
residuals and clean fill; ground water pumping and treatment onsite using chemical
precipitation, air stripping, and carbon adsorption, followed by reinjection and/or
discharge to surface water; disposing of ground water treatment residuals offsite; and
monitoring air and ground water. The estimated present worth cost for this remedial
action is $29,350,000, which includes an estimated annual O&M cost of $523,000 for 20
years.
PERFORMANCE STANDARDS OR GOALS: Initial soil cleanup levels are based on an average of
mOdel-derived cleanup levels to prevent further contamination of ground water, and
include PCE 2.2 mg/kg, TCE 0.8 mg/kg, toluene 1.5 mg/kg and xylenes 3.1 mg/kg.
PCB-contaminated soil will be treated to attain the level of 1 mg/kg (TSCA PCB policy) .
Chemical-specific goals for ground water are based primarily on the more stringent of
SDWA MCLs or State standards. Cleanup goals for over 50 contaminants are provided in the
ROD, including PCE 5 ug/l (CLP Quantitation Limit), TCE 5 ug/l (MCL), arsenic 25 ug/l
(State), noncarcinogenic PAHs 32,340 ug/l (health-based), and phenols 48,500 ug/l
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\f
RECORD OF DECISION
SOLVENT SAVERS SITE
TOWN OF LINCKLAEN
CHENANGO COUNTY, NEW YORK
PREPARED BY THE
U'. S. ENVIRONMENTAL PROTECTION AGENCY
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SITE
Name:
Location:
HRS Score:
NPL Rank:
ROD
Date Signed:
Remedy:
Capital Cost:
o & M/Year:
. ROD FACT SHEET
Solvent Savers
Town of Lincklaen
Chenango County, New York'
35.57-34.47
582/849
9/28/90
Source control component:
Low Temperature
Thermal Extraction
Groundwater Component:
Chemical Precipi~ation/
Air stripping/Carpon
Adsorption
$21,271,000
Present Worth Cost: $29,350,000
$523,000
LEAD
EPA Remedial
Primary contact:
Secondary contact:
Main PRPs:
WASTE
Type:
Medium:
Origin:
Lisa K. Wong (212) 264-9348
Elena T. Kissel (212) 264-4877
General Electric Company
Bristol Laboratories, Inc.
International Business Machine Corporation
Pass and Seymour, Inc.
American Locker Group, Inc.
UNISYS Corporation
Stauffer Chemical Company
U.S. Department of Air Force
Allied Corporation
Solvents & Petroleum Services, Inc.
Carrier corporation
champion International corporation (formerly
st. Regis Corp.)
organics, PCBs, metals
Soil, groundwater
Drums, solids, liquids, and sludges disposed of
on-site
Estimated quantity: contaminated
Contaminated
soil: 59,000 cubic yards
groundwater: 578,000,000 gallons
(flowrate: 55 gpm
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Declaration for the Record ~f Decision
. Site Name and Location
Solvent Savers Site
Town of Linck~aen, Chenango County, New York
statement of Basis and Purpose
This decision-document presents the selected remedial action for
the. Solvent Savers site (the "Site"), located in the Town of
Lincklaen, Chenango County, New York, which was chosen in accor-
dance ..,;i th the requirements of the Comprehensive Environmental
Response, Compensation, and Liability Act of 1980 ("CERCLA"), as
amended by the Superfund Amendments and Reauthorization Act of 1986
("SARA") an<;i, to the extent practicable, the National Oil and.
Hazardous Substances Pollution Contingency Plan ("NCP"). This
decision document. explains the factual and legal basis for
selecting the remedy for the Site.
The New York State Department of Environmental Conservation
(l;YSDEC) concurs with the selected remedy. The information
supporting this remedial action decision is contained in the
adr..inistrative record for the Site. The administrative record
index is attached.
Assessment of the site
Actual or threatened releases of hazardous substances from the
Site, if not addressed by implementing the response action selected
in this Record of Decision ("ROD"), may present an imminent anq
subs~antial threat to public health, welfare, or the environment.
Description of the Selected Remedy
The selected remedy will address the buried drums and soil contami-
nation at the Site (to the extent that the work required un~er the
September 1989 Administrative Order Index No. II CERCLA-90227 is
not completed by the Respondents in a timely fashion or to the
extent .that any soil contamination will remain at the Site
following the completion of that work) and contaminated groundwater
in the underlying aquifer. This action addresses the principal
threats remaining at the Site by removing the buried drums for off-
site treatment and disposal, by excavating and treating the most
highly contaminated soil and waste materials both on-site and off-
site, and by treating the groundwater at the Site. The excavated
drums and treatment residuals will be treated and disposed of off-
si te, and the soil contaminated with polychlorinated biphenyls
("PCBs") will be treated on-site or treated and disposed of off-
site (to be determined during the remedial design phase based on
treatability study results). The soils that will be treated and
redeposited on-site will contain contaminants well below hea1th-
based levels. Hence the Site will not require any long-term
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a comprehensive management and maintenance program to ensure-the
effectiveness of,the treatment and reinjection and/or discharge
system throughout the estimated treatment period of 20 years. .
The maj or comyonents
fOllov,ing:
of the selected remedy include the.
- Excavation and removal of an estimated 300 buried drums for
off~site treatment and disposal at an approved Resource
Conservation and Recovery Act ("RCRA") hazardous waste
facility; .
- Excavation of approximately 59,000 cubic yards of contami-
nated soil (including 1,000 cubic yards of PCB-contaminated
soil) ;
- On-site treatment, using low temperature thermal extraction,
of the soil highly contaminated with volatile organic
compounds (IIVOCS ") ;
- Backfilling of the excavated areas with the treated soil and
approximately 1,000 cubic yards of clean fill (if removal
of the PCB-contaminated soil for off-site incineration
is deemed necessary);
- Performance of treatability studies during the remedial
design to determine whether the low temperature thermal
extraction process is an appropriate treatment method for
the PCB-contaminated soil. If the treatability study resul ts
indicate that low temperature thermal extraction is an
appropriate treatment method, then this technology will be
utilized to treat the excavated soil contaminated with PCBs
on-site. Should the findings of the treatability studies
indicate that the on-site low temperature thermal extraction
process will not provide the desired degree of treatment,
then the excavated PCB-contaminated soil will be removed for
off-site incineration;
- Performance of treatability studies during the remedial
design to determine whether the soil flushing and/or vapor
extraction processes are appropriate treatment methods for
the excavated soil contaminated with low level VOCs. If the
treatability study results indicate that one or both of
these technologies are appropriate treatment methods, then
one or both of these technologies will be utilized to treat
the excavated soil contaminated with low level VOCs.
Should the findings of the treatability studies indicate
that these on-site treatment processes. will not provide the
desired degree of treatment, then the contaminated soil
will be treated on-site using low temperature thermal ex-
traction.
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Extraction and on-site treatment, using chemical precipita-
tion, air stripping and carbon adsorption, of the contami-
nated groundwater in the underlying aquifer: . .
, . ...
- Reinjection of the treated water into the ground, and/or
discharge of the treated water to surface water: and,
- Disposal of the treatment residuals at an off-site approved
RCRA hazardous waste facility.
Declaration of-Statutory Determinations
The selected remedy is protective of human health and the environ-
ment, complies with federal and state requirements that are legally
applicable or relevant and appropriate to the remedial action, and
is cost-effective. This remedy utilizes permanent solutions and
alternative treatment (or resource recovery) technologies to the
maximum extent practicable, and satisfies the statutory preference
for remedies that employ treatment that reduces toxicity, mobility,
or volume as a principal element. .
Because this remedy will not result in hazardous substances
remaining on-site above health-based levels, the five-year review
will not apply to this action.
/
;c:~ .
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DECISION SUMMARY
SOLVENT SAVERS SITE
TOWN OF LINCKLAEN
CHENANGO COUNTY, NEW YORK
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION II
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TABLE OF CONTENTS
SITE NAME, LOCATION AND DESCRIPTION...................... 1
SITE HISTORY............................................. 2
ENFORCEMENT ACTIVITIES................................... 5
HIGHLIGHTS OF COMMUNITY PARTICIPATION.................... 6
SCOPE AND ROLE OF RESPONSE ACTION........................ 6
SUMMARY OF SITE CHARACTERISTICS.......................... 7
SUMMARY OF SITE RISKS.................................... 9
DOCUMENTATION OF SIGNIFICANT CHANGES.....................18
DESCRIPTION OF ALTERNATIVES.............................. .19
SU'~RY OF COMPARATIVE ANA~YSIS OF ALTERNATIVES.........27
T A~ SELECTED REMEDY...................................... 34
STATUTORY DETERMINATIONS.................................38
ATTACHMENTS
APPENDIX 1
APPENDIX 2
APPENDIX 3
APPENDIX 4
APPENDIX 5
- TABLES
- FIGURES
- ADMINISTRATIVE RECORD INDEX
- NYSDEC LETTER OF CONCURRENCE
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,SITE NAME. LOCATION. AND DESCRIPTION
'-
The Solvent Savers site (the "Site") covers about 13 acres in a,
rural, sparsely populated a'rea, and is located in the TO'w'n of .
Lincklaen, Chenango County, New York (See Figure 1) . The Site iG
approximately 30 miles south of Syracuse, New York, and 40 miles
north of Binghamton, New York.
The Site is bounded by Union Valley Road to the west, Mud Creek to
the east, an unnamed intermittent stream to the north, and shrubs
and trees to the south (see Figure 2). Mud Creek is classified as
a trout strea~ by the New York State Department of Environmental'
Conservation ("NYSDEC") and is used for recreational ' activities and.
livestock watering. .
Two residential homes, whiGh utilize private wells as the so~rce
of drinking water i are located near the Site. The Springer
residence is located about 300 feet north of the Site, and the
Parkin residence is located about 200 feet to the west of the Site.
Two buildings are presently standing on-site (See Figure 2). A
vacant house owned by Mr. Robert Lindsey is located near the center
of the Site. An abandoned process building is located near the
north..'est corner of the property. Two small sheds, which were
erected during the potentially responsible parties' ("PRPs")
remedial investigation and feasibility study ("RIfFS") work for the
storage of the drums containing drill cuttings and well development
water, are located along the northeast boundary of the property.
A well house that existed along the driveway entrance to the
Lindsey house is now an open sunken basement. A second well house
located along the cliff near Mud Creek at the northeast corner of
the Site is presently a covered sunken basement filled with stone.
A concrete pad is situated next to the former Solvent Savers
process building. This pad was the foundation for a second process
building, which was dismantled in 1988. On the north side of this
pad is a hatchway that ~eads down into a cellar-like area. Figure
2 depicts the locations of the existing buildings and structures
on-site.
The Town of Lincklaen is located in the northwestern section of
Chenango County, New York. According to the 1980 census, 473
people reside in the Town of Lincklaen. This portion of Chenango
County is used primarily for dairy farming. There are presently
15 dairy farms in the Town of Lincklaen. 'Dairy cattle pastures are
located less than two miles from the Site, and these pastures
adjoin Mud Creek, downstream of the Site. In addition to the dairy
farms in the area, there is also farming o~ alfalfa, corn and other
crops on a small scale.
The Solvent Savers Site is situated in a physiographic region known
as the Glaciated Allegheny Plateau. This physiographic region
consists of, a series of elongated, broad, undulating hills
separated by narrow floodplains. The elevation in the valley in
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G
sea level ("MSL"). The valley is approximately 1500 feet wide. at
the Site location. The Site is situated on a. kame terrace
.approximately 40 feet above the valley floor. The southern half
of the terrace i's generally flat with a slight grade to the east..
The northern half has been partially excavated and graded. This
area slopes to the north and northwest and to the intenn.i ttent
stream that flows along the northern perimeter of the Site. The
western portion of the Site ascends to a steep sloping hillside,
that rises 750 feet above the valley floor to an elevation of 1920
feet at its apex. The eastern portion of the Site plunges 40 feet
nearly straight down to the valley floor. The valley floor is
generally flat and is drained by the meandering Mud Creek.'
SITE HISTORY
Solvent Savers, Inc. was a chemical waste .recovery facility.
operated by Mr. -Dale Hough between . approximately 1967 and 19.74.
Waste industrial solvents w~re hauled from clients in the Syracuse
and Binghamton areas to the facility. A distillation process was
used to recover solvents for reuse. It is suspected that a wide
variety of wastes from the distillation process, including liquids /
solids, and sludges, were disposed of on the Site. In 'addition,
Mr. Hough owned and operated a drum reconditioning business (Cash
Barrel, Inc.) at the same location, which reconditioned and sold
many of the drums brought to the Site containing waste solvents.
Solvent Savers, Inc. ceased operations in 1974. In October 1978, .
Mr. Robert Lindsey purchased the property and regraded it, moving
some exposed drums ard al~rge tank, and covering them with soil.
He also removed some expo~=d drums from the ~ite.
In 1981, NYSDEC conducted an initial site characterization, which
included sampling of the on-site surface soils, water in Mud Creek,
and groundwater from three private wells in the immediate vicinity
of the Site. Sample analyses indicated the presence of contami-
nants that included volatile organics (primarily trichloroethylene
and 1,1, 1-trichloroethane) , polychlorinated biphenyls ("PCBs'.'), and
various inorganic substances (arsenic, cyanide, cadmium, and lead) .
In 1982, the EPA Field Investigation Team ("FIT") performed a
hazardous waste site inspection at the Site. During the FIT
investigation, metals and organic compounds were detected in the
surface soils, and organic chemicals were detected in the groundwa-
ter beneath the Site and in the surface water in Mud Creek. As a
result of the FIT investigation, the Site was listed on the
National Priorities List of uncontrolled hazardous waste sites in
1983.
EPA and NYSDEC identified a number of potentially responsible
parties ("PRPs") that had arranged for the disposal of wastes at
the Site. The State of New York initiated negotiations with the
PRPs to begin the site cleanup.
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,In 1984, a consent agreement between the PRPs and the New York
State Department.'of Law ("NYSDOL") was signed, requirin9 the PRPs
to perform a remedial investigation and feasibil i ty study ("RI/FS")' .
at the Site. In August 1985, a consultant for the PRPs preparti
an RI/FS repo~t that recommended the following: .
'.
i)
Excavate the buried drums for treatment and/or
disposal off-site;
ii)
Cover portions of the Site with a less permeable soil
cover and revegetate;
iii)
Restrict future use of contaminated groundwater using
institutional controls; and .
iv)
Allow natural flushing to reduce the levels of contaminants
in the groundwater to acceptable levels. (The estimated time
to naturally flush the contaminants from the soil was 85
years. )
On the basis of a review of the PRPs' RI/FS report, it was
determined that additional RI/FS work was necessary to obtain the
data and information needed to characterize the nature and extent
of contamination at the Site, and to formulate the optimum cleanup
strategy.
In 1988, notification was sent by the EPA to the PRPs, stating
EPA's intent to perform a supplemental RI/FS, and offering the PRPs
an opportunity to conduct the supplemental RI/FS. The failure of
the PRPs to agree to undertake the supplemental' RI/FS in an
acceptable manner prompted EPA to initiate a supplemental RI/FS
independently.
ICF Technology, Inc. ("ICF"), EPA's consultant, commenced field
investigations under the supplemental RI/FS in November 1988.
Field work was completed in May 1990. The field investigations
included surface and subsurface soil sampling, a magnetometer
survey, test pit excavations, soil gas sampling, monitoring well
installations, depth-to-water. measurements, surface water,
sediment, groundwater, and air sampling, a pump test, a study of
the biota in Mud Creek, a delineation of the wetlands and flood-
plains, and cultural and biological resources studies.
During the performance of the field work associated with the
supplemental RI, over 100 drums were excavated and overpacked by
ICF. An estimated 300 drums remain buried.
Results of the supplemental RI identified five source areas (See
Figure 3). Samples collected from surface and subsurface soils in
these areas show that the soils are contaminated with volatile
organic compounds ("VOCS"), extractable organic compounds, metals,
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and PCBs. While contaminated soils have been detected in all-.five
source areas, based upon the prel iminary results of a fat-e - and
. transport model ~mplemented by EPA to determine target soil clean-
\1P levels, it! appears that only Areas 2 and 4 will requir-e.
remediation. During the remedial design, the model will be
calibrated ~nd tested using current and additional sampling data,
as necessary~ to more precisely define the soil cleanup levels and
the areal extent of the areas requiring remediation. Should the
data collected during the remedial design indicate that Areas 1,
3 and/or .5 a1so require remediation, the contaminated soil fro:::
these areas will also be treated to achieve the target cleanup
levels. .
Area 1 (about 250 square feet (ft2»was previously' used as a dru~
storage area. Volatile and extractable organic contaminants were
found at a depth of about 12 feet. Chromium ~nd lead were found
in surface soils.
Area 2 (about 7,500 ft2) was previously use~ as a discharge area for
spent solvents and wastewaters and as a drum disposal area. Area
2 has the highest levels of surface and subsurface soil contamina-
tion on-site. The primary contaminants detected were tetrachloroe-
thene ("PCE"), trichloroethene ("TCE"), and 1, 1, 1-trichloroe-
thane. In addition, a PCB hot-spot was detected in this area.
Barium was detected above the background level.
Area 3 (about 250 ft2) was the location of an excavation that was
backf illed with a 500-gallon tank, a drum, and miscellaneous
debris. VOC contamination was detected in t~is area.
Area 4 (about 11,250 ft2) is located in the central portion of the
Site and includes a large drum burial area. VOC contamination was
found consistently in all borings down to the water table (approxi-
mately 40 feet). TCE was the chemical found most frequently. Low
levels of PAHs and phthalates were detected. PCB contamination was
detected in surface soils in this area. The highest level of
surface PCB contamination detected was 18,600 ppm.
Area 5 (about 250 ft2) is located near the former Lindsey residence.
voc contamination was detected at depths down to 32 feet. TCE was
the chemical detected most frequently in this area. Barium was
detected above the background level.
Groundwater samples collected on-site and downgradient show the
presence of contamination by VOCs and metals. The VOC contamina-
tion is primarily TCE, PCE, and degradation products of - these
compounds. The metals include lead, chromium, arsenic, beryllium,
and cadmium.
As part of the supplemental RI, EPA, in cooperation with the U.S.
Fish and Wildlife Service, completed the field work for a
bioassessment at the Site in May 1989. The objective of this study
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was to determine whether contaminants from the Site are cau~ing
adverse ecological impacts to the fish and wildlife resources in
.the Mud Creek. , . Samples of surface water, sediment" and fish
tissues were collected, and analyses were performed for VOCs, PCBs"
pesticides, base neutral/acid extractables (BNAs), metals and'
cyanide. No BNAs were detected in fish tissues. ,The lev.els of
BNAs detected-in surface water and sediment were below detection
1 imi ts. No pesticides or PCBs were detected, n surface water,
sediment or fish samples. The levels of VOCs and metals detected
in surface water, sediment, and fish tissues do not pose a
significant threat to aquatic organisms. VOCs are rapidly
biodegraded and exhibit a low potential for bioaccumulation. A
number of lesions in fish tissues were found, but none can be
a~tributed to the contamination at the site or are indicative of
serious health problems.
"
ENFORCEMENT ACTIVITIES
Thirteen PRPs, who arranged for the treatment or disposal of
hazardous substances which came to be disposed of at the Site, were
identified by the EPA in connection with the Solvent Savers Site.
As discussed earlier, the PRPs entered into a consent agreement
with the NYSDOL in 1984 and were obligated to conduct an RI/FS to
determine the nature and extent of the contamination at the Site,
and to evaluate the alternatives for final site remediation.
Following the submission of an inadequate RI/FS report by the PRPs'
consultant in August 1985, EPA sent several notice letters to the
PRPs, offerir.~ them the opportunity to agree to perform the
required supplemental investigations at the Site. No PRP volun-
teered to undertake or finance such activities. An EPA action
memorandum was approved on June 25, 1987, authorizing funding for
the supplemental RI/FS work.
In September 1989, EPA determined that 'it was necessary to address
the rlsks posed to the public and the environment due to the
potential release and migration of the contaminants in the over 100
surficial drums and in the drums that remained buried on-site, and
issued an Administrative Order to seven of the PRPs for which EPA
has evidence that they brought drummed wastes to the Site,
requiring them to undertake the following removal activities:
- Remove and properly dispose of the overpacked drums;
- Excavate, overpack,
buried drums;
remove,
and properly dispose of the
- Implement a soil sampling program to define the nature and
extent of contamination resulting from releases of hazardous
constituents from the buried drums; and
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- Excavate, treat and/or dispose of the contaminated soil-
associated with the drums.
. .
In October 1989; the PRPs' consultant submitted to EPA" a phase r' .
removal action work plan, which detailed the tasks that would be
involved in the removal and disposal of th~ overpacked drums. The
PRPs' consultant sampled the contents of the drums and is currently
in the process of obtaining disposal facility approvals for dis-
posal of the overpacked drums. Removal of the overpacked drums
containing ha~rdous substances is anticipated to be completed by
the fall of 1990. A phase II removal action work plan, which
outlines the activities to be implemented to address the drums that
remain buried and the contaminated soils at the Site, has undergone
E~A review and is being finalized by the PRPs. .
HIGHLIGHTS OF COMMUNITY P~RTICIP~TION
The RIfFS report and the Pr6posed Plan for the Solvent Savers Site
were released to the public for comment on July 23, 1990. These'
two documents were made available to the public in both the
administrative record and an information repository maintained at
the EPA Docket Room in Region II, New York, at the Pond Store in
DeRuyter, New York, and at NYSDEC's offices in Albany, New York.
A public comment period on these documents was held from July 23,
1990 through September 7, 1990. In addition, a publ~c meeting was
held at the Town of Lincklaen Town Hall on August 13, 1990. At
this meeting, representatives from the EPA and NYSDEC answered
questions about problems at the Site and the remedial alternatives
under consideration. Responses to the comments received during the
public comment period are included in the Responsiveness Summary,
which is appended to this ROD.
SCOPE ~ND ROLE OF RESPONSE ~CTION
The purpose of this response is to prevent current or future
exposure to' the contaminated soil, to ensure protection of the
groundwater, air, and surface water from the continued release of
contaminants from the soil and buried drums (to the extent that the
work is not completed by the Respondents in a timely fashion or to
the extent that any soil contamination will remain at the Site
following the completion of that work), to ensure protection of
human health and the environment from the migration of contaminants
in the groundwater, and to restore the groundwater to levels
consistent with the state and federal water qua1i ty standards.
This remedial action will be the final response action for the
Site.
To the extent that any of the drums or soil removal and treatment
called for by this ROD is not or will not be completed by the
Respondenets pursuant to the September 1989 Administrative Order,
the said work will be carried out together with the other remedial
measures called for by this ROD.
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SUMMARY OF SITE CHARACTERISTICS
Industrial solvents and other wastes were brought to Solvent
Savers, Inc., a chemical waste recovery facility for reprocessing.
or disposal. Operations included distillation to recover solvents
for reuse, d~um reconditioning, and burial of. liquids, Solids,
sl udges, and drums on-site. The quanti ties a~.O types of wastes
disposed of at the Site and their locations arc not fully known.
The primary contaminants of concern are associated with the past
distillation and drum reconditioning processes and waste handling
practices at the Site. . Consequently, the operations and waste
disposal activities conducted by Solvent Savers, Inc. are believed
to be the source of co~~amination of the soil and groundwater at
the Site. .
Soil Investiqation
Based on the results of the magnetometer survey and test pit
excavations, drums were found buried in four areas (Areas 1, 2, 3,
and 4). An estimated 300 drums remain buried at the Site (See
Figure 4).
The information gathered during the supplemental RI has identified.
five areas of soil contamination (See Figure 3). The nature and
extent of surface soil contamination is directly attributed to the
operations and waste handling practices utilized at the Site.
Surface and subsurface soil samples were collected, and analyses
were performed for VOCs, extractable organic compounds, PCBs, and
inorganic compounds. These sampling locations are shown on Figures
5 to 7. Summaries of analytical results are presented in Table
4 for surface soil samples, and in Tables 5 and 6 for subsurface
soil samples.
Soils at the Site are contaminated with VOCs, extractable organic
compounds, metals, and PCBs. The extent of VOC contamination is
widespread and is concentrated in the five areas. Metals contami-
nation is less widespread (most contamination is near background
levels), occurring in areas where VOC contamination also exists.
The PCB contamination is limited to two hot spots at the Site (See
Figure 6).
Halogenated hydrocarbon compounds such as trichloroethene,
tetrachloroethene, and 1, 1, 1-tricholoroethane were the most
frequently detected VOCs, and were found at the highest levels in
surface soil samples. Tetrachloroethene, trichloroethene, and
toluene are used as industrial solvents. 1, 1, I-trichloroethane,
1,2-dichloroethane, l,l-dichloroethene, and l,l-dichloroethane are
compounds that may have been present in solvents dumped at the Site
or formed through natural degradation processes of tetrachloroe-
thene and trichloroethene.
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Extractable organics detected in surfac'e soil samples included
. phthalate ester~ and polynuclear aromatic hydrocarbons (background
levels are presented in Table 3.) Most samples had concentration .
levels near the detection limit. Benzoic acid, benzo(b) fluoro-
anthene, benzg(k) fluoroanthene, and bis(~-ethyl-hexyl) phthalate
were the compounds detected most frequently.
Four separate aroclors of PCBs (1242, 1248, 1254, and 1260) were
identified- in surface soil samples. PCBs were found above 10 mg/kg
at six locations in the two PCB hot spots which are areas of
stressed vegetation (See Figure 6).
MQst inorganics found in surface soil samples are within the normal
background range for the area where the Site is located (See Table
2). Surface soil samples in Area 1 indicated the presence of.
chromium and lead above background levels.
High levels of PCE and TCE were detected in subsurface soil samples
collected from Areas 2 and 4. These contaminants were also found
at lower concentrations in subsurface soil samples from Areas 1,
3, and 5. High levels of l,l,l-trichloroethane were detected in
the subsurface of Area 2. Bromoform was found in subsurface soils
in Areas 2 and 3.
Extractable organic contamination is not widespread in subsurface
soils. Pentachlorophenol was detected in subsurface soil in Area
1. PCBs, isomers of chlorinated dibenzo dioxin (PCDD, HxCDD,
HPCDD, and OCDD) , 1, 2, 4-trichlorobenzene, various phthalate
esters aT' J pol":1uclear aromatic hydrocarbon compounds (anthracene,
pyrene, napthalene, 2-methylnapthalene, and phenanthrene) were
found in subsurface soil in Area 2. Bis(2-ethylhexyl) phthalate
was detected in subsurface soil in Area 3. Phthalate esters,
polynuclear aromatic hydrocarbons, PCBs, and isomers of chlorinated
benzene were found in subsurface soil in Area 4.
Most inorganics found in subsurface soil samples are within the
normal background range for the area where the Site is located (See
Table 2). Barium was detected in Areas 2 and 5, and cadmium was
detected in Area 4 above background levels.
Groundwater Investiqation
The groundwater investigation included installation of monitoring
wells and groundwater sampling. The monitoring well locations are
shown on Figure 8. Table 12 provides data for the depth of each
installed well and the total depth of the well boring at each
location. Groundwater samples collected from the 34 monitoring
wells and the three residential wells were analyzed for VOCs,
extractable organic compounds, and PCBs. Summaries of analytical
results are presented in Tables 7 and 8.
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The findings of the investigation revealed the presence of VOCs'and
metals in the groundwater samples collected on-site and downgradi-
'e:-:: of the Site... The VOC conta'mination is primarily TCE', PCE, and
b~~er related organic compounds that could be degradation products' ,
of TCE and PCE. Inorganic contaminants of primary concern fou!"....:
in the groundwater include arsenic, cadmium, lead, beryllium, and
chromium. Beryllium and chromium are typical chemicals found i~
waste sludges or spent solvents from metal finishing or electro-
plating operations. Soluble lead-containing compounds are used in
dyes and varni~hes, and electroplating processes.
.~
The buried drums and contaminated soil on-site have contributed to
the contamination of the groundwater underlying and downgtadient.
Table 33 provides a comparison of the maximum and geometric mean
contaminant concentrations detected to the groundwater action
levels.
Surface ~ater and Sediment Investiaation
Surface ~ater and sediment samples were collected from the
intermittent stream and Mud Creek, and analyzed for VOCs, extract-
able organics, PCBs, and metals. The sampling locations are shown
on Figure 9.
Summaries of analytical results are presented in Tables 9 and 10.
No PCBs were detected in any surface or sediment samples. Only one
sample had detected extractable organic compounds. VOCs were found
in surface water and sediment samples. As discussed earlier, these
organic cOffipounds exhibit a low potential for bioaccumulation, and
hence pose no significant threat to fish and wildlife resources.
SUMMARY OF SITE RISKS
A baseline pUblic health evaluation was performed as part of the
supplemental RI to define the carcinogenic risks and noncarcino-
genic chronic lifetime effects associated with the Solvent Savers
Site, assuming that no remedial action occurs. The risk assessment
was based on an analysis of the impact of 63 organic and 24
inorganic contaminants identified as chemicals of potential concern
(See Table 11) that are present at the Site.
Potential human health risks were evaluated for the
exposure pathways:
following
Current exposure of neighboring children and teenagers to
surface soil contaminants through direct contact, with
subsequent incidental ingestion and dermal absorption during
play activities;
Current exposure of nearby residents to groundwater contami-
nants through ir-jestion of drinking water from residential
wells;
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Current exposure of neighboring children and teenagers to
sediment a~' surface water contaminants in Mud Creek and the
intermittent stream through direct contact, with subsequent'
incidental ingestion and/or dermal absorption during play
activities;
Current expo,sure of nearby residents to site contaminants
through inhalation of vapors;
Future exposure of on-site residents to surface soil contami-
nants through direct contact, with subsequent incidental
ingestion and dermal absorption; ,
Future exposure of on-site residents to subsurface soil
contaminants through direct contact, with subsequent inciden-
tal ingestion and deIi!lal 'absorption during play activities;
Future exposure of on-site residents to groundwater contami-
nants through ingestion of drinking water from on-site wells;
and .
Future exposure of nearby residents to
through inhalation of vapors.
For each of the potential exposure pathways identified above,
potential risks to human health were estimated. Exposure scenarios
were developed for each path~ay to represent a reasonable maximum
exposure (IIRHE") case. Quanti tati ve risk estimates were developed
by calcl.latinl:-! intakes for the poter,. ially exposed populations
based on the assumed exposure scenarios and then combining these
intakes with reference doses(IIRfDs") for noncarcinogens or cancer
slope factors for carcinogens.
site
contaminants
EXPOSVRE ASSESSMENT
To determine potential exposures associated with each pathway, the
chronic daily intake (IICDI") of each chemical associated with that
pathway was estimated. A CDI was averaged over a lifetime for
carcinogens and over the exposure period for noncarcinogens.
For each exposure pathway, a RME case was considered. Under this
scenario, the 95th upper confidence limit on the arithmetic mean
val ue for exposure concentration was combined with reasonable
maximum values describing the extent, fraquency, and duration of
exposure to estimate the CDI. In a case where the 95th upper
confidence limit on the arithmetic mean exceeded the maximum
detected value, the maximum concentration was used.
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Current Land Use Scenarios
I.
Direct Con:yct with Surface Soils by Children
Childre~- playing on the Site may directly contact contaminated
surface soils- with subsequent incidental. ingestion and dermal
absorption of chemicals. Assumptions made in de~ermining CDIs for
this scenario under RME conditions are presentee. in Table 13.
II.
Inqestion-of Water from Residential Wells by Residents
Assumptions used to evaluate exposure to contaminants in groundwa-
ter through ingestion are summarized in Table 14.
III.
Direct Contact with Sediments/Surface Water by Children
and Teenaqers
Children and teenagers who play on or pass through the Site may
corne into contact with sediments and surface water by wading,
riding their bicycles through, or playing in and around the
intermi ttent stream and/or Mud Creek. The exposure parameters used
to evaluate this pathway are shown in Tables 15 and 16. The same
assumptions used to evaluate direct soil contact were used with t~c
exceptions: the area of exposed skin was taken to be the hands,
arms, legs, and feet, and the frequency of exposure for wading in
the water was assumed to be lower for playing in and around the
stream (four times per week from May through September) than for
playing in soils on the ground. .
IV.
On-Site Inhalation C-. Children
Children playing on the Site may be exposed to airborne contami-
nants via inhalation. Most of the assumptions (i.e., exposure
frequency and duration, and body weight) made in determining CDIs
for this scenario are the same as those made for the direct contact
with surface soils by children, which are presented in Table 13.
Two additional assumptions regarding exposure time and inhalation
rate were made for this scenario. An average duration of exposure
of 8 hrs/day was considered a RME condition. A reasonable worst-
case inhalation rate of 3.7 m3/hr was calculated using the inhala-
tion rate of a 10-year-old child (average age) spending 50 percent
of the time at a heavy activity level and 50 percent of the time
at a moderate activity level.
Future Land Use Scenarios
I.
Direct Contact with Surface and Subsurface Soils bv Residents
The Site is located in a primarily residential/agricultural area.
Consequently, possible future uses of the Site include site
development for residential purposes and/or agricultural uses.
Residents could potentially be exposed to contaminants present in
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surface and subsurface soil through dermal absorption and inciden-
tal ingestion resulting from activities' such as gardening" or
'playing. It was!assumed that subsurface soils (up to 10'ft) might
be redistributed to the surface during grading or other soil'
disturbing activities.
- ,
Table 17 summarizes the exposure parameter values used to evaluate
these two pathways for both surface and subsurface soil.
II.
Inqestion-of Water from On-Site Wells by Residents'
The assumptions used in evaluating future exposure to contaminants
in groundwater through ingestion are the same as those employed
unqer current land use conditions, which are presented in Table 14.
III.
On-Site Inhalation by Residents
The assumptions used to evaluate exposure of on-site residents to
contaminants through inhalation are presented in Table lB.
RISK CHARACTERIZATION
The health effects criteria (cancer slope factors and RfDs) , for
the chemicals of potential concern at the Solvent Savers Site are
presented in Tables 19 and 20 for oral and inhalation exposures,
respectively.
Cancer slope factors, which are expressed in units of
(mg/kg-day) ,}, have been developed :JY EP', I S carcinogenic Asressmeit
Group for estimating excess life~ime Cctncer risksl associ~~ed ~_ch
exposure to potentially carcinogenic chemicals. The cancer slope
factors are multiplied by the estimated, intakes of potential
carcinogens (mg/kg-day) to provide upper-bound estimates of the
excess lifetime cancer risks associated with exposures at those
intake levels. The term "upper bound" reflects the conservative
estimate of the risk calculated from the cancer slope factor. Use
of this approach makes underestimation of the actual cancer risk
unlikely. Cancer slope factors are derived from the results of
human epidemiological studies or chronic animal bioassays to which
animal-to-human extrapolation and uncertainty factors have been
applied.
~Excess lifetime cancer risks are probabilities that are generally
expressed in scientific notation (e.g., lxlO~). An excess lifetime
cancer risk of lxlO~ indicates that, as a maximum upper bound, an
individual has a one in one million chance of developing cancer as
a result of site-related exposure to a carcinogen over a 70-year
lifetime under the specific exposure conditions at a site.
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RfDs have been developed by EPA for evaluation of the potential -for
,adverse health effects from exposure t'C chemicals exhibiting
nQncarcinogenic~ffects. RfDs, which are expressed in' units' of
rng/}>3-day, are estimates of lifetime daily exposure' levels fer'.
humans, including sensi ti ve individuals. Estimated intakes c:
chemicals from environmental media (e.g., the amo~nt of a chemical
ingested from contaminated drinking water) can ~. compared to the
RfD. RfDs are derived from human epidemiological studies or animal
studies to which uncertainty factors have been applied (e.g., to
account for tne use of animal data to predict effects on humans) .
These uncertainty factors help ensure that the RfD wi.ll not
underestimate the potential for adverse noncarcinogenic effects tc
Occur.
.~
Estimated CDIs are used to determine the potential health risks
associated with exposures to ~arcinogens and' the potential for.
adverse noncarcinogenic health effects. For potential carcino-
gens, excess lifetime cancer risks are obtained by multiplying the
CDIs of the contaminants under consideration by their respective
cancer slope factors.
Potential concern for noncarcinogenic effects of a single contami-
nant in a single medium is expressed as the hazard quotient ("HQ")
(i.e., the ratio of the estimated intake derived from the contami-
nant concentration in a given medium to the contaminant's RfD).
By adding the HQs for all contaIToinants within a medium or across
all media to which a given population may reasonably be exposed,
the Hazard Index (HI)2 can be generated. The HI provides a useful
reference point for guaging the potential significance of multiple
~ontaminant exposures within a single medium or across media.
The context within which to judge the relative risk from each of
the pathways has been established by EPA. For carcinogens, the
target risk range is a lO~ to lO~ excess lifetime cancer risk.
For noncarcinogens, where the sum of the expected intake/RfD rati-
os (HQs), i. e. HI, exceeds unity, observed concentrations pose
unacceptable risks of exposure.
The results of the risk characterization
exposure evaluated are summarized below:
for each pathway of
~For noncarcinogens, a hazard index greater than one indicates that
adverse noncarcinogenic effects could occur, while a value below
one ~ndicates that such effects are unlikely to occur.
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Current Land Use Scenarios
'I.
Direct Contact with Surface Soil by Chfldren
The estimated excess upper-bound lifetime cancer risks and the
noncarcinogenic HQs associated with this exposure pathway are
presented in Table 21. The estimated total excess lifetime cancer
risk (4x10~) exceeds EPA's target cancer risk range, due to the
presence of PCBs in the soil. The cancer risk for PCBs is at least
4 orders of ma~nitude higher than the cancer risks for the other
chemicals of p,0tential concern. The HI value for noncarcinogenic
effects (4x10) also exceeds the threshold level of one for this
pathway, due to the presence of PCBs. No other contaminant poses
a bealth threat via this exposure pathway.
II.
Inqestion of Water fro~ R~sidential Wells 'by Residents
The estimated excess upper-bound lifetime cancer risks and the
noncarcinogenic HQs associated with this exposure pathway are
presented in Table 22. The Lindsey, Springer, and Parkin residen-
tial wells were considered separately. The estimated total excess
lifetime cancer risk for the Lindsey well (presently not in use)
is 1X10~, due to the presence of 1,1-dichloroethane, choromethane,
and chloroform. The estimated total excess lifetime cancer risk
for users of the Parkin well is 8X10-6, due primarily to the
presence of trichoroethene. No chemicals of potential concern
exhibiting carcinogenic effects were detected in the Springer well.
Hence, the excess lifetime cancer risks for this pathway are w,~ll
whithin EPA's target risk range. The HI values are less than ~ne
for users of both the Lindsey and Parkin wells. No chemicals of
potential concern exhibiting noncarcinogenic effects we~e detected
in the Springer well.
III.
Direct Contact with Sediment/Surface Water by Children and
'I'eenaqers
The estimated excess upper-bound lifetime cancer risks and the
noncarcinogenic HQs associated with these two exposure pathways are
presented in Tables 23 and 24. The estimated total excess lifetime
cancer risk for direct contact exposure of children to contami-
nants in the surface water of Mud Creek is 9X10~. No chemicals of
potential concern exhibiting ~arcinogenic effects were detected in
the intermittent stream surface water. The HI values are less than
one for exposures to the surface water in Mud Creek and the
intermittent stream.
~he estimated total excess lifetime cancer risk for direct contact
exposure of children to contaminants in the sediments of Mud Creek
is lxlO's, primarily due to the presence of N-nitroso-di-n-propylam-
ine, carcinogenic PAHs, and arsenic. The HI values are less than
one for sediments in both Mud Creek and the intermittent stream.
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IV.
~~ite Inhalation by Children
The estl;.,ated excess upper-bound lifetime. cancer risks and t.he
noncarcinogenic HQs associated with this exposure. pathway are.
presented in Table 25. The estimated total excess lifetime cance~
risk for the inhalation of on-site air by children is 4XIO~., due
to the presence of trichloroethene. The estimated HI is two orders
of magnitude less than one.
'-.
Future Land Use Scenarios
I.
Direct Contact with Surface and Subsurface Soils by Residents
The estimated excess upper-bound lifetime cancer .risks and the
noncarcinogenic HQs associated with these two exposure pathways are
presented in Tables 26 and 27.
The estimated total excess lifetime cancer risk for direct contact
exposure of on-site residents to contaminants in surface soil
(6XI02) exceeds EPA's target cancer risk range, due to the presence
of PCBs at hi~h concentrations. The HI value for noncarcinogenic
effects (2xlO) also exceeds the threshold level of one for this
pathway, due to the presence of PCBs in the surface soil. No other
contaminant poses a health threat via this exposure pathway.
The es~imated total excess lifetime cancer risk for direct contact
exposure of on-site residents to contaminants in subsurface soil
is 2XI02, due to the ~resence of PCBs. The HI value for noncarcin-
ogenic effects (6xlO) also exceeds unity, due to the presence of
PCBs. No other contaminant poses a health threat via this exposure
pathway.
II.
Inqestion of On-Site Groundwater
The estimated excess upper-bound lifetime cancer .risks a'nd the
noncarcinogenic HQs associated with this exposure pathway are
presented in Table 28.
The estimated total excess lifetime cancer risk for ingestion of
groundwater by on-site residents is 3XIO~, primarily due to the
presence of trichloroethene and related chlorinated aliphatics,
and PCBs.
The HI value (7) is greater than one, due to PCBs and the combined
effects of various organic solvents and arsenic.
III.
On-Site Inhalation by Residents
The estimated excess upper-bound lifetime cancer risks and the
noncarcinogenic HQs associated with this exposure pathway are
presented in Table 29. The estimated total excess lifetime cancer
risk is 2XIO.s, due to the presence of trichloroethene. The
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estimated HI is 5xl03, which is below the ~arget criterion of o~e.
CLEANUP LEVELS FOR CONTAMINATED MEDIA
Groundi,;ater
~
The groundwater at the Solvent Savers Site is classified by NYSDEC
as cl ass "GA", which indicates that the water is suitable as a
drinking water supply. The RI has determined that contaminants
from the Site-have contaminated the on-site groundwater. The
remedial response objectives, therefore, include the following:
-Protect human health and the environment from current and
potential future migration of contaminants in groundwater:
and
-Restore on-site groundwater to levels consistent with federal
and state groundwater standards.
Table 33 presents the chemical concentrations and action levels
[appl icable or relevant and appropriate requirements (" ARARs")] for
the contaminants of concern at the Site. Chemical concentrations
are expressed as the geometric mean and maximum contaminant
concentrations in the groundwater samples taken, which were applied
in the risk assessment of the supplemental RI. A comparison of the
concentration of the chemicals of concern detected in groundwater
to the ARARs indicates that most VOCs exceed the regulatory
standards.
The risk assessment, using EPA's acceptable risk range of lO~ to
lO~, does not conclusively indicate the need for remediation based
upon ingestion of groundwater: however, the federal and state
groundwater standards are considered health-based numbers and these
are currently being contravened in the aquifer. Hence the more
stringent of the ARARs (federal MCLs and New York State groundwater
standards) shall be used as the cleanup objectives for the
contaminants at the Site.
Soil
The risk asessment indicates that the presence and concentration
of VOCs in the soils do not pose a significant threat to human
heal th via inhalation and ingestion, i. e., the potential risks
associated with the levels of VOCs are within EPA's acceptable risk
range: however, soil-to-groundwater models have indicated' the
potential for VOCs in soil to contaminate the aquifer above potable
water standards. In order to minimize the impact of the VOCs on
the groundwater and enhance the groundwater treatment remedy,
ini tial soil cleanup levels have been established for the VOCs
based on preliminary modeling results.
While contaminated soils have been detected in all five source
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areas, based upon the preliminary model results, it appears ~hat
'only Areas 2 and ,4 require remediation based upon the. potential
impact of the VOCs on the groundwater. Areas 1, 3 and 5, which.
contain lesser concentrations of VOCs below health-based levels, .
depending c:-. - the results of soil sampl ing and analysis. to be
conducted d~=ing the remedial design, may not require remediation.
The vast majority of contaminated soil, amountir- to approximately
59,000 cubic yards, is located in Areas 2 and 4.
'-
The initial soil cleanup levels, which are based on an average of
the model-derived cleanup levels for Areas 2 and 4, are as follows:
Tetrachloroethene
Trichloroethene
1, 1, 1-Trichloroethane
1,1,2-Trichloroethane
Toluene '
1,2-Dichloroethene
Xylenes (total)
2.2 ppm
0.8 ppm
0.9 ppm
o . 4 ppm
1. 5 ppm
0.8 ppm
3.1 ppm
(Area 2 only)
(Area 2 only)
These levels represent average contaminant concentrations of
indicator chemicals in the soil which will theoretically produce
contaminant concentrations in the groundwater at the nearest
receptor which meet potable water standards. The nearest potential
receptor is considered to be Mud Creek.
For cost estimating purposes, the entire areal extent of Areas 2
and 4 down to the water table has been conservatively estimated to
be in need of remediation. During the remedial design, further
sampling will be conducted to better define the distribution of
contamination in the five source areas. In addition, the model
will be calibrated and tested during the remedial design using
existing and additional sampling data, as necessary, to more
precisely define the soil cleanup levels and the associated volume
of contaminated soil requiring remediation. Should the data
collected during the remedial design indicate that Areas 1, 3,
and/or 5 require remediation, the contaminated soil from these
source areas will also be treated meet all target cleanup levels.
The PCBs discovered on-site are regulated under TSCA (40 CFR 761)
and RCRA (40 CFR 264 and 268). They are present in sufficient
quantities to be of concern with respect to protection of human
health according to the risk assessment. EPA's Office of Solid
Waste and Emergency Response ("OSWER") issued a directive (No.
9355.4-01) on August 15, 1990 which is to serve as a guide for all
remedial actions at Superfund sites with PCB contamination. It
basically combines the elements of all applicable laws (including
the Clean Water Act and Safe Drinking Water Act for groundwater
cleanups) into one cohesive document which is the basis of EPA's
PCB policy.
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I
This directive recommends a 1 ppm action ievel as a starting point
. f~r PCB cleanupg . in residential areas, treatment of 1DO ppm or
greater PCB hot spots as principal threats, and containment of low'
threat PCB contamination in the 1-100 ppm range. Treatment ~aybe
warranted at ~tes involving relatively small volumes of cotamina-
tion or sensitive environments.
<>
Since the Site is located on a rural agricultural area where
residential hofues are situated in proximity of the Site,' and the
amount of PCB-contaminated soil that poses potential human-health
threat to the public is small (about 1,000 cubic yards), treatment
of the contaminated soil to attain the level of I ppm is appropri-
ate for this Site.
DOCUMENTATION OF SIGNIFICANT CHANGES
The Proposed Plan which was released for public comment on July 23,
1990, identified Alternative SC-S, Excavation /Low-Temperature
Thermal Extraction/On-Site Redeposition, and Off-Site Incineration
of the PCB-Contaminated Soils, as the preferred alternative. Two
of the other alternatives, Alternative SC-4 and Alternative SC-7,
which involve vapor extraction and soil flushing technologies
respecti vely, were also presented in the Proposed Plan and the
RI/FS report. The preference for Alternative SC-S was primarily
due to the potential of preferential flow in the vadose zone of the
subsurface, which is complex and heterogeneous in nature, and thus
may render Alternatives SC-4 and SC-7 inappropriate for successful
re~.)val of the contaminants in the soil. Based upon the comments
re~eived during the p~blic ~omment period, a more cost-effective
approach for site remediation was developed by EPA in consultation
wi th NYSDEC. The remedy set forth in -the ROD includes low
temperature thermal extraction for the soils highly contaminated
with VOCs. Treatability studies will be performed during the
remedial design to determine whether the low temperature thermal
extraction technology is appropriate for treatment of the PCB-
contaminated soil on-site, and whether the soil flushing and/or
vapor extraction processes are appropriate for on-site treatment
of the excavated soil contaminated with low level VOCs. If the
treatability study results indicate that low temperature thermal
extraction is an appropriate treatment method, then this technology
will be employed to treat the excavated soil contaminated with PCBs
on-site. Should the findings of the treatability studies indicate
that the on-site low temperature thermal extraction process would
not provide the disired degree of treatment, then the PCB-contami-
nated soil excavated will be removed for off-site incineration/dis-
posal. If the treatability study results indicate that the vapor
extraction and/or soil flushing technologies are appropriate
treatment methods, then one or both of these technologies will be
utilized to treat the excavated soil contaminated with low level
vocs. Should the findings of the treatability studies indicate
that vapor extraction and soil flushing would not provide the
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desired degree of treatment for the excav~ted soils contaminated
with low levels o~ ~OCs, then the contaminated soil will be treated
on-site using low temperature thermal extraction. '
DESCRIPTION O~ALTERNATIVES
A total of thirteen alternatives were evaluated ~ detail for site
remediation. Seven remedial alternatives address the contaminated
soil that - contributes to groundwater contamination, and six
remedial alternatives address the groundwater contamination,at the
Solvent Savers Site. The$e alternatives are as follows:
SOIL ALTERNATIVES
Alternative SC-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 control the source of contamination. However,
long-term monitoring of the Site (for a minimum period of 30 years)
would be necessary to monitor contaminant migration. Monitoring
would consist of annual soil, sediment, and surface water sampling
and analyses for a variety of contaminants.
Because this alternative would result in contaminants remaining on-
site above levels that would allow for unlimited use and unre-
stricted exposure, CERCLA requires that the Site be reviewed every
five years. If justified by the review, remedial actions might be
implemented to remove or treat wastes.
The estimated total present worth cost for this al ternati ve is
$231,000.
Alternative SC-2:
Limited Action
The Limited Action alternative would limit public exposure to the
contamination at the Site, but would not treat or remove the
contamination. Thi~ alternative would include the installation of
a security fence an~ the posting of warning signs around the Site;
annual soil and groundwater monitoring arid ' site inspections: a
public education program, institutional co~~rols to limit site use
and site access; and a review of site conditions every five years.
If justified by the review, remedial actions might be implemented
to remove or treat wastes.
The estimated total present worth cost for this alternative is
$462,000.
Alternative SC-3:
Site CaDDina
This alternative would include clearing the vegetation at the Site,
grading and compacting the soil, and placing a 40-mil thick high
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density polyethylene ("HDPE") liner and a compacted, 18-inch c.lay
layer over the contaminated areas. Additionally, an 18-inch tayer
, of topsoil would be placed on top of the clay, and vegetation would
be planted to mInimize the erosion of the topsoil. A fence would
be constructed to surround the capped area,and land use restric-
tions would be implemented. This alternative would minimize the
risks to the~ublic of direct contact with the contaminated soil.
Further, the HDPE liner and impermeable clay layer would limit
rainfall infiltration into the subsurface, thereby. limiting
contaminant transport to the groundwater. The cap and fence would
be inspected, and the soil and groundwater would be sampled, in a
long-term monitoring program . Five-year reviews would be conducted
to determine the effectivene~s of the remedy. .'
The estimated total present worth cost for this al ternati ve is
$862,000. The estimated implementation time frame for this.
alternative is 6 months (after' the start of construction).
Alternative SC-4:
In-Situ Vapor Extraction
This alternative would employ in-situ vapor extraction to treat .the
contaminated soils.
Soil vapor extraction involves the collection of soil vapor from
the unsaturated (vadose) zone by applying a vacuum at extraction
points. The vacuum would draw vapor from the unsaturated zone, at
the sarne time decreasing the pressure around the soil particles and
releasing the VOCs. Because of the pressure difference, clean air
from the atmosphere wJuld e~ter the soil and replace the extracted
air. The technology depends on factors such 1S so'1 permeability
and depth to groundwater. Extraction wells, piping, and a positive
displacement blower (vacuum pump) would be required to draw the
vapor from the vadose zone. The collected air would be treated
through an activated carbon unit. Spent carbon would be removed
for off-site regeneration or treatment/disposal.
Under this alternative, approximately 1,000 cubic yards qf PCB-
contaminated soil would be excavated and removed from the Site for
off-site incineration and disposal at an approved facility.
Incineration of the contaminated soil at the off-site thermal
treatment facility would be conducted in conformance with all
applicable RCRA requirements, and this facility would be responsi-
ble for proper disposal of the treated soil. The buried drums
would also be excavated and removed from the Site for off-site
treatment/disposal at an approved RCRA hazardous waste facility.
Clean fill would be used to backfill the excavated areas. .On-site
treatment was not considered due to the low volume of PCB-contami-
nated soil.
Under this alternative, long-term monitoring would not be required.
The estimated total present worth cost for this alternative is
$7,887,000. The estimated time frame for construction of this
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alternative is 6 months. Target cleanup l~vels would be achieved
within 12 months .after operation of the system.
Alternative sc-s:
Excavation/Low-Temperature Thermal Extraction!
On-Site Redeposition .
This alternative involves the excavation and on-site treatment of
approximately 59,000 cubic yards of contaminated soil by low-
temperature thermal extraction. The excavated soil would be fed
to a thermal treatment unit, where application of heat (e. g. ,
injection of hot air) with mechanical agitation would raise the
soil temperature above the boiling points of the organic contami-
nants and allow the moisture and the organic contaminants to be
volatilized into gases and removed from the soil. The organic
vapors extracted from the soil would then be ~reated in an air
pollution control system to ensure that air emissions are within
the federal and state regulatory requirements.
Several thermal treatment units (such as heated screw conveyors,
rotary calcination devices, etc.) may be applicable. A variety of
air pollution control options are also available, including after-
burners, activated carbon adsorbers, and condensers. The specific
performance requirements of the thermal treatment method and of the
air pollution control system would be determined in the remedial
design phase. The specific treatment systems would be determined
through the competitive bidding process.
All the residuals from the treatment (such as spent carbon from the
carbon adsorption units) would be s~~t to an off-site hazardous
waste facili~y for treatment and disposal.
Following treatment, the soil would be tested in accordance with
the Toxicity Characteristic Leaching Procedure ("TCLP") to deter-
mine whether it constitutes a RCRA hazardous waste. . Provided that
it passes the test, it would no longer contain contaminants above
health-based levels, and would be used as backfill material for the
excavated areas. Clean topsoil would be placed on the excavated
areas, and the Site would be regraded and revegetateg.
Under this alternative, approximately 1,000 cubic yards of PCB-
contaminated soil would be excavated and removed from the Site for
off-site incineration and disposal at an approved facility.
Incineration of the contaminated soil at the off-site thermal
treatment facility would be conducted in- conformance with all
applicable RCRA requirements, and this facility would be responsi-
ble for proper disposal of the treated soil. The buried drums
would also be excavated and removed from the Site for off-site
treatment/disposal at an approved RCRA hazardous waste facility.
Clean fill would be used to backfill the excavated areas. On-site
treatment was not considered due to the low volume of PCB-contami-
nated soil.
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At the completion of the implementation Qf this alternative,. the
.most mobile of the organic contaminants in the soil. would' be
reduced to concentrations that would result in groundwater levels.
below the federal and state standards at the receptor nearest to
the Site when leached to the groundwater through rainwatEr
infiltration. - .
Under this alternative, long-term monitoring would not be required.
The estimated .total present worth cost for this alternative is
$19,416,000. The estimated time frame for construction of this
alternative is 6 months. Target cleanup levels would be achieved
within 12 months after operation of the system.
~lternative SC-6:
Off-site Incineration
This alternative would involv~ excavation of about 59,000 cubic
yards of contaminated soil and transport of the soil to a permi tt.ed
off-site incinerator for treatment and disposal. Incineration of
the contaminated soil at the off-site thermal treatment facility
would be conducted in conformance with all applicable RCRA require-
ments, and this facility would be responsible for proper disposal
of the treated soil. The buried drums would also be excavated and
removed from the Site for off-site treatment/disposal at an
approved RCRA hazardous waste facility.
The contaminated soil and buried drums would be excavated and
staged. Contaminated soil would then be placed into 20-cubic yard
trucks for shipment to an available hazardou~ waste incinerator.
The excavated drums would also be shipped " ia t:..: ucks to a RCRA
hazardous waste facility for treatment/disposal. Clean fill would
be used to backfill the excavated areas, and the Site would be
regraded and revegetated.
Under this alternative, long-term monitoring would not be required.
The estimated total present worth cost for this alternative is
$96,800,000. The estimated implementation time frame for this
alternative is 1 year (after the start of construction).
~lternative SC-7:
In-situ Soil Flushing
This alternative would consist of the use of treated groundwater
to flush the areas of soil contamination. A groundwater extraction
and treatment system would be required. Because this is an in-
situ contaminant removal process, this alternative would require
minimal excavation (well installation, distribution system, and
grading ~f the recharge basins) for implementation.
Since the total volume of groundwater extracted and treated could
not be recharged (flushed), discharge of a portion of the treated
water to Mud Creek would be required.
Under this alternative, approximately 1,000 cubic yards of PCB-
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contaminated soil would be excavated and removed from the Site -for
,off-site incineration and disposal at"an approved facillty.
Incineration of! the contaminated soil at the off-site thsrrnal
treatment facility would be conducted inconforrnance wi t:-. all,
applicable RCRA requirements, and this facility would be responsi-
ble for prop&C disposal of the treated soil. The buried'drums
would also be excavated and removed from the Site for off-site
treatment/disposal at an approvedRCRA hazardo,-,.: waste facility.
Clean fill would be used to backfill the excavated areas. On-site
treatment was hot considered due to the low volume of PCB-contami-
nated soils.
Environmental monitoring would be required during the life of the
treatment process. In addition, monitoring of the 'groundwater at
the Site would continue for at least five years after the comple-
tion of the remediation to ensu~e that the goals of the remediation.
have been met. .
The estimated total present worth cost for this al ternati ve is
$1,076,000. The estimated time frame for construction of this
al ternati ve is 6 months, but this al ternati ve would require 20
years to achieve target cleanup levels.
GROUNDWATER ALTERNATIVES
Alternative GW-l:
No Action
Under this al ternati ve, no action would be taken to remedy the
groundwater contamination at the Site or to control its spread.
This alternat:ve would not ensure protection of human health and
the environment, and is used as a basis of comparison for other
groundwater remediation alternatives. Under this alternative, the
contaminants would remain on-site, hence the Site would need to be
reviewed every five years.
The estimated total present worth cost for this alternative
$231,000.
is
Alternative GW-2:
Limited Action
This al ternati ve would include long-term groundwater monitoring and
institutional restrictions on on-site groundwater use. The
monitoring would consist of annual groundwater sampling to track
the movement of contaminated water and assess the need for future
remediation. Institutional restrictions would prohibit the use or
installation of water supply wells on-site. Under this alterna-
tive, the Site would be reviewed every five years.
The estimated total present worth cost for this alternative is
$985,000.
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'"
~lternative GW-3: Groun~water.Extraction/Chemical Precinitationl
Carbon ~~sorntion
Under this alterh~tive, contaminated groundwater would'~e pumped.
out of the ground through extraction wells. The extracted
groundwater would be pumped to an equalization tank. Chemical
precipitation~ould be employed to remove inorganic contaminants,
followed by carbon adsorption to remove organic contaminants. The
treated water would be reinjected into the aquifer and/or
discharged.to Mud Creek.
The chemical precipitation process would consist of the addition
of chemical substances {e.g., lime) to precipitate dissolved
metals. A coagulant would be added to induce flocculation. The
slUdge generated would undergo filtration and would be transported
to an off-site treatment/disposal facility.
Carbon adsorption would expose the contaminated groundwater. to .
units filled with carbon. The contaminants would come out of the.
solution with the water and adhere to (adsorb onto) the carbon
surface. The spent carbon would be collected by the carbon
supplier and shipped off-site for treatment/disposal or regenera-
tion for reuse.
In order, to prevent the loss of vapors to the atmosphere, the
equalization tank, the chemical precipitation unit, and the
filtration unit would be equipped with floating covers to prevent
volatilization.
The number and location of extraction wells, the specifications for
the chemical pretreatment and carbon adsorption systems, and the
specific type of reinjection and/or discharge system would be
determined during the remedial design phase of the. project.
Environmental monitoring would be required during the life of the
treatment process. In addition, monitoring of the groundwater at
the site would be conducted for a period of five years after
completion of the remediation to ensure that the goals of the
remedial action have been met.
At the completion of the remedial alternative, the organic contami-
nants found in groundwater would meet groundwater quality stan-
dards, and the migration of those contaminants to the surface water
would be prevented.
The estimated total present worth. cost for this alternative is
$14,279,000. This alternative could be implemented within 18
months (after the start of construction). The estimated aquifer
restoration time frame for this alternative is about 20 years.
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Alternative GW-4: Groundwater Extraction/Chemical PreciDitation/
. . Air StriDDina/Carbon AdsorDtion
Under this alternative, contaminated groundwater would be pumped'
out of the ground through extraction wells.. The ex~ractej
groundwater would be pumped to a centrally 'located treatment plant
on-site, where it would be treated by chemica precipitation to
remove inorganic contaminants, and by air str .lpping and c;::arbon
adsorption to remove organic contaminants. The treated water would
be reinjected and/or discharged to Mud Creek.
The groundwater extraction, chemical precipitation, and carbon
aqsorption processes would be the same as Alternative GW-3.
Air stripping is a mass transfer process in which volatile organics
in water are transferred to the air blown in from the bottom of the
air stripper. The air and VOC mixture exiting the air stripper
would then be treated by a vapor phase carbon adsorption unit for
the removal of the stripped VOCs. Clean air would be emitted to
the atmosphere. The air-stripped groundwater, which may contain
some contaminants, would be processed through liquid phase carbon
adsorbers. The spent carbon in the carbon adsorption units would
be removed fo~ off-site regeneration or incineration, thus destroy-
ing all organic contaminants.
The nU~~er and lo=ation of extraction wells, the specifications for
the chemicalpre~reatment, air stripping, and carbon adsorption
syster.!s, and thE: specific type of reinjection and/or discharge
system would be determined during the remedial design phase of the
project.
Environmental monitoring would be required during the life of the
treatment process. In addition, monitoring of the groundwater at
the Site would be conducted for a period of five years after
completion of the remediation to ensure that the goals of the
remedial action have been met.
At the completion of this remedial alternative, the
contaminants found in groundwater would meet groundwater
standards, and the migration of those contaminants to the
water would be prevented.
organic
quality
surface
The estimated total present worth cost for this al ternati ve is
$9,934,000. This alternative could be implemented within 18 months
(after the start of construction). The estimated aquifer re.stora-
tion time frame for this alternative is about 20 years.
Alternative GW-5: Groundwater Extraction/Chemical Precioitation/
UV Oxidation
Under this alternative, contaminated groundwater would be pumped
out of the ground through extraction wells. The extracted
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groundwater would be pumped to an equalization tank, and thell -.to
a rapid mixing tank, where inorganic contaminants would be removed
by. chemical precipitation. Next, the water would be treited by L~
oxidation to remove organic contaminants. The treated water would
be reinjected and/or discharged to Mud Creek. .
The groundwater extraction and chemical precipitation processes
would be the same as Alternative GW-3.
'"
Following chemIcal precipitation, the groundwater would enter an
oxidation tank. There, it would be mixed with a metered dose of
an oxidant (e.g., hydrogen peroxide or ozone) and exposed to high
intensi ty ultraviolet ("UV") radiation. In the presence of UV
1 ic;ht, the oxidant molecules would decompose. to form hydroxyl
radicals. Also, some organic contaminants would absorb UV light
and become more reactive. The hydroxyl radicals would break down
the organic molecules into smaller blocks and eventually to carbon
dioxide, water, and non-hazardous salts. The treated water would
be filtered for the removal of suspended particles and collected
in a storage tank. To prevent the loss of vapors to the atmo-
sphere, the equalization tank, the chemical precipitation.unit, and
the filtration process unit would be equipped with floating covers
to prevent volatilization.
The number and location of extraction wells, the specifications for
the chemical pretreatment and UV oxidation systems, and the
specific type of reinjection and/or discharge system would be
determined during the remedial design phase of the project.
Environ!':1e:.tal r......nitoring would be required during the life of the
treatment process. In addition, monitoring of the groundwater at
the Site would be conducted for a period of five years after
completion of the remediation to ensure that the goals of the
remedial action have been met.
The estimated total present worth cost for this alternative is
$15,094,000. This al ternati ve could be implemented wi thin 18
months (after the start of construction). The estimated aquifer
restoration time frame for this alternative is about 20 years.
Alternative GW-6: Groundwater Extraction/Chemical PreciDitation/
Bioloqical Treatment
Under this alternative, contaminated groundwater would be pumped
out of the ground through extraction wells. The extracted
groundwater would be treated by chemical precipitation to remove
inorganic contaminants, and by activated carbon biological
treatment to remove organic contaminants. The treated water would
be reinjected and/or discharged to Mud Creek.
The groundwater extraction and chemical precipitation processes
would be the same as Alternative GW-3.
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After chemical precipitation, the water would be pumped into the
aeration tank, wh~re it would be mixed with granular activated
carbon and biological solids. The water-carbon-biological solids
mixture would be aerated so that the biodegradable content of the'
groundwater could be biologically oxidized and assimilated. Afte:
aeration, the -mixture would be sent to a' clarifier, wher'e the
granular carbon and the biological solids would settle and be?
separated from the treated water. The clarifier overflow (treated
water) wOUld b~ filtered and collected in a storage tank. The
clarifier underflow solids would be recycled to the aeration tank
to maintain the appropriate concentration of granular activated
carbon and biological solids. \ portion of the clarifier underflo~
co~taining granular activated carbon and excess biological solids
would be wasted daily, dewatered, and aerobi~ally digested and
disposed of. Make-up granular activated carbon would be added to
the aeration tank daily to acc~unt for the loss 'of that substance.
The equal ization tank, the' c!:=,rnical precipitation unit, and ,the
filtration unit would be equipped with floating covers to prevent
the loss of volatile chemicals prior to adsorption in the biologi-
cal unit.
The number and location of extraction wells, the specifications
for the chemical pretreatment and biological treatment systems,
and the specific type of reinjection and/or discharge system would
be determined during the remedial design phase of the project.
Under this alternative, treatability studies would need to be
performed during remedial design to provide design information and
verification of the effectiveness of the alternative in achieving
removal efficiencies required to ensure complianc~ with all federal
MCLs and state groundwater standards.
Environmental monitoring would be required during the life of the
treatment process. In addition, monitoring of the groundwater at
the 5i te would be conducted for a period of five years after
completion of the remediation to ensure that the goals of the
remedial action have been met.
The estimated total present worth cost for this al ternati ve is
$5,739,00. This alternative could be implemented within 18 months
(after the start of construction). The estimated aquifer restora-
tion time frame for this alternative is about 20 years.
All alternatives described above would include pre-construction,
construction and post-construction air monitoring.
SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES
During the detailed evaluation of remedial alternatives, each
alternative is assessed against nine evaluation criteria, namely
overall protection of human health and the environment, compliance
with ARARs, long-term effectiveness and permanence, reduction of
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toxicity, mobility or volume (including,~he statutory preference
for treatment), short-term effectiveness, implementability, cost,
state acceptanc~ 'and community acceptance.
Each criterion will be briefly addressed with respect to the
alternatives~or remediation of the soil and groundwater.
'",
SOIL ALTERNATIVES
overall Protection of Human Health and the Environment
A.
Alternative SC-l provi~es no protection of human health and the
environment from direct contact with contaminated soils. Alterna-
tive SC-2 provides a limited measure of protection through the
installation of a site perimeter fence and th~ implementation of
site use restrictions. Alternative $C-3 includes the installation
of a site perimeter fence and construction of a cap, thereby
providing additional protection due to reduction in direct contact
risks. Over the long-term, the cap is anticipated to decrease the
generation, mobility, and volume of leachate reaching the aquifer.
A1 ternati ves SC-4, SC-5, SC-6, and SC-7 provide even greater
protection by direct treatment of contaminated soils and subsequent
reduction of leachate within a relatively short time frame. These
alternatives, which also remove PCB-contaminated soils and drums,
are far more protective of human health and the environment than
Alternative SC-3.
The treat.ment of soils to remove the most mobile wastes would
resu1 t in the elimination of a long-term source of groundwater
contamination and it would mitigate the risks to public health and
the environment associated with the migration of those contaminants
off-site.
Alternatives SC-3 through SC-7 would mitigate the risks to public
health and the environment associated with the leaching of
contaminants into the groundwater and their migration off-site.
Under Alternatives SC-l and SC-2, contaminants would continue to
leach from the soil into the groundwater and continued off-site
migration of contaminants would occur. Moni toring would be
implemented to observe contaminant migration, but an indeterminate
amount of time would elapse between detection and the implementa-
tion of mitigating measures.
B. ComDliance with ARARs
All technologies proposed for use in Alternatives SC-3 through SC-
7 would be designed and implemented to satisfy all chemical-
specific, action-specific, and location-specific ARARs, including
all emission standards. ARARs for on-site alternatives would
include, but not be limited to, RCRA closure requirements, RCRA
landfill requirements, and TSCA PCB requirments. ARARs for off-
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site alternatives would include, but l').ot be limited to .RCRA
. gener~to: and. transporter requirements, RCRA land, disposal
restr~ct~ons and TSCA regulations for PCB management and disposal.
A complete list of all potential ARARs is included in Tables 30 to .
32.
No federal or New York State regulations specify -leanup levels for
contaminants in soils. In terms of achieving ~arget levels for
soils for the purpose of removing potential sources of groundwater
contamination, Alternatives SC-4 through SC-7 would be effective.
c.
Reduction of Toxicitv. Mobilitv. or Volume
'-,
Alternatives SC-l and SC-2 would provide no reduction in toxicity,
mobility, or volume. Alternative SC-3 would ~educe the mobility
of the contaminants via capFing but would not reduce the toxicity
or volume of contaminants and would not satisfy the statu'tory
preference for treatment. Alternatives SC-S and SC-6 would result
in comparable reductions in the toxicity, mobility, and volume
through the use of treatmer.t. Alternatives SC-4 and SC-7 would
result in the reduction of ~oxicity, mobility, and volume but to
a lesser degree than the thermal treatment alternatives due to the
possibility of preferential flow in the vadose zone.
D.
ImDlementability
All of the alternatives are technically feasible, but differ in the
complexity of implementation. Alternatives SC-3, SC-4, SC-S, SC-
6, and SC-7 would utilize relatively common const.'uction equipment
and materials. Alternative SC-4, which requires soil gas extrac-
tion wells, piping, a vacuum system, and a mobile treatment system,
would be relatively easy to implement. Alternative SC-7 may
require extensive start-up testing to determine optimum recharge
rates and to monitor changes in groundwater flow directions.
Although the technologies employed in Alternatives SC-4 and SC-7
have been successfully pilot tested and have been utilized on a
full scale basis for treatment of soils contaminated with VOCs, the
complex and heterogeneous nature of the soils at the Site may
render Alternatives SC-4 and SC-7 inappropriate for site
remediation. Alternatives SC-S and SC-6, which involve larc;, scale
excavation and backfilling operations, would be more diffi=ult to
implement than the in-situ remedies due to the volume of soil
(about S9,000 cubic yards) required to be handled.
Al ternative SC-S, excavation/low temperature thermal extraction/on-
si te redeposition, has been successfully pilot tested and has
preformed on a full-scale basis with similar organic contaminants.
Alternatives SC-4, SC-S, SC-6, and SC-7 include the excavation and
off-site treatment/disposal of PCB-contaminated soils and buried
drums which would be relatively easy to implement.
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E.
Lonq-Term Effectiveness
'"
Alternatives SC-l and SC-2 do not include any removal,contai~ment,
or. treatment of bontaminated soils, ~nd herice, the health risks.
present at the Site would remain. Alternative SC-2 would restrict
site access and potential direct contact with contaminated soils.
Installation 5f the cap under Alternative SC-3 would provide
reduction of the residual risks due to direct contact and of the
leaching of contaminants to the groundwater.
Alternatives SC-4, SC-S, SC-6, and SC-7 include the treatment of
contaminated soils. In Al ternati ves SC-S and SC-6, no residual
risks would remain, as the backfilled soils would be clean. In
Al ternatives SC-4 and SC-7, some levels of contamination below
action levels may remain in the soil. These calculated concentra-
tion levels are the levels whereby the leachate generated would be
below MCLs. However, the effec.ts of. this residual. contamination
would be mitigated by the groundwater extraction and treatment
alternative. .
Alternatives SC-3, SC-4, SC-S, SC-6, and SC-7 incorporate proven
engineering methods that are reliable for the control of leachate
generation and protection of the groundwater.
The success of Alternatives SC-4 and SC-7 would be a function of
the perrneabil i ty of the vadose zone. Since the vadose zone is
complex and heterogeneous in nature, these two alternatives may not
result in the successful removal of the contaminants due to the
possibility of preferential flow )aths in some areas, and little
or negligible flow in other area~.
All risks associated with the buried drums and PCB-contaminated
soils in Alternatives SC-4, SC-S, SC-6, andSC-7 would be complete-
ly mitigated as these wastes would be properly treated and disposed
of at approved Toxic Substances Control ActjRCRA facilities. The
capping in Alternative SC-3 would only reduce the risks relating
to the direct contact with PCB-contaminated soil and buried drums.
F.
Short-Term Effectiveness
All alternatives, with the exception of Alternatives SC-l,
SC-2, and SC-3, include activities such as excavation and off-site
transport of contaminated soils for disposal that could result in
potential exposure of residents to volatilized contaminants and
contaminated dust. However, mitigative. measures, such as the
utilization of vapor suppressive foams and water spraying, . to
reduce the probability of exposure would be implemented.
Alternatives SC-4 through SC-7 would result in worker exposure to
volatilized contaminants and derrna~ contact with contaminated soils
during waste excavation and handling. In addition, Alternative SC-
S might result in low-level emissions exposure from the on-site
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treatment unit. The threat to on-site wQrkers and the community,
. however, wouldbe.mitigated through the use of protective equipment
by the on-site 'workers and control of emissions would be accom7
plished by emissions treatment. Additionally, scrubber wastewater'
would require removal and treatment prior to complete demopiliza-
tion from the-Site. .
The groundwater and site use restrictions of Alte=native SC-2 could
be implemented within 6 months after start of construction.
However, Alternative SC-2 would only reduce the potential risk
associated with groundwater ingestion, and. not directly address the
continued leaching of contaminants. Al ternati ve SC-3 could be
completed within 6 months after start of construction. Alterna-
tives SC-4, SC-S, and SC-6 could be completed -within 1 year after
start of construction. Al ternati ve SC-7 cQuld be implemented
within 3 months after start of construction, but would require 20
years to achieve remediatiOn.-
G. Cost
The total present worth cost for Alternative Sc-s is $19,416,~00.
The lowest cost alternative is Alternative SC-l at $231,000. The
highest cost alternative is Alternative SC-6 at $96,800,000.
Alternatives SC-2, SC-3, SC-4, and SC-7 have total present worth
costs of $462,000, $862,000, $7,887,000, and $1,076,000, respec-
tively.
The total capital, annual operation and maintenance, and present
worth costs in all soil 21ternatives are presented in Table 1 for
=ornparison purposes.
GROUNDWATER
A.
Overall Protection of Human Health and the Environment
Alternative GW-2 would prevent exposure to groundwater contaminants
by restricting its use as a potable water supply on-site. Protec-
tion of the public off-site would be dependent on the effectiveness
of state and local governments in restricting groundwater usage.
In the long-term, the extraction and treatment options within
Alternatives GW-3, GW-4, GW-S, and GW-~ would reduce contaminant
levels in the groundwater to below MCLs, reduce non-carcinogenic
risks to acceptable levels, and reduce - cumulative carcinogenic
risks to acceptable levels, thus protecting human health and the
environment.
B.
ComDliance with ARARs
Alternatives GW-l and GW-2 would not satisfy contaminant-specific
ARARs, i. e., federal MCLs and state groundwater standards (see
Table 33). The long-term monitoring and groundwater use restric-
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tions would be intended to limit ~ccess to contaminated groundw~-
ter. -
,
'Groundwater trea'ted through implementation of Alternatives GW':'3,
GW-4, or Gv;'-6 is expected to meet surface water discharge require-' .
ments, achieve concentrations below federal ,MCLs and state
groundwater ~andards, and meet risk-based action levels for
chemicals of concern. The ability of Alternative GW-S to achieve
the groundwater quality standards for organic contaminants is of
a lower certainty as compared to those of Alternatives GW-3, GW-
4 and GW-o due to limited experience with the UV oxidation
treatment process. Al ternati ve GW-6 requires performance of treat-
ability studies during remedial design to ensure that this
al ternative would attain the removal efficiencies required to
achieve the federal MCLs and state groundwater ,standards.
'"
Alternative GW-4 would include,air emission cOhtrols meeting the
requirements of state and federal tegulations should control' be
deemed necessary based on treatability study results. '
c.
Reduction of Toxicity. Mobility or Volume
Alternatives Gv;'-l and GW-2 would not reduce the toxicity, mobility,
or volume of contaminants. Alternatives GW-3, GW-4, GW-S, and GW-
6 would provide significant overall reduction in toxicity, mobil-
ity, and volume of the contaminants in the groundwater through the
extraction and treatment of the groundwater.
D.
Im~lementability
All of the alternatives are technically feasible, but differ in the
complexity of implementation. All components of Alternatives GW-
I and GW-2 could be easily implemented due to their limited scope.
The treatment technologies associated with Alternatives GW-3, GW-
4 and GW-6 employ reliable operations. All components (extrac-
tion, treatment and reinjection) of these three alternatives
utilize relatively common construction equipment and materials and
could be easily implemented. The processes included in Alterna-
tives GW-3 and GW-4 are proven and widely used methods of removing
the contaminants of concern in the groundwater, and are readily
available. Al ternative GW-6, however, requires performance of
treatability studies during remedial design to ensure that this
alternative would be effective in achieving the removal efficienci-
es required to attain target groundwater cleanup levels.
In contrast, the treatment technology in Alternative GW-S (UV
oxidation), although successful in pilot runs, has had limited full
scale use to date. Therefore, site-specific pilot scale studies
would be required to confirm its adequacy for the Site.
Furthermore, the UV oxidation units are currently available from
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two vendors nationwide, and the sludge units of Alternative G~-6
are available from only one vendor who holds the patent.
'-
E.'
.
Lona-Term Etfectiveness ancS Permanence
Alternatives @W-l and GW-2 allow risks from the long-term migration
of contaminants to continue. Alternative GW-2 includes monitori~g
to track the spread of contamination and instituting groundwater
use restrictions to prevent potential exposure. Achievement of
concentrations below MCLs and risk-based ARARs would be approached
at a rate governed by natural attenuation.
Alternatives GW-3, GW-4,GW-5, and GW-6 would effectively reduce
the potential risks associated with the contaminated groundwater
by extracting and treating the contaminated groundwater, and
returning the treated water to the aquifer and/or discharging the
treated water to surface wate~. After the specified remediation
period, i.e. approximately 20 years, there should be little or .no
long term management required of the aquifer.
F.
Short-Term Effectiveness
Alternative G~-l presents no additional short-term risks to workers
or the community during implementation. Alternative GW-2 presents
minimal short-term risks to workers during the sampling of the
monitoring wells. Neither alternatives, however, is particularly
effective in the short term. Alternatives GW-3, GW-4, GW-5, and
GW-6 present short-term risks to workers and the community due to
potential fugitive dust emissions during construction of the
treatment plants, extraction systems, and associated piping.
However, mitigative measures, such as the utilization of vapor
suppressive foams and water spraying, would be implemented to
reduce the potential risk of exposure during remedial activities.
The annual sampling of monitoring wells and implementation of
groundwater use restrictions that are contained in Alternative GW-
2 could be initiated within 6 months. However, Alternative GW-2
would only reduce the potential for ingestion of groundwater on-
site and not directly address remediation of contaminated groundwa-
ter. The systems installed in Alternatives GW-3, GW-4, GW-5, and
GW-6 would be operational within 18 months following the start of
construction. The estimated time for aquifer restoration for all
four alternatives is approximately 20 years.
G.
Cost
The present worth cost for Alternative GW-4 is $9,934,000. The
lowest cost alternative is Alternative GW-1 at $231,000. The
highest cost alternative is Alternative GW-5 at $15,094,000. The
present worth costs for Alternatives GW-2, GW-3, and GW-6 are
$985,000, $14,279,000 and $5,739,000, respectively.
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The total capital, annual operation and maintenance, and pre~ent
worth costs for all groundwater alternativ~s are presented in Table
'1 for compariso~ ~urposes. ' , '
state Acceptance
'"
NYSDEC concurs with the selected soil and groundwater remedial
alternatives.
Community Accebtance
The Town Board of the Town of Lincklaen has expressed ,overall
support for the alternatives selected for remediation of the soil
and groundwater. Several residents have expressed concerns
associated with volatile emissions and the generation of dust
associated with the on-site ex.cavation acti vi t'ies and discharges
to the surface water and emissions to the atmosphere associated
wi th the ground'water treatment and thermal treatment al terna-
ti ves , respectively. These concerns are responded, to in the
attached Responsiveness Summary.
THE SELECTED REMEDY
Based upon consideration of the requirements of CERCLA, the
detailed analysis of the alternatives, and public comments, both
EPA and NYSDEC have determined that Alternative SC-S, Excavation/
Low-Temperature Thermal Extraction/On-Site Redeposition (on-site
or off-site treatment of PCB-contaminated soil), for treatment of
the contaminated soil, and Alternative GW-4, Groundwater Extrac-
tic"/Chemical Precipitation/ Air Stripping/Carbon Adsorption, for
treatment of the groundwater, constitute the appropriate remedy for
the Solvent Savers Site. The major components of the selected
remedy are as follows: '
The buried drums will be excavated and removed off-site for
treatment and disposal at an approved RCRA hazardous waste facility
(to the extent that the work required under the September 1989
Administrative Order is not completed by the Respondents in a
timely fashion or to the extent that any soil contamination will
remain at the Site following the completion of that work).
Approximately 59,000 cubic yards of contaminated soil (includ-
ing about 1,000 cubic yards of PCB-contaminated soil from the two
hot spots located in Areas 2 and 4) will be excavated from the two
source areas (Areas 2 and 4) of the Site. The lateral and vertical
extent of the excavation will be more precisely defined by
additional sampling during the remedial design phase to determine
the extent of the areas where soil contaminant concentrations
exceed the soil cleanup levels set to protect the groundwater.
Furthermore, during the remedial design phase, the fate and
transport model used to derive the soil cleanup levels will be
calibrated and further tested using current and additional sampling
..
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-
data, as necessary, to more precisely define the soil cleanup
levels and the areq.l extent of the source areas requiring remedia-
tion. Should the! data and information. updated during the remedial
design indicate that Areas 1, 3, and/or 5 require remediation, the' .
co~~aminated soil from these 3 areas will also be treated as set
forth in this ~OD to attain target soil cleanup ievels. Contami-
nated soil in the source areas will be excavated ~own to the levels
required to ensure that all the target soil clean~p levels are met.
Fugitive emiss~ons will be controlled during the excavation by such
techniques as water spraying, vapor suppression foams, etc.
The organic contaminants in the highly contaminated soil will
be. treated on-site using a low temperature thermal extraction
technology.
- Treatability studies will be performed during the remedial design
phase to determine whether the low temperature thermal extraction
technology is an appropriate treatment method for the PCB-contami-
nated soil. If the treatability study results indicate that low
temperature thermal extraction is an appropriate treatment method,
then this technology will be utilized to treat the excavated soil
contaminated with PCBs on-site. Should the findings of the
treatabil i ty studies indicate that the on-site low temperature
thermal extraction process would not provide the desired degree of .
treatment, then the PCB-contaminated soil excavated will be removed
for off-site incineration.
If removal of the PCB-contaminated soil for off-site treatment/dis-
posal is required, the receiving thermal treatment facility will
be responsible for ensuring that incineration of t~e contamiJ1ated
soil is conducted in accordance with all applicable RCRA and TSCA
requirements and that the treated soil is properly disposed of off-
site. Following completion of the excavation and removal activi-
ties associated with the PCB-contaminated soil, clean fill will be
used to backfill the excavated areas.
- Treatability studies will be conducted during the remedial
design phase to determine whether the soil flushing and/or
vapor extraction processes are appropriate treatment methods
for the excavated soil contaminated with low level VOCs.
If the treatability study results indicate that one or both
of these technologies are appropriate treatment methods,
then one or both of these technologies will be utilized to
treat the excavated soil contaminated with low level VOCs.
Should the findings of the treatability studies indicate
that these on-site treatment processes would not provide the
desired degree of treatment, then the contaminated soil
will be treated on-site using low temperature thermal extraction.
The treated soil will be subjected to the TCLP to determine
whether all the RCRA hazardous wastes contained in it meet the Land
Disposal Restrictions ("LOR") treatment standards (TCLP concentra-
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-
<:!
tions). Since the treated soil which passes the test will meet-~he
RCRA LDR standards and will no longer con~ain hazardous cons~itu-
. ents above heal~h~based levels, as determined by the risk assess-
ment, it will not be subject to regulation under Subtitle C of RCRA .
(including the LDRs imposed by the Hazardous and Solid Waste
Amendments to RCRA) and may be replaced in~o the areas from 'it was
removed. (Clean soil may have to be utilized to supplement the
treated soil in filling the excavated areas). Clean top soil will
be placed on the fill areas. The Site will be regraded and
revegetated. ,
In the unlikely event that the treated soil does not pass the
TCLP toxicity test, it will be further treated to meet the TCLP
r~quirements prior to its placement in the excavated areas (to the
extent that the work required under the September 1989 Admini-
strative Order is not completed by the Respondents in a timely.
fashion or to the extent that 'any soil contamination will remain
at the Site following the completion of that work). '
<>
Contaminated groundwater will be removed from the underlying
aquifers at the Site by a system of extraction wells. The contami-
nated groundwater ",'ill be treated on-site for removal of the
inorganic contaminants using the' chemical precipitation technology,
and removal of the organic contaminants using a combination of air
stripping and carbon adsorption technologies.
The treated water will be recharged back into the ground and/or
discharged to surface water on-site. The number and locations of
the extraction wells, the pumping routes, the specifications for
th~ pretreatment, air stripping, and carbon adsorption systems, as
well as the type of the recharge and/or discharge system will be
determined during the remedial design phase.
The groundwater treatment will continue until federal MCLs and
state groundwater standards for the organic and inorganic contami-
nants have been achieved in the groundwater. The goal of this
remedial action is to restore groundwater to its beneficial use,
which is, at this Site, a drinking water source. Based on informa-
tion obtained during the supplemental RI and on an analysis of all
remedial alternatives, EPA and NYSDEC believe that the selected
remedy will achieve this goal. It may become apparent, during
implementation or operation of the groundwater extraction system
and its modifications, that contaminant levels have ceased to
decl ine and are remaining constant at levels higher than the
remediation goal. In such a case, the system performance standards
and/or the remedy may be reevaluated.
The selected remedy will include groundwater extraction and
treatment via chemical precipitation, carbon adsorption, and air
stripping for an estimated period of 20 years, during which the
system's performance will be carefully minitored on a regular basis
and adjusted as warranted by the performance data collected during
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-
operation.
. Wastes and drums containing wastes generated during the supple-
mental RI that have been identified as hazardous will be treated.
on-site with the soil and groundwater treatment systems. RI dru~s
that contain ~olid matter, other than soiL, will be shipped off-
site for disposal at a licensed facility.
All residuals from the treatment of the soil and of the
groundwater (such as filtered suspended solids and spent carbon)
will be shipped to an off-site RCRA hazardous waste facility for
treatment/disposal.
- 'Air monitoring will be performed prior to, during and following
construction at the Site. Air emissions from the treatment units
during both the soil and groundwater remediation will meet the air.
e~ission ARARs. Environmental monitoring will be required during
the life of the treatment process. In addition, monitoring of the
groundwater at the Site will be conducted for a period of five
years after completion of the remediation, to ensure that the goals
of the remedial action have been met.
A wetlands/floodplains assessment, and/or a stage IB cultural
resources survey will be performed, if determined to be necessary,
d~ring the remedial design phase.
Remediation Goals
The purpose of this response action is to reduce the present risk
to human health and the environment uue to the contamination of the
on-site soil and groundwater, to restore the groundwater underlying
the Site to levels consistent with state and federal ARARs, and to
ensure protection of the air, ground and surface water in the
vicinity of the Site from the continued release of contaminants
from the soil. Since no federal or state ARARs exist for soil
which set forth numerical standards to which the soil has to be
cleaned up, the action levels for the VOCs in soil were determined
through a site-specific analysis. This analysis used fate and
transport modeling to determine levels to which VOCs in soils
should be reduced in order to .ensure that no receptor would be
exposed to contaminated groundwater above drinking water standards,
i.e., MCLs. Reduction to these levels also would ensure that no
excessive risk would result from human contact with soil at the
Site.
The PCBs discovered on-site are present in sufficient quantities
to be of concern with respect to protection of human health
according to the risk assessment. As noted above, EPA' s OSWER
directive 9355.4-01 serves as a guide for all remedial actions at
Superfund sites with PCB contamination. It basically combines the
elements of all applicable laws (including the Clean Water Act and
Safe Drinking Water Act for groundwater cleanups) into one cohesive
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-
document which is the basis of EPA's PCB pOlicy. The directive
recommends a 1 ppm action level as a .~tarting point for' PCB
'cleanups in resi~ential areas, treatment of 100 ppm or gieater PCB
hot spots as principal threats, and containment of low threat PCB"
contamination in the 1-100 ppm range. Treatment may be warrantEd
at sites invo~ving relatively small volumes of cotamina-tion or
sensitive environments.
<>
Since the Site is located on a rural agricultural area where
residential homes are situated in proximity of the Site, and the
amount of PCB-contaminated soil that poses potential human health
threat to the public is small (about 1000 cubic yards), treatment
of the contaminated soil to attain the level of 1 ppm is appropri-
ate for this Site.
STATUTORY DETERMINATIONS
Under its legal authorities, EPA's primary responsibility at
Superfund sites is to undertake remedial actions that achieve
protection of human health and the environment. In addition,
Section 121 of CERCLA establishes several other statutory require-
ments and preferences. These specify that when completed, the
selected remedial action for this site must comply with applicable
or relevant and appropriate environmental standards established
under federal and state environmental laws unless a statutory
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. F .:.nall' , the statute includ2s a f'reference for
remedies that employ ~reatment that permanentlj and significantly
redu~e the volume, toxicity, or mobility of hazardous wastes as
their principal element. The following sections discuss how the
selected remedy meets these statutory requirements.
Protection of Human Health and the Environment
The selected remedy protects human health and the environment
through the removal and treatment of the inorganic and organic
contaminants in groundwater, using chemical precipitation, air
stripping, and carbon adsorption. In addition, the removal of the
buried drums and PCB-contaminated soil for off-site treatment/dis-
posal, and treatment of the soil contaminated primarily with VOCs
through a low temperature thermal extraction process will remove
the most mobile wastes from the soil, resulting in the elimination
of a long-term source of groundwater contamination. It will .also
mitigate the risks to public health and the environment associated
with the leaching of contaminants into the groundwater and the
migration of those contaminants off-site. There are no short-term
threats associated with the selected remedy that cannot be readily
controlled. .
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ComD1iance wi th ADD1icab1e or Relevant and ADDroDriate Reauiremerits
I ......
'.
The. selected remetdy, which consists of exc.:.vation and removal of
th~ buried drums and PCB-contaminated soil c :-site for treatment/-
disposal, excavation and on-site treatment 0: the soil contarninate~
with VOCs ut1lizing low-temperature thermal extraction,. and
extraction of the contaminated groundwater for treatment utilizing
chemical precipitation, air stripping and carbon adsorption, will
comply with aLl chemical-, action-, and location-specific ARARs
(see Tables 30, 31 and 32).
Cost-Effectiveness
" .
The selected remedy is cost-effective for it provides overall
effectiveness proportional to its cost. The estimated net present
worth cost for this remedy is $29,350,000. The" estimated cost of
the source control component of the selected remedy ($19,416,000)
is only 20 percent of the estimated cost of the alternative
involving off-site incineration, yet the selected remedy mitigates,
as effectively as that alternative, all the risks posed by the
contaminants at the Site. The effectiveness of the in-situ vapor
extraction and soil flushing alternatives would depend on the
permeability of the vadose zone. Although the estimated costs for
these two alternatives are less than the estimated cost for the
selected source control alternative, these two alternatives may not
result in the effective removal of contaminants from the soil due
to the complex and heterogeneous nature of the subsurface "struc-
ture" at the Site. Furthermore, the selected source control
alternative would likely enable tcrget cleanup levels to be
achieved wi~hin 12 months, whereas the alternative involving soil
flushing would require an estimated 20 years to achieve target
cleanup levels.
The estimated cost of the groundwater component. of the remedy
($9,934,000) is 73 percent higher than the estimated cost for the
UV oxidation alternative, but it offers a much higher degree of
certainty with regard to the effective removal of organic contami-
nants from the groundwater. The alternative which includes only
chemical precipitation and carbon adsorption, and the selected
groundwater alternative that also includes air stripping, would
effectively mitigate the risks associated with the groundwater
contamination. However, the estimated cost of the selected
groundwater alternative is about 30 percent lower than the
estimated cost of the alternative involving only chemical precipi-
tation and carbon adsorption. Although the estimated total present
worth cost of the al ternati ve involving biological treatment/carbon
adsorption is about 40 percent lower than that of the selected
groundwater alternative, treatability studies would need to be
performed during remedial design to provide design information and
verification of the effectiveness of this alternative in achieving
removal efficiencies required to comply with all federal MCLs and
state groundwater standards.
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utilization of Permanent Solutions and Alternative
Technoloqies to the Maximum Extent Practicable
.
Treatment
~.
EPA and Nev.' York State have determined that the selected remedy'
represents the maximum extent to which permanent solutions and
al ternati ve tFeatment technologies can be utilized in a . cost-
effective manner for the Solvent Savers Site. Of those alterna-
tives that are protective of human health and the environment and
comply with ARARs, EPA and NYSDEC have determined that the selected
remedy best balances the goals of long-term effectiveness and
permanence, reduction in toxicity, mobility, or volume achieved
through treatment, short-term effectiveness, implementability, and
cost, also considering the statutory preference for treatment as
a principal element and considering state and community acceptance.
wi th regard to the most mobile soil wastes that pose the maj or
risks at the Site, the selected. remedy will offer a higher degree
of long-term effectiveness and permanence than the other treatment
alternatives, involving in-situ soil flushing and vapor extraction,
by permanently removing the source of groundwater contamination and
reducing the risk to human health and the environment. The
selected remedy will result in significant reductions in the
toxicity of the contaminated material through thermal destruction
of the organic contaminants. The selected remedy is as effective
as the off-site incineration alternative. However, in the short-
term , it offers the additional advantage of on-site treatment,
thereby reducing the potential risks to residents along transporta-
tion routes. Implementation of the selected source control
alternative is a cost-effective treatment option that is protective
of public health and the environment.
"
The decision to treat the contaminated soil is consistent with
program requirements that state that highly toxic and mobile wastes
should be treated to ensure the long-term effectiveness of a
remedy. Long-term effectiveness, reduction of toxicity, mobility,
or volume, and implementability are the major factors that provide
the basis for the selection of the soil portion of the remedy. The
selected remedy can be implemented with less risk to area residents
and, therefore, is determined to be the most appropriate solution
for the contaminated soil at the Solvent Savers site.
The selected alternative for the groundwater offers as high a
degree of long-term effectiveness and permanence, and reduction of
toxicity, mobility, and volume as the other treatment options.
The selected alternative is also as effective in the short-term as
the other treatment options. With regard to implementability, the
components of the selected groundwater alternative and of the
chemical precipitation/carbon adsorption alternative are easily
implemented, proven technologies and are readily available. In
contrast, the treatment technologies for UV oxidation, although
successful in pilot runs, has had limited use to date. In
addition, UV oxidation units are currently available from only two
sources nationwide, and the sludge units of the biological
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treatment alternative are available f~om only one vendDr.
rrnplementation of.the selected groundwater alternative iS,the most
cost-effective treatment option that is protective of public health
and environment. ,.'
'.
Since all treatment options for the groundwater are reasonably
comparable with respect to long-term effective~:ss, reduction of
toxicity, mobility, and volume, and short~term e:fectiveness, the
maj or factors .that provide the basis for the selection of the
,chemical precipitation/air stripping/carbon adsorption alternative
as the remedy for the groundwater are implementability' when
compared to the UV oxidation and biological treatment options, and
cos~ when compared to the chemical precipitation/carbon adsorption
alternative. The technology for the selected alternative is proven
and readily available, and the carbon adsorption, system when added
to the air stripping option ensures complete removal of contami-
nants.
Preference for Treatment as a Princi~al Element
The selected remedy addresses the principal threat posed by the
Si te through the use of treatment technologies by removing the
buried drums off-site for treatment/disposal, by removing the PCB-
contaminated soil for off-site treatment in an incinerator, by
treating the VOC-contaminated soil on-site in a low-temperature
thermal treatment unit, and by treating the contaminated groundwa-
ter via chemical precipitation, air stripping, and carbon adsorp-
tion. Therefore, the statutory preference for remedies that employ
treatment as Z' principal'element is satisfied.
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APPENDIX 1
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TABLE 1
~dST ESTIMATE BUMMARY OF ALTERNATIVES
SOIL ALTERNATIVES Capital 1\nnui'll O&M Tot~J arcsent worth
(30-yr, ,1(, l~;count ra .c)
SC-l: No Action $ 0 $ 15,000 $ 231,000
SC-2: Limited Action $ 54,000 $ 2),800 $ . 4 62 , ob 0
SC-): site Capping $ 562,500 $ 16,£100 $ 862,000 .
SC-4: In-situ Vapor Extraction $ 7,087,000 $ 0 $ 7,887,000
SC-5: f~cavaii~ntLoW Tem~aratu£e $19,416,000 $ 0 $19,416,000
arma . ¥ ractlon n-S1 e
e eposl Ion
SC-6: Off-site Incineration $96,800,000 $ 0 $96,800,000
SC-7: In-situ Soil Flushing $ 981,000 $ 6,200 $ 1,076,000
GROUNDWATER ALTERNATIVES
GW-1 : No Action $ 0 $ 15,000 $ 231,000
GW-2: Limited Action $ 48,000 $ 58,000 $ 985,000
GW-3: gfiouDdwlt~r E¥tr~c~ionl. $ 1,618,000 $821,000 $14,279,000
e~lca d reCt~l a 10n{
ar on sorp on
G\'1--4 : ~&OUDdwyt~r E¥tr~c~ionl. $ 1,855,000 $523,000 $ 9,934,000
emS£a recj81 ~ 10n{
ar £lRRlng ar on
sorp 1
GW-5: gQOUDdwyt~r E¥tr~c~ionl. $ 3,138,000 $775,000 $15,094,000
e~lC~ t rec1pl a 10n{
Xl a Ion
GW-6: ~&OUDdw~trr E¥tr~c~ionl. $ 2,300,000 $220,000 $ 5,739,000
eT1ca rfC1~t a ton{
10 oglca re men
.'
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TABLE 2
SOLVENr SAVERS R! REPCRr
6A:(~~~~~ SO," C~NCENTRA7!C~S FOR lWCRGAN:C CHE~!:A"S
C~~: :al
C:netr.t ,at i 0t1 in
C~t~..er>So C:.
eest of Sher~rne (a)
(ms/kg)
Conctr.trBtien in
C~en.er>S:: C=:.
soutn of Bair.cricge (a)
(1':'I;/kg)
Ceneent,etien in
Onon:::asa Ce.
1-90 at exit 35 (a)
(ms/kg)
--
At U!",i i~
_rse...i:
6arilT.1
6 e ry l l i .r.;
Caa-::.r.;
Calci.r.;
C~rx>ilT.1
Cct.cl:
Copoe,
! rcr.
Lee<:
lIas~s i.r.;
lIar>Senese
lIercury
Wiele,
Potessil.r.1
Sele-1'1;1.r.1
Soci\.l:l
. Ver""oj u:I
Z :nc
100,000
8.1,
500
2.0
Ii"
1,9C0
100
10
20
50,000
20
5,OCO
300
0.13
2,"
17,300
0.2
7,000
1S0
101
70 OCO
e.2
200
1.0
. Ii"
2,000
30
10
15
15,000
3C
3,000
700
0.08
20
10,000
0.6
7,000
SO
eo
20,OCO
2.0
2tC
Ii~
IiA
3,600
15
3.0
30
15,OCO
15
3,000
3CO
0.6
7.0
10,800
0.6
7,000
30
1.1
(II) As repo-te-:::! in S':3cklette an:::l Boerngen (198.r.).
ND = Not det~teC.
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TABLE 3
BACKCROUND SOIL CONCENTRATIONS OF TARCET C~POUN: LIST
POLYCYCLIC AROMATIC HYDROCARBONS (PAHS)
Conc~tretion (ug/kg)
-.-[[[
Rurll Soil
Agric:ul turll .Soi I
Urbln Sc i l
Clre:inog~ic: PAH
..........-...............
BenzoCb)fluorlnthene
BenzoCj)fluorlnthene
5 - 20
20 - 30
56 - 1 10
58 - 220
169 . 59,000
15,000 . 62,000
BenzoCI)lnthrlc:ene
6,000 . 97,000
B~zoCb-j)fluorlnthene
B~zoCk)fluorlnthene
25 - 110.
10 . 110
B~ZO(I)pyrene
Chrysene
2 - 1,300
3S.3
58 - 250
1,.6 - 900
300 . 26,000
165 - 22,000
78 . 120
251 - 6J" 000
DibenzCI,h)lnthrlc:ene
IndenoIC1,2,3-e:d pyrene)
10 . 15
63 - 100
B,OOO . 61,000
..a.............................................."..........a...........................
Non-Clre: ;nog~; c: PAH
...-..-...................
Ac:enaphthene
Acenaphthylene
1.7
6
5
B~zO(8,h,;)perylene
8~zoCe)pyrene
10 . 70
11 . 13
66
900 . '7,000
60 . 14,000
Anthrlcene
53 . 130
Biphenyl
Fluorlnthene
1'.B
0.3 . 75
120 - 210
9.7
200 . 166,000
Fluorene
8IIphthilene
Perylene
46.2
Phenanthrene
30.0
l' . 18
loa . 140
100 . ',800
Pyrene
0.1 . 64
99 . 150
3,000 - 147,000
Sources:
lAIC (1973)
lluaer (1917)
White end Vanderslice (1980)
Windsor and Mlt.. (197'9)
Pucltnet (1981)
Eo.ards (1983)
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TAE:'E 4
I:~VE~~ IAVE-S R1 R:~:~T
C:~:c~7~7::~$ c~ C~E~ICALS [~ SURFA:e s::~
C~""'CI~
F~Kj~''''=Y
0'
C.ae~ \;r- c.,
..~g. Of C.t.::.:
COr':eef1tr8: \ Cr'..
Ra~.e C~ Icek;-:~~:
C:~C'~:~J:~:~S (:)
Or-;'''!C8
(~;.'(.~; .
......,..........
. Ac:.t::.r-. ';' 2~ I/A
. hn;;I; le!c 317 Z~~'6S:; iliA
. 2'&i.U~c:"" ~r 13 II':'
I 1~~yl~~zY~~~~I:lt. /7 ~~ hA
. el-n-Buty.~:r.I\et! 117 II~
. CII~l)riXle~zer':e /7 3.0 ""
. CII~c":1crr.: V' ~.: Ii~
. ~""~:~l:rcI:~J,"' /7 V' 1/,\
. ,2-C1:~~:r~t~lre V7 .0 III.
I ""i'C~l:roetr~ 11 3.0 ""
I b'l( -e:ryl",.xy.)~:r.e:a:~ ",., '00'22 ~:C Io'A
~, .
. H,xlclllcr~~ze~ ~~Z ,~C h...
. ..tnrl~ne C~lo";de I' '8.0'23.0 )j),
. Clrc.nc;I~I: PAk5 ~1!',5:
'e~zc(= Ind k)~L_crlr'::he~e 2/7 4~C"~C3::J
a8l'lZc(l)pyrme '/7 1c 5-;::
CII ~Y5~.e 1/7 4E~ 7S-~-:
TO:IL c'r:!ncie~!c PAl'i5 (0) 2/1 410-',61:: 31a.\':~
. noncI":!nc;en~c F ri
'LL;cr8r.tr.~. 111 2!~ '20-2~C
P~M8"1::'\r~e 1'" '0: /,8.\.:.0
I'
',"'" '/7 13:: ~;.~~:;
-- ~ .~'--- '. Pt..., (C) 1;1 '73~ '31 .7~?
0.11. n."'\CI. .'....'1'0..
I PCh
'CB-\2'2 36."~ 7'0-\~OOCl:C iii A
PC8-1254 1 i"~ 260- 7~~ :: IIA
'C8'~~6~ ""6 42Z 0,," HA
PCS', I.! 1SI106 5,,8C; tC.JO~-,. HA
.Tcu~ ~CB5 (c} 2~/"e 26,,- . 50' 3w.5' c.- IIA
. T.t~ecllloroe:n.". I' 2. -73 II"
. TCI1~ ~/1 17C IiA
. ',J. -Trlclllor(' :tllr:8 /7 e.O'3150 Ii..
. "" -iric~(oroe:ne~e ~/7 825 IfA
. 'rlcftleroetn.". 17 Z,S-Z6,5CO jjA
rnorganlc. (m;/~;)1
.................-
Al_in"'" 111 12t3CO-,e,e:o 2::,O:O-'CC,~::
I Aru"i: 4/:' ~.,~.2 7.6.8.4
'arllo1Ti ~/7 9. -e .6 Z~O'5:C
lery\ l i~ /1 0.61,1.05 1II0-2.C
I tacmHIT! ~' '0.6 iii A
CI~C!1oITi /1 4''''3'2''0 1,900-3,.( 6CO
I thrcwnfl.rn ~/7 '8.9- 89 'i: ~CC
I tObelt 11 81.1-'/c' 0
. to~r 7/7 , ,e- 06 '~-jC
I r 01'1 7/7 33~750"0,6CO 1! 000- 0 000
. L.ed ;11 2.Z-!J , ' '5.30'
I .a;:"I8I'",," 2,nO:5gfO :5 o"c-. c,..,
~~ ' IJ ..~ w.
I .anganeae 300-7 C
. ..rcury ~t 0.3S.t .0 a.oa-o.fI
. IIlckel Z4.'<496g 7-20
'cu..i",," 17 4'<' 2 'o,aCO-11~3CO
Ie l tr\ I \III 2/7 . a. '-6239 0.2'0.
Vaned I \III ~' 23.7-3 . ie- pc
. lire 17 15.:,",," ,- 01
. tya"iae 1/7 7.0 NA
CI) The number ef ..~l.1 In ~nlch the c~nt.m;nlnt w.. d.tected dlvld.d by the tot.1 ~r of
.~le. .nelyzlC. Tot.1 nwr~r of .ampla. I... than 7 Indicate th.t Icme II~l'8 .er.
re j ected fer QA/QC r...ona.
(b) Ilclground concentr.tion. fcr loll al 'r..ent.d '1'1 Tables 2 and 3
(c) TotaL ~.rclnoge";c PAHI, tetl, ncnc.rc no;e,,'c PAM.L ano COCII ~~.. 1~ In e.ch .lmFI. we-.
dcc.~,1'\8d for ..ch ..mple locltion. The r.nse ef ~hes. total. w.. then determined.
. . ,.llcted .1 chemic.1 of pote"tilL conclrn.
WA. Noc IVI!L.CI..
-------
-
!
TABLE 5
SCLVEWT SAVERS RI RE?CRT
C:W::~KA~ICNS CF CHE~ICALS IN S~SS~RFACE SC:~
C'1~; ca ~
F r l!'C'Ue~'f
C~
De~~~icn (a)
Re~5e of Oe~~~~
C:r.ce~:~i~~o<"'S
.. .. .. .. .. .. .. .. .. .. .. .. .. .... ..
C~;enics (~5/.:):
. A::e!:r:e
-- . Benz e-.e
. B~.:ci:: ide
. B ~ t:r.1O'!1e ~ '1 II r. e
. ,-Bu:enot'\e
. ButylOe~:ylph:~ala~e
. ~i-n-E~tylpnt~a,ate
. C~lorober,:~
. C~~cr:~:~
. 1,2-Di::~i=re~:e~
. 1,3-0ic~lore~:e~
. 1,'-C;c~lcro~ze~e
. 1, 1-Dic~loroethene
. 1,1-C;::~loroethe~
. tote I 1,2-C;c~ler~t~~
. cis(2-Ethylhe~yl)pr.t~e~ate
. E tl'lylben2~
. I scp1ercne
. Methylene c~lcriee
. ~-Metl'lylpn~l
. di-n-Octylphtl'lelete
. cerci~~ic PAHs
Ben:c(l)enthrac~
Ben%c(b end I)flucrant~e~
C!lryse~
Total carci~enic PAHs (=)
. noncarcinogenic PAris
Acenephtl'l~
'Antl'lracene
Cibenzofuran
Flucrenthene
Flucr~
2-"ethylnapnthll~
Nephtl'll I ene
PI'I~entnrene
Pyrene
Tetal noncarcinogenic PAHs (b)
. PCBs
PCS- 1C~6
PCS-12'2
PCB.1Z(,1!
PC9.125..
Total PCSs (b)
. Pentacn 1 oropneno I
. Phenol
. 1,1;2,2-Tetrlchloroethlne
. Tetrlchloroethene
. Tol~
. 1,2,('-Trichlorobenzene
. 1,1,1-Trichloroethene
. 1,1,2-Trichloroetnlne
. Tri~~loroethene
. toul Xylenes
~/tC '~C.3,7::
2/t: O.:~>7,4::
3/S 1C;C.3e:
1/t:: i,lt::
9/'~ '.:J-i2,C:C
1/5y ,~~
I ~
6/:9 3;-2,7:::
2It,J , .0-2~
2':'/~ 1 .~..7,:::
"/:9 SC"13,C::
1/~9 73::
1/~9 2,~C
'It: ,.",
,~
71tN 1~O-2. 7":0
10/6<: 0.90-6,5CO
29/59 38-2~,0:C
7/6<: 1.0-29,OOC
2159 73-530
"/bJ 5':'0-890
1/59 170
2/59 2'-57
1/59 57
1/59 88
1/59 61
1/59 206
1/59 92
1/59 580
1/59 210
1/59 71"
1/59 220
5/59 7'9-52,000
1,159 56-53,000
6/59 1,,3-620
2/59 89-'1,0
9/59 81..0
5/58 620-29,500
3/58 500-"',000
3/58 470.22,000
7/58 290-10:0,500
13/58 661.75,7C0
1/59 370-370
1/59 120
2/60 3.0-5.0
47/60 3.0-67,000
2(,/60 1.0-1.00,000
3/59 220-1,200,000
~/60 2.0-170,000
8/60 6.0-1,200
51,/60 6.0-750,000
12/60 5.0-229,500
(I) The ruTCe~ of s~les in which the conuminent VI' detected divided
by the tetll ruTCer of s~les analyzed. Totll ruTCer of s8mCles
less thIn 60 indiclte thlt some semples were rejected for QA/QC
relSons .
(b) Totll clrcinogenic PAHs, totll noncarcinogenic PAHs, and totll PCBs
foo.rc:j in eech semple were determined fo,. each 1811)18 location. The
range of these totlls VIS then determined. The carcinogenic PAHs
were detected In the s- semple.
-------
.
. TABLE 5 (Ccntinue-:)
- s.::LVEIi: SA'''E.S R: RE?CR7' .
C:NCENTRATICHS OF CHEM\~ALS CETECTE~ IN s~e~RFA:: SC:L
C:"\~:=3:
F" e<:~e~.c'l
c"
De:e::icl"\ (a)
Ral"\se of Ce:e::~
Ccnce~:~8: ::1"\
'-
I~c";a:"'.: :5
(~/~;) :
Ral"\se c' 6act;~:'~c
C:l"\ce~:~a:icl"\ (~;
...............-........-
"~'J':,:~~
. "1",:: ::-cr.y
. Arse~1C
Baril.T.'. -
ee~f~ ~ r~
. Clli:T.'iU"\
. Cal:i\.T.:
C:-: r~ i ;r.;
. C:~,:
. C:coer
! r:;.r.
. Le~
. fllilsnesil.l:'
. ~e,.,..anese
. N;cxe~
PotesS;~
. Selel"\i\,1;1
. ~: i ;e~
S.x:::.r.1
Val".ec i Lr.:
. 2 inc
tO/C:;
12.'~c:
59 / ~ ~
~/~::;
3\;/,:"
3.:./tC
6<)/6.;)
56/~7
6::;/bC
1.9/1.9
6()/tJ
1.5/1.5
6C/e:O
60/bC
55/55
60/bG
, ~ /52
'/57
20/26
6<)/60
to/6lJ
!,t2C'2I.,tC:J
2.3'9.E
6.1.-1.6.8
20.3-158
0.32-1.3
C.69'E.6
1.~6-53,9CO
'1.5.3..:..E
e.7-19.9
17.9-7':'.6
22,9CO-39,2':0
9.!-,77
3,31.0-7,600
251.-' ,s.30
2':.3-..0_9
61i!:.1,!~0
0.1.3'2.3
1.0
52.6-"t
8.2-1.2.'
58.1.-33~
2~,C:C..iCC,~C:
IiA
7.6- = ..'
2C:.~:C
N:-2.0
. /Ii;"
',9CC'3,~::::
15.10:
3- 10
'C...~
. --
'~,CC::>5;:,C::
'5.3C
3,OCO-5,OCO
-30C-7CO
7-20
'O,OC:::'17,3::
0.2-0.6
NA
7,0::0
3"-15,,
I.~-'O~
(II) i~e ~r of samcles in whic~ the
s8/!'Cles el".olY:r:<:. To:al n.r.cer of
re:~:ed for ~/~C reesor~.
(b) Bec:x;rQUI"\C concentrations fOl" soil
c:nt~i~nt WIS detected divided by the total ~r of
samples less tnan 6lJ indicate that some samples were
as pl"es~ted in Ta~.e
. = Sel~:ed IS chemical of potential c:~ncern.
NA R Nc: Ivail!:ie.
ND R Ne: cet~:rc.
-------
-
-'
TABLE 6
S=~VE~i SAVE~S ~! REPC~~
CIOX:H 15C"EilS
F~E~UE~CT OF CEiE:i:OH AHALTSiS
S~:S~~FACE S~:L SAMP~E5
---------------------------------------------------------------------------
C:MPOOHO
IILtlBER OF
OEiEC710HS/SAXPLES
~AHGE OF
VALUES
(~/)~6 )
---------------------------------------------------------------------------
TOTAL TC~O. TETRACHLOROOIBEHZOOIOXIH Oll1
TOTAL PC:O. PEHTACHLOROOIBEH:OOICX!H 1/11 0.159
TOTAL HxC~O. HEXACHLOROOIBEHZOOICX:N 2/11 0.271-1.270
TOTAL HpC:O. HEPTAC~~ORCOIeEHZOOICx:H 21:5 : .4,5-2.591
TOTAL CCOO. OCTACHLOROOIBENZOOICXIH 2/11 5.035-7.835
-------
-
S:~VE~7 S~~E~S Ri RE::~: .
C:~:;~:~~7::~S :; C~£~i:~~S I~ G~:~S:~~7E~.
TAB:"E 7
\.
C~~,::~ .
rre::.:eoo::/
c~
Ce:e:::c~. (~:
~ax'~:':~
C:"':!"":"'~: :::~.'
~...
R~~;e c~ Ce:!::~:
C:~ce~::"a::::"s
ca::.-:.;:--::..:-::
.!~:s ~:~
c-;~- :::~ (-: I'::
---------------
. A.:!::-~e
. ~e"'::!"'e
. :~"'.::': a:':
. !e:-:~:f':e~:!"'e
. Ca~::~ :e:;~:~:c;:ce
. c."\ ;c:"::e:".:~~e
. c.", ~:;:e:~..t:-:e
. :~ ~C~:::~
. 2.:~;c:,,:::~~!~e
. ~~:~~=;~:::~e~e
. ~.2-~1~~::;::e:-::e~e
. l.~-J:::-:::;::e~=e~e
. ~.J-~:c~~c;::e~:e;e
. c'c~j:;:=~~~~:;~£:~~~e
. :. :-C::~~c;:e~~a~e
. :.2-J:c:-:~:;:e:~t"':e
. ~. 1-C ~c:-: 1cr:e:~.e~e
. :'s-,.2-Jlc:":c:-:e:~e:"e
. :~!;,:"'1,2-~::~1c;:e:~e~e
. 2.:-~~c~1cr::~e~ci
. E ::'1v it:e~.;:er:e
. bl~12-::~yi~exy'):r.:~~'!:e
. I scc:"crcr:e
. Iscc:-Ccyl:e:-:e:-e
. p-Is::~;~y~~:1~e~e
. Me~~yie~e C~ic:-1ce
. '-~ethyl-2-~er::ancr:e
. 2-~et~yl~r.encl
. '-Met~yl~r.encl
. ncncar:ir.ccen1: PAH,
2-~e~~v'n~c~~~~ie~e
lia::n:~ale~e
ic:a: ncnc3r:inc;en1c
PAHs (c)
. PCSs
PC:S-l,;,
PC:!!-l,"
Tcal P~:s (c)
. P!":encl
. n-Prccylbenzene
. Styrene
. 1.1.1.2-Tetrachlerce~hane
. 1.1.2.2-iet~acnlereethane
. ie!rac~lcrcethene
. Te luene
. 1.1.1-Trich1creethane
. 1.1.2-ir1chleroethane
. Tr1chlcrcethene
. Tr1chlerofluercmethane
. 1.;.5-Tr1methylbenzene
. Vinyl chloriae
. toul Xylene:!
1"':': 7.7:: s:
1~.':~ 7.:-::: s:
,,':.~ .::.~-i:.': II:
7,':: 0.:~-2.C II:
I .:. E::.C II:
.... ...-
~ ',. 9.C-!:.: s:
./ "".
c: 'e:' 1::.C-2EC s:
., .-
1 :.::': l:::'-Z.:C: s:
1,':: 0.96 N:
1/:: 1.1 N:
'/:~ 3~.5-::: s:
C'I:".: 0.5~-2..! II:
-I --
7/E:: 0.52-:.! II:
8/:0 1.7-::.~ s:
lE/E.! 67.0-1.9:0 s:
E/:.! 14.0-4:.: II:
Ie/E..! :!C. C'-~::: Ii:
Z2/E, 5.S-V.ace Ii:
9/:'\ 5.1-12.0 Ii:
3/:6 1:.0-45.0 Ii:
1. . -. 12.0-17C NJ
...;/ :-
3/E2 3.0-12.0 Ii::
216:: 6.0-S.0 N:
5/5: C.7;:-::.5 Ii:
1216: 0.51-7.5 Ii:
5/6' 770-15.0CO NO
8/6' 47.0-67~ Ii:
4/:5 15.0-75.0 Ii:
2/5: 8.0-..0.0 N(:
3/63 3.0-29.0 N~
4/E.! 16.0-::.0 N~
4/6' 2:.0 NO
3/62 2.3-72.0 NO
1/5, 12.0 NO
4/62 2.6-7::.2 NO
5/57 8.0-25.0 Ii:)
7/61 0.77-4.7 NO
2/64 25.8-330 liD
7/61 0.67-4.8 N:)
2/64 19.0-21.1 NO
17/64 8.7-1.950 NO
10/64 330-::.500 Ii:)
20/6' ;30-16.000 NO
10/64 27.0-170 NO
20/64 2.600-57.000 N':
22/61 0.55-240 KD
10/61 0.57-23.0 NO
9/64 7.4-32.0 NO
12/64 30.0-1.300 NO
(a) The number ef samples In which the centaminant was detec~ed dlviced by the tetal n~ber of s~~le'
analyzeo. Tet.l n~~er of samples less tnan 52 indtC3te that some samples were rejectec for QA/QC
reason,.
(b) A statIstical test of sIgnificance was performed ustng data frem both background wells.
Comelete backgreund data .nd t-test result, .re presented tn Appendix C.
(c) If either total or disselved concentration, exceeded background (,ee Appendtx C) both total
.nd dtssolved chemicals were a'ed.
(d) Tetal carclnegentc PAHs, tetal noncarcinogenic PAMs. and total PCBs found tn e.ch tample were
determined for each lample locatton. The range of these tetals w., then det~rmtned.
. . Selected .s chemical of potent1al concern.
-------
-
TABI..E 7 :c~~: 'r:",~:::
SCLV£~- S~V£~: ~: R£~C~~
c:~:~~-,~-::~: Cr C~£~::A~S IN G~C~N:.~~£;
C:':e~.::~ '
F:,,!::..e"'::f
c~
Ce:e::,c~. (a;
~ax~~.:.;'::
Ka~;e c: Ce:e~~!~
C::1c!:-:::-a:1::-:s
C:~::!~::-a'; ~=~ ::-
8a:",;-:...:",,:: '.e~ ~s (::
1-.':"';3r.:cs (..;;/'~ {:~:
.....----------------
. A :~::!: ~.:.;~. _.~..- 'Ie:} "/1:- l.:::-a;.~:c N:
\- -..- .., -..
. #.~L.:':':~r:~~ (~::~~) :2/:': 6i::S-i~:.C:: 13.5::
.. A~se~\c ~."s.'ve-\ 2<". 2.6-3:.5 ., . :
- .......' -/ ./ :,
A:"'se"":~: :::.!~) 4 ~ /:3 1.2-73.: : ..S
Ba~I:';~ 1-,sso've-' ::/:~ .. ... ,....
.... ...' -I ! . . .' -~:'.. ..,
Ea- ;...-::: :::.a ~; 5: /:~ 12.7-:.1:: ,~:
. 8e-ylil~ ~::::ss:lve::~ 1/ E~ 42 N:
e~-y':1:"-. ._.~~, 1~/E~ 0 7:-5 2 N:
\ -....... I
. :.!~:~~~ ,-.~." -~ 53:':3 7.S7:-1:2.C:: 25,:::
(..os.,.e.,
:~;c~~~ . -. .a ~ \ 63 ':2 7. 6~:-251, ec: ':;.5::J
"'....- . J
. C:'::-::!11\;~ ~c,uoive-\ :/E~ 6.0-1:0 N:
C~:-::r:1~~~ :~:~~) -, 46/:~ 5.0-2:4 22.5
. C:::a1: (:'ss::::..e:; C . c::: I 4.2-:4.5 NC
.l ..-
. C::a~: ,.. -- ~ , \ ". I:' 4.~.1:: 1:.9
\ ...-...- J I ...., --
.. Ir:~ ~"'.s~-~'Yo..., , c:;:' 1.000-165.::~ N:
.... -- --I ...-, --
.. 1~:,,: . -. .:8 . , 5C/SJ 8C8-2~4.C:: 2S.~::
~,- ~~~;~:~..e=; 2' =, 2.140-3.2:: N:
. .w'"
.. - ~~::~~; 2154 735-1.14: N:
""",-, I""""': 52/5..\ 948-39.7CO ::.:20
Ma;~es~~ ::~~.; 6' ,=, B09-e3.40C i. 72:
-, ...-
Ma~;anese Clssc've=: 49/ SJ 58.0-11.BOO 7:.7
Man;anes~ to:~'~ 63/54 58.4-1:.5':0 7S:
. ~.~-"-y 1C's.- ve"'" 1 ,,:. 0.80 NC
.- ...' . --' - / ..-
M~:-::.;:-)' ::~J Ii 8/64 0.20-:.0 NO
. HIC' .1 !C~SSClv~:::) 1/5:: 240 NO
. Hicir.el :::a:) 1::;64 99.0-406 NO
. Potass 11..'":1 !c".o've-' 35/64 B07-13,200 NO
''''- , -,
Po~ass 11..."11 ."'.1I~\ 47/54 B36-13,200 2.620
........- .,
. Se le~ 1~"!: (d~~so~vec) 3/64 1.2-1.6 NO
5Cdiu:TI 1c:ssclv~d) 61/63 l,750-42.5i:0 7.370
SOCIU::I tc:a 1) 59/53 2.040-0\0,80: 7,470
. Tnalllurn iC1SS01ve::' 1/64 2.1 NO
Vanadlu::I c,sso1vec) 6/64 3.1-132 NLI
. Vanac!!.:::! :cu11 45/64 3.2-219 20.8
Z1n: !dISS0iv~CI 9/5..\ 3,230-31.000 NC
. Z in: to:a 1) 12164 2.970-17,400 NO
(a1 The n~~~e:- c& sa~cles In which the con:~lnant was detected dlylded ~y the total numte~ of samoles
analy:e:::. Tc~al n~~er of sample: less than S2 ,nd,cate that some samples were rejected for QA/QC
renons.
(~: ; stat1stical test of significance was performed using dltl from both backgrcund wells.
C~lete background data and t-test results Ire presented In A~pendix C.
(c) If e::her total or dIssolved concentrat,ons exceeded background (see Appendix C) both total
anc dissolved chemIcals were .'ed.
. . Sele::ed 1$ c~eml:a1 of potential concern.
.. . Present within backgrounc concentrat10ns but aboye Hew York State drinking
.ater standa~s t~erefore retl1ned for evaluatIon (see Appendix C).
-------
-
TAS:":: 8
! i2~vE~. 5~VE~S R: ~~~:~T
c:,c:,~,~~::,s c; C~:~::~~5 1, R:S::~,~:A, G;C~':~~.~'
F"'e:~!"'::'
~cx '-'..-
:-e-:":.! ~
C'
:e:!:: ':"'\ (~:
~~~~~!:~~~~~~;~e:
~:;.:=;."::-!: ~:;
."
, . .
:~cK;"':~~: .e,.5
'-
~:~:~~..
--------
c...;~ "'.':!:
f -'"
\...,:,' .
c~;::.. ~.~~:f~:e
Co. '.:-:.1:--:-,
c-: .:-;'-e:-.c!-e
: , ~ ..: . :... . : ...: e: ~.G ,"', e
2,''''
2.' 2
2, :
C =-,' =
-, .
o. co:
1.:-:.9
C.:~-:.S~
,:
s:
~:
s:
...---...-------...--
!-;.;~-;:: (~;.":'
~: E: C
1=2
2~.:
2::.6::
4:.':::
25.:::
3. :E:
7. ~::
7\? :
N:
2,5::
7.:!7:
7,47:
N:J
HC
-----------------
g ~ ... ".- I,..."..... ~.. e ~ ,
~~~.~~ ~~:~~:; -,
~~:~:~~ !~~~~~;.e::
.. :........ ,.....:) ~
. -" ,..... ~ - ' .
~c!;.e:'~~ }:'s:::.ec:
;~~;~;~~~ )~~~~:~
r::.!:S',-'*:, ~:~~!: :'Ve:~
F:~a!s:~ ~:::a~;
S:c'~~ (c'ss:~.e:)
Scca;r."I (~::! ~ ~
., .,... ~...." c:...' e" \
~ ,.- ... '...... ,v -I
Z ~r,: ~::! 1 ~
2 :
2.' "
, ,
!~:- -.
2::-::5
- '"
~=.1::-:2.;:C
" ,
2,
2:2
2,' 2
2.'2
2:2
2/2
3:. ~::;-;:. 7::
:.~7:-~.E~:
4.2;:-~.2::
lC~-::~
2. :
...2
2.'~
1.370-; .:!;C
.3:0-1,4:::
;:.:CC-3:.e~~
ze.400-2e.6::
A_=
'1-
l.1ZQ-:.S':~
PAl< C ~ :
C-,!:'I\CS
{ . i 1: :
Bar\~~ (c~~::i.e:)
earH.m (::a:)
CJ;:,~m (:1s~~1.e:)
C.a:c::.:::! (::tai)
Mag~esl~ \d1SS01Ved)
Ma;ne51~ total)
Ma~9anese total! .
Potassium C1SSOlvec)
50C\~~ (olssc\.ec)
500 H:II (total)
1/2 4::.5 N:
2.'2 407 -42~ 1e2
2/Z 407-414 2.g
, -
2/2 25.9CC-Z6.ECC 29.5QO
Z/2 24.600-25.6:0 40.eOO
2/2 5.000-5.030 3.580
Z/2 4.860-5.030 7.720
1/2 2!:,4 7\? 1
212 674 NO
212 24.S00-2S.lCC 7.:!70
212 23.4CO-Z4.80C 7.4iO
----------.----
c~s-1.Z-~,:~1c~:e~~e~e
1nor;1n IOS (.;;1 ~: :
-----------------
SP!:t!H!:E:L
---------
1nor;anlcs (u;/i):
ArsenIc (dissolved)
ArsenIo (tctal)
BarIum (dissolved)
BarIum (toUl)
Calcl~ (olssolved)
CalclUl!l (toul)
.. Iren (toul)
M.gnesl~ \dISS01Ved)
M.gnesl~ tot.l
Mang.nese dlsso\ved)
M.ng.nese tot.l)
SodIum (dissolved)
Scdlum (toul)
2/2
212
2/2
. 2/2
2/2
2/2
2/2
2/2
2/2
2/2
2/2
1/2
2/2
4.0-4.9
3.5- 5.2
46.0-48.7
46.7-46.9
35.500-35.800
33.800-35.200
91.IH04
3.930-4.080
3.910-3.950
118-119
117-121
2.600
2.370-3.090
4.10
5.80
182
278
29.600
40.800
26.000
3.580
7.720
71.7
791
7.370
7.470
-----------------
(.) The number of l&mPles in .hlch the cont.mln.nt .as dete::ed dIvIded by the total number
of I~lel analyzed.
. . Selected .s chemlc.l of potentl.l concern.
.. . Present It .Ithln background concentratIons
drinking ..ter Jtandar~ therefore retaIned
NO . Not detected.
(see Appendix C) but at above New York State
-------
-
TAB;"E 9
S:LVEHT SAVERS R! RE~CRT
C:h::H7~A~:C~S OF C~E~!CALS IN ~~~ CREE~ SE~!~E~7 AH~ S~RFACE ~ATE~
Ch~i C3 ~
Fr~e~y
c.
Oe!e~!;c~ (a)
Rarse of c:~ce~tre!jcns
Oe:e~:~ Oc.~s:eam
of Si!e
U~:ream
Ccnce~:ra:icl".
Sf:) !~E"7
.. .. .. .. .. .. .. ..
Cr;a!""j cs (,,:'Sfi;):
------.......---..--
. ~-Chlcr:-3.~:hylphe~cl 1f4 1,7tC I/O
. 2'Chl:r:ot",~l 1" 1.5cu I/O
,-
. 1.2'Clch,erc~:e~ 1,- 5E.O 1i:J
. 1.I.'Oich~or~z~ 1fl. 7~2 I/:J
. teal 1.2'OiChlcroe:~~e 3" 1.0-7.5 NO
,.
. 2.I.'Oinitrotolu~ 1fl. e'" 1/:;)
'-
. I..I.'.~C: '/.:. 3.::.C liD
. Cis(2.E:~ylnexyl)phthelete 1" 1.1t: ~:J
i-
. Me:~ylene chlorice 1/' 11.: I/O
. ~-l/itrop'1e~l 1f3 1. 9CC I/O
. I/-Hitroso'ci'n'~r~pylemine 1f':' eiS 1i:J
. carci~~;c PA~S
Benzc(e)enthrec~ 1f4 2CO I/O
6~zo(c lno k)tlucrenthe~ 1f':' 3E7 I/O
B~zo(I)~r~ 1/' 2~0 NO
Chrysene 1f':' 2~ I/O
Total carcinogenic PA~S (0) 1/4 1,O~3 I/O
. noncarcinos~;c PA"S
Acenaphthene 1/':' 7~2 NO
F luor.nthene 1f':' 150 NO
2'"ethylnaphthlle~ 1fl. 86.0 I/:J
Naphthal~ . 1/4 no NO
Phenanthrene 1/':' 110 NO
Pyrene 1/1. 912 NO
Total noncarcinogenic PAHs (0) 1/1. 2,oeO NO
. Pentachloropnenol 1/:' 2,500 NO
. Phe~l 1/' 1,'60 I/O
. 1,2,"Trichlorobenzene 1/' 762 NO
. Trichloroethene 1/1. 1.0-'.0 NO
Inorglnics (mg/kg):
-.-...--....-.-...
Aluni"'-JTI 'II. 12,300-11.,1.00 13,!00
. Arsenic 'I" 2.5-11.5 NA
881";l.1li 'II. 51..1-89.8 62.8
Beryll iun "f" 0.90 0.7'9
Calc;un 'II. 1,380-2,5eO 2,100
Chrcmiu:l 'II. 18.8-20.9 21.0
Cobel t 'II. 10.6-12.6 12.0
tOP!)er 'I' 11.0-18.0 19.3
Iron 'II. 21.,500'35,600 36,100
Leed 'I' 9.5-11.7 11.5
...gnes i un 'I' 3,5'0-1.,980 5,170
M'!'I9arwse 1.11. 316-1,20 511
Nickel 1.11. 23.6-32.0 36.1
Pouss hn 'f" 7".1,040 992
V.nediun 101" 17.9-21.2 21.1
Zinc 1.1' 71..3-87.7 89.7
CA) The ~r ot 18mples in which the cont8minant was detected divided by the tot.l number of
18mples analyzed. Toul FUlCer ot 18mples less than 4 indicate th.t scme "1I~les were
rejected for QA/OC r..sons.
(b) Tot.l carcinogenic PAHs, tot.l nonc.rcinogenic PAHs, and total PCBs ~ound in e.ch sample
were detenftined for e.ch 18mple location- The r.nge of ~~~e toUls w.s then detenftined.
. . Selected as chenical ot potenti.l ccncem.
NA . Not .vailable.
-------
~
I .,
TAB:'~ 9 CI::::r.t!nuec)
IO~V£W7 SAwERS .: .fP~Ri
C:~:!HiRA7JCW OF C"E~:=AlS !w M~O
IE~IME-7 AW: S~RFAI:E WAi£~
:1\H(
CHE~::":'~
Fj:iE::JE~:. CF
OEiE:7:CW (8)
RANGE C:
C:~::!W7fl~7!C"S
OErEC7E:
CC'o>S~HA'"
OF SI':'£
I.:PS-QE.I."
C::~=Elii~A-:C~
S~R:":':: _A7:~
.............
Orglnl:s (u;!~):
...............
Iner;.n!:, (~;/~):
2/.. 0.6:-0.65 ~:
3/~ 1.7-4.' 1/:
21' D.'0'O.5~ I/O
'I' 0.'0-1B.5 I/O
1/1. 1.25 N::
3/4 8.2-23 liC
1'':' 3.5 ..:
'I' '.6-10.5 W~
!/' 1.'-'.6 NO
'I- 11-39.5 IiC
2/' 0.'.0.7 1i0
2/' 5.321: 15.3
"I. 18.C-60.' 18.7
'II. 30/COO-3' .1C:> 30,2CO
1/1. 9.0 ND
'11, 4.3 NO
'I' 238-'0.700 2~7
1/4 6.1 MC
4/1. 42.6-456 36.7
'1' 8.8 NO
4/1, 876- 1 ,'60 W
1/4 '.2 NO
2/2 J_6-43.3 NO
. Ber.: e"le
. '.1-:~c~loroet~e~e
. T.trlc~lero~~M~~e
. --:cr~:~~t-~~
~etnyl.~. C~L:riCI
A:eto~e
C~.cr:~or:T:
'/ ','-Tr!c~lcrClt~11'\1
Tc:t",~~
1,2-C~c~LOroetMer.e
XyL.",.
\
.................
. A l \1111 r.:r..
. hrl.r.\ .
CI L dllr.
. C~r=l~
. Coboa t t
. I r::1
. Leac
. "In.lnue
. NIckeL
lIoUIi I Ln-
. Ver.ec!iun
. Zinc
(8)
Thl number of 'Imple. in which ~he contaminant wa. dltlctld divided by the totll ~~r 01 .~~Ie'
InlLyzeC. iOCIL numCe~ of II~ll. l.l. tftln 4 Indiclee chit .ome II~~LI' w.r. rljeceed for QA/:C
rellon. .
tID
'.Llcted I' chemical of potentIal conclrn.
Not C.ucted.
-------
-
TABLE 10
SC~VE~T S~V~~S R: RE?:~7
C:~:~~~;.;'.7::~S C, C!-:E"i::;'~S IN I~7E::\!":T7E~7 SiREA." SE:::~E~: AS: S::Rn,:: 'oo'':'7E::\
C:-.e~':~ .
Oe:e~:ed
C:r':::e~:-a:'::~
U:s:~!!r.i
C:~::e~:~a::cr': (a)
S~::W:';-
-----...--
I;.c;;~!"!\:::s
(~.'\c.;~ :
------------------
C~.~::r..' -~
92.7 EE. 7
1.1 C.8:
1 . ~~: 1.S:C
2:.: 12.5
2:.3 1: .7
1~.3 15.6
:2.~::' 3:.C~:
30:.3 1:9
4.7EC 3. S:':
2.4::: 6-'
,-
~. . 2:.8
...., . oJ
52: 722
:::J 2:.9
1:: 55.:
Ea-'1~~
Ee-:' i 1\..":1
Co!~:: ~--,
. C::a1~
C:::e-
Ir:~
. Le.!c
Mac:1esil:.':
. Ma;cane~e
tI'c~e~
F::B! 11..~
Va~.a:'-'":',
z: ~.:
~'."';~:'C~ ..~.~::~
-----..-------
I~:-;a~1cs (u;/~):
-----------------
. A 1~'"I11nL..~
Ear' '-~
Ca 1:: ~:...~
. C~:-Or:l1l..":1
. I r:n
. Lead
Magnes 1,-":1
. Manganese
Po:as! 11..":1
. Vanac:L:TI
. Z:nc
2.550
34.4
12.3::
5.!!
4,750
3.3
2,050
2~6
. 909
5.4
19.3
75.3
18.7
30.2:0
N:J
227
ND
3.530
36.7
ss:
N~
3.1
(a) The u:s::-e~~ background concentration for surface water was taken upstream In
Mud C:-eeJl:..
. . Sele:::ec .5 chemica' of potenti.l concern.
-------
-
TAB:':: 1 ~
SClVEI/~ SAvns III REPCI!,
Si.:i't"A'~! CF C~E~l :)~5 OF P~TENi:AL e:l/e=~s
C."i~~C3t ~..;:-~ac~' ~~~ ~ S...t:swr~ace Sc il Se-=;me~: S...:;fac~. '.a:~;"' G'-:...~.c:e-
C~~).i::~:
- .. .. .. .. ......
A:etc:r,c X X X
6 ~~.: e~.e X X X
6en:::I: a;;o X X X
Bi:::rrD'T'le!!"\~:"",e X
2-Bwanc:re x X
see -61.:t'1! ~~:e~,e X
B~tyl~:'1tph:~ala:e x X
c;-n-Sl.:t'1\pnt~B\a:e X X
eJr~r. cisul':oe X
e ar=>on te:~ac:'\~::r;c:e X
e~ lorcoer.:e:-,e X X X
C~lorQe:hene X
Chlortr.let~ane X
C'I t cr:)Tcr::: X X X
'-~hl::ro-3-me:h'1lpne~c:l X
2-Chlorc:OI'IencI X
2 - eh l ere't:) l o;e~e X
'.C~lQrQt::lue~ X
, . , ' -ceo x
1.2-0ic:~l:)rQ~:~ X X X
'.3-0ic:hlcreoen:~ X X
. -':':~::r:oe~:~~ x x X
;;~~~:~~~f~~cr~:~!ne X
'. '-O;c~lc:reet~ane X X X X
'.2-0ichlcrcethare X X
'. '-Dicht:)rcethe~ X X X
C;s-'.Z-dichlcroethent x
trln5-'.41-D'c~lc:rceth~ X
Total '.41-Dichlcroetr.~ X X
2.'-Dichloropnenol x
41.'-Din;trotolu~ X
Ethylbenzrne X X
b;s(2-Eth'1lhe.yl)phthalate X X X X
HeJachlorobenz~e X
I scCl'lorone X X
IsopropylbenZe!"\e X
p-Isopropyltclue~ x
~e!hylene chlorice X X X X
'-Methyl-2-~tanone X
2-MethylFtlenol X
'-Methyl pI'Ie!'lO l X x
'-N;tropnenol X
N-Nitroso-d;.n-~ropylam;ne X
di-n-Octylpnthallte X
Carcinogenic PAHS X X X
Noncarcinogenic PAHs X X X X
ToUl PCBs X X X
Pentachlorophenol X X
Phenol X X X
n-Propylbenzene X
Styrene X
'.1.1.2-Tetrlchloroethene X
1.1~2.2.Tetrechloroethane X X
Tetrachloroetnene X X X X
Toluene X X X
1.2.'-Trichlorobenzene X X
1.1.'-Tr;chloroethene X X X X
1.1.2-Trichloroethene X X X
Tr;chloroethene X X X X X
Trichlorofluoromethlne X
1.3.5-Triaethylbenzene X
Vinyl Chloride X
-------
-
TAB,-E 11 (continued)
~LVENT SAVERS RI REPORT
S~~~~RT Of CHE~~:ALS OF POTENTIAL C:NC:~N
C~r'r,;a~
5~~'ac~ So:: i l
S.,;=s:..:dac~ Soi t
Se-: i ~!".:
S...~fac~ '.;a:e~
C;rc...rc..a:~-
H,:I
-------
-
TABLE 12
'SO~VEKT SAv~RS RI REPORT
SL-xYJ..RY OF y.m;~TORING ~ELL CONSTR~CTION
(PAGE 1 OF 2)
Well I.D.
Depth of Well
(F~. Below
Grade)
Depth
of Screened
Interval (Ft.
Belo',,: Grade)
Eleva~io;;
0:
Screene'=
Inten/al
(Ft. M5:')
3015
16
6-16
1191.7-1181.7
3013
42.6
32.6-42.6
1165.3-1155.3
3025
17
7-17
11133.1-1173.1
3021
40
30-40
1160.0-115C.G
3':35
15.7
5.7-15.7
1167.0-1:.57.0
3045
37
27-37
11:::~.S-115~.E
30~D
108
98-108
1093.5-1023.5
305D
110
100-110
1104.5-109~.5
306S
14.8
4.8-14.8
1163.9-1153.9
307S
17.1
7.1-17.1
1158.7-1140.7
307D
88.5
78.5-88.5
1087.2-1077.2
306S
15.6
5.6-15.6
1158.7-114£.7
308D
54
44-54
1120.3-1110.3
308B
128
118-128
1046.3-1036.3
3095
17
7-17
1157.1-1147.1
309D
119.5
109.5-119.5
1055.4-1045.4
310S
45
35-45
1169.1-1159.1
310I
72.7
62.7-72.7
1141. 4 -1131. 4
311
103
62-103
-------
-
TABLE 12
SOLVENT SAVERS RI REPORT
Sw~~-~Y OF MONITORING WELL CONSTRV~7ION
(PAGE :2 OF :2)
Elevatio~
Depth of
Depth of Well of Screened Screened
(F~. Below. Interval (Ft. Inten;al
Well I.D. Grade) Below Grade) (Ft. MSL)
101 42 37-42 1164.6-115S.S
102 11 6-11 1170.0-11E5.C
103 28 23-28 1162.5-115"7.5
10';A 67 62-67 1143.4-1135.4
104B 50 47-50 1156.3-1155.3
105 47 42-47 1157.3-1152.3
106 35 30-35 1159.2-115~.2
201 58 43-58 1160.5-1145.5
202 27 7-27 1172.3-1152.3
203A 73 53-73 1114.7-1094.7
203B 25 15-25 1152.6-1142.6
204 34 24-34 1162.2-1152.2
205A 73 61-73 1105.6-1093.6
2058 15 7-15 1159.3-1151.3
206A 74 59-74 1107.1-1092.1
-------
-
TABLE 13
S-C~V!Ni S"V!RS Rt REPOl<~
.SSU-P1'IOWS L~EO iO Esrl~~1'E EX~JRE FOQ DIRE:~ COWi":1'
.I1'M $JRF":E SOI~S BT CH:~DREN P~"TIN~ ow THE S:1'E
'-
Plr8llle t er
h:posur~
Ass~t i 01"1
Exposure Fr~Y (e)
Exposure Durltion (b)
120 c!a~/yur .
'0 yurs
Skin Surfec~ "r~e (d)
1 1 0 II;/~y
5,870 c:N./eay
Soi l In;~stion RIa (c)
Soil Contlct rlt~
, .1.5 lI;/crr2
8,510 lI!iI/dly
Soil to Skin Adh~rrnce rlctor (e)
Body ..ei;l'It (f)
Lifetime (;)
3e kii
70 yurs
.elltiv~ orll IbSo~tion friction for loil ~trix:
Arunic (h)
PCBs, PAHS, bis(2.Ethylhexyl)phthlllte Ci)
Other chem;cIls of concern (j)
0.8
0.5
1.0
Denm8l absorption frlctior.:
Clrcinogenic PAHS Ck)
~onclrcinogen;c PAHS (k)
PCBs Ck)
bis(2-Ethylhexyl)phthlllte Ck)
Other phthilites (I)
'enzoic Icid (m)
Other orglnics (I)
lnorglnics Cl)
0.02
0.05
0.07
0.03
0.05
C.~
0.1
C
CI) lased on five t;8S per _k OJr;n; ILllDtr (13 _ks) and three
times per _k D.lrln; Ipring and fill ""en the .In;-
temperlture is ,relter than 32 degrees F (18.3 _kl).
Cb) 'ased on aVt range 6-15.
Cc)" weighted avera,e llf'tl8 'ngestlon rates baled on EPA (19891).
Cd) 'aled on aurfact ar.. of the 11"', .,.. and less. Calculated
fr~ dati In EPA (1989b).
Ce) 'aled on EPA (1989a).
(1) Calculated fr. atA (1ge9b).
(g) "Ied on EPA (1ma) lunard "l&8Ptlon for. llfet'8.
(h) An orll 8bao~tlon factor of 0.8 II wed for .,..en;c blcl'-Wt
In oral c:anc:er JIOt~ factor II baaed on an abaortl8d do&e.
CI) 'aaed on data an 2,3,7,8-TCDO CPol"r end Schlatter 1910,
~lIrc et .l. 1989, I'cCarnLL et al. 19&10).
(J) Default valw.
ct) laNd an daU fr. '" et al. (19868,b), Wester at aL. (1987),
end pol"r and SchLatter (1980).
(\) AaU8ed val",.
-------
-
..
TABi.E 14
SOLVENT SAVERS I' IEPOIT
AS~PTIOWS USEe TC ESTIKATE RESIDENTIAL
GROUNC.ATER IN~ESTJ~ EXPOSURES
Pa~_ar
hPosu~e
ASS~t i cr.
Ingestion aate Ca)
2 L/dly
Eapcsure fr~ncy
E~s~rt Duratibn Cb)
365 cia~/year
30 yeus
lady Wti;~t (c)
Lifeti. Cd)
70 is
7'0 yurs
Ca) lased on EPA C19t9a) values for edult ingestion.
Cb) lased on EPA C1ge9a) values for ..aimum Ouration
for residents in the I~ place.
Cc) lased on EPA (1989a) standard aSlumption for edult
boc:y we i ;n t.
Cd) aased on EPA C'ge9a) Itandard aSlumption for a
-------
-
TABLE 15
SOLVfIl~ SAVU5 RI REPORT
ASS~PTI~5 USE: TC tST]KATE EXPOSURE FOR
OJRE~T CONTA~~ WITH SEOIMEIIT5 IT CHILORE~
c:.
P Ir v.'
-------
-
TABLE 16
. SOLVEIIT SAVEU al aEPORT
! AS~PTIOIIS USED TO ESTIMATE EXPOSURE
DIRECT COIITA" WI'H SURFACE WATER IT CHILDREN
Plr_ter
Exposure.
AS$~t ion
Exposure Fr~ncy (I)
Exposure Duration (b)
M days/year
10 Y.lrs
Arel of Skin Ea~ed Cc)
Per8elbility Constlnt (d)
6 . 180 c:rn2
8E - 0/. Cll/hour
loe; we i gh~ (f)
Lihtillle (g)
2.6 hours/day
3e kg
Exposure Length (e)
TO yelrs
(I) Bued 01"1 four ti_s per _it frCI/II MlY throu;h Sept~r.
Cb) 'ISed 01"1 age range 6-15.
(c) 'ISed on lurflce Irel of the anms, hindS, less, Ind f~t.
Cilculited from dati in (PI. ('98~).
Cd) Vilue for ~ater (111nk et II. '9~ IS cited in (PI. 19891).
ASlumes ch~icals in ~Iter Ire ablor~ It the 18me rite 85
water itself.
Ce) Bised 01"1 EPA C'ge91).
Cf) Calcullted from EPA C'ge~).
Cg) 'ISed 01"1 EPA ('989.) Itana.rd 811unptiOl"l for lifetiMe.
-------
-
..
TA3:'=: 1 i
SO~VEIIT SAVERS R! REPORT.
ASS~~7jC~~ USE~ T: ESTI"ATE EXPC~URE FOR
OIRE:7 C~TA:T .:Tw S:I~S iT RES:OE~7S
P.rame~e~
EJtpos;.;-e
Ass~t i en
E~posure Fr~uen:y (a)
9.:. days/Yl!a~
E~pcsure Duration (C)
Sei I l"gest ion Rate (c) .
3C yurs
120 ms;/d'!y
Skin Surtace Area (d)
1,.790 crr2/dey
1.'5 lI'G/c.':'.2
Soil to Skin A~erence Facter (c)
Soil cor.:a:: rate
6,950 ms;/day
BOG'y Wl!iS~~ (c)
Lifetime (e)
1,8 k;
7C yu~s
Rela:ive o~a! absorption tractien tor soil ~tri~:
peas, P~~s, bls(2'Ethylhuyl)pl'lf,halau (1)
Other chemicals of concern (S)
Oermel absorption traction:
Car:;noge~jc PAHS (h)
Hon:a~cinoge~ic PAws (1'1)
PCBs (h)
bisC~ Ethylhe~yl)pMthalate (h)
O~l'Ie' ~thatltes (i)
Benzoic acic (j)
Pheno l (j)
Phenolic comcouncs (k)
Other organics (i)
lnorganics (;)
0.5
1.0
C.02
0.05
0.07
0.03
0.05
0.36
0.03
0.03
O. ,
o
(I) Bls.c on thret times per week when the minimum t~rlture is
greater thIn 32 degrets F (e.;., 2'9 days. 3/7).
(b) Blsed on EPA (1ge9a) vIlues for ..xlmun duration for residents
in the same pllce.
(c) a'ied on EPA (1ge91).
(d) alsed on lurflce area of the hInds. Ir=s, Ind Legs for chiLdren
(' to 1e yelrs) and surflce area of the hInds, forelrms, Ind
Lower Le;s for edults. CalcuL8ted from dati in EPA (1ge9b).
(e) aased on EPA (19891) Itlnd8rd 8ss~tion for a Lifetime.
(f) alsed on datIon 2,3,7,e-TCOD (Poiger and SchLatter 19ao,
Wendl in; et al. 1989, Mc:ComeLL It 8L. 19&/.).
(8) Deflult vIL~.
(h) alsed on datI fr~ Tan; et II. (1986a,b), Wester It 8L. (1ge7),
8nd Poiger .nd SchL.tter (1980~.
(I) Alsuned vllue.
() ',sed on flldn8n .nd "Iibach (1970).
-------
-
TABLE 18
SOlVEW1 SAVERS R: REPORT
ASS~F110~S USEO TO ESTIMATE EXPOSURE
FOR OW-SITE IWHA~ATI~ 8T RESIOEw1S
P.r.metr~
h.posure
Ass~t i or.
Inhalation Rate Ca)
30 II'J/cily
365 days/yeer
Exposure Frequency
Exposure Cur.tion Cb)
30 yurs
Li1etime Cd)
70 kg
'70 yurs
Body ~e i gl1: (c)
(a) Suggest~ ~r bound value CEPA 1989.).
(b) Bas~ on EPA C1989a) v.lues 10r maximum
duration for residents in the s.me pl.ce.
(c) 8aseC on EPA C1ge9a) standard .ssumption 10r
.dul t boOy wi;l1t.
Cd) B.see on EPA C1989a) standard assumption'
-------
-
" TABLE: 19
SOLVENT SAVUS I I REPOI!T
HE A~ ~ H E;FE:~S 'CRITERIA FOR ORA~ EXPOSURE TO CHE".:U.lS OF P::JT::"~ I A~ COIi::E."
ItT~~~nc~ Dose Slo~ ' IoIt; S':
(Rf~) Saf~!y faete~ c'
cnrmiee: (1nI;/kS-Cay) fee!c~ (e) Soure~ (0) (rng/kg-cay) - 1 SOU":t (:: Ev;ct-:t (::
Orgln;e:
'"
Aerton~ 0.1 1,000 IllS eo )
8~n%~n~ .. . 0.029 IRIS A
ten%o; e Ie id &. 1 IRIS
B r om&::rnI! t 1'1 I ne O.O:::'~ 1,000 IRIS
2-8uunone 0.05 1,000 IllS
lee -Butyl bef'lzene
8utyl~%ylphtl'\etett C.2 1,000 IRIS IR:S C
d;-n-Butylphthelet~ 0.1 1,000 IRIS
Clrbon disulfio~ 0.1 100 IRIS
Clrbon tetrlchlorid~ D.D007 1,000 IRIS 0.13 IllS 82
Chlor~%- 0.02. 1,000 IRI S,
Ch l oroetl'\lne
CII I orOIl'lethlne 0.013 HEA Cd) C
Chloroform 0.01 1,000 IRIS 0.0061 IRiS 52
'-Cl'\loro'3-~tnyl~,~~ol
2'CnloroP"encl 0.OC5 ', 000 IRIS
2 - : -, , : -:';': .J~".t
'-Cn\orot;......,-~
0.00:5 100 II:S 0.3' II:S 62
1,~.:.:~~:rOben%r~ 0.09 1,000 IRIS
',3'C'cnlorCbc~%~~t
1,"Oien:or:benl~ne 0.02&. HEA 62
Dichloroc,flucrcmethlne 0.2 1CO IR:S
1, "Oichloroeth8ne 0." ,000 HfA 0.091 HfA 62
1,2'Dichloroethen~ 0.09' IR I S 62
','-Oichloroetn~ne D.009 , ,000 IRIS 0_6 IR:S c
,2'DichLoroetn~ne (tout):
cis'
trlns- D.02 1,000 IRIS
2,'-Dichlorophenol 0.003 100 IRIS
Z,"Din;trotoluene 0.65 MEA 62
Ethylbenzene 0.1 ' ,000 IRIS
bil(2'Ethylheayl)phthllete D.02 ',000 IRIS 0.0" IR IS 62
Healchlorobenlene D.0008 1DO IRIS 1.7 MEA 62
II~orone 0.2 1,000 IRIS O.OGlo1 . MEA C
I lopropyI bef'lzef'le
p-Ilopropyltol~e
Methylene chloride 0.06 100 III IS 0.0075 IRIS 62
"Methyl-Z-pentlnone 0.05 1,000 11115
2-Methylp\enol 0.05 1,000 IRIS
"Methyl P'leno I 0.05 1,000 1111 5
,..It ropheno I
...itrolo'di'n'propylem;ne 7 IRIS 62
dl-n-Octylp\thilite
tlrctnogenic '''"I (e) 11_5 . MEA (1) 12
CII lenzo[l)pyrene)
Monclrclnogenic '''", Ct) 0.' . 100 ilEA
CII .,phthllene)
PClI (totel) 0.0001 100 CII) 7.7 IRIS 12
hnt8dl1 oraptleno l 0.03 100 IllS .- .
"'eno I 0.6 100 11115
n-,ropylbenlene O.Z
Ityrww 1,000 IllS
1,1,1,2-1.trlChloroethene. 0.003 3,000 IllS 0.026 111$ C
1,1.2,2-1.trlchloroethene 0.2 111$ C
,.trechloroethene 0.01 1,000 1115 0.051 . MEA 12
Toluene 0.3 100 IUS
1,2,4-TrichtorobenZene 0.02 1,000 IlEA
1.','-Trtchloroethane 0.09 1,000 1115
1,1,Z"rfchloroethane O. OGlo 1,000 111$ 0.057 1115 C
1 rtctlloroethene 0.011 lEA 12
Trlchlorofluoronethlne 0.3 1,000 IllS
1,2,"1rlmethylben1ene
1,3,S-1ri8ethylbenzene
Vinyl chloride 2.3 ilEA "
-------
1'"::;'.. . ~
TAEi..E 19 (Cont inued)
SCl'wt;,; SAlJt;;S RI RE?:'?~
t"E:~s!:r:!E~:~ FO? ORA~ EX?CSURE TO C"EMICA~S C' P:~E~7:A~ CO;,:!;;;,
C~e"":':a,
~e.e-e"':e- ::.~~
( - .' .
'" ..../
(~,,;:(;'.:ay)
Sa:e:y
Fa;:c- (a)
Source (!::)
S.=~
. Fac:c-
(~/1t5'day' .
S,j<.;rce (!::)
I.e';-'
c'
E'. ; c:e-.c e (::
: -...:~;z-:::
A . .r' '-'...r
A!"',~ ~rn..:,.,
A'se"'c (~~
Ear ieT'
Ee - y: : : \J"'.
Caa-'~
..ea::
Ma5~e> 'J
...an;a,...'!::t
Merc~rv i e):
I".c'sa-': &
a : r y ~
C.:::... 1, OC: IRIS
C,OO~ . 1 HEA
C.:~ 10: IF.: S
C,::~ 1e: 1.:S
O.::~ (;) 10 HEA
C.C::~ (..a:e-)
1, cec I R.: S
C.0:5 .500 II<:S
C.C: SOD HE A
C.~ ,'- HEA
'"
C.:::;: 1C IR:S
C.C::~ ~C IR: S
r ,...-~ ~ , C:C HE A
c. C2 3':: IR:S
0.0:3 . 15 HEA
0.0':3 2 IRIS
c.oe:::' 3,C:: HEA
C.::7 10: HEA
0.2 1C HEA
'"
2 (;) A
IR:S 62
-. (It)
:a~:::u--
C~ron-'\J"'. (e):
C...~~:~ (:!:)
C-.ror.::u- ,,::
Cc:..a. :
Ccooe.'
-. (k)
..
CV2:'::e
j"'c"
1 R: S
62
""." . ~ .
.:";c-.:~
. - .. - .. .
.. - - - .
;, . : (e .
F:':ass~..r.
Se l er. I I,T..
S 11 ve~
Soc;~
'I:Ial tilT.
lIana"; IT.
Z'nc
= Penc:"'S/I.:~.c:e- ,,,vie,,,.
.. = Crlter:cn nas nct teen deve:cped ~or t~is c~~ical.
la) Safety factors are the prodl.:cts cf uncertainty factors and modifying factors. Uncertainty factors us~ to
cevelc~ re-erence ~cses grneralty consist of muttiples of 10. with each fe::or representing a specific area
o. uncerta:~ty in tne data available. Thr standard uncertainty factors i~-.ude the followin;:
II 10-fc~d factor to account for the variation in sensitivity 8/IIOng the menCers of the human population;
a 10.fold factor to account for the uncertainty in extrapolating animal data to the case of humans;
a 'O'fold factor to account for uncertainty in extrapolating from less-than-chronic NOAELs to chronic
NOAE~s; anc
. a 10.folc te::or to account for the uncertainty in extrapolating from LOAELs to NOAELs.
Modifying factors are applied It the discretIon of the reviewer to cover other uncertainties in the data.
(b) IRIS = the chemical files of EPA'S Integrated Risk Infonnltion System (8S of 12/01/89); and HEA s Healtn
Ef'ects Assessment Summary Tables (0'/01/89).
(c) EPA weignt of evidence classification scheme for carcinogens: A-.Human Carcinogen. sufficient evidence from
hum.n epicemiological studies; B'.-Probeble Human Carcinogen. limited evidence from epidemiological studies and
adequate evidence from animal studies; 82--Probable Human Carcinogen. inadequate evidence from epidemiological
studies anc ad~ate evidence from .nimal studes; Co-Possible Human c.rcinogen. limited evidence in animals in
the acsence of h~n Qata; D--Not Classified as to human carcinogenicity; and E--Evidence of Noncarcinogenicitf.
Cd) aasee: on route-to-route extrapol.tion.
(e) For these chemical mixtures, toxicity data for one of the mest toxic compounds ;n the mixture ;s used to
represent the entire mixture. e.g.. benzoCa)pyrene for carcinogenic PAHs. naphth.lene for noncarcinogenic PAHS,
trans-1.2-diChloroethene for 1,Z-dichloroethene (total), and chromium VI for total chromium. For mercury, all
three forms for which toxicity criteria are available have the same reference dose.
(f) He.lth Effects Assessment for Benzo(.)pyr.ne, Environment.l Criteria and Assessment Office. Cincinnati, Ohio.
EPA 5'0/1-!6-0'6.
(g) Calculated by Clement Associates based on data ;n Barsotti, A., and Van Miller, J. P. 1984. Accumul~tion of
commercial polychlorinated biphenyl mixture (Aroclor 1016) ;n adult rheSus monkeys and their nursing Infants.
Pathology. 30(1984) 31.". Received conditional site-specific approval from EPA Environmental Criteria and
ASSessment Office or Dr. Choudhury January 1989.
(h) The chronic daily intake for arsenic is based on an absorbed dose, because the toxicity criteria are based o~
absorbed doses. EightyX absorption from ingested soil was assumed based on EPA (1984).
Ci) EPA. 1988. Special Report on Ingested lnorg.nic Arsenic. Skin Cancer; Nutritional Essentiality. Risk
Assessment Forum. U.S. Environmental Protection Agency. ~ashington. D.C.
Cj) In accordance with EPA guidance, the listed caamium RfD is used for exposures to food and other nonaqueous
lIIudals (Le., lOll).
-------
-
TABLE 20
SOL VENT SAVERS III REPOR~
HEA~~~ E~FE=iS,C~ITERIA fOR IIiHA~ATIOIi EXPOSURE TO CHE"i:'::ALS OF POiEli~IA.. COIi:E.~
Refe"ence Dose SloDe wei!;"".:
- (RtO) Saf~~y F,,:::r c'
c~~i:a! (ms/Is'day) Fac:o~ C a) Source (~) (rn:;/ks-day)" Scu":e (~) E":~,",,e- C:)
Or;anlc:
'" Acetone
Benzene 0.029 IRIS A
Benzoi: ecic
B rcrnr:methene 0.008 1,000 HEA
2-Buunone 0.0'1 1,OCe HEA
s~-8utylben~ene
Butylbenzylphthalate I R: 5 C
di ..n'Butylph that ate ..
Carbon disulfide
Cerbon tetrechloride 0.13. IRIS 62
Chloroeel'\zene 0.005 1,000 HEA
Ch I oroe thine
Chloromethlne
Ch I oroform 0.081 IR:5 6Z
'-Chloro'3-methyl~e~l
2'Chlc~opl1enoi
2'Chlorotoluene
"Chlorotoluene
DtT 0.>:' IRIS 62
1,2'Dichlorobcnze~e O.O/' 1,000 HEA
~.~;c~lorQbe~:e~e
- ~.. -:oe"".: e'''"\f: C.2 . (C) 100 HEA HEA 62
Olcn.~~oc1TLucrome:~ane O. ~~ 10,000 HEA
" '-Oichloroethane O. , 1,000 MEA
1,2-Dichlororthene 0.091 IRIS 62
1,1-0ichloroethene 1.2 IRIS C
1,Z-Oichloroethene (toul):
cis-
trens-
2,'-Oichlorophenol
2,.-oinltrotoluene HEA 62
cthylbenane
bis(2-Ethylhexyl ).p/'Ithalau 11115 82
"e.achlorobenz~e
Ilop'Iorone HEA C
I lopropy I benzene
p-Ilopropyl toluene
~.thyl.ne chloriee 0.86 Cd) 100 MEA 0.01' 11115 82
'-Rethyl-2-pentanone 0_02 1,000 IRIS
2-"ethylphenol
,-".tll~enol
'-lIltr enol
N-liitrOio-di-n-propyl.mine
dl-n-Octylphthelete
Carcinogenic PA"s (e) 6.1 . MEA C f) 82
(81 lenzotl)pyrene)
lIancarcinogenic PAHS
(II lIapMhal ere)
PClI
,...tadll or.eno I -- .
PtI~1
,,-propyl bIN-
1tY"eN 0_026
',1,1,2-1etrachloroethane IllS C
',',2,2-1etrachloroethane 0_2 IllS C
1etrachloroethene 0_0Q33 . IlEA 12
1olUII'W 0_57 (d) 100 IlEA
',2,4-1richlorobenzene 0.003 1,000 lEA MEA 82
',1,1-1richloroethene 0.3 ',000 lEA
',1,2-1~lchloroethane 0.057 1115 C
1ridl'oroethene 0. 00t06 ilEA (II) 82
1rtchlorof,uoramethane 0.2 10,000 lEA
'.2,'-1ri8ethylbenzene
1,3,5-1rieethylbenZene 0_295 (h)
VInyl chlodo. IRIS A
-------
-
TABLE 20 (CanTiNJe
-------
-
/
TABl.E 21
SOLV£~~ SAVEKS Rl REPOR~
CHR~~!C OAI~! 1~7A(£S A~: R:StS A~$:~!A~E:'~:~H
CO~:ACi ~!i" SURFACE selL: B! CH!LOR:~
OIRE:.
£571~A~:j CH.:~:: OA!~T l~iA(E (:::)
(Ing/Ig-cay)
CHE~!:'~ \':-H
P:7E"'~: :...
CAI<: Hi~=': ~i! :
EFF£:~S
I~C!~£N!A~
Ui::>ESi :c~
. ................ ... .... ............ .....
OE~"""~
AB~:RC~ :0..
S,-:"E
FA:TO.
'.1-0ic~loro~thll~~
'.2-0iChlcroetha~~
'. '-Oichloroeth~n~
bis(2'EthylhUyl )pI'It!'\.lll:t
Neaachlorobenlene
Methylene chloride
C.rcinose~ic PAHS
Tcut PCBs
.Tet r.ch loroethene
1.1,2-Trlchloroeth.ne
T r; c~. i oroethene
5.'-':':-1C
'-.89:-10
6.53£-10
'- .08: - 1C
6.56£-0,
'.e9£.Oe
2.'-3E'09
7.33£-C8
'.38£-C':'
'.23E-C8
'.7..E-0£
1.51£-06
1.27:-06
Aruni c
Totll! Eacess C.ncer Risk
'.21E-09
3 .7'9£ - Q<;
5.05£-09
3.16£-09
3 .0000E -06
3.7'9:'07
1.!.!!: - 08
2.22£-07
'.7'-E-03
3_27E'Oi
3.67E-C7
1 . 17E - 05
w:
6.~OE-C3
9. 1CE -0::
9.10E-02
6_ooE'01
1.'0£ -02
1. 70£.0:: .
7.50£'03
'.15E.O~
7.70E.O:J
5 "10E -02
5.70E-02
'.'OE-02
2.00E.00
2.9£ - i i
3.9: -,:
5..2£ - iO
2. 1£ - 09
5.2E-C:
7.3£-::-
1.6£-1:;-
3 .'-E' Dt
3.9£-:2
1.9:-:£
2.'-E-C8
1.5£-07
2.5£-06
'E-O::
ESTIKATE~ CHRC~IC OAILY INTA(£ <~:)
(m;/kg-dly)
CHEMi:AL WITH ---.....................-............ REFEREN:E
11010:1.1: IIIOGEIi! C INCIOE~TAL DEIIV.~ DOSE (RtC)
EFFE:rs IlIc;ES~!C~ ABSORPTION (IIIII/kg.dly) O! :R':
Acetone , .9h-Ce. 1.l.!e. 07 1. OOE . 0' 1. 1! - ~6
hr.zo;c .eie:! 6.19£-07 1. 72e. 05 ,.ooe.oo '.SE-C6
2 - B u tI "'0'1" 1.2'-E .08 9.51£.08 5.00E'02 2.2:-00
iutylbenlylpnth.llte 3.27E.07 ' .21£ -06 2.00E-01 e.o£.oo
d;.n.Butylpnth.L.te 3.03E-Gi 1.11£-06 1.00E.01 1.5E'05
th l orobef'l%ene 2.&6E'09 2.21£.05 2.00e.02 1.2E-06
Chlorofo,.", 3.81E-09 2.95e-08 1.00E-02 3.3E-06
1,1-0ichloroethane 3.'3E'09 2.65E.08 1.00E.0' 3.0E'07
','-Dichloroethene 2.!6E-09 2.21£.08 9.00E-03 2.8E .06
bil<2-EthyLhexyl)phthlllte ".59£,06 2.13E,05 2.00E-02 1.3E-03
NeXlchlorocenzene 3.'3e-07 2.65E-06 8.00E.o.t. 3.1£-03
Methylene chloride ,. 70E-08 1.32E-07 6.00E-02 2.5E.06
lIIonc:ercinogenic PAHs . '.'XIE-07 3.7'9E-06 4.00E-01 1.1£.05
Toul peis 3.06E'03 3.32E-02 1.00E-()l. 3.6E.:Z
Tetrlchloroethene 2.96E'07 2.29E-06 1.ooE-02 2.6E-0.:.
Toluene 6.99£-08 5.41£-07 3.ooE-0' 2.0E.06
1,1,'-Trichloroethane 1.21£-06 9.7'9£-06 9.ooE-02 ,.2E.e.:.
1,',2-Trichloroethane 3.32£-07 2.57'E-06 4.DDE.Q3 7 .3E. ()l.
Arlenlc 8.91£.06 lie '.0DE-03 8.9£-03
e8Cill; l.1li 4.'1£-06 lie 1.00£-03 4.5E-03
ChrC8illl '.2IE.()l. IIC 5.00£-03 2.6E.02
Cyan I ex 2.95E.06 lilt 2.00E-02 1.5E-()l.
MrQ8I"Iese 8. '9£-()l. IIC 2.DOE-0' 4.1£.03
Mercury 6.09E-06 lie 3.ooE -o.t. 2.0E-02
Ilckel 4.35E.05 IIC 2.DOE-02 2.2£ -03
Zinc 2.24E.()l. IIC 2.ooE.0' 1.1£-03
~otll MIZlrd Index 4£.02
-------
-
TABLE 22
SOLvtNT SAVERS Rl REPO~T
CHRO~:~ DAILY INTAeES AND RIses ASS:~:AT~O ~11H
.. II/(;ES11010 Of CROJNOIIATER IN REsIOENTIA.. WEL,-S
C.".E"'::~.. .::1"1
PCTE"- :A~
C~~.:: ",:'CE"::
EFF::1S
EsTIM~TEO ~HR:~::
DAILY I~TAe: (:01)
US:~G TriE ~XI~JM (a)
(msllqi'day)
SlO-:
FACiCP.
(ms/l.s/cay).1
EX:ESS UP-Ei\
8OJ~: LIfEr:!':
::AN:ER RIse
LIN~StY:
~r" ere f er~
~!'\ler~~!'\I1"~
1. 1'Oie!'\lcreet~an~
6.'''E.06
2.33:.C5
1. 19:-05
6.10E.03
1.30:,02
9.10E'02
'.OE'O~
3.0E.07
1 . 1£ - 06
Te:at Excess Cancer Risk
-u.co
PARe:.. :
Tetrachloroethene
1.1.2'Trichloreethane
T I' i ch l croe~hene
2.36E.05
3. 9'-E - e5 -
I. .62: -0':'
.5.10E-C2
5.70E-02
1.10E-02
1.2E-06
2.2E-06
5.U-CO
Tc:a. Excess Ca~c~r RisK
eE-06
CHEW: :A~ \I::".
W=,,:H: I Ii::n I:
E;<::1S
ESTI~TEO CH~ONIC
DAllY II/un (CD!)
USING THe KAXI~ (I)
(ms/ks-dey)
REFERE":E
DOSE (1110)
(~/k;-dIY)
CD I :R~~
UN:::::
Caroon disulfide
C~. ~ erefer::-
1.1-Dic!'\leroethane
2 i,...;
5. "E-es
1. 51£ - os
2.m-OS
5.51.E-02
1. OOE - 0'
1. OOE -02
1.00E-0'
2.00E-0'
5.U-04
1. 5E - 03
2.U-04
2.eE-0'
Tc:al Hazar: lnoex
3E - 0'
PARON:
hriun
1.2'0ichlorobenzene
TetrlchLoroethene
,.'.'-Trichloroethlne
1.1,2-Trichloroethlne
Xyle!'1eS (total)
1 _20E-02
1.6eE-04
5.12E-05
2.53E-0l.
8.51.E-05
7.97E-05
5.00E-02
9.00E-02
, .00E-02
9.ooE-02
4.00E-03
2.00£.00
2£-0'
2£-03
5£-03
3£-03
2£-02
4£-05
Totll Hazard Index
3£-01
(a) The ~r 95th confidenCe lI..it cOYld not be c.lculated .;~e only t- NlllPles _re
-------
-
TABLE 23
SOLVEWT SAVERS RI RE~~
CKR~~:: OA:~~ !W.AKES AN: RISKS ASS~!A~E: ~:~~
CIRE:T CO~~A:: .:TH SEOI~E~TS 8! C":~:~E~
CHE"::A. Ii::"
PC~:..'" ;~...
CAR:INC::EN:C
EFF::::
ES~IMAiE::> CH~:J~:C OA:~T l"aJ:E (::1).
(ms/It;'eay)
...... --.-.---- -- ..----...-.-...-...-......---..
IWC!CEWTA~
)WCiEST J::~
CcR"-A:'
A8SCRPi:C~
5~C=-::
FA:TOR
(ms/its'day)' ~
EX::SS L'o:o'
BOJ,,: :.! F: i : ..::
CAW:E~ R:S(
".:: CREE ( :
CC: (tcal)
,.I.'Cichlorcbenzene
2.I.'Oini~rotol~
c:s(2'Ethylhexyl)~th8Ia:e
~ethylene chloriee
~.witrc$~'di'n'~-opyl~ine
C.rcinQgenic PA~s
Trichloroethe~
Arser.i c
To:.\ Excess C8~er Risk
3.16E'09
6.I.1E'0~
7.21.E-C~
5.08E-0~
1.'9[-08
8.l.1::-08
5.:33::,08
3. 99E - '0
8.85E-07
5.t5E'Q9
5.73::'C7
6.I.7'E-C7
2.73::,07
'.OcE.e7
7.52E.C7
, .91:-07
3.56E-09
we
3.1.0:-01
2.'0:: 'C2
6.80E-01
1. I. 0:: "02
7.50E-03
. 7.00:-0C
'.'5E-01
1. 10E-02
2.00E-00
3.0E'09
,. ~:...::
I..cre-c-
'.5£-:;
8.8::.1:
5.9:-::
2.8: -:t
I..l.:< "
1. SE - ~t
H'C~
C~E~!:A~ 1IJ1~
IIO":",:JIi::..EIi:C
EF FECTS
ESTIKATEO CKROI/IC CAlLY INTAtE (COI)
(/I'G/k;-aay)
--------------...-.-.-----.---...----
INCIOEWTA:.
INCESi lOt.
DE R "-A:'
ABSORPT 1011
RE~EREN:E
DOSE (R ~ [) )
(rnr;/ks-a..y)
C:::R~:
KJO CREEK:
2'Chloroc/'er-ool
OCT (t:t8~)
',2-DiChlorobenzene
',2'OiChloroethene
bis(2-E~hylheJyl)cn~n818te
Methylene chlor;Qe
jjonc.rcinQ9e!"1;C PAt1s
Pent.chlorophenol
Phenol
1,2.I.-Tricnlorobrnzene
Arse!"Ii c
Tot.l H.zard Index
STREN!:
~e
9.1.2£-07
2.21E-0~
'.05E":;
5.23E-09
3.S6C-07
8.31E'0!
6.39E -07
1.6oI.E - 06
8.W -07
'.m-07
6.20E-06
2. 53E - 06-
3.95E'08
3.62e-07
'.68E-08
1.9U-06
7./'2E-07
S.1U-06
'.'OE-06
2.:W-06
'.2it-06
IIC
5 _OOE -03
5 .00E'c<'
9.00E-02
2.00E-02
2.DOE-02
6.00£-02
I,.OOE-O'
3.00E-02
6.00E-01
2_00E-02
, .DOE-03
2.00E-01
6.9E-0':'
. L2:-~
I..5E-~
2.6E.~t
1. 1E - C.
1.l.E-C:
1.tE'C:
2.0E .0;,
5.I.E'Cc
2.I.E .c.;.
6.2£-03
8E.03
IIC . lIot calculated.
9£-03
1. 7l,E -03
-------
-
TABLE 24
SOLVE~T SAVERS RI REPORT
CHR~:C DAILY II/TAtES Awe RIStS ASSOCIATED WITH DIRECT C~~AC~ WITH
SURFA~E WATER AW~ SUBSEQUE~T DERKAL ABSOR?TIO~'1~ CH!LDRE~
CHE~::AL wiT"
POTEIiTiA~
CARCII/:- ,IiIC
fFfEC:
EST IKATE:
CHRo!;: C OA! L Y
II/THE (C:lI)
('"!i/ks'day)
SLOPE
FACTO" .
(mg/I:g/da"y)"
EXCUS UPPE.
80.'" L IFn I~E
~. :ER R:St
KX CREn: -
Benzene
'. '-Dle~loroet~ane
Tetra:~lcroet~~
Triehloroetrlene
8.9'H-Q9
5.e.BE.De
6.39E'09
2.'3E.07
2.90E'02
9.10E.02
5.10E'02
1.10E'OZ
2.6E"0
5.'E.09
3.3E'10
2.1£-09
Totel E-eess Cancer Risk
9£-0'9
EST I ItA TED
CHE~ I CJ.L W! ~ H CHRCh:C DAILY REFEREI/CE
8ICJIj:AR: II/OGEI/ I C I~TAtE (CD I ) OOSE (Rf:)
EFFECTS (rng/kg-dey) (mg/kg'Ch) CDI :R!O
ML[) C; - '. ( :
1.1 :~loroet~.ne 3.'Oe'07 1.00E-01 3.'E-06
Tet. _~loroethene '.,re .08 1.00E':: '.5E-06
hrii.rn '.81E'06 5.00E-C2 9.6E.05
C~romi~ 7.0re-C:7 5 .OOE -03 1. 'E - c.:.
"'anganese 3.1,9E.05 2.00E'0' 1.7E-0l0
..ieke' 7.16E-07 2.00E-C2 3.6E-05
Van8C ,rl 6."E-07 7.00E-03 9.2E-05
Zinc 3.39£-06 2.00E-0' 1 .7E - 05
Toul Huard Inde- 6£-0l0
.II/TER~ITTEI/T STRE»I:
C~romi\.ITI 5.19E-07 5.00E-03 1.0E-0l0
"'anganese 1.93£.05 2.00E'01 9. n-D5
Van8Ciur. '.83E-07 7.00E-03 6.9£-05
Zinc 1. 73E'06 2.00E'0' 8.6E-06
-------
-
TAB:.E 25
SOLVENT SAVERS RJ REPORT
CHRO~:C CAll' IWTA(ES A~~ RJS(S ASSOCIA~EC ~:~k
o..'SITE INHAlA~Ic;.; BY CHIlCREN
CHEI\!U,:, ""!TH
POH~'IA.
U,R:lI/OCE~:C
EFFECTS
ESTIIU.TEC
CHRc;.; I C OA! l Y
11i1 A(E (C~:)
(IIIS/iq;-day)
SLoP: "
FA:iOt(
("'iiI/kg/cay)-'
EXCESS UPPER
BOJIiD 1I FET I":
CAI/CER RISK
Trichloroeth~~
1etracnloroetne~
P~6s (TcUl)
2. "E-().:.
3. nE'CS
1."!E - 09
1 . 70E - 02
3.30E'(;3
(8)
3_59:-06
1.03E.07
............
Toul:
'E-06
CHElo!lCAl IJITH
1j000CAR C II/OCE Ii I C
EFFECTS
EST IIU.TE~
CHROWIC DAilY
II/lAKE (Ct: I )
(rnr:;/k;'d.8y)
RE FEI~EI/C:E
DOSE (RfC)
(llg/k;/d.8y)
~1:R1D
1,'. '-Tr;chloroethane
Toluene
9.2"E .c.:-
1. 1'9E . ().:.
3.00E'0'
2.00E.00
3.~E'03
8.96E-05
...........-
To:a", :
c, (3E-03)
(a) ~c tOJ;c;ty value is available for the innalation of PCBs (personal communication
-------
-
..
TABLE 26
SOLVENT SAvERS II REPORT
CAll' INTA(ES ANt RIS(S ASSOCIATED WITH CIRE:~
COh7ACT ~ITH SURFACE SOILS IY RESICENTS
CHROW j:
ES7!~A7E~ CHROWIC CAlLY INTAKE CC:I)
(1II!i/i;-C)8.t>
C:HE":CA~ lo':iM
PCiEN7 jA~
CUCiI.:x:.E~::
EFFE:1S
INCICENTAl
IN~ESTION
.....-._...._...-..-....~._...~---_.-
DEO.AAL
AISORPi 101i
SL O~ :
FACiOP.
Cmg/ig-de'l)-'
EX::SS UHf.
10,)1.: U FE~ I,.E
CAIiCER RIS(
e:h l O"oj: ",,",
'.'-Cic~.:-~~~e~t
, .2: C \ c~, l oroe~!'\ene
, . roC i ch t o-oe~l'\e~
bis(2-E:!'\ylhe.y! )p/",thelete
He,ac~\or~.zene
Metl'\' lene Chlo"iCt
Cercin0ge~ic PA~s
Toul PCSs
ie:"achlo-oe:he~
'.'.2-iric~!croet~ene
iric~loroe:he~
1.'OE.09
9.9:3:"0
1.32: -09
5.28:-'0
1.3:3£-06
9.93E'08
'-.9..E-09
, .'-9E.07
5 . e.e £ -.OJ,
!.S8E-Oe
9.6:3£-08
:3.00£-06
2.58e-06
Ars~ic
To:el E,cess Ce~e' Risk
. 6.39:-09
5.75£-09
7.67'E-Q9
'-.19:-09
'-.63£-06
S.75E-07
2_86E-OS
3.'-5E-07
7.20£-0:3
'-.97'E-07
5.58E-07
1.77E-OS
Ne:
6.'OE-C!
9.'OE.e:2
9. '0£-02
6_00£-Ot
1.'0£ -02
'.70:.CO
7.50:-C!
l' - 15£+01
7.70£.00
5. '0:-02
5.70:-02
1. 10E-02
2.00£.00
'-.6:-1~
6.1£ .10
. 8.2:,1:
:3.1.:.0'=
5.3E'CE
1. 1£ - Cc:
2.5E-1:
5 . 7'E . C6
6.0:-C2
:3.0E,0£
:3.7E - Cf
2.:3E-C7
5.2:-06
6:-::
ESilAAiEC C~ROWIC DAILY INTAKE (CI)
(mg/k;-dey)
CHE~!:Al 1o'11H -.-.-............-..................- REFERENCE
1I000CAI: IIiXEIi I: I Ne: IDENTAL DERKAL DOSE (R~D)
EFFE:'!S INGESTIOH AlSORPT IDi (~/k;-da'l) C:! :R':
Acetone 1.29E-08 7.50E-OS 1. OOE -01 8.!£-07
lenzoic add '_18E-07 8.73E-06 '-.OOE.OO 2.3E-0~
2-luunone e.37E-09 '.8SE-Oe 5.00E-02 1 . 1£ - o~
lutylbenZ'Ilphthelete 2.Z1E-07 6.' U-07 2.00E-C1 '.3E-C6
di-n-Iutylpnthala:e 2.0SE-07 5.93E-07 1.00E-01 8. OE - 06
ePllorobenze~ 1_93E-09 1.12E-OS 2.00E-02 6_6E-C7
CMorofonTI 2.S8E-09 1.'9£-08 1.00E-ci2 1.7'E-06
1.1-Dichloroethene 2.32E-09 1 _3I.E-08 1.ooE-01 1.6E-07
1.1-CichloroetPlene 1. 9'3E -09 1.1U-08 9.00E-03 1.5E-06
b;s(2-Ethylheayl)phthalate 3.11E-06 1.1* -05 2.00E-02 7.0E'0.;,
"eaachlor~zene 2.32E-07 1.3I.E-06 8.00E-o.c. 2.0E-03
Methylene chloride 1.15E-08 6.6n-08 6.00E-02 1.3£-06
Noncarc;nogenic PAHS 3.32E-01 1.92E-06 4.ooE-01 S .6E-06
Toul PCBs 2.0n-03 1.W-02 1.00E-o.c. 1 - 9E.C2
1etrachloroethene 2.00E-07 1.16E-06 1.00E-02 1.'E-0.;,
ToL~ 4.13E-08 2.74E-07 3.00E-01 1.1E-06
1.1.1-1r;chloroethane 8.56e-07 4.96£-06 9.00£-02 6.5E.05
1.1.2-Tr;chloroethane 2_25E-07 1_30£-06 Io_00E-03 3.8E-0l0
A"I~ic 6.03E-06 IIC 1.00E-03 6.0E.0:3
C8CI!Ih.I!I 3.03E-06 IIC 1.00E-03 3.0E-03
ChrCllli~ 8.69£-05 IIC 5_00E-03 1.1£-02
Cyan; de 2.ooe-06 IIC 2_ooE-02 .1 .0E.0l0
M~anese 5_5IoE-()oI. Ie 2.ooE-01 2.8E - 03
Mercury '.12£-06 IIC 3.00E-()I. 1.4E-02
lI;ckel 2.94E-05 It 2_00E-02 1.5E-03
Zinc 1_51e-0lt IIC 2.00E-01 7 _6E-0l0
Total Hazard Inde, 2£.02
-------
-
TABLE 27
SOLVEN1 SAVERS R: REPORT
~MR~IC OA:~Y IN1AKES ANO R~S(S Assoc:iTE' w:~~
"'OIR:::: e:)1i1A:' w:,~ SUBSURrACE SCILS BT RESICE.~S
ES:]~~1E~ CHR:N:: OA~LY IIi'A(:: (~:)
(rnr;/\:;-eay)
C~f"'::A~ .':i~
P:~E". :~~
CAR: ! No:. < Ii: :
EnE:T S
SLoP::
F.:; ~~
(rnr;/\:;-cey)- ,
EX:::SS L'~:::
B~Ii: ~:rE-:'E
CANC::. R:S'
........ .e- .-.... -............. .-..- ..-------....-
OERM..A -
ABS~1~,lCli
Ch ~ c~:fo~,
'. "Cic~~c-oet~e~e
'.2'Cl:~:c~oet~e"~
'. "O\c~~c'oet~e~e
tis(2-Et~y\he.yl)~t~e~ete
"e.ach~orocenIene
Methylene c~loridc
Cer:;noge~lc PA"S
Tctel PCSs
1.'.2.2'Tct'ae~lo~oethene
Tctrac~lo'oet~c~
'. '.2-T';c~lo'oct~ene
Tr;chloroc!~enc
A~ser.i c
Tote: E.:ess Canec" Risk
IIiCICEIiTA~
IIi:;eST I Cli
l..H.E-~
1.~:-C'9
'.32::-C9
7.37E-Oe
7.02::-07
9.93E-0E.
5.13::-0e
1.'-9::-07
2.9QE-0.;.
1.0e::.os
1 .90: - CO
8. 17t - oe '
3.0U-C5
2.32E-06
2.l.0::-07
9.7'5E-('9
7 . 67E . OC;
l..27t-C7
2 .'-'E -06
5.7'5E-07
2.97E-07
3.l.5E-07
2.35E-03
6.23E-D9
1.10E~05
1,.'73E-07
1. 7..E-0.;.
6.10£.03
9.10£-:2
9. 'OE -"2
6.00E-O~
1./'0::-02
1. 70E.00
7. 5 ° E-!:: 3
1. '5::.01
7.7i:>e.0:
2.00E-01
5.10E-02
5.70E-02
1. 1 OE - 02
2.00E.00
1./: -cc;
, .C:-:C;
f.2E' ',:
3'.:::-:1
".:'E~C~
'L 1E-::
2.6: -:=
5.7:-::
2.::-:2
1 ,5: . C c;
6.t: -:-
3.2: -:E.
2.2:-Cc
w:
L.~:.~t
2<-:,
£S'IMA,eo eHRCliIC OAILY 11/,.(:: (I:) I)
USlli~ THE UPPE~ 95th eOliFIOEN::: LIM:'
(~/\:!I-CeY)
CHEII]CA. \J!T~ ..................................... . RE FERENCE
IjOH:AR: 1 liOGE Ii I C IN:ICEIiH~ DERKAl DOSE (Rf~)
EFFE:1S INGES~ 1010 ABSOIIPT IOH (~/lr.g-~y)
Acetone 7.08[-0:- 1..10E-06 ' 1.00E-0'
Benzo;c lCic: 3.0n-Oi 6_28E-06 I..OOE.OO
B r QIII:J!Ie t ~ a ne 3.~E-C7 2.13E-06 1.I,OE-03
2-Buunonc 1 ,l.6E-~ e.1,6E-08 5.00E-C2
ButyIDcnzyl~,t~alate 2.CL[-C7 5.9'E-07 2.00e-0'
d;-"-Butyl~t~alete 5.92E-07 1. 7'2£' CO 1.00E-0'
CII I oroeenzeone 1,.51E-a! 2 .6U -07 2.00E-02
ell l or01 01"::1 9.66E-OB 5.59£-07 1.00E .02
1,2-Dicllloroben%cnc 1.OI.E-06 9.5U-co 9.00E-02
,."Oitllioroetnine 3.93E-09 2.2n-08 1.00e-01
'. 1-0icllloroctll~nc 1. 7'2E-07 9.96E-07 9.00E-03
1.2-0icllloroctllcnc (total) 7.2~-07 1..21E-06 2.00E-02
£tllylbenz~ne 2.29£-06 1.32E-05 1 .OOE '0'
bil(2-Etllylh~.yl)phthlllte 1.OI.E-06 5.69'£-06 2.ooE-02
KeAlcllI orobcnIrnc 2.32~-07 1.3IoE - 06 e.OOE-()./,
Methylene chloride 1.20E-07 6.9'E-07 6_ooE-02
I.-Methyl phenol 1.09£-07 1.90£-07 5.00e'02
Noncarcinogenic 'AHI 1.1ZE.06 6.47E-06 4.0DE-01
Toul ,eBI 6.7U.()./, 5.48E-Q3 1_00£,()./,
Pllenol 7.73E-~ 1.3I.E'07 6.ooE-01
Tetrlchlorocthene 4.1.21-06 2.5U-05 1.ooE-02
ToLuene 1.55E.06 8.95£-06 3.00£-01
1.Z,4-TrlclllorobenZene 1_65E-06 9.55E-06 2.00e-OZ
1,1,1'Trichloroethane 9.e5£-06 5.71£-05 9.00£-02
1,1.2.Triehloroetllane 1.91£-07 1. 1QE-06 4.00£ -03
Xylerws 3.09£-05 1.7'9£-()I. 2.00£+00
Ant I..". 3.'1£-06 Ie I..DOE.()I.
Araenic 5.1.1£-06 Ie 1_DOE-03
c.- i UI 1.22£'06 Ie 1.00£.03
01 r. 11111 3_55E.05 Ie 5.DOE'03
Cyan i de 2.00£-06 Ie 2.00e-02
Mang8nC S c l..eSE-()./, Ie 2.00£ '0'
Mercury 1..'2£-06 lie 3.ooE-()./,
Mickel 2.' 1£ -OS Ie 2_ooE-02
SelenlLIII 1. 9'3E' 07 lie 3.00£-03
Si Iver 5.19E-07 lie 3.00£-03
Zinc 8.95E-05 lie 2.00£-01
Total '.I.rd IndIA
c:: :~~:
l. .BE .~~
1.6::-C~
1.8E-:::
2.C::-uc
".C: .:':.
2.3E-C5
1.sE-05
6.6E-C:
1.2£ -c,.;.
2./:-07
1.3E-0.
2.~E-0.;.
1.6£ -~
3.n-c.;.
2.0e-O::
1.U -05
6.0E-06
1.9E-05
6.2e.0~
3.5E-07
3.0E-03
3.5E-0~
5.U-0.;.
7.U-0.;.
3.2E-1)O.
1 .oe-I)O.
e.5E-03
5.U-03
1_21-03
7.U-03
1.0£-0.;.
2.'E-03
1.U-02
1.U-03
6.'[-05
1. 9E - 0.:.
4 .5E-1)O.
U+01
-------
-
TABLE 28
SOLVEMT SAVERS II IEPORT
~HRbN1C DAll! INTAKES AND RISKS ASS~CIATED WITH
INGESTI~ OF CROUNDWATER IN ON-S:TE WEllS
CHE".ICAl WITH ESTIIUTEO
PC H Ii T : A ~ CHROHIC DAllT SLOPe EXCESS UPPER
CARCIIIOGEN:C I N TAre (~:) fACTOR !OJNO LI f ET : ~E
EffE::TS (mg/kll' clay) (~/kll/aay)" :ANCER RISI:
B~ze~ 9. O6E . G/. 2.90E'02 2.6E'05
Carbon tetrachloride 3.92:'05 1.30E-0~ 5.1E-06
Chlorofo~ 3.60e-03 6.10e-03 2 .2£ . 05
1.L'Oichlorobenz~e 6.61E-05 2.'OE-02 1.6E-06
1.1-0ichloroethane 2.&l.E-03 9.10E-02 2.6E-G/.
.. '.,-Oichloroethane 6.61E-05 9.10E-02 6;OE-06
1."Oichloroethene 6.99E-G/. 6.00E-0' '.2E-0,:.
bis(2'Et~ylhexyl)phthalate 6.'9E-05 1.LOE-02 9.1E-Oi
Isop/'lorone 6.3n-05 '.10e'03 2.6E-07
"ethytrne chloride 1.15E-02. 7.50E-03 8.6E-05
Toul PCBs 5.63E-05 7.70£+00 '.3E-G/.
1.1. ,.,-Tetrachloroethane 1.10£-05 2.60£-02 2.9E'07
'.'.2,2'Tet~ach,oroeth.ne 2.5n-OS 2_00e-01 5.1E-06
Tetrachloroethene 2."E-03 5.10E-02 1.1E-0,:.
'. ',2-Trichloroethane 2.39£ -G/. 5.70E-02 1.'E-05
Trichloroetl'lene 8_6SE-02 1.10£-02 9.SE-G/.
Vinyl chlorice 5.51£-05 2.30E+00 , .3E'G/.
Arsenic 2.19E-G/. 2.00£.00 '.'E-GO.
Teal Eacess Cancer Risk 3E'03
-------
-
TABLE 28 (Contil"&Jed)
. SOLVEli1 SAvERS a: REP~T
! CHROWI: DAILY IWTAKES AND Rises ASSOCIATED.WITH
I~CES~IO~ OF CROU~O~ATER I~ ON-S:TE WE~~S'
CHEI'!::"~ ~:~"
N::~:A~:jW::~:~!:
EFFE:iS
ESTI~ATeD
CH.~:: OA:LY
I ~1AeE (CO 1 )
(mg/llg-oay)
tHERE.;::
DOSE (RfC)
(!!'G/lts.day)
COI :Rf:
Acetene
6e....:0;c ede
Carbo~ te!racnlcriee
CI'II oro~,...:ene
Cl'Ilorcfcm
',Z-Cichlorobenzene
Dichlcr~iftucrometl'lene
1,'-Dicnlorcetnane
','-Djcn!crcet~ene
trens-',Z-c;chlcrcethe~
Z.'-Cichlcrcpnencl
Etnyl~~:e!"W! .
C;s(Z-ethylhe.yl)pnthelate
Isopncrcne
~etnylene c~lcr;ce
'.Metnyl.,-~ntencne
Z-~ethyl ~e.-.: I
'.Metl'lylpt':e~cl
Noncarcinogenic PAHS
Totel P:6s
pne"!cl
Styre"!e
'.'. '.?-Tetrecnlorcethene
TetrlChloroethene
To l Ul!ne
',', '-Tricnlcrcetnene
'.'.Z-Tricnlcrcet~ene
Trichlorofluoromr nine
Totel .ylenes
Arsen; c
Beryll,ur,
c:nrcmi.r.>
Mensanese
Mercllry
..,cltel
Selenil.lTl
Thell ;\.11'.
Val'l8Ciil.lTl
Zinc
Total HlZlrd Inde.
9_>:'E-03
II. 06E-o.:.
9. "E-05
7.'3e-05
a.'0£-03
'.5~E -0.:.
1. 56£ - 03
6.63£-03
'.63£.03
a.oo£-OS
2.3n-0.:.
5.51£ -0.;.
1.51£.0.:.
1.'9£-0.;.
2.67E.02
1.53£-03
3.09£ - CIo
, . 510E - 0':'
5 .00£ - 0'
, .31E-Cio
1. 97E -0':'
'.23:-0'
2. 5n .05
5.00E.03
9.86E'03
6.80£-02
5.5n-c.:,
a.20£-CIo
2_9n'03
5.1U-CIo
5.1IoE'05
l.!loe.03
7.r.3E.02
5.71e-06
2.62£-03
2.2ge-05
2.86£-05
1. 406E' 03
8.03E-02
1.0C: -o~
'.00£+00
7 .00E'a.:-
2.00E-C2
, .OO£-OZ
9.0C£'02
2.00£-0'
1.00£-0'
9.00£-03
2.00E-02
3.00E-03
'.OCE-O'
2.00£,02
2.00E-01
6.00£-02
5.00E.02
5.00E-02
5_00E-C2
'.OOE-O'
1.00£-0.:.
6.00:-01
2 . 00£ - 0'
3.00E-03
1 .00£ - 02
3 .OOE - 0'
9.00E.02
, . DOE - 03
3.00E-0'
2.00e+Oo
9.3£-02
2.0£ -a.:-
1.3e -0'
3.n'03
e.IoE-C'
5.0E-03
7.8E-C3
6.6E-C2
1.8E-0'
'.0£-03
7.9E-02
5.5e-(3
7.6e-03
7.1oE-0':'
'.5£-0'
3.U-0?
6.2e-03
3. ,£.03
1.3E-03
1.3£-00
3.3£-0'
2.U-03
8.6E-03
5.0E'C1
3.3E'02
-7.6E-0'
1.'E.01
2.n'03
1.5E-03
5.1£,01
1.0E-02
. 3.n-0'
3.9E-0'
1.9E-02
1.3E-0'
7.6£,03
, .1£-0'
2.1£-0'
'.OE-O'
1.00E-03
5 . ODE, 03
5.00E-03
2.00E-0'
3. DOE - Olo
2.00E-02
3.00E-03
7.00E-05
7.00£-03
2.00E-0'
-------
-
TABLE 29
. SOLV£NT SAVERS II UPORT .
CHROWIC DAILY INTAtES AND RIStS ASSOCIATE~ WITH
ON-SITE INHALATIOh BT RESIDENTS
-
CHf"~CA~ \i;~~
PC~EIiT!A~
CA.CINCCEN:C
EFFECTS
EST I IV. TE~
CHRONIC DAILY
INTAKE CC;jI)
(mg/kg-dey)
SLOPE
FACTCR
(lII5J/kg-aay). ,
exCESS. :R
BOJIi~ L 1 ! . . ,~E
CANCE. 1151:
Tric!'lloroet!'lene
Te~r.c!'l.croet~e~
PCaS (Toal)
1.06E -03
1. S 6E - 0-
7.':'2E-09
1. 70E -02
3.30E-03
(a)
1. eOE - 05
S.,SE-07
............
2E.05
Tote: :
CHEI\I<:A~ W:TH
IiOWCAR<:INOGENIC
EfFE=TS
. ESTIMATED
CHIICH I C DA 1 L Y
INTAKE (CO!)
CIIISI/kg-day)
REFERENCE
DOSE (1110)
(mg/kSl-day)
1::)1 :1110
'.',1-Tric~loroethane
Toluene
L5SE-03
3 .OOE-oo.
3.00E-0'
2.00E.00
5.1e:=.-C3
1.5: :"-0..
.....-........
ToUL:
<, CSE-03)
Ca) lio to~icity value is IVlilable for the inhllation 01 PCBs cpersonal communic.tion
-------
-
'J;ABLE 30
SUMMARY OF POTl_TIAL FEDERAL ARARs AND TeCS
Solvent Savers Site
(Page 1 of 2)
Cont~~insnt.Specific
Rat ionele
Safe Drinking Water Act (SOWA) Maximum
Contaminants Levels (MCLs) and Maximum
Contaminant Level Goals (MCLGs) . ~O
CFR '11.11 . '11.18, -
Sets acceptable concentration of
chemicals in current or potential
drinking water based on leaching of
contaminants from soi l
Toxic Substances Control Act (TSCA)
standards for PCBs. '0 CFR 761
Regulates cleanup of chlorinated solve~t
concentrations in soil
Clea~ Water Act (C~A) Water Quality
Regulates embient concentration of
Criteria contaminants in surface wate-
for human and aquatic exposure scenarios.
Also establishes NPOES permit syst~.
under which discharges to surface watec
are regulated based on use of water, a.nC
POTW pretreatment stanoards.
Clean Air Act
Regulates ambient and release
concentrations of chemicals to air.
Locatio~.Spec;fic
Rationale
Rivers and Harbors Act (33 CFR Parts
329)
Corps of Engineer regulations for 3,:'
wetlands and navigable waters of U.S.
Executive Order 11990 - Protection of
wet~ancs
Requires consideration during r~;al
action' that may affect known wetianos
Executive Order 119~ . Flooc~Lain
Management
Requires consideration if remedial
actions affect flOOdplains
RCRA Location Standards - '0 CFR 264.18
Requires that units located in a 10D'yeac
floodplain be designed and operated to
avoid a washout.
Fish and Wildlife Coordination Act
<16 use 661):
Regulates remedial actions that affect
bodies of water or pose potential harm to
fish or wildlife.
1978 Improvement Act (16 USC 7'2)
1980 Coorcination Act (16 use 2901)
Act i on-Spec if i c
Rationale
DOT Rules for Hazardous Materials
Transport ('9 CFR 107, 171.1-171.500)
Regulates remedial measures involving
transportation or hazardous materials.
OSHA - Health and Safety Standerds
(29 CFR 1910)
Provides .afety standards for onsite
-------
-
Table 30
SUMMARY OF POTEkllAl FEDERAL ARARs AWD TeCS
Solvent Savers Site
(Page 2 of 2)
Action-Spec; fic
Rationale
OSHA - Recordkeeping, Reporting, and
Related Regulations (29 CFR 1904)
Resource Conservation and Recovery Act
(RCRA), Subtitle C (40 CFR 260 -270)
RCRA . Subpart F Standards for Owner
Operators of Permitted Hazardous
Waste Facilities (40 CFR 264.90 -
264.101)
RCRA . Closure and Post'Closure for
hazardous waste facilities (40 CFR
264.110-264.120)
RCRA . Manifesting, Recordkeeping
Reporting (40 CFR 264.70-264.77)
RCRA - landfills (40 CF~ 264, Subpart N)
RCRA land Ban ('0 CFR 268, Subpart 0)
RCRA . Incinerators <'0 CFR 264,
S~rt 0) .
RCRA ('0 CFR 761,70)
RCRA Standards Applicable to Generators
Transporters of Hazardous
Waste - RCRA Section 3003 ('0 CFR
262 and 263, '0 CFR 170 to 179)
RCRA Hazardous Waste Penmit Program
RCRA Section 30-35 (40 CFR 270, 124)
TSCA - PCB Management and Landfills
('0 CFR 761)
Clean Air Act. Prevention of
Significa~~ Deterioration (PSO)
and New Source Performance Standards
(NSPS) ('0 CFR 60.52)
OSHA regulations for recordkeep,ng a"~
reporting of compliance with safety
conditions during management of h8zaeo~us
waste.
RCRA standards for management of
hazardous waste.
General requirements for ground wate"
monitoring.
Specific requirements for capping waste
fac i l ; ties.
Requirements for hazardous waste
management -
Regulates the design and constructio~ c~
landfills.
Regulates land disposal of RCkA haza.d~us
wastes or wastes that are sufficIently
similar to RCRA hazardous wastes.
Regulates design and operation of
incinerators.
Establishes performance standards fee
incinerators.
Regulates offsite transport ane
management of hazardous waste.
Specifies permit requirements for RCRA
hazardous waste management activities.
Regulates soil cleanup requirements ane
establishes regulations for ch~ica:
waste I~ndfills into which PCB wastes may
be lend disposed.
Establishes particulate emission limits
for inciner.tors.
-------
-
TABLE 31
SUMMARY Q; P01~_1 IAL STATE A~AR~ AWD TBCS
Solvent Saver~ S'te
Contaminant-Specific
Rat ioneie
Wew York State Water Quality
Regulatio~: WYCRR Tit~e 6,
Part 700-703
Pertains to surface water and grounc
water, quality classificatIon, ane usage.
Wew York State Air Guide-'
Guidelines for t~e Contrel of
Toxic Amoie~t Air contaminants
Sets 8mCient concentration for to.ic 8'-
pollutants used as a pOss'ole scree~'~;
mechanism to oetermlne w~ether perm::.
should be issueo.
~ew York Air Pollution Control
Regulations; WYCRR Title 6, Ill;
Parts 202, 212, and 2'9
Regulates emissions from treatment
processeS such as land farming, vacu~
extraction, and air stripping
Wew York Ambient Air Quality
SUndaros; WYCRR, Title 6111; .
Part 375farming, vacuum extraction, air stripping, etc.
Establishes treatment p~ocess em;ss'~
standards for treatments suc~ as' lane
New York Effluent Standards and
Lim;tations for Class GA Aquifers
Regulates direct or indirect injec:l~ c~
treatment effluents into t~e grounc wate-
eQuifer.
Location-Specific
Rationale
~ew York ~etlancs Laws, New York
Environmental Conservation La-,
Title 7, Fresnwater Wetland
Regulations (Article 2~)
Regulates impacts of remedial aCt10nS
aOJacent to wetlands.
6 WYCRR Part 3t~ - Citing of Hazardo~s
Waste Faci lit ies
Regulates siting of certain industrial
hazaroous waste facilities.
New York Rules for Inactive Hazardous
Waste Disposal Sites; NYCRR Title 6,
Chapter 375
Dictates involvement of federal, state,
local governments, etc.
Action-Specific
Ret ionale
Wew York General Hazardous ~aste
Management Systems Regulations;
NYCRR Title 6, Chepter 370
General reguletions for hazardous waste
management -
New York Hazardous Waste Manifest
System R~uirements; 6 NYCRR Chapter
372
Regulates trensportation of hazardous
lIIeste.
New York Hezardous ~aste Treatment
Storage, and Disposal Facility'
Pennitting R~uirements; NTCRR Title
6, Chepter 373
Regulates pennitting for hazardous waste
storage, and disposal.
New York Final Stetus Stendards for
Owners & Operators of Hazardous ~este
Treatment, Storage, and Disposal
Fecilities; 6 NYCRR Chapter 373'2
Regulates hezardous waste treatment,
-------
1',1111<> .17
SUMMARY OF POTENTIAL LOCATION-SPECIFIC ARARs
(By LOClltion)
LOCBtion
R equ i r I'IIIen t
Action To BI' TAken To Comply
O('scription
floodplain:
E~ecutive Order (EO) 11968
RCRA location Standards (40 CFR
26/..18)
\Ie t lends:
E~ecutive Order (EO) 11990
NY \lettands Low (7 MYCRR 2')
River:
Fish and \lildlife Coordination
Act (16 use 661)
Rivers and Harbors Act
The potrntial ('ffects of Any
Act ion tIIkl'n in it SOO-yeilr floodplnin
must be eVllluated to ensure thAt
plAnning and dl'cision-m;tking
reflect considrration of flood
h01Ards And floodplAin m;tnilg~nt.
Units in 100-yellr floodplnins
nlst be designed, o~rated,
and mointoin~ to prrvent washout
of any halitrdous Wilstl'S.
Actions
Adverse
and, to
enhance
nlst ~ ~'nitg~ to avoid
effects, minimile horm,
e.tent practicable,
we tronds .
Potrnt iol effects of I rI.",TII'rliol
will be consider~ before.
any r~ial action is taken:
Alternatives involving retention
ofhalardous wAstes on sites
wi II be i~1 emented and operitted
to prev!'nt woshout.
Actions will be evalunted for
potential effects on neArby
w!'tlands.
Considl'rotion of effects in Closs II
wetlands will be modI' before r~ial
actions are taken-
If any actions hAve an effect on the
activities of the River, the sljbsl8ntiv~
provisions of th.-se requiremP.nts wi II bt-
met. Superf.. v.. i tes do not have 10
mf'et the odninlstroti"ve cooponents of
. on ARAR for on on-site action.
(See Fish and \lildlife CoordinAtion Act)
Requires ~rmit And consideration.
of potential adverse effects for
Any action affecting freshwAter
wetlands (wetlAnds are DesignAted
Class II under NY State Law).
Proposals affect a body of water
must be referred to the U.S. Fish
and \lildlife Service for consul-
tot ion.
Actions that require diversion,
channelling, or olher activities
nffecting regulated ~fies of
wAter lMy require consul tot ion
with Corps of Engin~Ns.
-------
Q
TARLE J) (p:1ge i j1f )
SIll ¥EIT SAVERS S IfE
PIKI'OSEO QlOOIIJ unR AC'IOII I.FVUS
CARCIr«U'IIS AND Nmrf-C/I'CIHlIGEIIS
Potenttal 11./1." OthH" Q,!t~e,
MIIII f... .
c:or.:ent rat I CJnS «:mt_. CIP
10.6 IIi sit U ff!t 1- I""nt Ccntrect
"rUh_tlc: .... f- .~ Tork Ile8lt h Level .~I~
CIIn:lnogenlc New! flaX f.... C'een-~ cmt-I nlW1t GrOtnd Adv 1 SM I f!tI Goels o.--.tlutlon
P.r.-ter (LQ/U (ug! IJ leftl (ug") l~1 (ug/I) V"t~r (ug/I) (ug/I) (UIj/I) LI.lts (uq/l)
ArMftfc 1.44E.81 7.J1£.o1 . 0.0'1 50 2'i 50 10
IMN- 4.861:.81 6. 10f eOl ~.984 S Nt 0 S
Carbon Jetr8Chtorlc1e 1.~.00 6.JOE401 0.6J1 5 5 0 5
01101'0'- 1.94E.Ol 2.SOE.oJ 11.44 100 5
1.4-Dichl~- 5.101:.00 1.9OE.o1 J.415 75 4.1 75 15 10
1.1~ldhloroeth8n8 1.5](.02 1.9Of.oJ 0.901 ')
1.2.0ldhloroethene J.4~.e0 4.JOE.o1 0.901 5 0 S
1.1.0Idhloroethene ].9JE401 4.JO:.ol 0.U1 7 7 T ')
li8(Z-£thylhexyl) 5. '(1(.80 '.2OE.oI 5.055 10
Phthalate
18apharon! 5.101:+80 a.DOC401 19.992 10
"'thyl- OIlodele 4.6N:+82 1.5Of404 1.093 ')
Tot.1 PCB. Z .501:+00 7.45£.01 0.011 .5 0.1 0 .ft
1.1.1.Z-Tetra- 1.oeIE'01 5.111:.00 ].153 S 5
c:hloroeth8ne
I.1.Z.Z-Tetra- 1.4(1(.80 Z.IJE401 4.098 5 5
c:h I oroeth8ne
Trlc:hloroelhene 4.7'9£.03 5.711:4«14 7.C5l 5 10 0 5
vinyl Chloride ].:50E.oo J.~tOI 0.016 2 5 0 10
Tetr8Chtoroeth- I .Oft(~ 2.1"403 I .60n 5 10 0 5
1.1.2-1richlor~ 1.21£.01 1.711:.02 1.438 3 5
ethane
-------
TARt!:. )) (pi1J'.P 2 of ))
SIOl VEIf SAVEIS S IfE
PtlOI'05t'O gloom ,"1[1 _[fUN 'Fvns
.11*. CJlJK: 'Ior.ns
PalMt 1.1 NlN/<; !J! hN" ().J i rt.1!:,,"..:.!.
"".1.81
tmtent ret tOM Con t.... n,
11M I t"- UfetlR IfWtt Contnu:t
Arlth-t Ie RMed "01- IN York lien I th l~l R",~ired
I8an- C8f'Cf"",eni c Mean ..,..i.. C I"n- '-" [....I_I..nt r.rOlnrt Advi SOriH GMtA Outn'if.tlon
p.-..rter tug! I) (ug! I) leftl (ugll» lnet (ug/I) IIIIter (ugfl) (Ullfl) (ug/I) l i.its (~IIJ'"
.
AcetCIIR 1.26Ef02 1.~fOJ B.1J8"j '0
8enIo": Acid 2.66E+01 1.t.(EtG1 ].2]0 ')0
carbon '.tr.hl.,.lde 1.1444]0 6..JIIt4)1 .,
a.tordJenRene 1.9(1;+00 1.m:t4)1 1.615 100 20 3.150 100 ')
a.torofont 1.~t02 2.~.OJ 5
'.2.'lchl~ene 1.06E+01 '.~.02 1.2"" iIOO 4.1 J.T50 foOD 10
Dlchlorod'fluor~th8ne ].47E+01 4.47E.OJ 16.170 50 5
'.'-.Ichloroeth... .. S][ +Ol 1.9OE+OJ "i
,.'-Olchloroethen8 ].9JE+01 I,.J~02 "i
Tr8nS-1.Z-0Ichlor8e~ 2.IOE+OO 1.80Et01 1.615 100 50 350 100 5
2.".Olch1oraphenol 6.7UEtGO }. mEtOI 240 0.3 10
E ttlylbenrene 1.16E+01 1.1OE+02 8.OM 700 50 3.400 700 'i
.,.(Z.Ethylheayl, 5.10EtOO I .20E+01 10
Phthel.te
r .ophorone S~ 111[-+00 8.00£+00 10
f'ethylene I:"orl. 4.66E+1IZ 1.5DEfCK 5
4-"ethyl-Z.'~tanone ].2&+01 6.7OE+0l 4.040 10
Z....ettlyl"'-' 8.00E.00 6.JOE.01 4.040 10
Io-ttethy'ph-' 5.2«1:.00 8.00E+OO 4.040 10.
8anl:8rclnogmlc Pail. '_M+01 ].~f(l1 12. J40 10
10t.1 PCBs 2.5(1;+00 1.45E+01 0.5
"'enD' 6.1111:+00 2.50E.01 48.500 10
Styrene 6.1111:fOO ].]O[f02 16.110 5 931 1.000 0 'i
1.'.'.Z.Tet,.ch'.roethane 7.0111:-01 S.10EtOO 5
1etrech'oraethene 1.1181:+02 2.10E.01 5
10luene 2. 15E+02 3.5O(-OJ 24.250 2.000 50 10.800 2.000 ')
1.1.1-'r(Chloroeth8n8 1.63E+0} 2.20£.0' 7.21'-' 200 50 1.000 200 C;
'.1.l.triChloroethane 1.21£+01 1.9OE-02 ')
'rlehtorofluoronelh8ne 1.BU-01 2.40Et02 2' . 250 ")0 10
'.'a' .yl..- 6.00(tG1 1.30(+OJ 16.100 10.000 50 4~O 10.000 S
Arsenic 1.'U+OI 1.JU+01 50 2'i ")0 10
lery' 'hll 1.'0(.00 6.20(-00 400 1 ] ').
thr_h.. I,.9UtG1 2.")4(.02 400 '50 ')B 170 100 10
-------
TARLE 31 (p;"',e 1 of 1)
SOlVt. . SIIVUS SHf.
PIOPOSED r.ROMD ""'ER AUI(J,I lEVFLS
tDI-CARCINOCFlS
c
Pot..ntial "-~
t8nCentnt Ions
Heetth-
lased
tleen.~
l~t hllJlt)
"..In..
("Ant sri Mnt
le¥et (ug/I)
11- York
GrOthi
U8ter (ug/tJ
lorrt.rclnogenle
P.rllleter
IIrt tt81et 1 e
11-
(~/I)
... Ian
(ug/I )
e.ercwy
I I cite I
~leniUlt
'h.1I i...
Verwdi WI
Zinc
1.IIOE.o1 I. OOE.OO 2~ 2 2
6.96EtOI 4.Wt02 1.615 100
8.IIOE.OI 1.60£.00 2~ 10 20
1.lIOEtOO 2.10£.00 5 1. 4
].lI7Et01 2.19[t02 56'>
1.72I:tO] ].10£.\K 16.170 5,000
Other r.ul~~ '
l Het l!We
I_I th
".tvi~nrIM
(ug/ t)
5.5
150
"..1-
Corn-
IMnt
l~1
Goat,
(ug/I)
2
50
-.
a..
(mtrect
"f'(fJ I r f'd
Quant t t Itt'on
Usri IS (1~/t)
0.2
40
5
10
50
20
-------
-
APPENDIX 2
-------
o
a
I
I
,---l'\ "
j ".1 1\ ...../~---~_.-~
I' )<" " ,f I" !,.' '~, ~: I'
,: ,~- r -- .J- - VA01~ON \ rn I
'\ ( '{H" - '\ '- »i-
- ~I ,,:I('\~ ' /
\ ./ "~ ", /\. "~ ,
\ ' ( /' //
l.INCI(lArN ---..J -1'" ~~V,- MAliS" lANn'
/~I": ,,'
, \ "I>n "1 ,--' / I
( '" ~ /'"""-- ' (
-' I""
~ \ '" r~..-... .1,--
: fll~'" w ,.-
\ \ 0 0 A,' ::
, ZI"'" tll
:'. ~ Ai" I SOlvrNf
" "17 ~. ' 'AV''', '''f
\ 0. ~ r:f I
Mun CArne ~ \ '~"I'" I
ORAINAG{ , DIVlor \ 0 J
i /
, s'~ I
, fj'1 ,
\ f, ~ I I
} ~~'\ ~' '
\ ~., o+{
\ 11" I ~';-' , .
\ "I I iJ-t. '~,,~
I~"I _~.l' .,(...:;f.
, ..' 0-
\ ~ '
I 'OWN Oil' '
. rl'CII[n
, I
'-
ORA.ffAOf "A~'HI
''''4 SO".fI' Mllr'
@
,I
o
1
SCAlf IN "Ilr~
"
Flr,tlre I
LN".AnON MAP
IInL\TN' f."VEn., 0--
ntfNAt ..r.
-------
/'NT=:..MiTTENT Si~EAM
--"'((:~
e;22~~cc'," ..
\\~ y- FLOW O'"EO'>CN
\ .
\
\
/65
ell\ I
~ [J 'r
1
~D
"- S7~ '/
r-:::J 0 'I
/U eeY '/ .
I.
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I E:)GE
-
.. ._\\--... ---...
\ ~ T:;::-::- LI/\;::-
\ \ I u_-
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\\
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V" ::- y \ ./'
..--- \,
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/
::~~
8,
D
82
e~
84
Be
"-- TREE LINE
@
o
100
IN
200
FEET
SCALE
~PIT
D
\ \/MUC
CREEo(
I (
/
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:;;...-
ID
"'"1'01(
II
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,,,,,,"U,I .' hi.... U f,,.,..
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h"d...",1 ... hl.Ud \I r,,,,,,,,t
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l '...., 'u ,'t"C,
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II
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11,..1& ,..
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s...ru VU" "IC ItU
",1,1 ,....t, ,.--.e'M 'f vir''', (tr\L. "........, .11.
Figu:-e 2
SOL-VENT SAvERS SITE
COMPOSITE MAP OF
STRUCTURES
p":":'...",,".:
IH\
It~~ 1'"
IH~ IH!
n~\ :,. ~
I'~ ~ I'"
I'H
,,~\ :,..
11" ,...
Iti.! h,,,-:
:\U
;".
",) ..",..t
It" h'ufII\
."'".'''
I'"
It..
It..
BUILDINGS
-------
,
1
~f
!;Ii
I:!
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ill I
;;--......-.". \. ~ <:"":'.'.'.''-.',<, .
"', ; ~",..-- ..".. ':;
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'-"'-'-'-------"-:"'::'~~""\ flOOD P,-,,'N '. '. ' ._--;;- ,,_.'~~~~: :1 ~""; ,',- --".~ .
'-" " I C' ~r [0, '''~'' . "-' , " . "
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. ", . ;... .. ... ", .....-.-......""" ......"
". ,..' ',.. \. ..,' , . ." '. .'
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sou:
r::::=r::=r::: L-,
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rRorrs<;
re.IJG.
1
,fonAnr
i
:-
i
I
pr<;IOr.NI
wILL
"
n
....
c;rnIPJCf "
pr $lor fle[
"IIOTO nrouc£O rnol.l SURV[Y£O
IIA st I.IAI'S
~
FIr." re 3 SIT£ MAl"
SOI.YENT SAVF.RS US
IIOUNOAfIIF.S 0.' souner. An ,
----
-.-----
-------
ItE~IDCNCI.
- r-.. - 'I
1_1 .--'
===~~-,~--~,=--=---- '. -----.-,
- - -'--"'- '---------
7X
;- --
--J
fir ~I[)I IIf [
w
'ill
'J.1J
...'-
'.'
'ill
~-
." -"""-.
-.--
/J'I'.' "J \''11,''-;' ~(!,\r;""--'
--------
---~--_.
. - "----
, f ,HU' R PHI In . .r,
. ,III "
r ". ,
-'----.-, /
ESTIMATEO EXTENT
OF HEMAININr. X:
X/--. X ~mJHlE() ()HIIMS.....c" --.)
( \ . ~X X
X , .1 X ) X X '-~,,'.
'. / I'
X'., --- ' /" X ,I
--, \
W()OPr- [)
AHI A
w
-..... .
1.1111' fRl f I.
:\ X
-~'
~-
- - - -- ~
-"---- '#iJ -' -'
w;.,-,.,,"-'
,
/"
/'
~/"
"
"
':)
FIGURE 4
TEST I'IT I.OUTIONS
<;ol.\'J:rn S.\VEIIS II!
"
. .-
111'1 If 0 '-_r:4 I
-0_._'----
....-
- ------
. .,:.
r
111"",1.111' .
II "' H'-HIIIIII
<,11(1 I., I
I X
'ill
~0
f)
'L0
'1.1l
111'0111111
.
ill ;'
r
I
w
1..1 I
HI ~.I"I lie'(
, "'1-(1
Nil A
't!1J
IJ:CENII
X TEST PIT
1.01.,\ TION
-------
----'---.'-------
"I '.11 ,I ", I
III
-, -
'- .
I., ,
- ~ -..---
- -- ---
11'"'11, \ \J I"
'0 I." I
''''111.111/1'1111'1',',
(,lIf (I
I
---~..
j/
I
(
:.1-'1" r. ~'
J
/ -.
--J
'II)
Rr ',II.r '1([
/
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, I
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, I
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r'IJ
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('
1 (') Anr ~ - .~\ \ " );-~- _~_/f
~~-~-~----~ ( 1.1"":) .
",,-,'"ro ""'" ' '--------...---. -,.,-"
101111,"1'1', AlII wO(..""
Nil"
'J:lJ '
,/"-,-----"---.... \l11
,/ ,
_r----~ ../--"-':-
, /.'
- ...., '.. - , '
-. ~ ..--~ .
~
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ill
ill
/.
.- -'
-,'
~.
:~
1.41111 I' fill v.
II" I , () ',f I~ I
d
II II. I
/ ,
..II 111',111 "
11111'''.1111 III
. It I I II
/1 I
'1"'1
~.J
'0
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L.U
'!.:!;j
IJ '",
1111'" 1111
/'
-~
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: (III 1111,' t
v1.l
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I I I
I
t
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\8.1 -.......... ;
---- --:-.-- _.. .
~~
,
'ill
'.'.11111.111
/"., "
'clJ
FIGURE 5
I') '.ItI.'1 ;.1 I. ',1'11 ';AMP\.".n'\.OCAnoNS
'I" v, ,,' ',',vii' ,"1 ~J
-----------------.--..---------------.
-------
~
!leAU
t--=.I.-
o '0
~
100 .~.
"rSlorNe(
ArSIO,,,,,,
. . OWIII
-- ------- -~_._._------._--
- ----.---
-
----.- -------'
---- --IW).o_------- (i)
------ f'-I
rn
1-1
\nI'OOI
LEGEND
+ KNOWN POINT OF CONTAMINATION
o SAMPLE POINT
. . ~ . .. .. ..
. ,
" .
, '
.
, .
. '.. '.
. .
. ........
.
.
.
,
Cl;;; iooE . , , , - , . , . . , , , . ,
. .
to, ".."""."...".""""""""'''''.'''
....
"'..."
.
.
.
.
.
",,,...........
. .
, .
: . "-
".,",': "" /(.::::'~:
..
""......
".........-
FIGURE 6
SO\.Y£NT SAVERS AI AEPOnT
PC8 $AMPLINO LOCAnONS. SECOND ROUND SUAF'ACE SOILS
.---. --.- -
v.ltO -
R[SIOrH'
wrll
o
nrSIMNC(
~nocr ~
N.rW)
II
[-J --- .-
fo1 r1 0 fol
. . F1 f) ftJ
+ fo)..,. t =. ,t,
' ?iJ ~'I ~'J
".~I ~ .."
. MUO CREEK' ' , , , , ,
....0....--.-.-..
...-
.'--.
-.--
..
.
- "F.UAINfNO
IURI( 0
ORUU!t
...-
n '" rl:>r.r
'lOW ()oI1[C'IOH
..A '
(11
(11
rJ) ro 1
LJ
,
I
/
/. '
/' "
.-.-
film
~'l
fil IoJ
~~I fo1
~ r!J r!J ~
~J rJf
reI - j
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....
..., "'.
....., .
-'. .'
. .
~) I
""'QFH'
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)n' ..
..rslor..e r
..
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t
-------
~
SCALE
t;:-.' I. .t:: -I - J - . - .I
o '" '00 ."'.
UNI()Ot
0....... "
.
, .
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"., I
FIGURE 7
SOt.VENT SAVERS AI REPORT
SOll80RINO lOCAnON9
'.
. .
. ,
. .
"
C~';; (ME
. .
. .'
"f~'OENCE
"r~mf'"
.- [lwm
-- V.A~I!,,!-
--'---
~---_.---
1If810lHr
!l1I1t JJ1 WIll
!I'''' A
III "01 He E
:8
.
UUf)(;nfFK . ' , , .
"
o
,.-
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.
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A
Sill
A
-.--
- rwr;~.'_:~,~.'==-==~==-~~----'--"--'-
.-
'fVY.f S!I
1111'"
..
'118 "8
rAn
'II "
A
311
...
31"
.
[--] ~
A£WAIN''''''
IURFO
om,...!
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~"t'
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.m
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'.
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/,' .
"~.~C:IION
~
~A'
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----...,
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'.
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z
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n
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A
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~
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-----------.-. --
I't 10 TO IlF Otic. f n r fY1f.A SlIrNrYf. n
-------
~
SCA~~ - ----=)
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50 lOG
o
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.. JI)I)S 0
-.= :
:~ ~ ~ ~ ~ - . . . -. - .. . .. . - . -
"
..-.-
. 9
JOe 5,0,
FIGURE 8 RI REPORT
50lVfHr SAvfm OCAnON'>
...ON"OI11NO WFlll
nr ~'on"r:E nrSIDHU
.IIWUl
.
101
-
-----VAtlE1-
-- -
---------"
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-
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.
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----
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. 1010
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--
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n frV)"" Sllr 'f "--,,,',
PHOTO nrnl/rF.., N" II "I !lACK I
IIA';f- UAI~; 1'111, ---:----
-------
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o 50
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' . nwrll
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-
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SWISI' 05
, '/\
MIIOCRfTK'
'.
FIGURE 9 At "I!PORT 0 lOCAnON<;
!lOlYrNf SAVI!m WATrR AND AIR SAMPUN
SUR'ACI!
SfDIM(Nf.
-
o
--
-- -------
~- noAO ..-
-
-
-
..------
Pt10CFSS
nt 110
L__J~
~I IfF Emf
swr.;r 1M
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.
!'AII
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!;wr.;r n.
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-
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wnl.
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., 0
~,.-
~' . n£SIOfNCF
~'
@
t
swr.;r 01
1\
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' IrFO rnoM 5 . '~)1:""1
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nAr.r MAf~ I'''r~r''~
"
-------
-
-------
-
!
.'
SO:"~.~::~:T S;'.V::RS SIT::
AD~I~IST~.~IV:: RECOR~ FILE
I~::::X CF DOCCX::~;:-S
No":ificati:>~
SITE IDE~TIFICA;:-IO~
/ Si":e
p. 1-16
p. 1/-~1
!~s~ec":ic~ Re~crts
Pcter.tial Hazardous Waste Site Inspection Repcrt.
Fetruary 11, 1982.
Report: Fi~al Re~ort: Tec~nical Review of
Docu~er.ts, prepared ~y Ca~p, Dresser & McKee.
May 6, 1987. '
~aster P2.a::.
R't"~~:::)I;'.T !N\7::ST:G.~::'IO!J /
Field O~erations Plan
p. 48-223
p. 22';-2';5
p. 246-362
p. 363-370
p. 371-504
p. 505-524
FEASIBILITY STUDY
\\- ':: ~ :--: P: 2. :: s ,
Report: Re~edial Action Master Plan, prepared by
m:s Corpcratic:.. December, 1983.
Re~or~: work Plar. - SU~Dle~ental Data Collection,
prep~red ty Conestcga-Rov2rs & Associates.
Mar'j 27, 1987.
Report: Re~edial Investiaation/Feasibilitv Studv
Work Plan. Su~~le~ental Data Collection, prepared
by Conestoga-Rovers & Associates. June, 1988.
Re~ort: Com~arison of EPA's Final Work Plan
,
(March 1988\ tc CPA's Work Plan (June 1988)"
prepared by Conestoga-Rovers & Associates.
JU:ie, 1988.
ReDort: Final Work Plan Remedial Investiaation/
Feasibilitv Study a": the Solvent Savers Site,
prepared by EBASC~ Services, Inc. November 24,
1988.
Report: Final Field ODeration Plan for the
Re~edial Investication and Feasibilitv Study
the Solvent Savers Site, prepared by EBASCO,
November, 1988.
at
Inc.
Remedial Investiaation ReDorts
p. 525-609
Report: Final Re~ort. Solvent Savers Site
Re~edial Investiaation/Feasibilitv Studv. Vol. I.,
-------
-
p. 610-775
p. 776-121~
p. 1215-1541
CorresDondence
p. 1542-1545
p. 15~6-1502
p. 1529-1599
p. 1600-1606
p. 1607-1608
p. 1609-1610
p. 1611-1612
.
Re~c~~: Final ReDO~~, Solvent Savers Site
Re~e~ial I~ves~i=atio~/Feasibility Study, Vol. r:,
p~epa~ed by E.C. Jordan Co. August, 1985.
Repo~t: Final Re~edial Investiqation ReDort.
Sclve~t Sa~e~s Site, Lincaklaen. Chenanqo Countv.
Neh Ycr~, prepared by EB~SCO, Services, Inc. J~ly
23, 1990.
Report: Final Re~edial Investiqation Report
ADDendices. Solvent Savers Site, L1ncklaen.
Chenanco Co~ntv, Ne~ York, prepared by EBASCO,
Services, r~c. July 23, 1990.
Letter to David Weinberg of Porter, Wright,
Morris & Arthur Law Fir~, from David Munro
and Dean So~~er, NYS Department of Law,
re: Sta~e's cO~wents on RI/FS. November 8,
1985.
Response to April 29, 1967 State Request for
Supplewental Inves~igation, prepared by Conestoga-
Revers & Associates. May, 1987.
Letter from Mr. John V. Czapor, re: U.S. EPA
resprnses to Conestoga-Rovers & Associates
S~pplewenta~ Data Co~lection Work Plan.
June 9, 1987. Responses are attached.
Letter to Joel Singerman, U.S. EPA, from William
Gill, U.S. Depar~ment of the Interior, re: Review
0: 1987 Draft Work Plan and Draft Field operations
Plan. January 28, :968.
Letter to Reed Ne~~an of Fox, Weinberg & Bennett,
:ro~ Paul Si~on, U.S. EPA, re: Conestoga-Rovers &
Associates Remedial Investigation/Feasibility
Study Work Plan. August 9, 1988.
Letter to Ms. A. Ross from William M. Moran.
July 23, 1990.
Letter to Addresses from Joel Sigerman.
August 7, 1990.
Feasibilitv Studv ReDort
p. 1613-1862
Report: Feasibilitv Studv Report. Solvent Savers
. Site. Lincklaen, Chenaqo Countv.New York,
-------
-
S:';'.TE
coc?r;!~;';T: 2~J .
Sta~e Ce~tific2~io~
Rec-..:::.~e:7:e;.ts
J.."oprop~iate
p. 1883-1903
Cc~res'Ocnde~ce
p. 190';
ES:O?CE!-!:::~:'!'
Notice Lette~s
c: A~~::catle o~ ?e:eva;.~and
Le~te~ frc::1 Dea:1 S. SO::-.:.1e~, State of New York
Department 0: Law, re: State of New York v.
Allied Ccr~o~ation. et a1. April, 1987. The
following are attached:
a) NY/EPA responses to Conestoga-Rovers
We::-k Plan;
b) Over=~rden Well Figure 1;
c) Bed~ock Well Figure 2~
d) Proposed Soil Gas Survey Locations Fig 3;
e) J...ttac:-or::ent "B".
Lette~ to Ga~y Bewitch, KYSDEC, from Ca~oline
Kwa~, ~.S. E?~, re: Additier.al informatien on
Sclve:1t Save::-s a~d Pe~pey Sites. June 10, 1982.
2~C ?e:s~cr-.ses
p. 1905-1912
p. 1913-1914
p. 1915-1918
p. 1919-1920
p. 1921-1947
General R!/:S Kctice LE~ter ~rom Stephen D. Luft~g
to P~?'s listed en attach~ent. June~, 1987.
Letter to Caroline Kwan, ~.S. EPA, from Scott
Slaughter, u.S. Depa::-tment of Justice, re: Air
Ferce's response to June 5, 1987 notice letter.
June 10, 1987.
Letter to Elena Kissel, u.S. EPA, from Peter
Paden of Teitelbaum & Hiller, P.C., re: To
confirm the response of G.E., Bristol-Myers and
Stauffer Che~ieal Companies to the EPA's request
to corn~itting to a work plan and supplemental
RI/FS. July 9, 1987.
Letter to Careline Kwan, u.S. EPA, from Karl
Bo::-deaux ef Beveridge & Diamond, P.C., re: UNISYS
response to June 5, 1987 notice letter.
June 11, 1987.
Special RI/FS net ice letter from Steve Luftig to
-------
p. '1923-1930
p. 1931
p. -.1932
p. 1933-1935
p. 1936-:53,
p. 193 9-19~ 0
p. 19';1
p. 1942-1944
p. 1945-1946
p. 19~ 7-1953
p. 1954-1956
Lette~ t~ Ca~~line K~an, U.S. EPA, from David
~einre~g c: Fox, ~einbe~g & Bennett, re: Response'.
on behalf cf clien~, Bristol-Myers Company, to E?~
-notice le~t~~ received April 26, 1988.
May 9, 1983.
_Letter to Ca~cline Kwan, U.S. EP~, from Mr.
F~ancis Esposito, USAF, re: Air Force response
~o EFA le~ter of April 25, 1988.
Letter to Ca~oline K~an, U.S. EPA, from Guy
Hoadley, V!GS"iS Corporation, re: UNISYS Corp.
response to April 25, 1988 notice letter.
May 10, 1988. ' .
Lette~ t~ Elena Kissel, U.S. EPA, from Melinda
Ke~p, Cha~pion !nte~national Corporation,
re: Response to special notice letter received
April 26, 1928. May 10, 1988.
~e~te~ t~ Caroline Kwan, U.S. EPA, from Russel
Ran=le 0: Pa~~on, Boggs & Blow, re: Carrier COrF.
response t~ April 25, 1988 notice letter.
May 12, 1932.
Let~e~ to Ca~oline K~an, U.S. EPA, from Russel
Randle 0: Patton, Boggs & Blow, re: Norwich-
Eaton'~ response to April 25, 1988 notice 'letter.
May 18, 1988.
Lette~ to Ca~oline Kwan, U.S. EPA, from Allan
Topol of Covington & Burling, re: Extension of
ti~e for IE~ to respond to April 25, 1988 notice
letter until May 25, 1988. May 10, 1988.
Lette~ to Caroline K~an, U.S. EPA from, Mr. E.M.
Wonde~li, IBM, re: IBM response to April 25, 1988
n~tice lette~. May 10, 1988.
Letter to Caroline Kwan, u.S. EPA, J. Richard
Lauver of Kirkpatrick & Lockhart, re: Response
of A~erican Locker Group to April 25, 1988 notice
letter. June 27, 1988.
Special RI/FS Notice Letter to General Motors
Corpora~ion from Stephen D. LUftig, u.S. EPA.
June 23, 1988.
Letter to caroline Kwan, U.S.
Stephens of Raichle, Banning,
re: Denial of General Motors
June 27, 1988.
EPA, from William
Weiss & Stephens,
-------
-
p. 1957-195S.
'"
Lette~ to Ca~cly~ [sic] Kwa~, u.s. EPA, frori P~te~
Piden c~ Teitelbau~ & Hille~, P.C., re: ,'Response
to Ap~il 25, 1923 notice letter from G.E.,
E~istol-Mye~s and S~auffe~ Che~ical Companies.
-June 28, 1985. ' ' '
PUB~IC FA?TICIPATION
Cc!:":.:e!"lts
aJiC Res-::>cnses
p. ,,1961
p. 1962-1964
p. 1965-1966
CO!7~~~i t'l
Lette~ to Ms. Alondarae DelRossi, Town Clerk of
Lincklaen, fro~ Jill Hacke~, U.&. EPA, re: Makinc
RIIFS availatle to the public. December 28, 19S5~
Le~te~ to Glen Angell, Lincklaen Town Board,
Jill Hacke~, ~.S. EPA, re: Radiation at the
Sclvent Savers Site. March 31, 1989.
fro::1
Lette~ to Ms. Aloncarae DelRossi, Town Clerk of
Linck1aen, frc~ Jill Hacker, U.S. EPA, re:
Advisi!"lg the TOhn cf Lincklaen co~unity of the
E?A's work since Ma~ch, 1989. July 14, 1989.
Re::'2:i:::--.s
p. 1967-1993
Docur.'\entatio~
Repcrt:Fi~al e=~~unitv Relations Plan for the
Sol \'e!"lt Savers S:. te, prepared by EBASCO Servi'.es
Incorpcrated. Ja~uary, 1988.
of ether
Public Meetincs
p. 1994-2014
Repor~: Final Public In:o~ation Meetina Summarv
for the Solve~t Save~s Site, prepared by EBASCO.
July, 1989.
ProDosed Re~edial Action Plan
p. 2015-2018
p. 2019
p. 2020-2021
Proposed Plan concerning the Solvent Savers Site,
prepared by U.S. EPA. October, 1989.
Let~er to Marsden Chen, NYSDEC, from Joel
Singerman, ~.S. EPA, re: Draft Proposed Plan.
June 29, 1990.
Letter to Glen Angell, Lincklaen Town Board, from
Lisa Wong, U.S. EPA, re: Status of RIjFS.
-------
-
p., 2022-2023
t:. 202';-2051
p. 2052
'\.
Letter to the PRPs fror.\ Joel,S ingernan i U. S. .EPA,
re:! . Proposed Plan for the Solvent Savers 'Site. .
July 23, 1990.
Letter to Mars~e~ Chen, NYSDEC, f'~r.\
t' . S. EPA, re: F inalProposed Pla:..
1990. Proposed Plan is attached.
Lisa Wong,
July 23,
Le~ter to Richard L. Caspe, U.S. EPA, from Michael
J. O'Toole, Jr., New York State Department of
Environ~ental conservation, re: Draft Proposed
-------
,-
-------
-
o.
New York St.te Department of Envlronment.1 Con.ervaHon
10 Wolf Road. Albany. New YOrt('12ZU . ?OH)
ThoM.' C. Jotting .
Comm I'" "'...
~r. 'R:charo ~. Caspe. P.E.
t::ect~r
E~ergency an~ Reme=~al Respc~se
Div~sion
~.s. Envircn~enta: ?rcLec:iQn Agency
~ ~ P 2 0 1990
Regior. ::
26 FeQera~ Plaza
~8~ York, ~I :2078
Dear !-!.r. Caspe:
Re:
Draf~ Record c~ :c~~sion
Solvent SaV6rs S:te
DEC I.t. No. 70S8~2
1 a.T!'. p.;.eased to adv:.se you t~at t~e ~ew Yo~i< ~~2.~e .Departti",9:1t 0: -. :-;....:r~:'_::e;::.~~
Co~.serva+;:..o:: (~1S:EC) cO::C..lrs with the prov:"s':':::5 0: t~e ;:-e:...~ence:3 oo:::.:..-:~~:.
S?~:ifi~ally, tr.e ~ajor co~po~ents of ~~e se:e=~~= re~ed:es wi:: be;
- ,
~x~e~a~io:: a::d re~~va: 0: the ~~~ie~ dr~'s :~r o!!-site trea~~~~t =::=
ci.sp::>sal a~ 6~ appro'Jec Pes::>'..lrce Co::serve~:~:; a:"ld Recovery Act ("?:F~"',
hazardous waste facility;
:; )
Excava~ion of ap?roxi~a+;ely &Q,OOC cu~ic y~r~s of con~~Ti~a+;ec so::
(:..::c:;;=:..ng 1, O::J c'.l:ic yards of P:B-cc~ts.::,~~.;.';ed so:~);
3 )
O=:-site treat~e:':t \:s:ng :O'wi ~eITiperet~re t::e:-;':\a~ ex:raction ("L1':£") :0::
vola:.i1e c:-gar..:.c co:npou~ds ("VOCs") :ro~ :.:.g!-.:y cont.a..":,,inated soil;
4 )
Backfill 0: the excavatec areas with the t~e!ted lei: and approxi~a~~~Y
1,000 cubic yards o! clean fi:l (if rem::>~~: ~f the PCB-con~am~nate: s~:..:
for ~ff-site incine~a~ion i. aeemed ne:essa=y);
5)
£~~rection a~d on-sit.e trea~~e~t, using ~he~iccl precipitation, a~r
stripp:~g, and car~o~ aosorpt.ion of t~e co~:.~~ir.ated groundwater in t~e
~nderlying aqJ1fer;
~}
Rein~e:tion of the treated ~a~er into th~ ;~~~nd, and/or cisc~ar~e ~: :~~
trea~ed water ~~ sur!ace water:
7)
Disposal of ~~e resid~a16 from the treated ;=oundwater at an of!-&i~e
-------
'.
Mr. nicha::d :...
Cespe, P.!..
Page 2
6)
'!:eae;.ab.:l.ity st.'.:dies wlll beconduc~ed du:':':-.; the remedle.: Quig:-. ::~ese
~o de~e~.i~e ~he~r.er t~e on-site LTTt p:o:ess is a~ approprie~e trea:me~:
met!1~a for t~e PCB-co:".":.a:r.ir.atea soil. 1£ -:.he ":.reetabHi ty st\:cy res1.:.::£
ind~ca~e t~a~ ~7~E is an appropriate tree:~e~t. metnoc, the~ th~8
t.e:hi.olo~y wit:. be \:~i:ized to treat ~he e~::e'Jated soil co::ta.":'.~ne.-:.e: \.:~-:.:-,
PCBs. S~.culd the findings of t~e trea't~::':'::':y studies in~::'cate thao: :he
o~-s:teL~:E process wo~:d no~ prov:de tt~ des~::e: de;::Qe of trea~,e~~,
t~e~ the P:B-cor.t~~~nat8~ 6ci: excavatec ~~::. be ::e~ove~ !cr o!:-s::e
:ncinera-:.ion; a~d
9)
T:eatab:lity st.~cies w~ll b~ co~:u:ted d'.:::~; t~e reme~:a: desi9~ ?~a6e
to Qet~:~~~e whet~er t~e sc~l !:u8hi~g a~d.'=~ vap~r extra:~ion p:~:esses
are appropr:ate treatme~t met~ods for t~e ;x:avatec 60::'1 cor.t~.~r.a:e:
~i:h low leve: V~Cs. If ~he treatabili:y ~:~cy resul~& i~d~:a~e ~~a: C~6
o~ bc:t cf t~ese ~e~:.~~lo9:es are apprc?r::'~~~ ~re8~m@~t me~~o~s, the~ :~e
~~ b~~~ cf these ~e:~~ologies ~ill be ~:i~:zec ~o trea: ~~e 8xca~a~e:
sell contBIT:~:iate: ..i -:n VOCs. Sho...ld the :: :,.~ings of o:ne ~~ea-:ab~:'::y
s:udies indi~ate -:.ha": :hese o~-site :re8:~e~: processes wo'.::~ C~~ ;~~~!~e
the desi::ed de~ree cf t~ea-:'~e~t, the~ -:hi ~~~tar..lnated 60il ~ill ~~
treate: on-site ~sin9 L~:E.
::e::',5 8 Ii:'!:
9, (ad~:~io~s to t~e
t~e Ger.e~a~ ~:ectri:
mc~e~a:y &avi~;s.
:ei'':'...': ':':"'.
in1 tiel c:'a:t ::.::), ere a==e?:a:::e,
~>-., tohe trea,:c;;i.lity st.uci~s cc'..:.:d
E~:".:c as
p:"opose:3 by
si~Ir.~fi=,. '.~
We a~so ac:ept ~~e results
t~e NYS~EC sta:: re=e~v~~g
and cat.a ser.erated £0: :r.e
the US~?A's stete~en~: .
of your ~od&l, but :\:! acce?te~ce :8 ~o~t:~;e~: C~
a copy of and ::o:':!i~~:..~.; t.i':e e:L:a:y c: rc~= =-==!::.
Solve~t Savers site. 5bsed or. t~~s, ~~S;~: a::e~:s
"Areas ~, 3 a~d 5, which co~tain :esser c:~:sn~ra~ions of vo:s be:=~
healt.h-based leve:s, do no-:. re~u~re remeoi!!.:on. The vast IT'.ajor::;- ~!
conta;.,ina~&d sci~, ~~c~ntin9 to ep~~cxim8:e~;. 59,000 c~bi~ ya~ds, ig
:oceted in Areas 2 an~ 4.
T~e ~~~tia: &0:1 cleenu? leve:s, wh~ch are ~~5ed on e~ avera~e 0: t~e
mocs:-derived cleen~p :eve~s for Areas 2 ~~C 4, are 8& follc~s:
Tetrachlcroethene
Trichlcroe~~e~8
~,l,l-:richloroet~ane
:,1,2-~ri=hloroetha:.e
Toluene
1,2-Dic~loro.~her.e
Xylenes (tota:)
- 2.2 P?m
- C.8 ppm
- C. 9 P?IT'.
- 0.4 pPIT',
- l.S PP~
0.8 p?~
- 3.1 ppm
--'" ...,
w.~-~ ;
(Area :2
(Area :2
-------
Mr. ~~cha~d L. :a5pe, r.L.
Page 3
!~es. :eve~s rer~eser.t average co~tar..ir.a~: :c~:er.~rat~ons of lndica~:=
c~e~.:.:als .:.r. ':.he 6=:: whi:~...ill th.ore~i:.=.::y prod'.:.:e c:cnte.."'!\ina~t
co~~e~:~!:.:.or.s i~ :he ;:c~n~wa:.r at ~he nearest rece? ~i w~ic:h ~ee~
potable ~a~er s~A:.dards. ~he ~ea~est re:ep:o= i& cO:'5~~ered to ~e ~~~
CreeK. II
S~c~:d
orcin.
po~r.ts
N"!S~!: d:.se;ree
Please co~ta=':
fo~ discuas:cn.
wi':.~ yo~r f~nd.~;s, a
Ma:sde~ C~er. at (5:6)
re=?e~in9 of :he RC~ wi~l be ~~
4:~-~3~9 ~f ~here are furt~er
Sinc:.n:y,
2'. (S;.~QQ.
-
Edward O. Sullivan
~eputy CO!:'.:f.iss~on'r
-..
..- .
"
,,;.
-------
.
We:1 N Se:RG, Be: RGE:SON & N E:U.MAN
Ms. Lisa K. Wong
september 7, 1990
Page 3
that the alternative remedy would not achieve the established
remediation goals.
Please note that the enclosed comments also rec6mmend,
to address a matter not considered in the FS Report, that PCBs in
soils be disposed of in an off-site landfill, provided the soils
meet applicable treatment standards under the RCRA land disposal
restrictions. Those PCB soils not capable of meeting applicable
treatment standards would be thermally treated on-site. The
thermal treatment of these soils would result in the condensation
and collection of PCBs in the off-gas handling system, and the
resulting condensate would be destroyed by off-site incineration.
This approach avoids the off-site transport of unnecessarily
large volumes of PCB-contaminated soils, and avoids the ultimate
land disposal of large volumes following incineration.
Conestoga-Rovers is prepared to meet with you at your
earliest convenience to discuss issues raised by our comments.
Please do not hesitate to contact the undersigned or Mr. Frank
Rovers should you desire further information or wish to discuss
these issues.
Sincerely,
~'-$! ~~\.......~.
Reed W. Neuman
Counsel for Bristol-Myers
Squibb Company
~_.~ jl.
--.J c.-t-.. ~~'.
~.-'
John Hanna, Jr.
Counsel for General Electric
company
cc:
Joel Singerman
-------
. .
CRA
Consulting Engine.rs
CONESTOGA-ROVERS ., ASSOCIATES liMITED
651 Colby D"ve.
Waterloo. O~:a"o. Canada N2V 1C2
(519,884.0510
September 7, 1990
Reference Ko. 2077
Mr. Joel Singerman; Chief
\Vestern :Kew York Remedial Action Section
United States Environmental
Protection Agency
Region II
26 Federal Plaza
Ne'w York, New York
10278
Dear Mr. Singerman:
Re:
Comments on RIfFS and Proposed
Plan for the Solvent Savers Site
On behalf of General Electric Co. and Bristol-Myers Squibb Co., find attached
comments on the RIfFS and Proposed Plan for the Solvent Savers Site.
A separate cover letter is being forwarded to you from John Hanna, Jr. (\Vhiteman
Osterman & Hanna).
Should you have any questions, please do not hesitate to contact us.
Yours truly,
CONESTOGA-ROVERS & ASSOCIATES
JOffl-
r, /
,I .
r . Frank A. Rovers, P .Eng.
FARfcdd/1
C.c.
John Hanna, Jr., Esq. (w/encl.)
Reed Neuman, Esq. (w/encl.)
James Doyle (w/end.)
Mike Ianniello (w / encl.)
Ken Burns (w/encl.)
-------
.
-------
SOLVENT SAVERS SITE
LINCKLAEN, NEW YORK
-------
..
'.
-------
CHENANGO
NORTH
Citizens
8gainst
Radioactive
DumpinE,
~
August 3,
1950
Ms. Lisa Wong
U.S. E.P.A.
N.Y.-Carribean Remedial Action
26 Federal Plaza, Room 29102
New York City, New York 10278
Branch
Dear Ms.
Wong:
I am requesting a copy o~ the RI/SS and the Proposed Plan
~or the Solvent Savers, Linklean, Chenango County site. #,vqQ~2
This request is made under the Federal Freedom o~
In~ormati~n Act and will come to Chenango North, Citizens
Aeainst Radioactive Dumping, a not-~or-pro~it organization,
less than ~ive miles ~rom the Solvent Savers site.
It is essential that we get these documents as quickly as
possible so that we have time to review them before the
pu~lic meeting in Linklean, on August 13, 1990, so that we
can ~ormulate our questions appropriately.
Very truly yours,
.Su.
-------
'.
Cortland County
Low-Level.Radioactive Was'te Office'
County Office Building 60 Central Avenue
P.O. Box 5590
Cortland, New York 13045
Telephone (607) 756-3444
Cindy M. Monaco
LLRW Coordinator
Denise Cote-Hopkins
Assistant LLRW Coordinator
August 3, 1990
Ns. Lisa Wong
Remedial Project Manager
VS Environmental Protection Agency
Room 29-102
26 Federal Plaza
~ew York, ~l 10278
Dear Ms. Wong:
Pursuant to the Freedom of Information Act, I would like to request
the following documents on behalf of the Cortland County governmer.t. The
documents concern the Solvent Savers Site (site code # 709002) at Lincklaen,
~ew York.
The site rests approximately 1 ~ile from the Cortland County border.
Mud Creek, which flows past the site. also flows through the town of Taylor.
Cortland County. The town of Taylor has had two sites selected as potential
repositories for low-level radioactive waste.
The documents which we request include:
The Work Plan and Report for:
Phase I
Phase II
Remedial Investigation
Supplemental Investigation
Feasibility Study
(if any)
The Selection Process for Remedial Alternatives
The Record of Decision
It is our understanding that written comments must be submitted to you
before August 23. 1990. Having just received public notice in the Cortland
Standard newspaper on August 1, 1990. we. consequently, ask that this request
be acted upon expediently.
-------
Sincerely,
~~ (J~- t Jf ~~-/j
Denise Cote-Hopki~s
Assistant LLR~ Coordinator
-------
--
SHERWOOD BOEHLERT
..
25'.. Dr.'.ICT, Nt. YO..
~tIi~.
~
Q.:ongre5s of tbe '(!1 niteb gs,tate~.
~OUSt of ~tprtstntatibts
liBasbingtcn, 13~ 20515
".''''''G'fO.. OUltl
112' i.O"'C;WO.ft04 "'OUSI. O'IICI IUIi"OI...:'
WASWIHGTO" oc: :c~ I ~
(2021 225-36B
CO""'TTUS:
SCIENCE. S~ACE. AND TECHNOLOGY
PUIILIC WOAKS ANO T"ANSPOR-:-ATION
SELECT COMMITTEE ON AGING
C'''''..\. .,,,'et
NORTHEAST.MIDWEST CONGRESSIONAL
. CCALIT:ON
U.S. DELEGATION INTERPARLIAMENTARY UNION
ALlx."'OEa .''''''''( 'IDf.At,. 'UIL:I"'~
10 '''0&:1 STaUT
UTICA ...'" tJ!::1
13' 51 793-8' 46
TOl\, '.1£ '-IOO-2JS-2!:!
August 10, 1990
Ms. Lisa Wong
Remedial Project Manager
U.S. Environmental Protection
Roorn 29-102, 26 Federal Plaza
New York, New York 10278
Agency
Dear Ms. Wong:
I am following up on a preliminary inquiry by my staff to
endorse the Cortland County government's request for a copy 0:
the following documents regarding the Solvent Savers Site (site
code #709002) at Lincklaen, New York (copy enclosed) .
The documents requested by the county include:
- Phase I
- Phase II
Remedial Investigation
- Suppleme'.tal ~nvestigation
- Feasibility Study
- Selection Process for Remedial Alternatives
- Record of Decision
I appreciate your offer to provide access for Cortland to
this information in your New York City office. But given the
August 23 deadline for written comments, county officials will
require uninterrupted access to these documents if they are to
provide an accurate, quality presentation of the county's views.
The final decisions on this matter should be based upon the
best information available. Providing Cortland county with a
copy of these documents will allow them to do their part in
providing that information.
Thank you for your assistance. Should you have any
questions, please don't hesitate to call my Washington office at
(202) 225-3665.
SB:th
-------
:
Low-Level Radioactive Waste Office
County Office Suilding 60 Central Avenue
P.O. Sox 55SC
Cortland, New Yor~: 13045
Telephone (607) 75&-3444
Cindy M, MonOl~:
c.~r:ISt! Co~e.:-::=" -:
LLRV,' CO:li::iH3tO.
t-ssis~.:.:~ L~~.,., :'::.~.-':::
.~.'';;U.: :
::.. : 9 ~ (.
- '.
Z\.e::-~e~:..al
\.;cr,~
t' :- 0 -~ e :: r-: a ~~ a ~ c :'
~:~. Lis.!
..- - ..
~- ~~~:~cn~~~:~-
~.:..:::: ::'::--.
..~..~-=;'::::
,- .," ""',
t"OO:7. -,:-......;~
~;. Fe~~~a: P:a:~
1\ c -,,' ): -: ::.~. K"~
lr~"':
o..J_I--
uea:- :':.=.
\\c::;:
F~=sua~: tc th€ Freedoc c~ !n~or~a:ic~ A::. I ~=u:~ li~:~ :. r~~~=E:
the icllo~~::g ciocu~e::ts 0:: beha:~ c~ the Cc=tlan~ Cc~::ty go~~=::~a~: ..,-
documents cence:-:: t~~ Solve::: Savers Site (site co~e r 7090C: a.: :~~:;;:ae~,
l\e\.." ): ='=i~.
The site rests approximately 1 mile iro~ the
Xu: Creei:, which £lo~s pas: the site, als~ flows
Cortla::: County. The to~:: 0: Tayler has ha~ two
re?ositories for lo~-leve: radioactive wast:.
Cortland Cc~:::~ ~::-~~~.
through th~ :~~~ ~~ 1~'.::~.
.. -
s~tes se~ect~~ a~ ~::£~:~~-
T~e cocuments which we-request include:
The Work Plan and .Report fo::
Phase !.
Phase n
Remedial Investigation
Supplemental Investigation
Feasibility Study
(if any)
The Selection P=ocess fc: Remedia: Alternatives
The Record of Decision
1: is our understanding that written comments must be s~bmitted t~ y~~
before August 23. 1990. Having just received public notice i~ the Co~:la~c
Standard newspaper on August 1. '1990. we, consequently, ask tn~: ti,~~ rc~~es:
be acted upon expediently.
-------
.
~ugust 13, 1990
Questions on the Solvent Savers Site, Lincklaen, ~7
Submitted by~ Denise Cote-Hopkins, RD 2 Box 4555 - Taylor,
Cincinnatus, NY 13045
1) Why is. there only a ten day comment period from the" tLme or
the public information meeting?
Do you ever extend deadlines?
Will there be a "public hearing?"
Are there any other occasions for public comment?
remediation?
During
2) Why did this site make the National Priorities List?
rank is it: nationwide, statewide?
What
3) Exclusive of community comment, would there be any change
in the preferred method selected?
4) Would you draw a schematic of the proposed plans?
5) What is your "emission treatment" uS stated on page 19 for
soil, and "air emission controls" for ground water as stated on
page 20? How are they deemed necessary? Can the community
affect this?
6) Emissions (may have been answered in #5)
a) Ground Water method 4
Will a carbon filter be utilized to trap the air which leaves the
air-stripper? If not, what percentage of the contaminant is
being trapped in the planned carbon filtration for the water
which leaves the air-stripper? And, what percentage of the
contaminant is leaving via the air? In utilizing preferred
method GW-4, are the materials essentially being transferred
from the ground to the air?
b) Soil alternative method 5
While the scrubber will remove particulate and acidic gas, are
other volative organic compound vapors released to the
atmosphere, or would they be allowed to remain in the soil; thus,
accounting for the TCLP (Toxicity Characteris~ic Leaching
Procedure)?
7) Who will" do the clean-up? US, DEC, and sub-contractors?
the community comment on proposed contractors?
-------
.
8) Has an on-scene coordinator been selected? How will we
obtain notic~of such, and how may we communicate with the
cocrdinator?
9) Were air s~~ples taken? Were soil, air, g=ound and surface
water samples-taken off site? Where? Were samples handled
timely to prevent deterioration (cite Weston lawsuit)?
10) As the site effects both Chenango and Cortland counties,
could the public libraries of both county seats: Norwich,
Cortland, and also at Cincinnatus -- locally most available be
repositories? Do you ave available the EPA's Community
Relations Pla~? May it be sent to th7 r~,p~sitories?
\;,".~c""c.\.~f'~ 'oS +.x«~""&«"J ~(S '.A((~Qj,~-t,,- -rr:rl.Jor~~ peepk
11) Will remediation reports (monitoring, etc.) be available as
the work proceeds? Will they be ~ade available at the
repositories?
12) Have any health studies been conducted in the community?
If so, what were the geographical parameters for study, and is
this information available? Is there any need for a baseli~e
study prior to remediation?
13) Who are the prp's?
-------
TOWN .OF LINCKLAEN
County 01 Chenango
Alondarae Del Rossi. Town CIerI<
DeRuyter. N Y 13052
315852-9601
August 17, 1990
United States Environmental
Protection Agency Region II
Jacob J. Javits Federal Building
New York, New York 10278
Attention:
Lisa K. Wong
Project Manager
The Town Board of the Town of Lincklaen wishes to thank you
for the meeting held last week at the Town Hall.
The Boare is in support of the Proposed Plan of clean-up for
the Solvent Savers Site in the Town of Lincklaen, especially
Alternative SC-5 and GW-4.
Very truly yours,
.
4 u'
. , .: . ,.f.,1 ;' ..
- t...(. "- ,;,,_.1. , ..L' ..- -~'. /!... - '-
Alondarae Del Rossi
Town Clerk
-------
.
CitizCllS
&gainst
Radioactive Dumping
... .AmY J\T.T, C'Tllr::n T'r'11.11TJ('JI
lo.ugu~t 30, 1990
Ms. Lisa Wong, Project Manager
Solvent Savers Site
EPlo., N.Y./Ca~ribian Remedial lo.ction Branc~
26 Federal Plaza, Room 10278
New York, New York 10278
Dear Hs. Wong:
The citizens in Chenango North, who all live between 3 and
five miles down wind of the Lincklean 'Solvent Savers' site, are
not convinced that SC-5, Excavation/low temperature thermal
extraction/on-site redeposition, is the best alternative for our
well being.
It is clear that the excavation and the emissions possible
from thermal treatment, are risks which could represent health
hazards to our families.
The in-site vapor extraction, by contrast, is far better in
its short term effectiveness, and results in the same outcome,
as far as long term resolution of the problem.
Chenango North asks that the decision ot implement this method
is delayed until we have the opportunity to review the detailed site
review, which just arrived yesterday, and that we have another
opportunity to meet with someone form your staff to review the
in-site process in more detail.
With that in mind we invite your representative, and will
provide a meeting place, if the Lincklean Town Hall is not
available.
We ask that no media be present, and that the meeting be more
informal in nature than our previous meeting.
. I would like to take this opportunity to remind you that
the documents we requested through the Freedom of Information lo.ct,
were promised without charge. Indeed, the risk to our community,
and the impossibility of our community to access the Pond Store
documents, make it imperative that these documents be available
for detailed examination. To charge a low income community under
the circumstances, would be at the very least, inappropriate.
Contact #'s:
607-863-3872 home
607-753-0106 work
or by address below
Very truly yours.'
:)~: .' .
:5~'-j(-:': L (.I ,"J'-'1!--
Susan B. Griffin,
Coordinator, Chenango North C.lo..R.D.
... and all other pOllution
-------
Pass & Seymour
t1legrand .
;'
/
~.ug1-!st 3:',.
1.9::0
To:
Ms. LiEa K. Wong
P~cj~c~-M=na~e~ .
W~ste~~ N~w Yo~k R~m~dia! Actio~ S~ctic~
U.S. Environmental ?rctection Ag~ncy
26 Fe::-3;.:: ?laza, Rocm 29.-102
N~w Yor;':-. N. Y .
10278
?rom:
Edward F. Ea~mgras
~, . _. . ~
!"".!.a!"".: =.:-1g!r~-:~r-ln;- !..t.::.nc;er
Pass £, SeY::101..lr
50 Boyd Avenue
Syra.:-use. N. Y .
1310~
r~s. Wong.
~avin~ review@d your Fina: Feasibility S:udy R~por: of ~~:y 2?
l,;:;e., as ""'ell as attending Y0ur meeting c: ~.I-1gust ::'3. 19:-0 e.': -...
Lir.C':-~l.~-:-r: 70wn ~~ll. the f':1~10wing ql.lesticms / CQm.~en:s are
submi:ted for review.
1.
During the course of the mee:in~. r beli~ve it was sta:ed by
a member ~f you~- party th~t no TCE vapC'rs ar€ b€in~ e~::t~~
from th~ Site. and that there was no detectable TCE
contami~a:ion present in Mud Creek 200' downgradient from t~e
Site. It was also state~ by a reppesen~ tive o~ the New Y:r~
=tate Fish and Game Age;.:y. that species of fish s~c~ as :~~
envi~onmentc:ly sensitive Dace are thriving within t~e Cree~.
My q~estior. is: Does a definable TCE plume exist a~ this
Site. and i~ so how does it compare i~ size to earlier tes:
data?
-
.:..
rt would appear from t~e d~ta C~ pages 18. 19. anc 56 cf t~~
Final Feasibility Study that all healt~ risks w0uld be
ccmpletely satisfied by Alternative 5C-3. What realistica.~ ~y
is gained by EPendin~ an addltiona~ $18.554.000 ?
3.
Flease expi~in the practical need that requires any fUrth~;-
effcrtE. thar. those that are defined in Alter~ativ~s SC-3
and GW-2 ? (8€2K & 9S5K:
4.
What are the incremental costs associ~tec. with the remova~ cf
TCE. PCB's. and METALS by area. for Alte~natives SC-4 and
SC-5 ? (7.887K vs 19.416K)
Si~cerely yours.
~_.p, ~-
Edward F, Baumgras
~-~
--~
Pass & Seymour, Inc.
Fax 315-468-6296
P.O. Box 4822
Syracuse, New York 13221
-------
September 5, 1990
Ms. Lisa K. Wong
Project Manager
U.S. EPA, Region 2
26 Federal Plaza
Room 29-102
New York, New York
10278
Dear Ms. Wong:
A group of Lincklaen's Citizens concerned about the cleanup
of the Solvent Savers Site met on August 27th. The purpose of
this meeting was to explore various possibilities of how to hel~
with a successful completion of the proposed EPA Cleanup.
The unanimous feeling of the Lincklaen residents is they
want to work in a positive, constructive way with the E.P.A.
Many of our group were dismayed that several of the people from
various groups involved with fighting the siting of a Low Level
Radioactive Waste Facility perceived the E.P.A. as their enemy.
We want to assure you that we believe you are sincere in
. your desire to see this problem resolved.
We look forward to future meetings and early complete
cleanup of the Solvent Savers Site.
Yours truly,
rl4; '1~
-------
.
~ ==:~~~
208.262 Ha:::c, :)rove
POBox 1C5'::~
Stamlor: C- Qe9Q~.2501.
203.' 352.7000
Internallonal Business Machines Corporallon
Septe~ber 5, 1990
Ms. Lisa ~ong, Project Manager
~estern Kew York Remedial Action
rSEPA - Room 29-102
26 Federal Plaza
~ew York, KY 10278
Section
Re:
Comments on the Proposed Plan and the Remedial Investigatio,,!
Feasibility Study for the Solvent Savers Site, Lincklaen, ~e~ York
Dear Ms. Wong:
The following comments are sub~itted on behalf of IB~ in response to the
rSEPA's Proposed Plan and Remedial Investigation/Feasibility Study (RIfFS)
for the Solvent Savers site in Lincklaen, K.Y. The Proposed Plan was
received in this office on August I, 1990, and the RIfFS on August E, 1990.
Subsequent to our receipt of the plan, you granted Mr. Guerin of this office
an extension until September 7, 1990, for IBM to submit written co~~~nts.
Fo= the record, IBM has maintained for many years that none of its waste
went to the Solvent Savers site. New York State, ihe USEPA and IB~, after
extensive search, have been unable to produce a single document that
indicates IBM waste went to the Solvent Savers site. In spite of this and
as a result of the USEPA's persistent belief that IBM is a "potentially
responsible party" (PRP) at this site, IB~ submits these comments for the
public record in order to preserve any future rights for possible challenge
to the selected remedy.
In general, concerning the RI/FS, there are a number of serious flaws which
have resulted in the USEPA's selection of a recommended remedial program
that is not cost-effective, considering the degree of risk reduction and
clean-up afforded. Of significant concern is the manner in which the USEPA
characterizes the potential, future use of the site and associated risks.
By assuming the site may some day be developed and inhabited, rSEPA is
grossly overstating the risk posed by the site. This is especially true
concerning the location of the site in the 100-year flood plain because in
New York State, under prevailing policies, it is extremely unlikely that the
site will ever be developed.
The RI/FS data base is limited in many respects. Although data collection
has continued for several years, the RI relies mainly on data collected over
a two-to-three-month period in 1989. As a result, seasonal fluctuations and
long-term trends are not presently understood. Also, much of the data in
the RI is suspect as evidenced by significant contamination of quality
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.
Ms. L. V:ong
Page 2
September 5. 1990
IB~ believes that much of the evaluation concerning feasible remedial
alternatives is premature and needs to be supported with additional investi-
gations into the nature and extent of the source. For example. the limits
of soil and groundwater potentially requiring remedial action have not been
adequately established.
Detailed comments are as follows:
1.
Risks posed by the site are overstated due to the ove~ly
conservative assumptions about the anticipated future use of the
site. The risk calculations are based on a hypothetical individual
livi~g on-site and drinking on-site groundwater for his entire
lire. Risks should be recalculated using current EPA methods and
modifying assumptions to present a realistic potential exposure
scenario.
2.
The FS did not consider a proper or complete range of remedial
alternatives. The FS should have presented a series of alternatives
with increasing benefits and risk reduction corresponding to
increased cost. Of particular concern is the lack of intermediate
alternatives between capping ($862.000). in-situ vapor extraction
($7.877.000). and low-temperature thermal ($19.416.000). It is
particularly confusing that the Proposed Plan stated that the
highest cost alternative was Alternative SC-6 at $96.800.000 and
involved off-site incineration, where the Feasibility Study did
not present any costs associated with this alternative. Also. the
proposed soil alternative in the Proposed Plan is stated as
costing $19,416,000. whereas the Feasibility Study states this
alternative will cost $22.900.000.
There are other cases of inconsistencies of this nature, which
seem to indicate that some additional studies or documentation was
generated that is not made available in the Feasibility Study.
3.
The FS was structured such that the complementary effects of
source control and groundwater remediation were not considered in
any technical detail. For example. allowing natural attenuation
of the groundwater plume may be appropriate if the VOC source is
controlled or removed. Similarly, hydraulic containment of the
site might eliminate the need for removing VOC sources altogether.
4.
The risks to workers and off-site residents posed by excavating
s01ls to a depth of 40 feet are dismissed by the FS. In fact, the
risk to workers posed by air emissions of VOCs may outweigh the
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~s. 1. Wong
Page 3
Se?tember 5, 1990
5.
The FS did not consider a range of objectives, clean up levels,
or .time~rames for ground~ater remediation as required by EPA
guidance. Instead, the FS selected drinking water MCLs and
considered only one scenario for groundwater extraction.
6.
The "Blank" sa:r,ples collected in May 1989 were contaminated by 20
volatile compounds, suggesting field and/or laboratory quality
control problems. Two of these blanks contained TCE at levels c:
200 ppb and 140 ppb. The RI did not account for this cor.tamin-
ation in interpreting the data. As a result, as many a~ seven 0:
the wells which the RI concluded contained low-level chemistry may
in fact be clean. Additional sampling is appropriate to resolve
the status of these wells.
i.
In-situ soil vacuum extraction (SVE) was considered in the FS anc
presented as similar in performance and reliability to low te~pcr-
ature thermal (LTT). Yet the proposed plan selected lTT over 5':::
at an added cost of $11.5 million.
Also, this rationale is extremely confusing since the "vitrifi::atio:-."
remedy was eliminated from further consideration because, as the
feasibility study states, "in-situ vapor extraction can achieve
the remedial objectives using a treatment process for less cost."
8.
A 10 ppm PCB cleanup level ~as selected based on TSCA Spill Cleanup
policy, which is inapplicable to remedial sites. Recent EPA
comments tend to suggest that PCB cleanup levels in soils could
range from 1 to 100 pp~ and still be protective of human health.
9.
It is not clear in the report why the May 1990 PCB samples were
taken and presented but not used in the risk assessment. Duplicates
#27 and #37 show a )IO-fold error, which is unexplained. It is
not explained in the report why no Arclor 1260 was found in this
sampling round but detected in the others. Also, the bulk of the
PCBs contained in the soils is Arclor 1242 and 1248 with Arclor
1260 constituting three percent of the surface-bound PCB. Although
it is EPA policy to base total PCB cleanup levels on one commercial
mixture's toxicity, there is little correlation at this site between
the cancer risk level calculated and the substance-specific risk
present.
10.
Exposure assumptions for direct contact with on-site soils and
sediments as well as dermal exposures are overestimated by a
factor of~ten. The number of days exposed/year was calculated
using 24 hours per day exposure. This is incorrect. The proper
exposure durations were accounted for in the calculations
-------
Ms. L. V:ong
Page 4
Septe~ber 5. 1990
11.
All risks-were assumed to be additive. Only cancer risk anc
systemic toxic~nts with similar target organ effects are additive.
If you have any questions concerning the above com~ents. please contact me
at (203) 35~-794~.
Sincerely.
~
... .,/'- T. D. Morris
- Environmental Engineer
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September 6, 1990
Ms. Lisa Wong
Remedial Project Manager
US Environmental Protection Agency
Room 29-102
26 Federal Plaza
New York, NY 10278
Dear Ms. Wong:.
I write to comment on the United States Environmental
Protection Agency's cleanup for the Solvent Savers Site in
Lincklaen, New York. It is my understanding that the deadline
of August 23, 1990 has been extended to September 7, 1990.
Th~_e comments are in addition to the written questions
which I submitted at the August 13, 1990 pUblic meeting.
I have met with members of our local organization, Taylor
Against Low-level radioactive waste, many of whom are immediate
downstream neighbors to the site. Some of their comments are
contained within.
HEALTH RELATED ISSUES
The most obvious problem is that health risks have not been
explained to the public in plain English. Neighbors to the site
haven't technical expertise. While certainly it is important
that the EPA report in a technical manner, additional translation
into commonly accepted terms would have been beneficial. The
section on health of the "Proposed Plan'for Solvent Savers
Lincklaen, NY" is just beyond everyday comprehension. The public
has gained little or no knowledge of the risk to which they've
been exposed. Thus, I would ask that health problems be restated
in ~anguage which a layperson may comprehend.
More specifically:
Explain what the carcinogenic and adverse non-carcinogenic
-------
Explain your risk assessment results.
health risk assessment and when?
Who conducted the
Explain excess lifetice cancer risk with!
EPA's range.
Explain hazard index.
Explain reference doses.
Please clarify "assumed exposure scenarios." To what time
period does "current", and "future" exposure refer; that is, does
current mean one exposure, one year, sixteen years' (current
lifetime of site)? Why hasn't "future" exposure been applied to
pathways to the neighboring residents, but only to on-site
residents? Does the term "future" reflect prolonged exposure?
Are similar risk analyses calculated on remediation
activities?
As stated on page 6, "Actual or threatened releases of
hazardous substances from this site ... "may present a current or
potential threat to public health, welfare, or the environment."
If it may present a current threat to the public, etc., why
hasn't a health survey been done for people and bovine herds to
determine if there has been damage done? If there is regulatory
policy regarding this issue, please include references in enswer.
Are there any plans for current or future health monitoring?
Is there any mechanism through which this may be pursued?
REMEDIATION ISSUES
--
- .
Soil ./
.,~;ferred method chosen, SC-S is acceptable as a -
/remediation alternative. It is impera~r;-tnat all
'P1'e{"""~iORS are taAc:U.'t.o prevent community and worker exposure
to low-level emissions. As was described at the public meeting,
it is my understanding that the after burner would destroy the
VOCs, and that the scrubber would filter particulates. These
should not be designed out under any circumstances. Even if the
EPA should find through "treatability study results" that the
extra measures are unneccesary, the emission controls must be
instituted for the following reasons: 1) at present the materials
which are in the remaining barrels has not been identified; 2)
ther~ exists the possibility of treating more densely
contaminated soils -- a surge, which would render treatability
results inconsequential; 3) a deserved "peace of mind" for the
community. 4) to remove the contaminants from the soil to air
is not acceptable. Even -:hough there may be a potential for
photodecay, etc. in the air, it is particularly important that
-------
..
food production area. The possibility for bioaccumulation
exists in this agricultural setting.
- ~,-
- - \-
Explain the residual contamination level qf treated soil \. ~
which has passed the TCLP toxicity test. That-is, what are the \.
concentrations of contaminants in the soil when what is remaining'
is an It acceptable level?" - - -
It is not clear from what is stated on page 16 of the ---- --.
"Proposed Plan," to what degree metal compounds will remain in
the soil. Will they be removed at all? If not, why not? What
process could be utilized to remove these metals? What risk do
they pose if left in place? Consider the consequences if they
were to remain in place and were dislodged into the creek from
the cliff edge through natural erosion, or worse, a severe storm, .
-
For obvious reasons, the excavation should not be undertaken -
in dry seasons or in windy conditions where dust may carry the
contaminants away from the site. I recognize that some
individuals believe that a "bubble" should be utilized. Could we
receive more information on this? What are the pros and con~
regarding community and worker exposure?
-
Will all PCB contaminated soils be excavated, if not what -
concentration will remain?
Groundwater
I find the preferred treatment of GW-4 acceptable. The
additional carbon adsorption unit to filter the air from the air
stripper must be kept in place and not designed out under any
circumstances. All of the arguments raised regarding air
emission controls in SC-S above apply here s~ilarly.
-----
TESTING FOR CONTAMINANTS
Bioassessment
How far downstream were samples taken in Mud Creek? Were
samples taken from natural deposition areas further along the
creek where materials may have come to rest after being awash in
the stream?
How far downstream
evidence do you have to
metals detected "do not
organisms?"
were VOCs and metals detected? What
support the position that the VOC's and
pose a significant threat to aquatic
It is stated that "VOCs are rapidly biodegraded and exhibit
a low potential for bioaccumulation." This may be so~ however,
I have learned that a significant anomaly was found in testing
-------
unusual and perplexing. Could you please explain why, if the
VOCs are rap~ly biodegradable, that they appeared at all in t~~
fish? What is the toxicity of VOCs found in the fish samples?
If this is really so unusual why, was it not presented to the
public?
For the above question on VOCs in fish, as well as the
statement, "number of lesions in fish tissues were found," please
described what evidence you have to support the position that
"none can be attributed to the contamination at the site 0= are
indicative of serious health problems." Additionally, who made
this determination.
QUALITY ASSURANCE
The observation was made that the Roy F. Weston company
performed work for the bioassessment. The community is familiar
with the company and feels suspect of any of their actions.
Simply put, they do not have any credibility in the eyes of ou=
community. An EPA settlement of $730,000 is evidence which
questions the integrity of work performed by Roy F. Weston. A
consent judgment was signed as a resolution to the EPA's inquiry
into alledged practices by the Lyonsville, PA unit of the
company. I note for the public record statements made in
the February 14, 1990 "Superfund Report" page 6 - 7:
"The contract laboratory, a division of Roy F. Weston, Inc.,
falsified the dates on which tLme-sensitive Superfund
contaminant samples were studied, negating the accuracy of
the analyses.... Because the samples were volatile organic
contaminants that dissipate over a short period of time they
must be studied within six to ten days of their collection
if an accurate assessment is to be made, EPA officials
say. . . .
Millions of dollars and human health risks are at stake
when each contaminant is studied as almost all the remaining
decisions about cleanup, including whether or not the site
should be remediated, are based on the results of the
analyses. First, whether or not a hazardous substance
exists is determined. If so millions may be spent on site
cleanup. If not the site could be allowed to stay as is.
If the study's conclusions are inaccurate, money spent on
cleanup could be wasted on a non-existent threat, or a site
posing a significant health risk may be left unaddressed.
The results of a sample analysis are also used in the
remedy selection process. Not only is the type of remedy
determined by the study, but how long the treatment will
last also depends on the laboratory...."
-------
Report" page 7 DOE Site Investigations - Cost overruns, flawed
studies faulted. In this report on RIfFS studies, it is stated
'that: "Roy F~ Weston ... failed to give special consideration to
wetlands on the site and provided no procedure~,for handling
radioactive waste that might be dredged up by drilling crews....
Although Weston tried to downplay the seriousness of the charges,
a DOE officiai acknowledged that the (future) work was being
split to encourage "improved quality assurance."
"-
In light of these grievous offenses, the community, here, .
really has doubts about the credibility of tests conducted by
Weston. What assurances can you give that such is not the case
for the Solvent Savers Site? Which lab performed the tests?
Who from the EPA oversaw quality assurance in sub-contractors?
Is there any review process in EPA to determine whether
fraudulent activities have taken place elsewhere? Can this
review be applied to the Solvent Savers Site?
-------- ,
SAFETY
_.
A fence and signs at the site are ashamedly long overdue. '
These measures should be undertaken immediately.
To reiterate, it is my understanding
stability along the creek is questionable
or other erosive action take place. What
-- before gnd after excavation?
that the cliff edge
should a severe storm
can be drne ar~ut this
--,
PUBLIC PARTICIPATION
I believe that it is the EPAs duty to fully ~nform the
public about the problems of the site as it is, or upon
remediation. The community has been exposed to the risk.
Unlike probably exposure, it is a fait accompli. The people
have a right to know and understand what this bad place means to
their lives. Thus, the EPA should be as forthright as possible
in informing the public, particularly, with regard to health
related issues. Again in reiteration, information should be
provided in common layperson terms to the greatest degree
possible.
Public notification should be made of that which is found
in the residual drums. Additionally, notification should be
made regarding the results of the model being implemented by EPA
to determine target clean-up levels in areas 1, 3, and 5 of the
site (page 3).
I formally wish to address the inadequacy of the established
repository for information. The libraries in Cincinnatus and
DeRuyter would best serve the public. It is simply ludicrous
that research should be undertaken at the Pond Store in between
-------
:
even a chair in which to sit. The store is remote and is open
only a few ho~rs beyond normal working persons' hours. It is
quite simply unacceptable.
The comment period of twenty-five days after the public
meeting really isn't sufficient time to adequately review
materials and produce comments.
Public participation and review should be particularly
encouraged and allowed during the design phase which I understand
is prior to the Record of Decision. Furthermore, with or withou~
the aid of the Technical Assistance Grant, the public ehould be
allowed to participate in all phases of the project. Indeed, it
is obvious that the TAG liaison is advantageous to the EPA in
that they must deal with one community liaison, rather than
hundreds of local technically illiterate people. If the.TAG
funding were not obtained, it should not forfeit the community's
ability to receive information or participate in commenting on
the project.
Finally, I wish to comment on two speakers' statements made
at the public meeting. Their sentiments were that contaminated
material should not be transported, nor disposed of in other
communities. This ideology parallels arguments for on-site
point-of-generation storage of noxious wastes -- you make it, you
keep tt. Wh~t is seriously wrong in the conclusions which they
have drawn is that this site is in essence an accident. They are
concerned with how a transportation accident spill be handled.
However, their argument for retaining the wastes at the site is
pathetic in that they fail to see that this site is in fact an
accident. Because of the sites proximity to Mud Creek, it's an
accident which has occurred on a moving highway no less. They
are trying to suggest that we should not clean-up this spill.
This is not a fair assessment of the situation. It is
particularly unfair to the local community, particularly, the
gentleman who watches the barrels go "snap, crackle and pop"
(reference to comment made by ~ediate neighbor to the site at
the public hearing).
Respectfully submitted,
~ .;"'I \.
,r'.,. -;..... I I .
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Denise Cote-Hopkins
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-------
.
WEIN8ERG, BERGESON & NEUMAN
1300 '::YE: ST~E:;::T, N. 'I/'.':
SUITE: 600 EAS,
WASHINGTON, D. C. 20005
REEO W. NEUMAN
1£..£=-CNt. a:2.ge2-=;=~
rA=S!"'I~~' 2~2.9-5=-:=;';
September 7, 1990
Via Telecopy and Federal Express
Ms. Lisa K. Wong
Project Manager
Western New York Remedial" Action Section
u.S. Environmental Protection Agency
Region II
26 Federal Plaza, Room 29-102
New York, New York 10278
Re:
Solvent Savers Site
Dear Ms. Wong:
Under separate cover we are transmitting to you today
the joint comments of General Electric Company and Bristol-Myers
Squibb Company to EPA's recent "Final Remedial Investigation
Report," "Final Feasibility Study Report," and "Proposed Plan for
the Solvent Savers Site," all issued on July 23, 1990.1/ The
detailed comments were prepared on the Companies' behalf by
Conestoga-Rovers Associates Limited.
We believe that the materials noted above, and other
information we understand to be considered part of the
administrative record for this site, do not support the issuance
of a Record of Decision at this time. In particular, as more
fully detailed in the accompanying comments, insufficient data
have been collected and reviewed in support of the selected
source control remedy alternatives, and the reports do not
adequately develop and evaluate pertinent alternative treatment
technologies. As a result, the FS Report presently does not
satisfy the requirements for the development, screening and
evaluation of remedial alternatives as specified in the National
Contingency Plan, 40 C.R.F. S 300.430(f), and thus in our view
1./
We understand that, pursuant to recent communications with
representatives of Conestoga-Rovers, EPA has extended to today
-------
WEINBERG. BERGESON & NEUMAN
Ms. 'Lisa K. Wong
September 7, 1990
Page 2
precludes EPA from finalizing a remedy decision' . set out in the
Proposed Plan. -
The accompanying joint comments both address the
deficiencies noted in the RI/FS summary documents, and provide
support for a more thorough evaluation of available alternatives
and provide a basis for a ROD to be issued. In particular, the
comments encourage EPA to develop further information regarding,
and then to evaluate i~plementation of, a combination of on-site
treatment technologies in furtherance of its stated source
control remedial objectives. We understand that in recent
discussions EPA staff have acknowledged that, with the coll~ctior.
of additional pertinent data and requisite field de~~nstrations,
alternative treatment technologies may, at least in part, allow
equally-effective achievement 'of EPA's remediation goals.
Accordingly, should EPA choose to proceed at this ti~e
to issue a ROD for this site, EPA should incorporate the
recommendations expressed in our comments to provide an adequate
administrative record supporting development and consideration of
a combination of complementary treatment alternatives to its
preferred source control remedy. The ensuing ROD would sanction
development of data and technical demonstrations to evaluate
application of the in-situ treatment technologies (vacuum
extraction, soil flushing and land application), to address at
least a'portion of the soil volumes at the site exhibiting
contaminant c=~centrations of concern. Should that evaluation
determine that an alternative treatment technology is not
appropriate or, should an alternative be provisionally authc~ized
but ultimately not complet~ly achieve clean-up goals, the ROD
presumably would re~uire implementation of the pre-selected
alternative (Alternative SC-5: Excavation/Low Temperature
Thermal Extraction/On-Site Redeposition). The particulars of
this approach are explained in greater detail in the accompanying
comments.
We understand that the EPA regional offices have been
encouraged to evaluate, in appropriate circumstances, the use of
such contingent remedial alternative selections in RODs, and that
formal guidance on this subject is expected to be issued in the
near future. We also believe precedent exists fer EPA to
structure a ROD in this manner, and for particular example direct
your attention to the ROD for the York Oil site in Region II, in
which treatability studies were authorized to evaluate the
effectiveness of an alternative remedy, with the understanding
that further study and implementation of a prescribed treatment
-------
..
JOINT COMMENTS OF
GE AND BRISTOL ON RIfFS AND
PROPOSED PLAN FOR THE SOL VENT SAVERS SITE
SEFTEMBER 1990
REF. NO. 2077
-------
JOINT CO~E~TS OF GE A.'JD BRISTOL O~ RIfFS
A. ~D PROPOSED PLA.1\; FOR THE SOL VE~T SAVERS SITE
I~TRODUCTIO~
The following reports were reviewed. and are commen ted
on below:
1.
"Final Remedial Investigation Report, Solvent Savers Site, Lincklaen,
Chenango County, r-.:ew York, July 23, 1990", Ebasco Services
Incorporated, EPA Contract 68-01-7250, (RI Report).
2.
"Final Feasibility Study Report, Solvent Savers Site, Lincklaen,
Chenango County, !'ew York, July 23, 1990", Ebasco Services
Incorporated, EP A Contract No. 68-01-7250, (FS Report).
3.
"Proposed Plan for the Solvent Savers Site, Lincklaen, New York", C.5.
Environmental Protection Agency, July 23, 1990.
RI Report
The RI Report does not present a sufficient data base,
particularly as to subsurface soils, for a full. determination of the aerial and
vertical extent of soils with concentrations abov.: the target soil cleanup levels
established in the FS Report. From the RI Report itself and other historic site
data of which we are aware, it appears there exist discrete site subareas
exhibiting a fairly wide distribution of contaminant concentrations.
However, the data presented does not allow for identification of such
subareas nor delineation of contaminant ranges. As discussed below,
I
confirming these areas and ranges could facilitate application of a
combination of treatment technologies to meet EPA's cleanup objectives.
The analysis and comparison of remedial subsurface soil
source control alternatives presented in the FS Report was based on the
analytical data from a total of 21 sample locations (16 soil borings and five
monitoring well locations) from which a total of 61 investigative samples
(excluding QA/Q!:. samples) were collected and analyzed for TCL parameters.
This data base unfortunately does not allow conclusions to be drawn with an
-------
~
acceptable degree of confid~nce as to contaminated soil volumes and the
delineation of contaminant ranges.
Given a less-than-adequate data base, the FS Report
indicates the following assumptions were applied to calculate the volume of
soil with concentrations exceeding the target soil cleanup levels:
1.
Boreholes with samples which exceeded soil target cleanup levels
(contamination) were included in the source areas requiring
remediation. .
2.
The boundary of contamination was roughly defined as the midpoin:
between clean boreholes and contaminated boreholes or 50 feet be\'ond
the contaminated boreholes if no adjacent samples \,,'ere available,
which may result in underestimating/overestimating the aerial extent
of soil contamination. For example, in areas where no adjacent
samples were available, contamination may extend beyond the
arbitrary distance of 50 feet which was utilized, or be significantly less.
3.
Although the depth of conta .~Lination varied i;'\ each borehole, the
depth of contamination for the source control area was defined as all
soils within the boundaries for the two areas, from ground surface to
the top of the water table, which will result in overestimating the
volume of soil contamination. For example, if the depth to the water
tabl.e is 30 feet, and soil exceeds the target cleanup level in only the
lower 15 feet, the volume of soil estimated utilizing the entire depth
would be twice as high as the actual volume of soil requiring
treatment.
Therefore, an additional soil boring and analytical program, as part of a pilot
study, would facilitate evaluation of the efficacy of a combination of
treatment technologies. We understand EP A recognizes that additional data
would need to be collected, during the remedial design phase, to address the
uncertainties and data deficiencies noted above.
-------
.
To address those issues, a soil sampling an'd analytical
program along the lines of that summ2:-ized in Attachment 1 should be .
implemented. The program will pro' ~e extensive geologic and analytical
data on the ~oils above the water table. This additional data will allow for a
more complete evaluation of the soil characteristics, ar . mainly, a more
accurate determination of soil volume above target de... . .up levels and
identifiCation of subareas and soil volumes potentially amenable to
alternative treatment technologies.
FS REPORT
1)
Remedial Technologv Screening
The FS Report identified and initially screened potential remedial.
technologies for treatment of contaminated soil. Under the category vi
biological treatment alternatives, the FS Report included liquid solids
contact, in-situ treatment and land application, all of which were
eliminated (without substantial c~:5cussion) as ineffective, unpro\'en
and possibly resulti1lg in C'eatior~ of more toxic contaminants (i.e. TCE
to vinyl chloride). We concur that liquid solids contact and in-situ
bioremediation are unproven and should be eliminated. However,
particularly as to soils with low levels of contamination, we believe
land application (also sometimes referred to as landfarming) may be
highly effective as a complement to other treatment technologies
designed to address high-level material. Accordingly, landfarming
should be considered for further evaluation as a support technology.
The technology of landfarming uses biodegradation to degrade the
contaminants in the soil. The basic concept involves providing a
favorable environment to enhance microbial metabolism of organic
contaminants resulting in the breakdown and detoxification of those
contaminants. It has amply been demonstrated that landfarming is
effective for treating low level VOCs.
-------
A local State experience with landfarming which was effective was at
Union Fork & Hoe, !\;ew York State. Ne\..,' York State has. approv'ec i:-.
the past and continues to do so landfarming as an eifecti";'e technology.
Pafficularly when applied to soils with relatively low contami:,,,~tior.,
techniques exist to substantially mitigate any short-term
. environmental impacts associated with landfarming. For example,
landfarming operations could be conducted with the benefit of nut:ie:1:
enriched surfactants that would assist in minimizing the generatior. of
fugitive emissions of VOCs and odors. Excavation and landfarming
activities would be accompanied by an ambient air monitoring
program and potentially an emission control system.
The concern, noted without discussion in the FS Report, that
biodegradation of VOCs at this site may result in more toxic byproducts
(Le., TCE-vinyl chloride) in our view is unwarranted. In particular, the
aerobic environment typically found in soils likely would inhibit rapid
formation of vinyl chloride. Moreover, any vinyl chloride that does
form likely would evaporate rapidly, given its short half-life in soil (0.5
to 2 days), In addition, any vinyl chloride escaping to the air woul.J
degrade rapidly due to reaction with hydroxyl radicals. Under these
circumstances, vinyl chloride likely would not accumulate in
quantities posing a significant risk to human health and the
environment: It should be noted that any landfarming implemented
will be monitored with an approved program. This includes air
monitoring to insure no off-site VOC emissions in excess of
appropriate standards.
The principal merits of landfarming as a treatment technology for 10\..,'
level contaminated soils are as follows:
.
Handbook 01 Environmental Fate and Exposure Data, Vols. I & n, Philip H. Howard. Ed. Le\\is
Publishers, Chelsea, Michigan 1989.
-------
.
Effecti veness:
Landfarming low level contaminated soils welL: significantly reduce
the .wxicity, mobility, and volume of organic contamination and
provide a permanent solution for low level VOC contaminated soils
Potential releases of VOCs and odors to the air would be controlled b\'
- .
one or a variety of techniques if required.
Implementabilitv:
This technology is technically feasible and implementable. Thi::
technology would require site controls to manage the soils being
excavated and landfarmed and the implementation of an air
monitoring program. A treatability study would be required to
evaluate treatment time for soils.
Cost:
The costs associated with this alternative include manpower and
excavation equipment, construction of landfarming treatment unit, air
monitoring costs, and confirmation analysis of soils prior to backfilling.
No long-term operation and monitoring is required. All costs are
capital cost and are expected to range from $50 to $75 per cubic yard of
soil treated.
Conclusions:
Landfarming is a proven technology for treating low level VOC
contaminated soils, and should be considered in conjunction with
other treatment technologies (Le. low temperature thermal extraction
for PCB contaminated materials).
The FS Report analyzes source control remedial technologies based on
the RI data. As discussed in the comments on the RI Report, the
subsurface soil data base is insufficient for a complete determination of
the aerial and vertical extent of contaminated soils above the target soil
-------
~
cleanup levels, and a determination of the location and extent of .
subareas with high and low-level VOC concentrations.
2)
Preferred Technologv Selection (:'\on-PCB Materials)
As noted above, the uncertainty of the volume of subsurface soils
above -target levels, and the location and range of contaminated levels,
precludes on adequate evaluation of the merits and optimal utilizatio!"'.
of a mix of treatment technologies.
Incorporated here are the previous comments that landfarming should
be considered as an appropriate source control remedy at least as to
soils exhibiting relatively low-level VOC contamination.
The FS Report analyzes six source control remedial action alternatives.
Alternatives SC-4 (In-Situ Vapor Extraction), SC-5 (Low Temperature
Thermal Extraction) and SC-6 (In-Situ Flushing) were all considered to
be in compliance with ARARs and provide protection of human
health and the environment. EP A found the three alternatives to
performee equivalently under long-term effectivel1ess, reduction of
toxicity, mobility, or volume, implementability and availability of
services and materials. The three alternatives varied somewhat as to
short-term effectiveness.
The FS Report states that Alternative SC-5 (Low-Temperature Thermal
Extraction) resulted in an increased short-term environmental impact
due to the excavation activities (e.g. track traffic, noise, dust, potential
organic air emissions), compared to Alternatives SC-4 and SC-6.
Alternatives SC-4 and SC-5 could be completed within one year after
start of construction and Alternative SC-6 would require 20 years to
achieve ARARs. However, the FS Report fails to acknowledge that the
20-year period to achieve ARARs for Alternative SC-6 may be
inconsequential since the candidate groundwater remediation
alternatives all include (with exception of 'No Action' and 'Limited
Action' alternatives), a long term groundwater pump and treat system
which would all require a 20-year period to achieve ARARs.
-------
3)
Tariet Soil Cleanup Calculations
The estimated volume of soil utilized in the FS, requiring remediatior;
was cased on several calculations presented in Appendix A of the FS.
The calculations are based on the mass balance equation:
Qd
=
Qa + Qr
where:
Qd =
Qa =
Qr =
flow out of mixing zone
flow in to mixing zone
vol umetric recharge
One of the factors used to establish the target cleanup levels is the
dilution that naturally occurs in the subsoil. An important component
of the dilution factor is volumetric recharge. The volumetric recharge
was calculated based on an assumed infiltration rate, applied over the
entire site of 2.45 ft/yr (refer to Appendix A of the FS Report). The
!'ource of this infiltration rate was not referenced and its derivation is
unknown.
An appropriate methodology to calculate a realistic infiltration rate is
the following water balance equation:
I = P - Ro - ET j: 5w
where
I
P
Ro
ET
.15W
= infiltration (in)
= total precipitation (in)
= runoff (in)
= evapotranspiration (in)
= change in soil moisture
On page 1-7 of the RI Report, the total precipitation was stated to be
40 inches/year, while on page 1-10 the runoff was estimated to be
21 inches/year. Therefore, using EPA's reported numbers,
approximately 19 inches per year is available for infiltration. In
-------
'.
. .
addition, it is noted. that evapotranspiration at the site will suve to
reduce further the actual amount of precipitation available for.
infiltration. Evapotranspiration at the site is dependent upon climate,
vegetative cover and soil moisture conditions. Typical values of
potential evapotranspiration in humid climates range from 18 to
21 inches per year (Fenn et al, 1975r. Therefore, the infiltration rate
used in the FS Report likely.has been overestimated by a factor of 5 or
more.
A more realistic, but still highly conservative infiltration rate for the
site would be 6 inches/year (0.5 ft/year). As a result, the EPA's
calculated Qr values, used in calculating soil cleanup levels, may be
approximately five or more times that which would reasonably be
expected. Therefore, the reported dilution factors would be much
higher. This significantly affects the calculated target soil cleanup
levels and therefore, the volume of soil requiring remediation.
It is understood that EP A currently is reviewing the use of a new
model to calculate target soil cleanup levels. Comments on the FS
cannot be finalized until the target soil cleanup levels have been
recalculated and the method of calculation reviewed.
4)
Treatment Technologies for PCB Materials
Although the FS Report does not address the issue, the process
description presented for Alternative SC-S may also be appropriate as
an initial treatment technology for PCB contaminated soils. Based on
discussions with a vendor, the dryer would drive off PCB
contaminants at the specified temperatures. The volatilized PCBs
would be condensed and collected in the off-gas handling system. The
volume of PCB contaminated material for off-site incineration could be
greatly reduced if the process equipment as specified in the FS Report is
ultimately the preferred remedial alternative for at least a portion of
the contaminated soils.
.
Fenn, D.G. et a!. (1975): Use of the Water Balance Method for Predicting Leachate Generation;
USEPA SW-168, 4Opp.
-------
Dependent upon the final volume of PCB contaminated soils, it may
also be appropriate to dispose of the soils at a secure TSCA/RCRA
permitted landfill. Bas~..l on the analytical data for existing drums
sampled at the site, all drummed material satisfy ""'.e treatability
standards specified in 40 CFR Part 268. Therefort .>hould the
technology of low thermal extraction not be required for other soils
on site and the PCB contaminated soils satisfy all applicable landiilling
restrictions, the technology of off-site disposal may be appropriate.
5)
Remedial Alternatives Screening
The FS Report does not evaluate the merits of combining selected
alternatives for non-PCB soils. At this site, for example, it may be
equally effective to address heavily contaminated soils by thermal
extraction and the remaining contaminated soils by in-situ vacuum
extraction, soil flushing or landfarming.
We believe EPA frequently has authorized the implementation of a
combination of complementary treatment and other apt>roaches to
achieve cleanup objectives, and we understand the !\:CP strongly to
encourage EPA to do so in appropriate circumstances. [See 40 CFR
9300.430 (a)(1)(iii)(c»).
PROPOSED PLAN FO~ THE SOLVENT SAVERS SITE (PRAP)
1)
Source ConttQL&ternatives
The FS Report presents a detailed analysis of six source control
alternatives. These alternatives did not include off-site indneration
for all soils. The PRAP should not include off-site indneration for all
soils as a selected alternative when this was eliminated in the FS.
-------
..
2)
Selected Remedial Plan
The PRAP recommends Alternative SC-5, Excavation/Lo\\:'
Tem,perature ThermalExtraction/On-Site Redeposition for source
control (of non-PCB soils), and Alterr.ative GW-4, Groundwater
Extraction/Chemical Precipitation/ Air Stripping/Carbon Adsorption,
for migration control (groundwater). Alternative SC-5 also:
recommends the excavation and off-site incineration of PCB
contaminated soils.
The FS Report evaluated source control Alternatives SC-4 (In-Situ
Vapor Extraction); SC-5 (Low Temperature Thermal Extraction); SC-6
(In-Situ 50il Flushing) as all being in compliance with ARARs and
protective of human health and the environment and all being
equivalent in regards to reduction of toxicity, mobility or volume,
implementability and long-term effectiveness. According to EP A,
Alternative SC-5 resulted in greater short-term environmental impacts
than Alternatives SC-4 and 5C-6.
The PRAP ac!
-------
. '
make vacuum extradion and suil flushing ineffective, at least as to
soils exhibiting relatively low VOC concentrations. It should be ~oted
that In-Situ Vacuum Extraction does not appear to be affected by the
per~eability of the soil, as documented by EPA in the report entitled,
"Technology Demonstration Summary - Terra Vac In-Situ Vacuum
Extraction System, Graveland, Massachusetts, EPA/540/S5-89/003
May 1989" (see Attachment'2).
Like the FS Report, the PRAP does not address the viability of a
combination of source control measures. Concerns regarding the
vadose zone and complexity of the geology may be reduced
substantially if the in-situ technologies of vacuum extraction or soil
flushing were limited to soils with low levels of contamination, thus
allowing for the selection of a combination of cost-effective remedial
alternatives.
Like the FS Report, the PRAP also does not address the viability of
treating PCB contaminated soils by low temperature thermal extraction
or off-site landfill disposal. As discussed previously, the low
temperature thermal extraction tet:hnology described in the FS is
appropriate for treating PCB contaminants and would significantly
reduce the volume required for off-site incineration. Also, the
technology of off-site disposal of PCB contaminated soils would be
appropriate if the soils satisfy all applicable landfill restrictions.
RECOMMENDATIONS
We recommend that the foregoing comments be incorporated into the
Record of Decision ("ROD") as follows:
1)
Recalculate soil target cleanup levels using a more realistic - yet still
conservative - infiltration rate (i.e., 0.5 feet per year).
2)
Collect additional data to: (a) more fully define the volume of soil with
concentrations of volatile organic compounds ("VOCs") above revised
-------
'.
3)
soil target cleanup levels; (b) comprehensively identify the aerial and
vertical extent of contamination; and (c) identify / specify the
concentrations of contaminants in soil throughout the site.
Follo'wing the data collection activities outlined above, select one or a
combination of the following technologies as to volumes of soil
containing VOCs: .
(a) in-situ vacuum extraction (Alternative SC-4);
(b) in-situ soil flushing (Alternative SC-6);
(c) excavation, landfarming, and redeposition.
4)
Should appropriate field tests or pilot demonstrations indicate that
none of the above technologies is effective, Alternative SC-S
(excavation, low temperature thermal extraction, and redeposition)
would be implemented as to those soils for which the above remedies
are deemed ineffective. The efficacy of a given technology would be
determined based upon the results of approved representative
sampling techniques and statistical procedures.
5)
Excavate and dispose of in an off-site landfilJ soils cant "ining PCBs,
assuming such soils meet applicable treatment standards under the
RCRA land disposal restrictions. All off-site shipments would be to a
facility with appropriate RCRA/TSCA permits and/ or authorizations
and would be conducted in accordance with the CERCLA off-site policy.
6)
Utilize low temperature thermal extraction as to PCB soils not meeting
appropriate treatment standards under the land disposal restrictions.
Treated soils would be redeposited on site. PCB condensate would be
sent off-site for incineration at a TSCA-permitted facility. All
shipments of the condensate would be in accordance with the CERCLA
off-site policy.
Figure 1 illustrates the overall approach outlined above.
-------
:
A:>DITIONA~ DA 7 A
CCL~EeiiON (R:)
DE!='INE VOLUhAE OF'
CON UVIN A TEJ SOIL
- .
pea C,",ARAC7::~!Z:: SOIL .1
VOL.,hAE IN VADOSE ZONE CR:~':ftA -~;
.C:;NCO"'7AM:NA i::J -s "'0 ~~£A -v~... - I
~ e:;N 7 AINING pca I
S"" . ("-0 CC"'-AI,I.\A-:', i
'-""
IN VA:JOSE ZOfljE . I-tIGH LEVE:.. VOCs. NO pca !~ VA:C~~ z:,~'. i
. LOW ~EVEi., VOCs. NO PCS
: -
YES
SA TiSr;ES
LA'i:) :JIS=OSA~
RESTRIC7iCi'.S
(TREA TI81i.,iTY
S7A~DAR:JS)
Il'ts
.
, .~-
"!s
OF. S: TE
LAND
DIS;::IOSAL
,""G,., LEVEL. VOCs
NO ;::IC8s
IN VAi)OSE ZCNE
LGW ...£"~- 'J:'c.s
~O ~:=s
i~ VACCS:: z:.~::
,
E"'O
1"'°
SELECT REhADIAL.
TECHNOLOGY F'ROhA
. LANDF' ARhAlNG
. VACUUhA EXiRACT,CPIi
. SOIL F'LUSHING
,
EXTRACTE:O
pce
LOW
TEvPERA 7:.;RE
THRERMAL
EX'!'RACT:ON
INCINERA 7E
OF'F'-SiTE
E""O
I~"
.
LABORATORY TEST/
F'IELD TES7
SELECTED TECHNOLOGIES
8ACKF',LL.
ON-SITE
,
END
DEVELOP .' IF' POSSIL8LE
F'IEL.D SCREENING PROCEDURES
TO DIRECT SOIL TO
APPRQPRIA TE TECHNOLOGY
NO
[NO
figure 1
ALTERNATIVES SELECTION AND IMPLEMENTATION FLOW CHART
CRA Solven t Savers Site
-------
..
ATTACHME~T I
SOIL SAMPLL'\G
AND
-------
SOIL SAMPLING
AND
.A.'!AL Yi"::AL PROGRA~1 SUMMARY
A subsurface soil sampling grid Wil1 oe established on site.
The sampling grid will be centered around Areas 2 and 4. Figure 1 presents a
site Plan and presents a sampling grid. The grid interval is based on 50-foot
centers.
A total of approximately 75 locations will be sampled.
Split-spoon soil samples would be collected at 5-foot intervals from ground
surface to the top of the water table at each location for a total of
approximately 450 investigatory samples. Each sample would be analyzed
discretely for Target Compound list (TCL), Volatile Organic Compounds
(VOCs).
Based upon the analytical results for the soil analyses, an
accurate calculation for the volume of soil requiring remediation can be
undertaken. This program will also provide extensive geologic data for the
-------
.'
WiEHQ
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figure 1
SOil BORING lOCA nONS
SOLvr.NI SAvrRS SHE
Linck/oen, New YOlk
. UW loUt
CRA
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---...-.--.----..------ ---
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-------
.
A TT ACHME~T 2
TECID:OLOGY DEMO~STRA TION
-------
~
&EPA
United States
Environmenta! Protection
Agency
EP AlS<40ISS'891003
May 1989
Technology Demonstration
Summary
Terra Vac In. Situ Vacuum
Extraction System
Groveland, Massachusetts
Terra '':ac Inc's yacuum extraction
system was demonstrated at the
Yalley Manutactured Products
Company. Inc.; site In Groyeland.
Massachusetts. The property Is pan
at thl GrOYlllnd WeUs Suplrfund
sltl and Is contaminated mainly by
trlchlorolthyllne (TCE). Yacuum
Ixtractlon Intilis remoYII and
venting at .olltlll orglnlc conatlt.
uents (VOC.) such a. TCE trom the
Y8dose or un.aturated zonl In the
ground by USI ot IxtrlcUon wills Ind
Y8cuum pumps. The proce.s at r..
mowing YOC. tram the Yldo.1 zone
ualng Y8cuum Is I patented procesL
The light-week test run produced
thl toll owing rl.ul&l:
. extraction of 1,300 Ib at YOCs
e. atl.dy dlCllnl In thl YOC
recovery rate with timl
e a markld rlductlon In soli VOC
conclntraUon In thl teat .rl.
e .n indication that the proclsa can
NIftOVI YOCa from Clay .trata
Till. Summlry WI' de"l/opltI b,
!PA', AI,Ie Alductlon Eng/nll,/ng
'lbolltO'" C/nc/nnlU. OH, to
InnounCI lei' tlndlng, Of UtI S"E
program demonstration that Is fully
documented In two separate reports
of the ume title (see ordering
information at back).
Introduction
Environmental regulations enacted in
1984 (and recent amendments to the
Superfund program) disco~rage the
continued use of landfilling o¥ wastes in
favor of remedial methOds that will treat
or destroy the wastes. The Superfund
program now requires that, to the
maximum extent practicable, cleanups at
Superfund sites must employ permanent
solutions to the waste problem.
The Superfund Innovative Technology
Evaluation (SITE) program is one major
response to the challenge of finding safe
ways to deal with waste sites. Part of the
program includea carefully planned
demonstration projects at certain
Superfund lites to test new waste
trt.tment tlchnologies. These new
Iitemative technologiel will dtstroy.
ltabilize. or treat hazatdous wastes by
Changing hit Chemical. biological, or
physical Characteristics.
Under the SITE program, which is
sponsor8d joinUy by U\e USEPA Office of
Au8arch and Development (ORO) and
-------
Response (OSWER). the USEPA selects
10 or 12 Superfund sites each year at
which pilot' studies of promising
technologies can be conducted. Sites are
chosen to match the effectiveness and
applicability of a particular teCiAnology
with specific waste types and local
~onditions. The pilot studies are carefully
monitored by the USEPA. Monitoring and
data collection determines how
effectively the technology treats the
waste, how cost-effectiv.ely the
technology compares with more
traditional approaches, and that the
operation can be conducted within all
public health and environmental
guidelines.
The Groveland Wells site was selected
for such a demonstration project for
1987. The site is the location 01 a
machine shop, the Valley Manufactured
Products Company. Inc., which employs
approximately 2S people and
manufactures. among other things. parts
for valves. The company has been in
business at the site since 1964. As an
. -: ,,~.~' ;:a~ of its building-wide operation
of screw machines. the company has
used different types of cutting oils and
degreasing solvents, mainly trichloro-
ethylene. tetrachloroethylene, tranS-1.2-
dichloroethylene. and methylene chloride.
The contamination beneath the shop
apparently is caused by a leaking storage
tank and by former improper practices in
the storage and handling of waste oils
and solvents. The contamination plume is
moving in a northeasterly direction
towards and into the Mill Pond.
The USEPA has been involved since
1983. when the Groveland Wells site was
finalized on the National Priorities List.
The initial Remedial Investigation (RI) of
the Valley propeny 'Was carried out by
the responsible party (RP). Valley
Manufactured Products Company. Inc. A
supplemental RI was conducted by
Valley in the fall/winter of 1987 to
determine more completely the lull
nature of contamination It the Valley site.
A. source control Feasibility Sb.ldy WIS
performed by USEPA to evaluate various
methods lor cleaning up or controlling the
remaining contaminants. A Record of De-
cision (ROD) for the site was lignecl In
October 1988 calling for vacuum extrac-
tion and groundwatlr stripping.
The Terra Vac system is being utiO-
In many locatiON ICtOSS the nation. This
report is based on monitoring the T e".
Vac patented vacuum eJCtrlCtion PfOCIII
(U.S. Patent Nos. 4593760 and 46G0838)
at the Groveland Wells site during a four-
and-one-half-month lield operation
perloc:l. with empha.is on a 5&-day
demonstration test active treatment
period. The report interprets results of
analyses performed on samples and
establishes reliable cost and performance
dlta in order to evaluate the technolo;y's
applicability to other sites,
The main objectives of this project
were:
. The Quantification of the contaminants
removed by the process.
. The correlation of the recovery rate of
contaminants with time.
. The prediction of operating time
required bel ore achieving site
remediation.
. The effectiveness of the process in
removing contamination from diNerent
soil strata. .
Approach
The objectives of the project were
achieved by fOllowing a demonstration
test plan, which included a sampling and
analytical plan. The sampling and
analytical plan contained a Quality
assurance project plan. This QAPP
assured that the data collected during the
course of this project would be of
adequate Quality to support the ob-
jectives.
The sampling and analytical program
lor the test was split up into a pretest
period. which has been called a
pretreatment period. an active periOd.
midtreatment. and I posttreatment per-
iod.
The pretreatment period sampling
program consisted of:
. soil boring samp..s taken with .plit
spoons
. soil boring samples taken with Shelby
tubes
e soil gas samples tak.n with punch bar
probes
Soil borings taken by split spoon
sampling were analyzed for volatile
organic compounds (VOCs) using
hladspace screening tlChniQUII. purge
and traP. GClMS procedures. and the
EPA-TCLP procedure. Additional
properties of the soil were dlterminecl by
sampOng using a Shelby tube. whiCh was
pressed hydraulically into the soil by a
drill rig to a totaf depth of 24 leeL These
Shelby tube samples Wire anaIyZ8CI to
determine physical Characteristics of the
2
subsurface stratigraphy .suCh as bu
density, panicle density, porosity. ph.
g~aln size. Ind moisture. These parat!",-
elers were used to define the basic SO!:
ct\arac~eristics.
Shallow soil gas concenlratiors we~e
collected during pre., mid., anI:: pos~'
treatment activities. Four shallow vac;,;u~,
monitoring wells and twelve shallew .
punch bar tubes were used at sarr:ple
locations. The punCh bar sarr:~les were
collected from hollow stainless ste;;
prODes that had been driven to a ce~:~ ~.
3 to 5 lee:. Soil gas was drawn u~ Ine
punch bar probes with a low.\'o:u~~
personal pump and tygo~ tl,;:JI~;. Ga:.
tight SO.ml syringes were usee tc ::~t:e::
the sample out 01 the tygon tucir.;.
The active treatment periOd cens:ste:
of cOllecting samples of:
. wellhead gas
. separator outlet gas
. primary carbon outlet gas
. secondary carbon outlet gas.
. separator drain water
All samples with the exception of the
separator drain water were analyzed or:
site. On-site gas analysis conSIsted 0:
gas chromatogrlphy with a fla~
ionization detector (FIO) or an elec!r~
calJture detector (ECO). The FIO wa:.
used generally to quantify the
trichloroethylene (TCE) and trans 1.2.
dichtoroethylene (OCE) values. while the
ECD was used to quantify the 1. I, 1.
trichloroethane (TRI) Ind the tetra.
chloroethylene (PCE) values.
The separator drain water was
analyzed for VOC content using SW846
8010. Moisture content of the separator
inllt gas from the wells was" analyzed
using EPA Modified Method <&. This
method is good for the tWo-phase lIow
regime that existed in the gas emanlting
from the wellhead. See Table 1 for a
tiSting of anaIyUcaJ methods a~~lied, .
The posttreatment sampling essentially
consisted of repeating pretreatment sam-
pling procedure. at locations as close as
possible to the pretreatment sampling
locations.
The activated carbon canisters were
sampled. as cloH to the center 01 the
canister as possible. and these samples
Wire analyzed for VOC content IS I
ChICk on the mat8rial balance for the
procell. The method used was P&CAM
127. whiCh consisted of aesorption of the
carbon with ~ and subsequent gas
-------
. )1. ,. An8lylical Me/tlods
Analytical Me!flod
1.5TM 0422.63
SW'S46' 9040
ASTM D2216.S0
ASTM 069S.7S
S\oYS45' 9071
F. Fl. I1.71S6. Vol. 51.
No. 216. SWS46' S240
SWS46'lI060
SWS46' 3S10
GCIFIO or ECD
GC:FID or ECD
SWS46' S010
SWS46' S010
Modified P&CAM 127
SW846' S240
Parame1er
Gram size
pH
Moisture (f 'O'C)
PaTfJc/e Clens,ry
Oil anCl grease
ErA. TCtP
TOC
HeaClspace VOC
VOC
VOC
VOC
VOC
VOC
VOC
SampJeSource
Soil borings
Soil borin,s
Soil Corin,s
Soil borinps
Soil /)Ori"ps
Soil bori",s
SOil bonn,s
Soil oorinps
50,1 gls
Process glS
Separator "Qu,d
Grolindwl/er
Activl/eCl carbon
'Soi//)Orin,s
'T'"rd EditJon. November '986.
Process Description
The vacuum extraction process is a
leCh~ique lor. the removal and venting 01
volatile organiC constituents (VOCS) from
the vadose or unsaturated zone of soils.
Once a contaminated area is comC)lelely
'efined. an extraction well or wells. de-
,nding UPO!'l the extent 01 contamina.
non. will be i:"lstalled. A vacuum system
induces air lIow through the soil. stripping
and volatilizing the VOCs from tho soil
matrix into the air stream. Uquid water is
generally extracted as well along with the
contamination. The two-phase Ilow 01
contaminated air and water flows to a
vapor liquid separator where contam-
inated water is removed. The contam-
inated air stream then flows through
activated cart)on canisters arranged in a
parallel-series fashion. Primary or main
adsorbing canisters are lOll owed by a
secondary or backup ad sorber in order to
ensure that no contamination ,.aches the
atmosC)here.
Equipment layout and
Specifications
The equipment layout is Ihown in
Figure ,. and specificationl are given in
Table 2 for the equipment used in the
initial phaSe of the demonstration, This
equipment was later modified when
unlores..n circumstances required a
shutdown 01 the system. The vapor.Jiquid
..pararor. activated cart)on caniat8rs. and
vacuum pump skid were Inlide the
building. wtth the stack discharge outside
the building. The equipment wlS in an
area 01 the machine shop where used
cutting oils and metal shavings had been
stored.
Four extraction wells (EW1 - EW4) and
four monitoring wells (MW1 - MW4) were
drilled south 01 the shoC). Each well was
installed in two sections. one section to
just above the clay ler., and 0"", section
to just belOw the clay .ens. The <,xtri1ction
wells were screened abOve the c:ay .nd
belOw the clay. As shown in Figure 2. the
well section below the clay lens was
isol.ted Irom the section above by a
bentonite portland cement grout .eal.
E.ch section operated independently 01
the other. The welts were .rr.nged in .
triangular conliguration. with three wells
on the base 01 the tri.ngle (EWZ. EW3.
EW4) and one welt .t the apex (EW1).
The three wellS on the base were called
barrier wells. Their purpose w.s to
intercept contamination. lrom underneath
the building and to the lide of the
demonstration arI.. belore this contam-
Ination reached the main extraction well
(EW1). The area enclosed by the lour
extraction wells d.fined the area to be
cleaned.
Installatlon of Equipment
Well drilling and equipment ..tup were
begun on December " 1987, A mobile
drill rig was brought in and 'Quipped with
hollow-stem augers. split spoonl. and
Shelby tubel. The lOcations 01 the
extraction weill and monitoring wells had
been staked out based on contaminant
concenuation profiles trom a previoully
3
conducted remedial investigation and
Irom bar punch pro De soil gas. moni-
toring.
Each well drilled was sampled at 2,Ioot
intervals with a split spoon pounoed into
the subsurface by the drill rig in advance
01 the hollow stem auger. The hollow
stem auger would then clear out the soil
down to the depth 01 the split spoon. and
the cycle would continue in that manner
to a depth of 24 leet. The drilling tailings
were shoveled into 55-gallon drums Ic~
eventual disposal. Atter the holes were
sampled. the wells were installed using 2.
inch PVC pipes screened at varic.:s
depths depending upon the character-
istics.ol the soil in the particular hole. The
deep welt was installed first. screened
trom the bottom to various depths. A
layer 01 sand lollowed by" layer 01
bentonite and finally a thick layer 01 grout
were reQuired to seal 011 the section
below the clay lens Irom the section
above the cl.y lens. The grout was
allowed to set overnight belore the
shallow welt pipe was installed at the top
01 the grout. A layer 01 sand bentoMe
and grout finiShed the installation.
VOC Removal From the Vadose
Zone
The permeable vadose zone at U'.e
Groveland lite II divided into two layers
by a horizont.1 clay 'enl. which is
relatively impermeable. As explained
previoully. each exvaction well had a
..parate shallow and deep lection 10
-------
:
H
/
Secondary
Acwated
Carbon
Canister
Vapor.
Liou,d
Separator
Lwells
Vapor.Liouid
Separator
FI,ure f. $chem.rrc diapr.m of .quipment layout.
1.",.2. Eouipm.nt Lilt
EqYpment
&trI~on wells
~W8/J.
V.pot4quld ..petltOl'
ActN8ted carC»oll
CMi.."
V8CIIIIII unit
HoIdInO I8/VI
l'ump
NumlMr,lfeouired
. (2 .ecton. liCIt)
4 (2 .8CIOtI. .ach)
,
I'rim.ry: 2 uniI8 In
paflllel
~, unit
,
D8sC1ipMon
Z. SCH.O I'VC Z4' fDt8I d.p'"
Z. SCH 40 ~ Z4'I/OtaI d.pth
'OOO-g81 c.PICIIY. ....,
CaN... with 'ZOO Ib 0' C8I'OOII in
..Ch CMi.ter . ~ $$
.. inIIt and 0lIl., nozzle'
r.,.,. Vac I18Q0118" ~ . Model "fU7
(25 HI' Motor)
~~."..,
, Hl'mON . etmri~8I
,
, .
4
B
Primary
Activated
eareon
Canisters
Barrier
Wells
/
Monitoring
Well
~[~.
-------
\
2- pvC Pipe
Benronlle
Sana
Screening
r2.67'
Grout
77.5' Bentonite
rs' Sana
79'
Screening
24'
Figure 2. Schem.~c diagram of an eJtr8=on well.
area 01 the vadose zone above and below
the clay lens. The Quantification 01 VOCs
removed was achieved by measuring
. gas volumetric flow rate by rotameter
and wellhead gas VOC concentration
by gas chromatography
:) the amount 01 VOCs adsorbed by the
.ctivated carbon canisters by
desorption into CSz lollowed by gas
chromatography.
VOC flow rates were me.sured .nd
t.bulated for each well section
separately. The results of gas Ampling
by Iyringe and gas chromatographic
anaIyail indicate. total 01 , .297 Ib of
VOCI were IxtraCtld over a 56-day per-
iod. 95% of which was trichloroethylene.
A very good check on this total was
made by thl activated carbon VOC
. analysis. 1M results 01 which indicated .
VOC recovery of 1353 Ib; vinuatly 1M
same ,.su" was obtained by two very
dinlrlnt mlthods.
The soil gas results show a con-
siderable reduction in concentration over
'he course 01 the 5&-d.y demonstr.tion
period as can be seen from Figures 3
and ... This is to be Ixpected since soil
gas is the vapor halo existing around the
contamination and should be relatively
easy to remove by vacuum methods.
A more modest reduction can be seen
in the results obtained lor soil VOC
concentrations by GC'MS purge-and-trap
analytical techniques. Soil concentrations
include not only the vapor halo but also
Interstiti., liquid contamination th.t is
lither dissolved in the moisture in the soil
or exists as a two-phase liquid with the
moisture,
Table 3 shows the reduction of the
weighted average TCE levels in the soil
during the coursl of thl 56-day
dlmonstration tilt. The wlighted
ayer.ge TCE IeYII was obtainld by
averaging soil conclntrations obt.ined
every two feet by split spoon sampling
methods OYer VIe Intire 2""oot dlpth 01
the wells. The largest reduction in soil
TCE concentration occurr8c:l in Ixtr.ction
5
wen ... which had the highest initiaJ level
01 contamination. Extraction well 1. which
was expected to hive the greatest
concentration reduction potential.
exhibited only I minor decrease over the
course 01 the test. Undoubtedly this was
because 01 the greater-than-expected
level 01 contamination that exis'ted in the
area around monitoring well 3 that was
drawn into the soil around extraction well
" The decrease in the TCe level around
monitoring well 3 tends to bear this out.
Effectiveness of the
Technology In Various Soil
Types
The soil strata It the Groveland site
can be charaC1erized generally as con-
Sisting of the following types in order 01
increasing depth to groundwater.
. medium to very fine amy sands
. atin and WIt etays
-------
.
EM
VMW2 .
,~
,600 VMW3
,,00
,rPJ
2100
2,00
~ 2\00
K \100
S:
...,
~ ~W
\500
\200 IX
toO
fIIJ
,00
0
"'1118 2. """''''''''''''''0l/Il 8011 ,.. CCIftC8IIItdOtI.
8011 porosity. which Is the percenllOt
of IOtaI soil volume occupied by pores.
was relatively the sam. for both the clays
and the sanda. TypicaHy porosity. over
the 24-foot depth of the weill. would
range betwHn 40% and 50%. Penne-
abIliti... or more accurately hydraulic
conductivitiel. ranged from '0'" crnII8C:
for the IIftds 10 '0'" cmIl8C tor Ih8 claYI
wiU\ correaponcling grain lizll equat 10
'0-' mm 10 1G-a mm.
Pretalt soil boring ana\ys8I ind"lCIted
in general that moat of Ih8 contamination
wu In the strata ItIov8 1h8 clay lena. with
a conaiCIerlb18 Quantity perched on lOp of
the clay 18nI. This WIS the CII8 lor IX-
traction Will ... whiCh 8how8d 11\ IXCII-
lent reduction of TCE concentration in the
medium to fine sandy lOils Ixisting
above the clay layer. with no TCE
detected in Ih8 clay in either the pretalt
or poatt8lt borings (S88 TIbI8 4). One of
th8 weIll. howeY8t. WIS an exclption.
This was monitoring weD 3. whiCh con-
IainId Ih8 higl'l88t comaminatiOn I8V8Is of
."y of Ih8 wIlli. ItId WIS exceptional in
that moat of Ih8 c:onIIminaIiOn was in a
wit clay stratum. Thl 18v81s of
contaminatiOn .... in Ih8 200 tI) 1100
ppm range betcn Ih8 t8It. Ahlr Ih8 talt.
anaty..s of Ih8 IOiI IIOring adjacent 10
monitoring weD 3 IMW8CI 18V811 in the
.
.'
rang. of ND-60 ppm in 1he same clay
stratum. The data suggest that Ihe
technology can desorb or otnerwise
mobiliz. VOCs out Of certain Clays (s..
Tlbll 5).
From the results of this demonstration
it appears that the perrntlbility of a soil
ft8Id not be a consideration in applying
Ih8 vacuum extraCtion t8Chnology. This
may be Ixplained by th8 fact that the
porositill wert approximately the same
for ..I IOiI strata. 10 that thl IOtaI flow
area for striPPing air wlS the same in all
soil strati. It will tlke a long time for a
liQuid contaminant to percolat. through
-------
1250
.5
IU 0
~
E'rY2
~3
=":'4
VMW:I
VMW2
EWI
FI,ure.. Po....".", "'81/0. .Oil ga. COItC8II1r8ti0/l.
-
consequent low permeability. However.
the muCh ImaUer air molecules have a
lower resistance in passing through the
lame pores. This may explain why
contamination was generally not present
In the clay atrata but when it was. it was
not difficult to remove. Further telling
should be done in Order to confirm this
fanding.
Correlation of DecDnlng VOC
Recovery Rates
The vacuum extraction of volatile
organic constituents from "" soil may be
viewed as an unsteady state process
taking place in a nonhomogeneous
environment acted upon by the combined
convective forces 01 indUCed Stripping air
and by the vacuum induced volatilization
and diffusion of volatiles from a disSOlved
or SOrbed state. As such it is a V8f'y com-
plicated process. even though the
equipment required to operate the
process is very simple.
Unsteady ltate diffUSion processes in
general correlate wen by plotting the
logarithm 0' the rate 01 diffulion versus
7
Map Vie...
~[LJ
IX
VMW4
I
time. Although the
vacuum e.tractiol':
here might be SOl':"
correlation obtain.
logarithm 01 the
cOntaminant in the
time and Obtaining a
line was r"'On&bI~
plot, Ihown in Fig\."
data very well and is
a linear grlJ)h
concentration versus
best fit curve woulC=
-------
"
r,ble 3. AedllC~on 0' Weighted Aver.ge TCE L8V8l' in Soil (TCE Conc. in mgll
-------
~
Grove/andITe7ra.VAC Demonstration
Extraction Well' 1
Shallow
1000
~
e
Co
s
6
....
'II
~
c:
"
u
8
IU
~
~.
100
10
0.1
0.01
o
60
80
20
40
Oay 01 Active Treatlnent
FIQII' 5. Wellhead TeE concentration vs lime.
Looking at the plots for extraction well
'. shallow and deep, eQuations are given
for the least sQuares best fit :ine for the
data points. If the vacuum extraction
process is run long enough to .achieve
the detection limit for TCE on the ECO.
which is 1 ppbv, the length of time
reQuired to reach that concentration
would be approximately 250 days on the
shallow well and approximately 300 days
on the deep wen.
Prediction of Time Required for
Site Remediation
The soil concentration that would be
calculated from the wellhead gas
concentration using Henry's Law is in-
Table I. Compari,on 01 We/lllead Gas VOC COncentTIlion and Soil VOC Concentration
£%rflclion Well
fS
fO
2S
20
3$
30
4S
TCE Coneentration in
Wellhead Ga. ppmv
1.7
5.8
fl."
f..."
'25.0
58.7
'085.8
Predicted by Henry's
L6w PQmw
O.n
0.07
0.20
0.'7
r.53
0.7"
'2.'"
TCE COnC8lltration in
Soil QptrIW
5".5
7.2
ND
20."
20.1
'8.0
I.'
9
Y a: '59.33' EXP (4C5.1O
Cllrve Coefficient
RZ . 0.62
'00
eluded in the last column of Table 6. Cal.
culations for the predic:ted soil concen.
trations were made assuming a bulk
density of the soil of 1761 kgJm3. a total
porosity of 508/8. and a moisture content
of 2084. The calculated air filled porosity
of the soil is approximately '584. Henry's
eonstant was taken to be 0.492 KPatm3.
-------
. C H t:..1'I 1-\ I~ ~ '-I
....-..
Citizens
Against
RadioifCtive. . Dumping
.'
AND
ALL
OTHER
POLLUTION
Septerr.ber 10,
l~~\)
..-
Mr. Jo~l Sinaorman
501v~nt 5ev~r~ PrnJe;t
U.S. Environments1 PrD~.~tlon
Agency - R~Olon II
2r, Fr.ner8l PlazQ, noom 2~-10~
New York, Np-w Yorkl027S
Fax # 212-264-6607
. "
Op.i!r Mr.
S i "~Ie: ,'me. n:
In re8Rrd~ to our tel~phone c~nver-.ation o~ Fri~ay
e~tp.r-noO", Soptember 7th, 19:'1['1, I 11m rexing you 'this reply.
Che~en50 NDrt~'fi decIsion 1& to pursue the Pur-ther
DxpllcDtion of l~~~ ~£~ Ex~r.c.~lon~ (Se-4), .nd to
furthp.r- ex.mlno for ourselves the record/r-esulte ar ether
ce5e~ In which (5C-5). ~ Te~paraturo Ihermel Tree~Ment,
"rIve beon us,od.
. :.: .,
CDntr-Rry to the InrormD~ion you conveyed In our ~honp.
cnnvp.r-~"t i nn, 'tl1e R I /FS r"oport cont" i rml8 thet "... the 5C-~
eltern~tlvp. rp.~uJreB minimal excavation [well Inet~lletlon',
for- implemen~~t1en.
Thp.r-efore, the 'short ter-m effectiveneee' Ie rr.cre
fovorat:-1e t1eceH.I~f! it limit. the "f"ugitlvD dust eml&Dlone"
end "wind dl"'~f!r"ed .011 perticl...8", produced durIng
whole.ole excevetion.
Nowher-o deo& the RI/F~ repor-t mf!ntlen th.t the Llnckloan
eol1 ty~eft provont& the in-Gltu method ~rom belns
~ucceeeful. Ind.ed, 1n our convor&8tlon. you led me to
bellevo that both the ~rfectlven~fte IInd ~M. long 't.rm
r~~olutl~n Cr SC-4, wa~ ID~~ then de.lreble,
Agein, the RI/FS ..YR, ..."~h. o)('tr.c~lon oPf'iclclency
for voletile or-9ftn1c. 1. exp.~ted to be medoratoly hiSh...
os, much Be 60% - 90% o~ the VDC. could be removed ."end
th8't no further tre!ltment 0' the 1101111 would h. re.,ulred".
~urthor-. the totel Implementetion coet Ie eteted
$1,512,000 ~or SC-A. end $21,525,000 ~or 5C-5, "My
we ber~ merl!! rlRk and ~h. taxp.yer. more co.~, ~h8n
eb80lutely neCeeDftry?
lie
.hould
1-
-------
. . .
CHEI'JAGC' NaR~", e.A.R.D.
5DLVE~T 5AVE~~, LINC~LEA~,
JOEL 5INSER~AN - F2
N.Y.
~~ feel t~D~ ~e C6nn~t walt for the TAG Gr.rt, For now,
w~ hev~ fcu~d our own In~ependent expert who wl11.~e~law the
~I/Ff ~lt~rnatlvo or 5C-~, a~d Revise UBi
Thi~ wIll take approximatelY two weaks. For this reascn
w~ ~re Dsking for en extontion or the comment parlod a~d
c~l~y 1n tho sl~nlng of the ROD, until we heve c~nflr~ed
that your ~lternatlvc 16 In our best intorest.
Sin~e tho e~cevetlon oP t~e PCBs and oth~r burled barrels
~~ ~oxl~ wastD are scheduled this fall, we ere enxious
to work ~lth ~he other cltlz~n srcuOs .frootod by the site,
to ohtaln e TAG Grant as 800n 86 pos~ible, &0 our monltorln~
c~n bes1n ~h~n the excavation besln5.
Very truly yours,
.r'<.~ (t~~ (j .11~-,-
Sueen n. Grlr-fln,
Coordinator
Chenengo North C.A.A.O.
end ~ll O~her Pollution
cc:
Cilen Angell
-------
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Lie ~uyter, i~ . Y .
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Lisa wong,froject manager
26,Federal flaza,rtoorn 29-102
J.\lbany,~.Y.
Pear MZ. ~'iong:
1 attended the meeting at the town hall in 1incklaen in rega~ds
Solvent Savers Site.1 have lived all my life in close proxiIT.i~y
to ::--.e
of j\:uc C~ee.
i-
I am now nearly sixty nine years old. In your pample~ you state ~~re is
o:::.y
minute traces of chemicals in the water and sediment in this creek. I au
asking why in the last twelve to fifteen years there has been such a
dras-
tic reduction in the muskrat and mink population in this valley below this
dump site? They are now nearly non-existent.The only places where they wil~
live are in the privatly owned farm ponds and spring runs.The grassy veget--
ation will not thrive on the banks of this stream;neither will the willows
and these are the sourses of food for the muskrats. .,here there are no r..usi{-
rats, there willbe Vf:y fe;. mink as they are a najural food source for minI.
A sample was taken only 200 yards from this site. I would like to see
the results from some samples taken further downstream,I was told by the
wild-life services that it was hard for them to obtain permission from the
landowners to go on their land.I do not believe tmis to be true.My land
borders Mud Creek and I am wIling to have samples taken.Fact is,I would
encourage to having it done.! also believe the landowners in the whole
valley would like to have it done so they could see the results.I live
about one and one half miles due south of this site.
Yours truly, ~
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RESPONSES TO
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I.
BACKGROUND ON COMKUHITY INVOLVEMENT AND CONCERN
A.
History of Community Involvement
Communi ty concern and involvement associated with the Sol vent'
Savers Site is considerable. In 1987, when EPAbegan its supple-
mental remedial investigation and feasibility study (RI/FS),
community relations activities and the development of the community
relations plan for the Site were implemented. During most of the
RI/FS, local involvement in the Site activities has focused around
the residents living directly next to, or on, the Site. These
residents utilize private wells for their domestic water supply.
Typically, public interest in site activities increases when EPA
presents its Proposed Plan for comment. This is the case at the
Solvent Savers site as well. This interest has been spurred even
more by several local environmental organizations that organized".
to protest the siting of a low level radioactive waste dump in the'
area.
In fact, residents and officials within Chenango County have been
invol ved and concerned with many hazardous waste issues in the
area. There are seven hazardous waste sites in the County,
including this Site and the Novak Farm site, where Mr. Dale Hough
often disposed of toxic waste from Solvent Savers. Local county
officials are well informed about these sites and media coverage
of hazardous waste issues has been thorough. This concern has
res1llted in the formation of an Environmental Management Committee
by chenango County to oversee environmental issues.
B.
Key community Concerns
Community interviews, discussions with local officials and comments
received at the public meeting and during public comment periods
have identified the following major concerns.
Health and safety
Health and safety has consistently been a concern of local
officials and residents. Residents living near the Site have in
the past expressed concern about the possibility that their wells
may be contaminated. EPA has determined that those residential
wells being used by the public do not .present a health risk.
Additionally, residents are concerned that the Site does not have
a sign that indicates the presence of contaminated materials.
Residents are concerned about exposure to contaminated dust and
vapors during remediation and have requested that dust suppression,
air emission controls and discharge monitoring be implemented
throughout the life of the remediation.
Information on Site Activitv
Residents,
local
officials,
and
representatives
from
-------
environmental groups have stressed the importance of frequent,
~cc~rate and comprehensive information from EPA on the site. and
:he Superfund program in general. They anticipate close coordina-
tion and communication between EPA and interested parties during
remediation. -
II.
SUMHARY OF MAJOR QUESTIONS AND COMMENTS RECEIVED DURING THE
PUBLIC COMMENT PERIOD AND ZPA RESPONSES TO THESE COMMENTS.
Comments raised during the public comment period for the site and
the EPA responses are summarized in the following section.
Comments received during the public comment period are organized
into six categories: Remedial Alternatives/Proposed Plan, Remedial
Investigation/Feasibility Study, Cost and Schedule, Remedial
Design, Public Participation, and other.
REMEDIAL ALTERNATIVES/PROPOSED PLAN
comment:
Representatives of a local environmental group asked about oo;he
location of the disposal facilities and the amount of waste
materials to be carried off-site during the remedial efforts.
Specifically, they asked where the off-site incineration facility
was located, the amount of PCB contaminated soil that would be
incinerated, and where and how much carbon and sludges from
Al ternati ve GW-4, Groundwater Extraction/Chemical Precipitation/Air
Stripping/Carbon Adsorption would be disposed of.
Response:
EPA's Proposed Plan is conceptual. Approximately 1000 cubic yards
of PCB contaminated soil requires treatment. Treatability tests
are required to estimate the volume of carbon and sludges that will
be generated. These tests will be performed during the remedial
design. Additional sampling during the remedial design will better
assess the extent of PCB-contaminated soil requiring remediation.
If the PCBs are treated off-site by incineration, the construction
contractor will be responsible for selecting an appropriate vendor
for off-site incineration and carbon and sludge disposal.
Comment:
A resident felt that the Alternative GW-4 was an acceptable
al ternati ve for remediation. However, she expressed concern
regarding potential air emissions from the treatment unit.
Re.pon.e:
EPA is aware of the concerns of the community that all air released
by the processes of Alternative GW-4 meet discharge requirements.
At this point, EPA feels that this will be accomplished by
-------
"
Alternative GW-4 which in~iudes a carbon adsorption unit which will
filter air from the air stripper.
Comment:
A resident asked if surges of contaminants in the groundwater could
be handled by-Alternative GW-4. She asked if the. proposed system
would be designed to handle surges in the levels' of contaminants
and would the system shut down if it could not.
aesponse:
The system described by Alternative GW-4 would be designed for the
worst case scenarios to remediate those areas where the greatest
concentrations of contaminants are present. Environmental
monitoring would be conducted during the life of the treatment
system and the system could be should down if discharges did not
meet standards.
Comment:
A resident asked about the types of contaminants that the'community
would be exposed to when excavation and remediation took place.
Response:
During the remedial design, the design contractor will incorporate
methods into the engineering design that will minimize off-site
migration of the contamination t~ protect public health. Contami-
nants of concern include PCBs and volatile organic compounds. For
example, during excavation, dust suppression measures would be
taken to keep potentially contaminated dust to a minimum. Also,
during remediation, an on-site health and safety officer will
monitor all activities to ensure that dust control measures are
effective and that any air emissions or discharges as a result of
the operations are below federal and state action levels.
Comment:
Several individuals asked about the inorganicspresent in the soil
after treatment through the low temperature thermal destruction
process. Specif ically, why weren't the inorganic contaminants
being treated.
Response:
EPA has determined that the levels of inorganics in the soils do
not present a health risk to the public or the environment. That
is, that they are below health risk levels and federal and state
standards of cleanup. After treatment of the soil, toxicity
characteristic leaching procedure testing will be performed. If
the treated soils pass the toxici ty tests the soils will be
-------
.
replaced. If the soils do not pass the toxicity tests, fur~her
treatment might be necessary, before the soil can be replaced.
Comment:
A resident asked about the discharge of water to Mud Creek and the
groundwater during the implementation of Alternative GW-4. She
asked how acceptable levels of contaminants would be determined and
how this would affect the contaminant levels in Mud Creek and the
groundwater.
Response:
The acceptable level of contaminants, or the level to which they
must be treated is determined by the nature of the body of water
which is discharged to. Mud Creek is classified as a trout stream
by NYSDEC. As such, any discharge to the stream must meet NYSDEC-
established Ambient Water Quality Standards for trout streams. Any
discharges to groundwater must meet EPA and NYSDEC drinking water
standards. Discharges to the groundwater and Mud Creek will not
increase the contaminant levels present nor will they pose a threat
to either human health or the environment. The actual treated
discharge is expected to be cleaner than the water in Mud Creek.
Comment:
A resident as.ked why Alternative GW-4 was significantly less
expensive than Alternative GW-3, Groundwater Extraction/Chemical
Precipitation/Carbon Adsorption, when there seems to be additional
processes in Alternative GW-4.
Response:
The air stripper used in Alternative GW-4 will signif.icantly reduce
the carbon usage and has different operation and maintenance
requirements which over a twenty year period accounts for the
difference in cost estimates.
Comment:
A local official asked if recording monitors would be installed on
any exhaust gases from the processes of Alternative SC-S, Excava-
tion/Low Temperature Thermal Extraction/On-Site Redeposition, and
on discharges from the processes of Alternative GW-4.
R..pOD..:
Typically, recording monitors are installed on any discharge of
air. Discharges from Alternative GW-4 would be sampled on a
regular basis to assure that all federal and state regulatory
requirements are met. The implementation of the remedy must comply
with all federal and state requirements.
-------
.
Comment:
A resident asked about the scrubber process utilized in Alternative
SC~S.
Response:
A scrubber system uses water and a neutralizing agent such as lime
to remove particulates and acid .gases from an air stream.
Comment:
A resident asked about the fire protection methods utilized in
. Alternative SC-S.
Response:
National Fire Protection Association-approved fire extinguishers
will be used for fire protection. In addition, local emergency
planning officials will be advised regarding ongoing remedial
activities at the site and may comment on them.
Comment:
A representative of a local environmental group asked at what
temperature the thermal treatment unit and afterburner would
operate at, and whether this was sufficient to oxidize all of the
different organic compounds that have been found in the scil.
Respo..se:
While. there are different types of thermal extraction units, the
thermal treatment system would operate at approximately 400 to 800
degrees fahrenheit. This temperature is sufficient to oxidize all
organics. The after burner will operate at approximately 1200 to
1400 degrees fahrenheit.
Comment:
Several residents have suggested that an inflatable cover be
utilized during the remediation efforts to safeguard the community
from fugitive dust and vapors containing volatile organic com-
pounds.
Response:
An inflatable cover and other mitigative measures will be consid-
ered during the remedial design.
Comment:
A commentor stated that all health risks would be adequately
-------
reduced utilizing Alternative SC-3, site Capping, and questioned
why additional funds should be spent on EPA's preferred alterna-
tives, when Alternative SC-3 and GW-2, Limited Action, are protec-
tive of human health and the environment.
Response:
Alternative SC~3 would not meet contaminant-specific applicable or
relevant and appropriate requirements (ARARs) for PCBs. Alterna-
tive GW-2 would not meet ARARs for contaminants in ground water.
Neither alternative meets the preference in the Superfund law to
significantly reduce the toxicity, mobility, or volume of contami-
nation through treatment of contaminated materials, or the
Superfund mandate to use treatment to the maximum extent practica-
ble.
Comment:
A commentor asked for an explanation of the incremental costs
associated with the removal of TCE, PCBs, and metals by contami-
nated areas for Alternatives SC-4, and Sc-s.
Response:
The cost for remediation of PCBs is essentially the same for both
Alternatives SC-4 and SC-S. The major difference the cost between
Alternatives SC-4 and Sc-s is due to the respective costs for the
different treatment technologies; vapor extraction for Alternative
SC-4, and thermal extraction for Alternative SC-;. Thermal
extraction is approximately three times as costly.
Comment:
Several residents commented that Alternative SC-S for remediation
of soils is an acceptable alternative. One resident asked what
level of contaminants EPA will allow in residual soils that will
be backfilled.
Response:
The treated soils will meet the cleanup levels specified in the
ROD, which will ensure that the soils are at health-based levels.
Comment:
Alternative SC-S may also be appropriate as an initial treatment
technology for PCB-contaminated soils.
R..ponse:
EPA has incorporated this suggestion into the ROD.
Treatability
-------
studies will be performed during the remedial design to deter-
mine whether the low temperature thermal extraction process is an'
appropriate treatment method for the PCB-contaminated so~l. If the
treatability study results indicate that low temperature thermal
extraction is an appropriate treatment method, then this technology,
will be utilized to treat the excavated soil contaminated with PCBs'
on-site. Should the findings of the treatability ,'studies indicate
that the on-site low temperature thermal extraction process will
not provide the desired degree of treatment, then the excavated
PCB-contaminated soil will be removed for off-site incineration.
Comment:
The merits of combining selected alternatives for treatment of non-
PCB-contaminated soils should be evaluated.
Response:
In the ROD, EPA, has incorporated the option of implementing
different treatment technologies for the less contaminated soils
if the treatment is demonstrated to be effective in meeting cleanup
levels during treatability studies.
Comment:
The Proposed Plan should not include off-site incineration since
it was not included in the Feasibility Study (rS) Report.
Response:
The off-site incineration alternative for both the VOC- and PCB-
contaminated soils was screened out in the 'FS Report due to costs
of an order-of-magnitude higher than other alternatives. It was
included in the Proposed Plan to show the higher range of remedial
costs. Off-si te incineration of the VOC- contaminated soils,
however, is a viable alternative for this site.
Comment:
A PRP and representatives from local environmental groups ques-
tioned in the Proposed Plan the assertion that Alternative SC-S is
easier to implement, has a better short- and long-term effective-
ness and would achieve a greater reduction in toxicity, mobility,
and volume of contamination than Alternatives SC-4 and SC-7.
Response:
In-situ soil flushing and in-situ vapor extraction are effective
in treating highly permeable, homogeneous soils. The soil matrix
at the Solvent Savers site, however, is complex and heterogeneous
in nature. Accordingly, we believe that employing in-situ soil
flushing and in-situ vapor extraction at the Solvent Savers site
-------
would result in the preferential flow of the volatile organics
through the soil. As a result, the complete extraction of' the
volatile organics from the soil might not be achievable utilizing
Alternatives SC-4 or SC-7.
comment:
A representative of a local envirQnmental group and a PRP asked if
EPA would consider utilizing bioremediation (e.g., land applica-
tion) as a support technology. Additionally, a commentor asked if
EPA had considered photo-oxidation.
Response:
Due to the very limited successful laboratory scale and pilot scale
testing of the bioremediation technologies for treatment of
mixtures of organic contaminants, the potential generation of more
toxic contaminants as by-products of the biodegradation process,
the possibility of seasonal variations seriously impairing the
function of these technologies, and the uncertainties associated
with the time required for remediation, the biological treatment
technologies were eliminated during the initial. screening of
remedial technologies for the contaminated soil. Oxidation
technologies were considered in the FS. Photo-oxidation was not
included because it is not feasible for the large volume of water
to be treated and the size constraints of the site.
Comment:
The difference between the 20-year implementation period for
Alternative SC-6 and the l-year period for Alternatives SC-4, and
Alternative SC-5 may be inconsequential considering that the
groundwater remediation will take 20 years.
Response
This difference in not inconsequential. The time difference
between l-year and 20-years will have a significant effect because
the source will be remediated more quickly, thereby making the
qroundwater remediation process proceed more quickly and efficient-
ly. It also allows for the potential development or usage of the
site on an expedited basis.
Comment:
A commentor asked for details of the proposed lonq-term monitoring
program for Alternative SC-5 and Alternative GW-4. The commentor
was particularly concerned about the long-term monitoring of the
surface water aischarqe of treated qrounawater.
-------
Response:
During implementation of Alternative SC-S, soil. samples wou1-d" .be
analyzed to ensure that all contaminated soils are excavated for
treatment. After treatment the soils will be analyzed to ensure
that they are clean.
Alt~rnative GW-4 will be designed to meet the New York State Water
Quality Standat:ds. The flow is expected to be S6 gallons per
.minute. Long-term sampling of treated effluent is included in the
implementation of this alternative. The specifics of sampling
frequency and analytical parameters will be established during the
preparation of a New York S~ate Pollution Discharge Elimination
System permit.
REMEDIAL INVESTIGATION/FEASIBILITY STUDY
Comment:
A resident noted that some work during the RI/FS was conducted at
night and wanted to know why.
Response:
EP~ conducted a 24-hour measurement of groundwater levels during
a pump test, which provided information about the abi1i ty and
effectiveness o~ extracting groundwater during remediation.
Comment:
A representative of a local environmental group asked if the raw
data from EPA's studies of the Solvent Savers site was available
to citizens groups. .
Response:
All validated analytical data from EPA's studies is available to
the public. Upon receipt of the data from the laboratory, EPA
first evaluates and validates the data to assure that the labora-
tory has properly analyzed it and the samples have been properly
collected. The validated analytical data is available in the RI/FS
report. .
Comment:
A local official asked if a hydrogeologic study has been conducted
to determine if the groundwater flows from north to south.
Response:
As a part of the RI/FS, a hydrogeologic study was conducted. The
Solvent Savers site sits on a terrace. Above the site is a very
-------
steep rise. The groundwater' 'flow is controlled by this 'topography.
Groundwater flows, initially, west to east, but as the flow reaches
the center of the valley the groundwater arcs southward. Fu~ther
hydrogeologic characteristics are presented in the RI/FS report.
Comment:
Several residents asked about the downstream sampling of Mud Creek.
These residents feel that the downstream sampling conducted to date
is insufficient, and request further sampling.
Response:
EPA's furthest sample, approximately 200 yards south of the site,
revealed no detectable contamination. During remedial design, EPA
may determine that additional downstream testing is necessary.
Comment:
A resident asked if EPA was confident that it had ascertained the
extent of the pollution problem and its boundaries.
Response:
EPA is confident that it has determined the nature ,and extent of
the contamination problem. During the remedial design, EPA will
conduct some sampling activities to further refine the extent of
the contamination. This sampling is necessary so as to conduct the
reme~ial action in a cost-effective manner. '
Comment:
A resident asked about the bioassessment, performed by the U.s.
Fish and Wildlife Service, that had been conducted ,at the Site.
Response:
During the bioassessment, samples (sediment, water, fish, and
benthic invertebrates) were collected up to 1500 feet down stream
of the Site. The Fish and Wildlife study concluded that there were
no levels of metals or cyanide above background levels, but did
note low levels of volatile organic compounds. However, it was
determined that these low levels of volatile organics do not pose
a significant threat to aquatic organisms based on the following:
toxic levels of contaminants were not detected in
surface water:
no significant health problems were noted in white
suckers evaluated by a histopathologist:
fish species diversity was acceptable at all sampling
-------
'.
locations: and,
there were no dramatic differences in benthic
invertebrate diversity that might indicate chemical or
other stress.
Also, though there were low levels of volatile organics detected
in fish tissue, it was concluded. that these organisms are not
adversely affeGted by the low level chronic exposure. It was also
concluded, based on information provided by Dr. Roger Herman of the
National Fish Health Research Center in Kearneysville, West
Virginia, that the lesions detected in some fish cannot be
attributed to Site contaminants or any serious health problems.
Comment:
A resident asked if the contamination found in the monitoring wells
on the eastern side of Mud Creek would be cleaned up by the
proposed remediation efforts.
Response:
The proposed groundwater extraction system would capture water from
both sides of Mud Creek.
Comment:
A commentor que~tione1 the infiltration rate used in the calcula-
tion of soil cJ~anup ~eve1s presented in the FS report.
Response:
Upon consideration of the infiltration rate presented in the RI/FS
report (34 inches per year), EPA determined that this rate was not
accurate and recalculated it (6 inches per year). The recalculated
infiltration rate was used by EPA in its groundwater modeling to
calculate soil cleanup levels. These calculations will be refined
during the remedial design.
Comment:
Several commentors, including a PRP, raised questions about the
Risk Assessment, stating that the risks are overstated due to
overly conservative assumptions, asking for clarification of some
specific technical terms.
Response:
The Risk Assessment was prepared utilizing current guidelines as
detailed in "Risk Assessment Guidance for Superfund, Volume 1:
Human Health Evaluation Manual, September 29, 1989". A conserva-
tive approach is used to safeguard human health.
-------
.
Comment:
A commentor asked if c definable trichloroethylene plume exists at
the si~e and asked how it compares to earlier data.
ae.ponse:
A definable plume of trichloroethylene is pres, ,.t in the ground
water. This plume was illustrated in Figure 3-13 of the RI Report.
Comparison to previous data show that the levels of contamination
in downgradient wells have remained the same order of magnitude.
Comment:
The FS did not consider a range of remedial objectives showing
increased benefits corresponding to increased costs and range of
clean-up levels, or time frames.
aesponse:
The obj ecti ve to protect human health and the environment is a
threshold requirement that all remedies must meet. Clean-up levels
are set by groundwater ARARs. These are health-based standards
that EPA is required to meet. The FS developed different alterna-
tives to meet these minimum requirements with a range of costs and
remediation time frames.
Comment:
The FS Report did not consider the complementary effect of source
control on ground water quality. Groundwater treatment may not be
necessary if the source is removed. Source control may not be
necessary if the site is hydraulically contained.
aesponse:
The groundwater extraction and treatment system presented in the
FS was developed under the assumption that source control is
implemented. Groundwater remediation is required because contami-
nants are above health-based standards. Hydraulic containment of
the site was determined to be not feasible due to hydroqeoloqic
constraints.
Comment:
Since some
compounds,
levels of
necessary.
of the blank samples showed the presence of volatile
specifically TCE, some of the wel15 which show similar
TCE may in fact be clean. Addi -cional sampling is
-------
...
Response:
The presence of volatile organic compounds in blank s.amples is
apparently due to the presence of very high levels of TCE in the
samples analyzed immediately before the blanks. This was only
noted in two of the blank samples. Two rounds of groundwater, ""
samples were collected and the concentrations of contaminants in'
the wells questioned by the commentor were similar in both rounds
of sampl ing. However, even discounting the presence of TCE in some
wells, the le\tels of other contaminants are such as to," require
groundwater remediation. EPA intends to conduct additional
sampling during the remedial design.
Comment:
One commentor questioned why the results of the May, 1990 PCB
sample results were not included in the risks assessment, and
raised questions about the inconsistencies between the May 1990 '
sampling and the December 1988 sampling, specifically the Aroc1or "
1248 was detected in May 1990 but not in December 1988.
Response:
The May 1990 PCB sampling was conducted after the risk assessment"
was completed. It was intended to further define the extent of
the surface soil PCB contamination. Aroc1or 1248, although not
detected in December 1988, had been detected in previous studies
at the site.
Comment:
One commentor stated that exposure assumptions for direct contact
with on-site soils and sediments as well as dermal exposures are
overestimated by a factor of ten. The number of days exposed/year
was incorrectly calculated using 24 hours per day exposure.
Response:
Exposure assumptions were calculated correctly. The exposure
scenarios for direct contact and dermal exposure are based on
exposure to an assumed mass of soil per day, and in these cases do
not specify the number of hours per day.
Comment:
One commentor stated that the risks due to contaminants were
incorrectly assumed to be additive and that only toxic substances
which affect similar target organs are additive.
Response:
For calculations of the cancer risk, EPA procedures are to add the
-------
.
risks due to individual contaminants. The risks associated with
PCBs alone account for the significant portion of the risk.. . The
risk due to all other compounds is. so low in comparison to PCBs
that adding their effect would have little effect on the overall
potential adve5se effect to human health.
COST AND SCHEDULE
Comment:
A resident asked if EPA encountered much more contaminated material
than identified in the RI/FS, and this resulted in the remediation
effort becoming much larger than anticipated, would funds be
available to finish the remediation.
Response:
Although EPA is confident that it has properly characterized the
nature and extent of contamination, during the remedial design,
additional sampling will be conducted to revise the estimates and
then revised cost estimates will be developed. Although EPA cannot
absolutely guarantee that Superfund monies will be available, as
Superfund is up for reauthorization by Congress in 1991, EPA is
committed to the completion of the remediation effort spelled out
by the ROD.
EPA also recognizes that it is current cost estimates have an
expected level of accuracy of plus 50 percent and minus 30 percent.
Though the actual c~st may vary significantly from these estimates
due to the environmental uncertainties, EPA must evaluate alterna .
tive and use these "best guess" cost estimates.
Comment:
A resident asked if EPA would be negotiating with PRPs to take
responsibil i ty for the cost of the clean-up, and would those
negotiations delay the whole process.
Response:
EPA will first request that the PRPs undertake the cleanup efforts.
EPA has already issued a unilateral administrative order to some
of the PRPs to perform some of the work called for in the ROD.
FOllowing the issuance of the ROD, EPA will give the PRPs an
opportunity to agree to conduct those portions of the selected
remedy that they are not already performing under the 1989
Administrator Order. If the PRPs are willing to undertake this
work, EPA would negotiate the terms of a judicial consent decree
with the PRPs which would provide for their performance of the
work. If the PRPs do not volunteer to implement the remedy, EPA
may unilaterally require them to do so, and/or EPA will implement
the remedy itself. It is consistent with EPA's policy to attempt
-------
to have the PRPs either undertake or assume the costs of the
remedial action. We do not expect that negotiations with PRPs 'will
delay the remediation process significantly.
comment:
.A local official and several residents asked EPA .to estimate the
length of time necessary to complete the remedial design and
remedial action. .
Response:
EPA's current time estimate for the remedial design is approximate-
ly a year to 18 months. This includes the additional sampling that
may be required. The remediation of the soil will take approxi-
mately one year from the initiation of soil cleanup. It is
estimated that it will take approximately 18 months to construct
the groundwater systems, but approximately 20 years to fully
remediate the groundwater.
REMEDIAL DESIGN
Comment:
A local official asked if monitoring wells would be installed in
the substrata downstream from the Site toward the Town of Pitcher
line.
Response:
Additional wells may be installed if they are determined to be
necessary to monitor the progress of the remedial action.
Comment:
Because of the limited numbers of samples taken during the RI, the
actual soil volume requiring remediation may be overestimated. The
PRP has included a proposed scope of work for additional sampling.
Response:
EPA recognizes that additional data is need to refine the estimates
of the volume of soil requiring remediation. This data will be
collected in the remedial design phase.
PUBLIC PARTICIPATION
Comment:
Several individuals asked whether an opportunity existed
citizen input during the remedial design.
for
-------
.
.esponse:
EPA' encourages citizen participation throughout the remediation
process. In fact, many of the comments on the Proposed Plan and
ROD provided b~ the public and the PRPs will be factored into the
remedial design. The design documents will be available for public
comment. '.
Comment:
Several individuals have asked that EPA notify residents, local
officials and emergency responders when hazardous materials will
be taken off-site.
.esponse:
As a part of its remedial design, EPA will strengthen communica-
tion channels with local officials, emergency responders and
communi ty groups. This will include informing local officials,
emergency responders and concerned citizens of the schedule for
removal of hazardous materials from the site.
Comment:
A resident expressed dissatisfaction with EPA's communication about
site activities to date.
.esponse:
EPA is committed to providing timely information about site
activities to local officials and concerned citizens. EPA is
required by law to provide opportunities for the public to comment
on the process and site activities. To date, EPA has held an RIfFS
workplan scoping meeting with the public, distributed Superfund
Updates for the Site at strategic points in the remediation
process, distributed the Proposed Plan to the mailing list
maintained for the site, held a public meeting to discuss the
proposed plan and the RIfFS report, and provided the opportunity
for the public to comment on the Work Plan, RI/FS report and
Proposed Plan for the site. During the remedial design, EPA will
continue to provide information to the public and encourages the
pUblic to participate fully. One available mechanism is the
Technical Assistance Grant (TAG) program.
The TAG program offers funds to an incorporated citizen group which
is affected by the site for the purpose of providing independent
technical expertise to evaluate EPA's activities. This program
requires the citizen group to provide some in-kind services to be
eligible for the grant. EPA encourages the citizens affected by
the Solvent Savers site to apply for a Technical Assistance Grant.
Anyone interested should contact:
-------
.
Ms. Ann Rychlenski
Office of External Programs
U.S. Environmental Protection Agency
26 Federal Plaza
New York, New York 10278
Phone: (212) 264-7214
Comment:
A resident requested that EPA visit with some of the people in the
area so that they know how the people in the immediate area feel.
Response:
EPA is willing to meet with interested citizens during remedial
design to discuss any concerns that they have about the site.
Additionally, at many Superfund sites EPA has worked along with
citizens' groups that have formed.
Comment:
Several representatives of local environmental groups and residents
have expressed dissatisfaction with the availability of site
documents. They have indicated that the Pond Store is very
inconvenient and have suggested that EPA maintain information
repositories in the libraries of Cincinnatus and DeRuyter.
Response:
EPA will explore the viability of additional ~ite repositories.
Site documents will be made available, including the ROD and
Responsiveness Summary, in the information repositories.
Comment:
A resident of Lincklaen asked if there was any assurance that if
and when a TAG is granted it would be to representatives of the
people of Lincklaen.
Response:
TAGs are available only to those groups that can demonstrate that
they are affected by the site. Where more than one group applies
for a TAG, the group that can better demonstrate its qualifica-
tions, including its relative proximity to the site and the degree
to which it is affected, will have a better chance of qualifying
for the TAG.
Comment:
A local official asked if the Town of Lincklaen Town Board could
get involved in the TAG process.
-------
:
.e.ponse:
Th~ TAG grants are not distributed to local governments, politi-
cal subdivisions, academic institutions or PRPs. Existing
citizens' associations that are incorporated or working towards
incorporation -and environmental and health advocacy groups are
encouraged to apply. Only non-profit groups are:igible for TAGs.
OTHER
COJlUlent:
A resident asked for the names of EPA' s contractors that had
performed work at the site to date.
.esponse:
The following firms have been involved in work related to the
Solvent Savers site:
Ebasco Services, Inc.
ICF Technology, Inc.
NUS Corporation
Roy F. Weston, Inc.
COJlUlent:
Several residents have asked why no sign has been posted to denote
it as a hazardous waste site, and no fence has been put up to limit
access to the s i.. te. They request that this matter be resolved
immediately.
aesponse:
The PRPs are currently in the process of installing fencing and
warning signs along Union Valley Road.
COJlUlent:
A resident asked when the drums stored at the site would be
removed.
aeSpOD.e:
The work plan submitted by the PRPs will also deal with the removal
of some of the drums on the site. EPA has reviewed and approved
the work plan for the removal of the excavated drums. Before
removing the drums, the PRPs must receive approval from a licensed
disposal facility. It is anticipated that this approval will be
received shortly.
-------
.
Comment:
A resident asked if there is a ranking system for hazardous waste
sites and what is the rank for the Solvent Savers site.'
Response:
The National Priorities List (NPL) is a list of the nations worst
uncontrolled hazardous waste sites. Superfund monies are available
to investigate-those sites. The list is based on the Hazardous
Ranking Score for each site. This score is a reflection of the"
potential for human and environmental harm due to the migration of
contaminants by surface water, groundwater or air; potential for
harm due to fire or explosion; or, potential for harm due to direct
contact with hazardous substances. The NPL ranking of the Solvent
Savers site was 582 out of the 849 sites in the March 1989 listing.
Comment:
A resident was concerned that the potential existed for the Solvent
Savers site to become a dumping ground for hazardous wastes from
other sites.
Response:
This fear is unfounded. EPA is currently remediating this site
and has no intention of utilizinq the Solvent Savers site as a
disposal facility.
Comment:
A resident expressed concern for the rem:oval of waste and the
shipping of it through the community. She wanted to know who was
responsible for accidents that might occur along the shipping
route. She also wanted to know if EPA uses private haulers and if
they can backhaul.
Response:
Responsibility for accidents that might occur during the shipment
of waste is that of the contractors, PRPs and EPA. Private haulers
would be used to remove the waste from the site. The haulers must
decontaminate the exterior of their trucks before they leave the
site and the interior and exterior after shipment of the waste.
Comment:
A resident asked what could happen if mixed waste was found during
remedial design or action.
-------
.
aesponse:
A radiation survey at
mixed waste. However,
discovered, EPA would
time. -
the site did not indicate the presence of
in the unlikely event that mixed waste was
evaluate options for its disposal at that
COJll.1lent:
A resident stated that the presence of the Solvent Savers site has
caused property values in the area to decrease and wanted to know
what assurances EPA could give that property values would increase
when the site had been remediated.
aesponse:
Although EPA has not conducted any studies of the area property
value trends, it is not unlikely that proximity to the site may
cause a decline in property values. When the site is remediated,
property values should return to within ranges of similar homes in
comparable communities. However, EPA cannot guarantee or forecast
future property values.
COJll.1lent:
A resident asked what the motivation for PRPs is to cleanup a site
if the federal government is willing to do it.
aesponse:
Superfund has built-in cost recovery provisions. EPA will attempt
to recover from the PRPs all costs incurred from the cleanup of the
Solvent Savers site. EPA may also, at its discretion, order the
PRPs to conduct the design and construction of the selected remedy.
Such an order would include penalties for non-compliance.
Comment:
A resident has asked that a health survey be performed for
residents in the area.
aesponse:
EPA does not normally conduct health surveys as a part of its
remediation process. They are more appropriately conducted by
local and county health departments who have access. to area
records. EPA recommends that requests for a health survey be
directed to the local and county health departments.
Comment:
A resident questioned the cleanup standards for metals in soils.
-------
Response:
Because of the fact that most samples were within background
ranges, and the inorganics detected above background ranges were
not found at levels which were a health risk, inorganic cleanup
levels were not set for soil.
Comment:
A commentor asked for the cleanup standards for PCBs.
Response:
All soils containing PCBs above 1 ppm will be remediated.
level has been set jointly by EPA and NYSDEC.
This
Comment:
A resident requested
performed correctly.
,
assurance
that
all
analytical
work was
Response:
The EPA's Environmental Services Division continually audits
subcontractors and laboratories in the Contract Laboratory Program.
These subcontractors and laboratories also must have an indepen-
dent, internal quality assurance program that meets EPA approval.
Several audits were performed of field procedures at the Solvent
Savers site. All audits rep~rted that field activities were being
performed satisfactorily.
Comment:
A resident requested a list of the 63 organic and 24 inorganic
chemicals present on the site.
Response:
Oraanic ComDounds
Acetone
Benzene
Benzoic Acid
Bromomethane
2-Butanone
sec-Butylbenzene
Butylbenzylphthalate
di-n-Butylphthalate
Carbon disulfide
Carbon tetrachloride
Chlorobenzene
Chloroethane
-------
Chloromethane
Chloroform
4-Chloro-3-methylphenol
2-Chlorophenol
2-Chlorotoluene
4-Chlorotoluene
4,4'-DDD
1,2-Dichlorobenzene
1,3-Dichlorobenzene
1,4-Dichlorobenzene
Dichlorodifluoromethane
l,l-Dichloroethane
1,2-Dichloroethane
l,l-Dichloroethene
cis-l,2-Dichloroethene
trans-l,2-Dichloroethene
Total 1,2-Dichloroethene
2,4-Dichlorophenol
2,4-Dinitrotoluene
Ethylbenzene
biS-(2-Ethylhexyl) phthalate
Hexachlorobenzene
Isophorone
Isopropylbenzene
p-Isopropyltoluene
Methylene Chloride
4-Methyl-2-pentanone
2-Methylphenol
4-Methylphenol
4-Nitrophenol
4-Nitro-di-n-propylamine
di-n-Octylphthalate
Carcinogenic PAHs
Noncarcinogenic PAHs
Total PCBs
Pentachlorophenol
Phenol
n-Propylbenzene
Styrene
1,1,1,2,-Tetrachloroethane
1, 1, 2, 2,-Tetrachloroethane
Tetrachloroethane
Toluene
1,2,4-Trichlorobenzene
1, 1, l-Trichloroethane
l,l,2-Tricloroethane
Trichloroethene
Trichlorofluoromethane
l,3,5-Trimethylbenzene
Vinyl Chloride
Total Xylenes
-------
Inoraanics
Aluminum
Antimony
Arsenic
Barium
Beryllium
Cadmium
Calcium
Chromium
Cobalt
Copper
Cyanide
Iron
Lead
Magnesium
Manganese
Mercury
Nickel
Potassium
Selenium
Silver
Sodium
Thallium'
Vanadium
Zinc
Comment:
A res:Jent ~.~ked if children on school buses that rode by the site
are at risk from air contaminants now or during remediation.
Response:
Air sampling at the perimeters of the site indicated that contami-
nants were not migrating from the site. During remediation dust
supp~ession technologies will be utilized to prevent air-borne
contaminants from leaving the site.
Comment:
A resident requested a list of the PRPs.
Response:
The following entities have been identified as potentially
responsible parties:
Allied Corporation
American Locker Group
Bristol Laboratories, Inc.
Carrier Corporation
-------
General Electric Company
International Business Machines Corp.
Norwich Eaton Pharmaceuticals
Pass and Seymour, Inc.
St. Regis Corporation
Solvents and Petroleum Services, Inc.
Stauffer Chemical Company
UNISYS Corporation
U.S. Air Force
Comment:
A resident requested the name of the consultant who conducted the
PRP RI/FS in 1985.
aesponse:
EC Jordan, Inc. conducted the RI/FS undertaken by the PRPs in 1985.
Comment:
A resident asked where the funds used in Superfund investigations
come from.
aesponse:
Superfund is funded via taxes levied against the petrochemical
industry and/or the general treasury.
Comment:
A resident asked is there an update to the November 1986, EPA Test
Method for Evaluatina Solid Wastes, (8W-846).
aesponse:
The EPA guidance document, Test Method for Evaluatina 80lid Wastes,
(SW-846), was last revised in November 1986. However, c. suppleme-:::
was produced in 1987.
Comment:
A resident asked if there is an update to the March 1983, EPA
quidance document, Chemical Analvsis of Water and Wastes (EPA
600/4-79-020) .
aesponse:
The March 1983 revision to the EPA guidance document, Chemical
Analvsis of Water and Wastes (EPA 600/4-79-020), represents the
latest revision to that document.
-------
III. REMAINING CONCERNS
The primary areas of concern which should. be considered during
remedial design and remedial action are health and safety issues
and conununication of information about site activities to interest-,
ed parties. '
Residents and members of local environmental organizations have
strong convictions with regard to the necessary health and safety
precautions that should be taken during remedial implementation.
They also are concerned that the site be secured. This should be
a top priority.
Also of concern is the conununication of information about site
activities to interested parties. This includes schedules for site
activities and off-site disposal. The community is concerned about
the transportation of hazardous waste through their public streets.
-------
~:'".7:
~~.r
~.' .
AUG 271990
CERTIFIED ~~~IL -
RETURK RECEIPT REOUESTED
Ms. Susan B. Griffin
Coordinator
Chenango North Citizens
Against Radioactive Du~ping
P.o. Box 126
South Otselic, New York 13155
Re:
Freedom of Information Act Request (2) RIN-1760-90
Dear Ms. Griffin:
In response to your August 3, 1990 Freedo~ of Informa~ion Act
request, enclosed please find copies of the proposed plan, and
remedial investigation and feasibility study reports for the
Solvent Savers Superfund Site located in the Town of Lincklaen,
Chenango County, New York.
The cost for providing this 1nforrnation is $184.05. An itemized
invoice is enclosed. Please forward your check or money order,
made payable to the u.S. Environmental Protection Agency, within
30 days of the date of this response. Your check should refer to
the RIN number above and should be accompanied by the top portion
of the enclosed Bill for Collection. Your prompt payment of the
amount indicated will be appreciated.
Should you have any questions, please contact me at (212) 264-
9348.
Sincerely yours,
If.
Lisa K. Wong, Project Manager
Western New York Remedial Action Section
Enclosures
bcc:
OEP
FIN
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....
----
.
-
-
AUG 27 1990
CERTIFIED MAIL-
RETURN RECEIPT REOUESTED
Ms. Denise Cote-Hopkins
Assistant LLRW Coordinator
Cortland County Low-Level
Radioactive Waste Office
County Office Building
P.O. Box 5590
60 Central Avenue
Cortland, NY 13045
Re:
Freedom of Information Act Request (2) RIN-175;-90
Dear Ms. Hopkins:
This is in response to your letter dated August 3, 1990, re-
questing information under the Freedom of Informati~n Act with
regard to the Solvent Savers Superfund Site (lithe Site") located
in the Town of Lincklaen, Chenango County, New York. ~ne
following documents were requested in your letter:
i) Phase I work plan
ii) Phase II work plan
iii) Remedial investigation report
iv) Feasibility study report
v) Selection process for remedial
vi) Record of Decision
Enclosed please find copies of the remedial investigation and
feasibility study (RIfFS) reports, and the phase I removal action
work plan entitled, "Existing Drum Characterization and Disposal
Program" for the Site. In addition, a copy of the fact sheet
providing information on the Superfund program's remedial action
selection process is also enclosed for your reference.
alternatives
The phase II removal action work plan, which addresses the buried
drums and contaminated soils at the Site, is currently under
review by the United States Environmental Protection Agency
(EPA). After EPA's approval of the phase II removal action work
plan, a copy of this document will be prepared and sent to your
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. ,/
. ,-
.,
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"
Subseque~t to 'c~nsider~tion of all comments received during
the publ~c comment per~od for the RI/FS reports and the pro-
posed plan, the EPA will select a final remedy, and document
this decision in a Record of Decision ("ROD"). After the
ROD is signed, a-copy of the ROD document will also be pre-
pared and sent to your office.
The cost for providing the RI/FS reports and Phase I removal
action workplan is $199.80. An ite~ized invoice is enclosed.
Please forward ycur check or money crder, made payable to the
U. S. Environmental Protection Agency, within 30 days of the
date of this response. Your check should refer to the RIN
number above and should be accompanied by the top portion of
the enclosed Bill for Collection. Your prompt payment of the
amount indicated will be appreciated.
Should you have any questions, please contact me at (212) 264-
9348.
Sincerely yours,
/=l
Lisa K.
Western
Wong, Project Manager
New York Remedial Action Section
Enclosures
bcc:
OEP
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.
. . t ~ ." " . ~ : ",
;.,,,,,,.. . - ......-
Honorable Sherwood Boehlert
House of Representatives
~ashington, D.C. 20515
Dear Mr. Boehlert:
This is in response to your letter of August la, 1990
concerning Cortland County's Freedom o'f Information Act request
pertaining to the Solvent Savers superfund site.
A copy of each of the following Solvent Savers site documents
were requested by the County:
i)
Phase I removal action workplan
Phase II removal action workplan
ii)
iii)
Remedial investigation report
iv)
Supplemental investigation reports (if any)
v)
Feasibility study report
Selection Process for Remedial Alternatives
vi)
vii)
Record of Decision
In response to the County's request, the Solvent Savers site
remedial investigation and feasibility study reports, the phase I
removal actionworkplan (removal of the on-site surficial drums),
and a fact sheet on the Superfund program's remedial action
selection process will be sent to Denise cote-Hopkins, Assistant
Coordinator of the Cortland County Low-Level Radioactive Waste
Office. There are no supplemental investigation reports. A copy
of the phase II removal action workplan (excavation of the on-site
buried drums and associated contaminated soil) will be sent to Ms.
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. .,/
/
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It is anticipated that a Record of Decision, the document
which will selec~ a remedy for the site, will be signed by the end
of september 1990. At that time a copy will be sent. to the County.
In regard to the concern that the County ..-ill not have
sufficient time to ~=ovide written comments, it should be noted
that the remedial investigation and feasibility study reports,
as well as the proposed Plan, which describes the Environmental
Protection Agency's (EPA's) preferred remedy for the site, were
placed in Pond store, a local repository situated on Star Route,
DeRuyter, New York, in late July 1990. Also, a public meeting
was held on August 13, 1990 to discuss the results of the
investigations, to present EPA's preferred remedy, and to solicit
public comments. Please note that so as to allow the public more
time to review the available documents, the public comment period
has been extended to September 7, 1990.
If you have any questions concerning this response, please
let me know or have your staff contact Jeane Rosianski of the
Office of External Programs at (212) 264-7834.
Sincerely,
/5/
Constantine Sidamon-Eristoff
Regional Administrator
cc:
Thomas C. Jorling, commissioner
New York State Department of
Environmental Conservation
bcc:
.Alice Greene, A-101
-- - .---..-.---
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United States pepartment of the lnte'rior
FISH A~D WILDLIFE SERVICE
100 Grange Place
. Room 202
Cortland, New York 13045
September 17, 1990
Mr. Bill Moran
ICF Kaiser Engineers, Inc.
379 Thornall Street, 5th Floor
Edison, NJ 08837-0001
Dear :-11:. I-10l:tUl:
This responds to public comments you provided to us on the "Bioassessment
the Solvent Savers Superfund Site." Each question identified in your
communication of September 13, 1990 is answered below:
a~
....
Samp:es (sediment, water, fish, benthic invertebrates) were collected up
to 1500 feet downstream of the Solvent Savers Site (site). Sediment
samples were taken from natural deposition areas. If significant levels
of contaminants were detected at this location, the Fish and wildlife
Service (Service) would have recommended chemical analysis at locations
further downstream.
I. .
Low levels of volatile organic contaminants (VOCs) were detected at the
sample site noted above (see pp. 19-21 of the Bioassessment prepared by
the Service). As discussed on page 22 of the Bloassessment,
concentrations of metals and cyanide in sediment were all within
background limits for soils of New York State. Since sediment is where
inorganic substances are mostly likely to accumulate, we do not consider
there to be problems with the levels of metals/cyanide in Mud Creek.
3.
Our conclusion that the VOCs and metals do not pose a significant threa:
to aquatic organisms is based on the following:
. toxic levels of contaminants were not detected in surface water,
. no significant health problems were noted in white suckers evaluated by
a histopathologist,
. fish species diversity was acceptable
. there were no dramatic differences in
that might indicate chemical or other
at all sampling locations, and
benthic invertebrate diversity
stress.
4.
There 1s very little scientific documentation of VOCs in fish tissue.
However, it 1s not necessarily unusual or perplexing that they were
detected in fish from Mud Creek. Many laboratories find it difficult to
analyze for VOCs because of their ephemeral nature. Also, since VOCs ar~
not regarded &5 highly toxic to aquatic organisms, many scientists mav
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s.
,Our theory on why VOCs were detected in fish tissue is that the fish' are
being exposed to chronic, low levels of these substances. We concluded
that the level of exposure is not posing a significant threat to aquatic
organisms. ~is information was publicized in our Bioassessment report
and is part of the public record maintained at the site repository.
Our conclusion that none of the histological lesions detected in fish
tissue can be attributed to contamination at the site or are indicative 0:
serious health problems is based on information provided by Dr. Roger
Herman. Dr. Herman is a histopathologist with the National Fish Health
Research Center in Kearneysville, West Virginia.
We hope this adequately responds to the questions posed. If you would like
additional information, please contact Anne Secord of this office at 607-753-
9334.
Si1fere,~}- , .,,'
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,'... .. .I ( . - - V-'
.,_/~".r-
l '
Leonard P. Corin
Field Supervisor
cc:
EPA, New York, NY (L. Yong, RPM)
EPA, Edison, NJ (M. Sprenger, ERT)
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Ji'\1f.O S7~~i'
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UNITED ST ATES ENVIRON""'ENT AL PROTECTION AGENCY'
REGIO!\; II
JACOB K. JA VITS r~ERAI.. BULDI"'G
NEW YOF;K. NEW YORK 10272
t -~ - ...., .I ..-.. ....
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Ms. Susan B. Griffin, Coordinator
Chenango North Citizens Against Radioactive
Du~ping and All Other Pollution
P.O. Box 126
South Otselic, New York 13155
Dear Ms. Griffin:
This letter ~ill serve to me~orialize our September 7, 1990 and
September 10, 1990 telephone conversations which addressed the
issues concerning the Sol vent Savers Superfund site that were
raised in your August 30, 1990 and September 10, 1990 letters,
respectively.
:~ regard to your request that the Environmental Protection Agency
"~~?e the duplication costs associated with our response to your
Freedom of Information Act request, I suggested that you submit a
written request for a fee waiver or fee reduction to our Freedom
of Information Act Officer, Ms. Wanda Vasquez, at the follo~ing
address:
O~fice ~f External Programs
U.S. Environmental protection
Region II
26 Federal Plaza, Room 905
New York, NY 10278
Agency
In regard to your concerns associated with the excavation of the
contaminated soil and on-site thermal treatment (the preferred soil
remedy), I noted that, to limit the amount of volatile emissions
and dust generated during the soil excavation and handling
activities, vapor suppressive foams and dust suppression
mechanisms, such as water spraying, could be employed if necessary.
The levels of contaminants present in the ambient air during all
on-site soil excavation and handling activities would be monitored.
If unacceptable levels of contaminants are detected in the ambient
air, the on-site Health and Safety Officer would shut down the
operation until the situation could be rectified.' During
treatment, emissions from the thermal treatment unit would be
monitored to make sure that the discharge to the atmosphere
complies with all federal and state air discharge requirements.
If unacceptable levels of contamination are detected, the treatment
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-2-
In yo\:::- lettet:, you expressed a preference fo::- in-situ vapo::-
extraction for treatment of the volatile organic-contamina~cc
soils, since this alternative would reduce the po~ential for
volatile emissions and the generation of dust. As I noted du::-ing
our September 7, 1990 conversation, in-situ vapor extraction is
effective in treating highly permeable, homogeneous soils. The
soil matrix at the Solvent Savers site, however, is complex and
heterogeneous in nature. Accordingly, we believe that employing
in-situ vapor extraction at the Solvent Savers site would result
in the preferential flow of the volatile organics through the soil.
As a result, the complete extraction of the volatile organics fro~
the soil might not be achievable utilizing in-situ vapor
extraction.
You indicated during our September 7, 1990 conversation that, based
upon our discussion, you did not believe that it would be necessary
to have a meeting to discuss in-situ vapor extraction and 10\','
temperature thermal extraction further, as you requested in your
August 30, 1990 letter. You noted further, that your group woul=
:: ~eeting on September 8, 1990 and that you would telefax any
comments derived from your meeting.
As I noted to you during our September 10, 1990 telephone
conversation in regard to your request that we extend the comment
period so that your "independent expert" could review the remedial
investigation and feasibility study report, while we do not intend
to extend the comment period, which ended on Sept~mber 7, 1990, we
will take into consideration comments that are received before a
remedy is selected for the site.
The remaining questions and concerns raised in your September 10,
1990 letter will be addressed in the Responsiveness Summary, which
will be attached to the Record of Decision, the document w.hich will
formally select a remedy for the site.
Should you have any questions, please contact me at (212) 264-
1132.
Sincerely yours,
~~~
Joel Singerman, Chief
Western New York Remedial
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PROPOSED PLAN
FOR THE
SOLVENT SAVERS SITE
LINCKLAEN, NEW YORK
PREPARED BY THE
U.S. ENVIRONMENTAL PROTECTION AGENCY
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INTRODUCTION
This Proposed Plan describ~s the remedial alternatives c~nsidered
for the Sol vent Savers Superfund site and' identifies 'the U. S.
Environmental Protection Agency's (EPA's) and the New York State
Department of -Environmental Conservation's (NYSDEC I s) preferred.
remedy and the rationale for this preference..
This document i~ issued pursuant ~o section 117(a) of the.Compre-
hensive Environmental Response, Compensation, and Liability Act as
amended, 42 U.S.C. Section 9601 et sec. ("CERCLA"), commonly known
as Superfund.
SITE LOCATION
The Solvent Savers site (hereinafter, "the Site") covers about 13
acres in a rural, sparsely populated area, and is located in the
Town of Lincklaen, Chenango County, New York (See Figure 1). The
Site is bounded by Union Valley Road to the west, Mud Creek to the
east, an unnamed intermittent stream to the north, and shrubs and
trees to the south (see Figure 2). Mud Creek is classified as a
trout stream by NYSDEC and is used for recreational activities and
livestock watering. Three residences, which are located within 300
feet of the Site, utilize private wells as the source of drinking
water.
SITE HISTORY
Solvent ~avers, Inc. was a chemical waste recovery facility
operated by Mr. Dale Hough between approximately 1967 and 197~.
Waste industrial solvents were hauled from ~lients in the Syracuse
and Binghamton areas to the facility. A distillation process was
used to recover solvents for reuse. It is suspected that a wide
variety of wastes from the distillation process, including liquids,
solids, and sludges, were disposed of on the Site. In addition,
Mr. Hough owned and operated a drum reconditioning business (Cash
Barrel, Inc.) at the same location, which reconditioned and sold
many of the drums brought to the Site containing waste solvents.
Solvent Savers, Inc. ceased operations in 1974. In October 1978,
Mr. Robert Lindsey purchased the property and regraded it, moving
some exposed drums and a large tank, and covering them with soil.
He also removed some exposed drums from the Site.
In 1981, NYSDEC conducted an initial site characterization, which
included sampling of the on-site surface soils, water in Mud Creek,
and groundwater from three private wells in the immediate vicinity
of the Site. Sample analyses indicated the presence of contami-
nants that included volatile organics (primarily trichloroethylene
and 1,1, I-trichloroethane) , polychlorinated biphenyls ("PCBs") , and
various inorganic substances (arsenic, cyanide, cadmium, and lead) .
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In 1982, the EPA Field Investigation Team ("FIT") performeod a
hazardous waste site inspection at the Site. During the FIT
investigation, metals and organic compounds were detected in the
surface soils, and organic chemicals were detected in the groundwa-
ter beneath thg Site and in the surface water in Mud Creek. As a
result of the FIT investigation, the Site was. listed on the
National Priorities List of uncontrolled hazardou~ waste sites in
1983.
EPA and NYSDEC identified a number of potentially responsible
parties ("PRPs") that had arranged for the disposal of wastes at
the Site. The State of New York initiated negotiations with the
PRPs to begin the site cleanup.
In 1984, a consent agreement between the PRPs and the New York
State Department of Law ("NYSDOL") was si~ned, requiring the PRPs
to perform a remedial investigation and feasibility study ("RI/FS ")
at the Site. In August 1985, a consultant for the PRPs prepared
an RI/FS report that recommended the following:
i)
Excavate the buried drums for treatment and/or
disposal off-site;
ii)
Cover portions of the Site with a less permeable soil
cover and revegetate;
loii)
Restrict future use of contaminated groundwater using
institutional controls; and
iv)
Allow natural flushing to reduce the levels of con-
taminants in the groundwater to acceptable levels.
(The estimated time to naturally flush the contami-
nants from the soil was 85 years).
On the basis of a review the PRPs' RI/FS report, it was determined
that additional RI/FS work was necessary to obtain the data and
information needed to characterize the nature and extent of
contamination at the Site, and to formulate the optimum cleanup
strategy.
In 1988, notification was sent by the EPA to the PRPs, stating
EPA's intent to perform a supplemental RI/FS, and offering the PRPs
an opportunity to conduct the supplemental RI/FS. The failure of
the PRPs to agree to undertake the supplemental RI/FS in an
acceptable manner prompted EPA to initiate a supplemental RI/FS
independently.
ICF Technology, Inc. ("ICr"), EPA's consultant, commenced field
investigations under the supplemental RI/FS in November 1988.
Field work was completed in May 1990. The field investigations
included surface and subsurface soil sampling, a magnetometer
survey, test pit excavations, soil gas sampling, monitoring well
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installation, depth-to-water measurements, surface water, sediment I
groundwater, and air sampling, a pump test, a study of the biota
in" Mud Creek, a delineation of the wetlands and floodplains, and
cultural and biological resources studies.
During the pe-rformance of the field work associated with the
supplemental RI, over 100 drums were excavated and overpacked by
ICF. An unknown number of drums remain buried.
In September 1989, EPA issued an Administrative Order to the PRPs,
requiring the PRPs to undertake the following removal activities:
- Remove and properly dispose of the overpacked drums;
- Excavate, overpack, remove, and properly dispose of the
buried drums;
- Implement a soil sampling program to define the nature and
extent of contamination resulting from releases of hazardous
constituents from the buried drums; and
- Excavate, treat and/or dispose of the contaminated soil
associated with the drums.
In October 1989, the PRPs' consultant submitted to EPA a phase I
removal action work plan, which detailed the tasks that would be
involved in the removal and disposal of the overpacked drums. The
PRPs' consultant sampled the contents of the drums and is currently
in the process of obtainin~ disp;sal facility approvals for dis-
posal of the overpacked drums. A phase II removal action work
plan, which outlines the activities to be implemented to address
the drums that remain buried and the contaminated soils at the
Site, is presently under review by EPA.
During the RI conducted by rCF, five source areas were identified
(see Figure 2). Samples collected from surface and subsurface
soils in these areas show that the soils are contaminated with
volatile organic compounds (ItVOCslt), extractable organic compounds,
metals, and PCBs. Areas 2 and 4 are identified in the FS as
requiring remediation. Areas 1, 3, and 5 may require remediation
depending upon the results of a model currently being implemented
by EPA to determine target clean-up levels.
Area 1 was previously used as a drum storage area. Volatile and
extractable organic contaminants were found at a depth of about 12
feet. Chromium and lead were found in surface soils.
Area 2 was previously used as a discharge area for spent solvents
and wastewaters and as a drum disposal area. Area 2 has the
highest levels of surface and subsurface soil contamination on-
site. The primary contaminants detected were tetrachloroethene
(ItPCEIt), trichloroethene (ItTCE"), and 1,1, 1-trichloroethane. In
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addition, a PCB hot-spot was detected in this area.
det~cted above the background level.
Barium was
Area 3 was the location of an excavation that was backfilled with
a SOO-gallon ta~, a drum, and miscellaneous debris. VOC c~ntami-
nation was detected in this area.
Area 4 is located in the central portion of the Site and includes
a large drum burial area. VOC contamination was found consistently
in all borings down to the water table (approximately 40 feet).
TCE was the chemical found most frequently. Low levels of PAHs
and phthalates were detected. PCB contamination was detected in
surface soils in this area. The highest level of surface PCB
contamination detected was 18,600 ppm.
Area S is located near the former Lindsey residence. VOC contami-
nation was detected at depths down to 32 feet. TCE was the
chemical detected most frequently. Barium was detected above the
background level.
Groundwater samples collected on-site and downgradient show the
presence of contamination by VOCs and metals. The VOC contamina-
tion is primarily TCE, PCE, and degradation products of these
compounds. The metals include lead, chromium, arsenic, beryllium,
and cadmi Un',.
As part of the supplemental RI, EPA, in cooperation with the u.S.
Fish and Wildlife Service, completed the field work for a
bioassessment at the Site in May 1989. The objective of this study
was to determine whether contaminants from the Site are causing
adverse ecological impacts to the fish and wildlife resources in
the Mud Creek. Samples of surface water, sediment, and fish
tissues were collected, and analyses were performed for VOCs, PCBs,
pesticides, base neutral/acid extractables (BNAs)~ metals and
cyanide. No BNAs were detected in fish tissues. The levels of
BNAs detected in surface water and sediment were below detection
limi ts. No pesticides or PCBs were detected in surface water,
sediment or fish samples. The levels of VOCs and metals detected
in surface water, sediment, and fish tissues do not pose a
significant threat to aquatic organisms. VOCs are rapidly
biodegraded and exhibit a low potential for bioaccumulation. A
number of lesions in fish tissues were found, but none can be
attributed to the contamination at the site or are indicative of
serious health problems.
SUMMARY OF SITE RISKS
A baseline health risk assessment was performed as part of the
supplemental RI to describe t~e carcinogenic risks and nor..
carcinogenic chronic lifetime effects associated with the Solve~-
Savers site, assuming that no remedial action occurs. The risk
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assessment was based on the analysis of the impact of 63 organic
and 24 inorganic chemicals present at the Site.
Po'tential human health risks were evaluated for the following
exposure pathways:
Current exposure of neighboring children and teenagers to
surface soil contaminants through direct contact, with
subsequent incidental ingestion and dermal absorption during
play activities;
Current exposure of nearby residents to groundwater conta~i-
nants through ingestion of drinking water from residential
wells;
Current exposure of neighboring children and teenagers to
sediment and surface water contaminants in Mud Creek and the
intermittent stream through direct contact, with subsequent
incidental ingestion and/or dermal absorption d~ring play
activities;
Future exposure of on-site residents to surface soil conta~i-
nants through direct contact, with subsequent incidental
ingestion and dermal absorption;
Future exposure of on-site residents to subsurface soil,
contaminants through direct contact, with subsequent inciden-
tal ingestion and dermal absorption during play activities;
aTld
Future exposure of on-site residents to groundwater conta~i-
nants through ingestion of drinking water from on-site wells.
For each of the potential exposure pathways identified above,
potential risks to human health were estimated. Exposure scenarios
were developed for each pathway to represent a reasonable maximum
exposure case. Quanti tati ve risk estimates were developed by
calculating intakes for the potentially exposed populations based
on the assumed exposure scenarios and then combining these intakes
with reference doses (for noncarcinogens) or cancer slope factors
(for carcinogens).
Under current land use conditions, the excess estimated life-time
cancer risk for the direct soil contact p~thway (4XlO'2) exceeds
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[PAis target cancer risk range (lO~ to lO~)', primarily due to. the
presence of PCBs in the soil. The excess lifetime cancer risk is
about one in a hundred thousand for the direct sediment contact
pathway and about one in a million for the residential ground~ater
ingestion pathway. The excess lifetime cancer risks for these t~c
pathways fall -within [PAis target risk range. The hazard index
values for noncarcinogenic effects exceed the t~.~eshold level of
one2 for the direct soil contact pathway, due t~. the presence of
PCBs.
Under future land use conditions, the excess lifetime cancer risks
exceed [PAis target cancer risk range for all the pathways examined
(direct surface and subsurface soil contact, and ingestion of
groundwater). These risks were primarily associated with exposure
to PCBs for the soil pathway and to several volatile organics and
PCBs for the groundwater pathway. Additio~ally, the hazard index
values exceed one for these pathways, indicating that adverse
noncarcinogenic effects could occur. These potential noncarcinoge-
nic risks are predominantly due to exposure to PCB= for the soil
pathways and PCBs, chloroform, methylene chloride, PCE , and 1,1,1-
trichloroethane, for the groundwater pathways.
Actual or threatened releases of hazardous substances from this
Site, if not addressed by the preferred alternative or one of the
other remedial measures considered, may present a current or
potential threat to public health, welfare, or the environment.
PURPOSE OF THE PROPOSED PLAN
The Proposed Plan outlines the remedial alternatives evaluated for
the Site, and presents the rationale used in making the prelimina~y
selection of the preferred remedy to protect human health and t~e
environment from exposure to contamination at and emanating fro~
the Site.
'Excess lifetime cancer risks are probabilities that are generally
expressed in scientific notation (e.g., lX10.). An excess lifetime
cancer risk of lxlO. indicates that, as a maximum upper bound, an
individual has a one in one million chance of developing cancer as
a result of site-related exposure to a carcinogen over a 70-year
lifetime under the specific exposure conditions at a site.
2For noncarcinogens, hazard index values were calculated. A hazard
index greater than one indicates that adverse noncarcinogenic
effects could occur, while a value below one indicates that such
effects are unlikely to occur.
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Changes to the preferred remedy or a change from the preferred
remedy to another remedy. may be made if publ ic . comments or
additional data indicates that such a change will result in a more
appropriate. solution. The final decision regarding the" selected
remedy will be made after EPA has taken into consideration all
comments the ~blic. We are soliciting public comment on all of.
.the alternatives considered in the detailed analysis phase of the
RI/FS because EPA and NYSDEC may select a remedy other than the
preferred reme~y. .
The detailed information and data used in determining the nature
and extent of the contamination on-site and in the development of
remedial al ternati ves is contained in the RI/FS report. The
Proposed Plan highlights key information from the RI/FS report, but
it is not a substitute for that report.
Copies of the RI/FS report, Proposed Plan, and supporting documen-
tation are available at the following repositories:
- Pond's Store
Star Route
DeRuyter, New York 13052
- New York State Department of
Environmental Conservation
50 Wolf Road
Albany, N.Y. 12233
- U.S. Environmental Protection Agency
Emergency and Remedial Respo~se Di'ision
26 Federal Plaza, Room 29-102
New York, N.Y. 10278
SUMMARY OF REMEDIAL ALTERNATIVES
CERCLA requires that each selected site remedy be protective of
human health and the environment, be cost effective, comply with
other statutory laws, and utilize permanent solutions and alterna-
tive treatment technologies and resource recovery alternatives to
the maximum extent practicable. In addition, the statute includes
a preference for the use of treatment as a principal element for
the reduction of toxicity, mobility, or volume of the hazardous
substances.
The findings of the RI are summarized as follows:
Soils at the Site are contaminated with VOCs, extractable
organic compounds, metals, and PCBs. The extent of VOC contami-
nation is widespread and is concentrated in five areas. Metals
contamination is less widespread (most contamination is around
background levels), occurring in areas where VOC contamination
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also exists.
at the Site.
The PCB contamination is limited to two hot spots
Groundwater is contaminated with VOCs and metals underneath and
downgradient_of the Site. The VOC contamination is primarily
TCE, PCE, and related compounds that could be TCE and PCE
degradation products. The contamination decreases with distance
from the source areas.
The remedial response objectives can be summarized as follows:
Provide protection of human health and the environment fror:1
exposure to the PCB-contaminated soil:
Provide protection of the groundwater, air, and surface water
from the continued release of contaminants from the soils and
buried leaking drums (to the extent that the removal work is not
completed pursuant to the September 1989 Administrative Order) ;
and
Protect human health and the environment from current and
potential future migration of contaminants in groundwater.
Accordingly, the FS evaluates, in detail, seven remedial alterna-
tives for addressing the contaminated soils that contribute to
groundwater contamination, as well as six remedial alternatives for
addressing the groundwater contamination, at the Solvent Savers
site.
These alternatives are:
SOIL ALTERNATIVES
Alternative SC-l:
No Action
The Superfund program requires that the "no-action" alternative be
considered as a baseline for comparison of other alternatives.
Under this alternative, EPA would take no further action to control
the source of contamination. However, long-term monitoring of the
Site (for a minimum period of 30 years) would be necessary to
monitor contaminant migration. Monitoring would consist of annual
soil, sediment, and surface water samplinq and analyses for a
variety of contaminants.
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 to remove or treat wastes.
Alternative SC-2:
Limited Action
The Limited Action alternative would limit public exposure to the
contamination at the Site, but would not treat or remove the
-------
contamination. This alternative would include the installation of
a security fence and the posting of warning signs around the Site;
annual soil and groundwater monitoring and site inspections; a
public education program, institutional controls to limit site use
and site' access; and a review of site conditions every five years.
If justified b~ the review, remedial actions may be implemented tn
remove or treat wastes. ..
Alternative SC-3:
site Ca~~ina
This alternative would include clearing the vegetation at the Site,
grading and compacting the soil, and placing a 40-mil thick high
density polyethylene (HDPE) liner and a compacted, la-inch clay
layer over the contaminated areas. Additionally, an la-inch layer
of topsoil would be placed on top of the clay, and vegetation would
be planted to ~inimize the erosion of the topsoil. A fence would
be constructed to surround the capped area, and land use restric-
tions would be implemented. This alternative would minimize the
risks to the public of direct contact with the conta~inated soil.
Further, the HDPE liner and impermeable clay layer would limit
rainfall infiltration into the subsurface, thereby limiting
contaminant transport to the groundwater. The cap and fence would
be inspected, and the soil and groundwater would be sampled, in a
long-term monitoring program. Five-year reviews would be conducted
to deter~ine the effectiveness of the remedy.
Alternative SC-4:
In-situ VaDor Extraction
This alternative would employ in-situ vapor extraction to treat the
contaminated soils.
Soil vapor extraction involves the collection of soil vapor fro~
the unsaturated (vadose) zone by applying a vacuum at extraction
points. The vacuum would draw vapor from the unsaturated zone, at
the sa~e time decreasing the pressure around the soil particles and
releasing the VOCs. Because of the pressure difference, clean air
from the atmosphere would enter the soil and replace the extracted
air. The technology depends on factors such as soil permeability
and depth to groundwater. Extraction wells, piping, and a positive
displacement blower (vacuum pump) would be required to draw the
vapor from the vadose zone. The collected air would be treated
through an activated carbon unit. Spent carbon would be removed
for off-site regeneration or incineration.
Under this alternative, the PCB-contaminated soils would be exca-
vated and removed from the Site for off-site incineration. The
buried drums would be excavated and removed from the Site for off-
site treatment/disposal. On-site treatment was not considered due
to the low volume of PCB-contaminated soils.
Under this alternative, long-term monitoring would not be required.
-------
Alternative SC-5:
Excavation/Low-TemDerature Thermal
Extraction/on-Site RedeDosition
This alternative involves the excavation and on-site treatment of
contaminated soils by low-temperature thermal extraction. The
excavated soil would be fed to a thermal treatment. unit, where hot
air injected at a temperature above the boiling points of the
organic contaminants of concern would allow the moisture and the
organic contaminants to be volatilized into gases and escape fror.\
the soil. The organic vapors extracted from the soil would then
be treated in a scrubber for particulate removal and acidic gas
absorption.
FOllowing treatment, the soils would be tested in accordance with
the Toxicity Characteristic LeaChing Procedure (IITCLpll) to deter-
mine whether they constitute a Resource Conservation and Recovery
Act (IIRCRAn) hazardous waste. Provided that they pass the test,
they would be used as backfill material for the excavated area.
Clean topsoil would be placed on the excavated areas, and the site
would be regraded and revegetated.
Under this alternative, the PCB-contaminated soils would be exca-
vated and removed from the Site for off-site incineration. The
buried drums would be excavated and removed from the Site for off- .
site treatment/disposal. On-site treatment was not considered due
to the low volume of PCB-contaminated soils.
Under this alternative, long-term monitoring would not be required.
Alternative SC-6:
Off-site Incineration
This alternative would involve excavating the contaminated soi1
and transporting it to a permitted off-site incinerator for
treatment and disposal.
The contaminated soil and buried drums would be excavated and
staged. Contaminated materials would then be placed directly into
20-cubic yard trucks for shipment to the nearest available
hazardous waste incinerator. Clean fill would be used to backfill
the excavation area and the area would be revegetated.
Under this alternative, long-term monitoring would not be required.
Alternative SC-7:
In-Situ Soil Flushina
This alternative would consist of the use of treated groundwater
to flush the areas of soil contamination. A groundwater extraction
and treatment system would be required. Because this is an in-situ
contaminant removal process, this alternative would require minimal
excavation (well installation, distribution system, and grading of
the recharge basins) for implementation.
-------
Since the total volume of groundwater extracted and treated could
not be recharged (flushed), discharge of a portion of the treated
wa~er to Mud Creek would be required.
Under this alternative, the PCB-contaminated soils would be exca-
vated and rem~ved from the Site for off-site 'inc~neration. The
buried drums would be excavated and removed from the Site for off-
site treatment/disposal. On-site treatment was not considered due
to the low volume of PCB-contaminated soils.
Environmental monitoring would be required during the life of the
treatment process. In addition, monitoring of the groundwater at
the Site would continue for at least five years after the comple-
tion of the remediation to ensure that the goals of the remediation
have been met.
GROUNDWATER ALTERNATIVES
Alternative GW-l:
No Action
Under this al ternati ve, no action would be taken to remedy the
ground~ater contamination at the Site or to control its spread.
This alternative is used as a basis of comparison for other
groundwater remediation alternatives. Under this alternative, the
Site would be reviewed every five years.
Alternative GW-2:
Lwtec! Aet~
This al ternati V€ woulr, include long-term groundwater monitoring and
insti tutional .l.estn.~tions on groundwater use. The monitoring
would consist of annual groundwater sampling to track the movement
of contaminated water and assess the need for future remediation.
Institutional restrictions would prohibit the use or installation
of water supply wells on-site. Under this alternative, the Site
would be reviewed every five years.
Alternative GW-3:
Groun4water Extraction/Chemical
Preci~itation/Carbon A4sor~tion
Under this alternative, contaminated groundwater would be pumped
out of the ground through extraction wells. The extracted
groundwater would be pumped to an equalization tank. Chemical
precipitation would be employed to remove inorganic contaminants,
followed by carbon adsorption to remove organic contaminants.
The chemical precipitation process would consist of the addition
of lime to precipi tate dissolved metals. A coagulant would be
added to induce flocculation. The sludge generated would undergo
dewatering and would be transported to an off-site treatment/dispo-
sal facility.
-------
Carbon adsorption is the exposure of the contaminated groundwater
to units filled with carbon. The contaminants come out of solution
with the water and adhere to (are adsorbed onto) the carbor.
.surface.
In order to prevent the loss of vapors to the ~tmosphere, the
equalization tank, the chemical precipitatio'.. unit, and the
filtration unit would be equipped with floating ..:)vers to prevent
volatilization -
The treated water would be reinjected into the aquifer and/or
discharged to Mud Creek.
Environmental monitoring would be required during the life of the
treatment process. In addition, monitoring of the groundwater at
the Site would be conducted for a period of five years after
completion of the remediation to ensure that the goals of the
remedial action have been met.
Alternative GW-4:
Groundwater Extraction/Chemical PreciDitation/
Air striDDina/Carbon AdsorDtion
Under this alternative, contaminated groundwater would be pumped
out of the ground through extraction wells. The extracte::
groundwater would be pumped to a centrally located treatment plant
on-site, where it would be treated by chemical precipitation to
remove inorganic contaminants, and by air stripping and carbon
adsorption to remove organic contaminants.
The groundwater extraction, chemical precipitation, and carbon
adsorption processes would be the same as Alternative GW-3.
Air stripping is a mass transfer process in which volatile organics
in water are transferred to the air blown in at the bottom of a
packed tower.
The treated water would be reinjected and/or discharged to Mud
Creek.
Environmental monitoring would be required during the life of the
treatment process. In addition, monitoring of the groundwater at
the Site would be conducted for a period of five years after
completion of the remediation to ensure that the goals of the
remedial action have been met.
Alternative GW-S:
Groundwater Extraction/Chemical Precinitation/
UV Oxidation
Under this alternative, contaminated groundwater would be pumped
out of the ground through extraction wells. The extracted
qroundwater would be pumped to an equalization tank, and then to
a rapid mixing tank, where inorganic contaminants would be removed
-------
by chemical precipitation." Next, the water would be treated by UV
oxidation to remove organic contaminants.
The groundwater extraction and chemical precipitation .~rocesses
would be the same as Alternative GW-3.
Following cher:\lcal precipitation, the grou"ndwater" would enter an
oxidation tank. There, it would be mixed with a metered dose of
an oxidant (e.g., hydrogen peroxide or ozone) and be exposed to
high intensity-ultraviolet (It Wit) radiation. In the presence of
UV light, the oxidant molecules would decompose to form hydroxyl
radicals. Also, some organic contaminants would absorb UV light
and beco~e more reactive. The hydroxyl radicals would break down
the organic molecules into smaller blocks and eventually to carbon
dioxide, water, and non-hazardous salts. The treated water would
be filtered for the removal of suspended particles and collected
in a storage tank. To prevent the loss of vapors to the atmo-
sphere, the equalization tank, the chemical precipitation unit, and
the filtration process unit would be equipped with floating covers"
to prevent volatilization.
The treated water would be reinj ected and/or discharged to Mud
Creek.
Environmental monitoring would be required during the life of the
treat~ent process. In addition, monitoring of the groundwater at
the Site would be conducted for a period of five years after
completion of the remediation to ensure that the goals of the
remedial action have been met.
nlternative GW-6:
Groun~water Extraction/Chemical PreciDitation/
Bioloaical Treatment
Under this alternative, contaminated groundwater would be pumped
out of the ground through extraction wells. The extracted
groundwater would be treated by chemical precipitation to remove
inorganic contaminants, and by activated carbon biological
treatment to remove organic contaminants.
The groundwater extraction and chemical precipitation processes
would be the same as Alternative GW-3.
After chemical precipitation, the water would be pumped into the
aeration tank, where it would be mixed with granular activated
carbon and biological solids. The water-carbon-biological solids
mixture would be aerated so that the biodegradable content of the
groundwater could be biologically oxidized and assimilated. After
aeration, the mixture would be sent to a clarifier, where the
granular carbon and the biological solids would settle and be
separated from the treated water. The clarifier overflow (treated
water) would be filtered and collected in a storage tank. The
clarifier underflow solids would be recycled to the aeration tank
-------
to maintain the appropriate concentration of the granular activated
carbon and biological solids. A portion of the clarifier underflow
containing granular activated carbon and excess biological s~~ids
would be wasted daily, dewatered, and aerobically digested and
disposed. Make-up granular activated carbon would be added to the
aeration tank daily to account for the loss of that.substance. The
equalization tank, the chemical precipitation unit, and the
filtration unit would be equipped with floating covers to prevent
the loss of.volatile chemicals prior to adsorption in the biologi-
cal unit.
Environmental monitoring would be required during the life of the
treatment process. In addition, monitoring of the groundwater at
the Site would be conducted for a period of five years after
completion of the remediation to ensure that the goals of the
remedial action have been met.
All alternatives described above would include pre-construction,
construction and post-construction air monitoring. .
PREFERRED ALTERNATIVE
Based upon an evaluation of the various alternatives, EPA and
NYSDEC reco~~end Alternative SC-S, Excavation/Low Temperature
Thermal Extraction/On-Site Redeposition, for treatment of the
contaminated soil and Alternative GW-4, Groundwater Extraction!
Chemical Precipitation/Air Stripping/Carbon Adsorption, for
treatment of the contaminated groundwater, as the preliminary
choice for the Site remedy.
RATIONALE FOR SELECTION
During the detailed evaluation of remedial alternatives, each
alternative is assessed against nine evaluation criteria, namely
short-term effectiveness, long-term effectiveness and permanence,
reduction of toxicity, mobility or volume, implementability, cost,
compliance with applicable or relevant and appropriate requirements
("ARAR~"), overall protection of human health and the environment,
and state and community acceptance.
Each criterion will be briefly addressed with respect to the
preferred alternatives for both soil and groundwater.
-------
GLOSSARY OF EVALUATION CRITERIA
- Overall Drotection of human
health and the environment ad-
dresses whetherlOr not a remedy
provides adequate protection and
describes how risks posed
through each pathway are elimi-
nated, reduced or controlled
through treatment engineering
controls or institutional con-
trols.
- Compliance with ARARs address-
es whether or not a remedy will
meet all of the applicable or
relevant and appropriate requir-
ements of other federal and
state environmental statues
and/or provide grounds for in-
voking a waiver.
- Lonq-terr.! effectiveness and
Derrnanence refers to the ability
of a remedy to maintain reliable
protection of human health and
the environment over time, once
cleanup goals have been met.
It also addresses t~.e mag':"'d tude
and effectiveness of the mea-
sures that may be required to
manage the risk.
- Reduction of toxici tv. mobili-
tv. or volume through treatment
refers to the anticipated per-
formance of the treatment tech-
nologies, with respect to these
parameters.
- Short-term effectiveness in-
vol ves 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 of the
alternative.
- ImDlementabilitv involves the
technical and administrative
feasibility of a remedy, includ-
ing the availability of materi-
als and services needed to im-
plement the chosen solution.
- Cost includes both capital and
operation and maintenance
("O&M") costs. Cost comparisons
are made on the basis of present
worth values. Present worth
values are equivalent to the
amount of money which must be
invested to implement a certain
alternative at the start of
construction to provide for both
construction costs and 0 & M
costs over a 30 year period.
- State acceDtance indicates
whether, based on its review of
the RI/FS report and the Pro-
posed Plan, the State concurs
wi th, opposes, or has no comment
on the preferred alternative.
- Communi tv acceDtance will be
assessed in the ROD following
a review of the public comments
received on the RI/FS report and
the Proposed Plan.
-------
SOIL ALTERNATIVES
A.
Overall Protection of Human and the Environment
Alternative SCSl provides no protection of human health and the
environment from direct contact with contaminated soils. Alterna-
tive SC-2 provides a limited measure of protection through the
installatio" o( a site perimeter fence. and the implementation of
site use restrictions. Alternative SC-3 includes the installation
of a site perimeter fence and construction of a cap, thereby
providing additional protection due to reduction in direct contact
risks. Over the long-term, the cap is anticipated to decrease
leachate generation, mobility, and the volume of leachate reaching
the aquifer.
Al ternatives SC-4, SC-S, SC-6, and SC-7 provide even greater
protection by direct treatment of contaminated soils and subsequent
reduction of leachate within a relatively short timeframe. These
alternatives, which also remove PCB-contaminated soils and drums,
are far more protective of human health and the environment than
Alternative SC-3.
The treatment of soils to remove the most mobile wastes would
resul t in the elimination of a long-term source of groundwater
contamination and it would mitigate the risks to public health and
the environment associated with the migration of those contaminants
off-site. Alternative SC-S, the preferred alternative, would
effectively mitigate those risks by removing the most mobile wastes
from the soil leaving only the less l.!obile organic and metal
compounds in the soil (provided that the treated soil that is
replaced has passed the TCLP toxicity test).3
Alternatives SC-3 through SC-7 would also mitigate the risks to
public health and the environment associated with the leaching of
contaminants into the groundwater and their migration off-site.
Under Alternatives SC-l and SC-2, contaminants would continue to
leach from the soil into the groundwater and continued off-site
migration of contaminants would occur. Monitoring would be
implemented to observe contaminant migration, but an indeterminate
amount of time would elapse between detection and the implementa-
tion of mitigating measures.
B. ComDliance with ARARs
All technologies proposed for use in Alternatives SC-3 through SC-
7 would be designed and implemented to satisfy all action-specific
regulations, including all air emission standards. In addition,
. ~If the treated soil does not pass the TCLP test, further treatment
may be necessary.
-------
all disposal of buried drums, contaminated soils, and PCBs would
be,in accordance with the applicable RCRA/Toxic Substances Control
Act regulations, including the land disposal regulations under
RCRA.
No federal or New York State regulations specify cleanup levels for
contaminants in soils. In terms of achieving target levels for
soils for the purpose of removing potential sources of groundwater
contamination, Alternatives SC-4 through SC-7 would be effective.
C.
Reduction of Toxicitv. Mobilitv. or Volume
Alternatives SC-l and SC-2 would provide no reduction in toxicity,
mobility, or volume. Alternative SC-3 would reduce the mobility
of the contaminants but would not reduce the toxicity or volume.
Alternatives SC-S and SC-6 would result in comparable reductions
in the toxicity, mobility, or volume through the use of treatment.
Alternatives SC-4 and SC-7 would result in the reduction of
toxicity, mobility, or volume but to a lesser degree than the
thermal treatment alternatives due to the possibility of preferen-
tial flo~ in the vadose zone.
D.
ImDlementabilitv
All of the alternatives are technically feasible, but differ in the
complexity of implementation. Alternatives SC-3, SC-4, SC-S, and
SC-7 would utilize relatively common construction equipment and
materials. Alternate SC-4, which requires soi1 gas extraction
wells, piping, a vacuum system, and a mo}o.ile 'reatment syster.:,
would be relatively easy to implement. Al ternati ve SC-7 may
require extensive start-up testing to determine optimum recharge
rates and to monitor changes in groundwater flow directions. Al-
though the technologies employed in Alternatives SC-4 and SC-7 have
been successfully pilot tested and have been utilized on a full
scale basis for treatment of soils contaminated with VOCs, the
complex and heterogeneous nature of the soils at the Site may
render Alternatives SC-4 and SC-7 inappropriate for site
remediation. Alternatives SC-S and SC-6, which involve large scale
excavation and backfilling operations, would be more difficult to
implement than the in-situ remedies due to the volume of soil
(about 60,000 cubic yards) required to be handled.
Al ternative sC-S, excavation/low temperature thermal extraction/on-
site redeposition, the preferred alternative, has been successfully
pilot tested and has preformed on a full-scale basis with similar
organic contaminants.
Alternatives SC-4, SC-S, SC-6, and SC-7 include the excavation and
off-site treatment/disposal of PCB-contaminated soils and buried
drums which would be relatively easy to implement.
-------
.
E.
Lona-Term Effectiveness
~ .ternatives SC-l and SC-2 do not include any removal, containment,
C~ treatment of contaminated soils, and hence, the health risks
present at the~ite would remain. Alternative SC-2 would restrict
site access and potential direct contact with contaminated soils.
Installation of the cap under Alternative sc-: would provide
reduction of the residual risks of direct cc: .-act and of the
leaching of contaminants to the groundwater. The preferred
alternative, Alternative SC-S, as well as Alternatives SC-4, SC-6,
and SC-7, include the treatment of contaminated soils. In Alterna-
tives Sc-s and SC-6, no residual risks would remain, as the
backfilled soils would be clean. In Alternative SC-4 and SC-7,
some levels of contamination below action levels may remain in the
soil. These calculated concentration levels are the levels whereby
the leachate generated would be below MCLs. However, the effects
of this residual contamination would be mitigated by the groundwa-
ter extraction and treatment alternative.
Alternatives SC-3, SC-4, SC-S, SC-6, and SC-7 incorporate proven
engineering methods that are reliable for the control of leachate
generation and protection of the groundwater.
The success of Alternatives SC-4 and SC-7 would be a function of
the permeability of the vadose zone. Since the vadose zone is
co~plex and heterogeneous in nature, these two alternatives may not
result in the successful removal of the contaminants due to the
possibility of preferential "flow" paths in some areas, and little
or negligible flow in other areas.
All risks associated with the buried drums and PCB-contaminated
soils in Alternatives SC-4, SC-S, SC-6, and SC-7 would be complete-
ly mitigated as these wastes would be properly treated and disposed
of at approved Toxic Substances Control Act/RCRA facilities. The
capping in Alternative SC-3 would only reduce the risks relating
to the direct contact with PCB-contaminated soil and buried drums.
F.
Short-Term Effectiveness
All alternatives, with the exception of Alternatives Se-l,
Se-2, and Se-3, include activities such as excavation and off-site
transport of contaminated soils for disposal that could result in
potential exposure of residents to volatilized contaminants and
contaminated dust. However, mitigative measures to reduce the
probability of exposure would be implemented.
Alternatives SC-4 through SC-7 would result in worker exposure to
volatilized contaminants and dermal contact with contaminated soils
uring waste excavation and handling. In addition, the preferred
.lternative, Alternative sC-S, might result in low-level emissions
~xposure from the on-site treatment unit. The threat to on-site
workers end the community, however, would be mitigated through the
-------
"
use of protective equipment by the on-site workers and control of
emissions would be accomplished by emissions treatment. Addition-
ally, scrubber wastewater would require removal and treatment prior
to' complete demobilization from the Site. .
The groundwate~ and site use restrictions of Alternative SC-2 could
be iIr.plemented wi thin 6 months after start p'f construction. '
, However, Alternative SC-2 would only reduce the potential risk
associated with groundwater ingestion, and not directly address the
continued leaching of contaminants. Al ternative SC-3 ,could be
completed within 6 months after start of construction, but would
require more than 30 years for achieving remediation. Alternatives
SC-4, SC-S, and SC-6 could be completed within 1 year after start
of construction. Alternative SC-7 could be implemented within 3
months after start of construction, but would require 20 years to
achieve remediation.
G. Cost
The total present worth cost for the preferred soil Alternative SC-
5 is $19,416,000. The lowest cost alternative is Alternative SC-
1 at $42,000. The highest cost alternative is Alternative SC-6 at
$96,800,000. Alternatives SC-2, SC-3, SC-4, and SC-7 have total
present worth costs of $462,000, $862,000, $7,887,000, and
$1,076,000, respectively.
The total capital, annual operation and maintenance, and present
worth costs in,a11 soil alternatives are presented in Table 1 for
com~ariso~ purposes.
GROUNDWATER
A.
Overall Protection of Human Health and the Environment
Alternatives GW-1 and GW-2 would prevent exposure to groundwater
contaminants. by restricting its use as a potable water supply.
Protection of the public would be dependent on the effectiveness
of institutional controls on groundwater use.
In the long-term, the extraction and treatment options within
Alternatives GW-3, GW-4, GW-S, and GW-6 would reduce contaminant
levels in the groundwater to below MCLs, reduce non-carcinogenic
risks to acceptable levels, and reduce cumulative carcinogenic
risks to below 10~, thus protecting human health and the environ-
ment.
B.
ComDliance with ARARs
Alternatives GW-1 and GW-2 would not satisfy contaminant-specific
ARARs, i.e., federal and state MCLS. The long-term monitoring and
-------
groundwater use
specific ARARs.
restrictions would meet
location- and
act:ion-
Groundwater treated through implementation of Alternatives GW-3,
GW-4, or GW-6 i~ expected to meet surface water discharge require-
ments, achieve concentrations below MCLs, and me~t risked-based
action levels for chemicals of concern. .
. -
The ability of Alternative GW-S to achieve the groundwater quality
standards for organic contaminants is of a lower certainty as
compared to those of Alternatives GW-3, GW-4 and GW-6 due to
limited experience with the UV oxidation treatment process.
Alternative GW-4 would include air emission controls meeting the
requirements of state and federal regulations should control be
deemed necessary based on treatability study results.
c.
Reduction of Toxicity. Mobility or Volume
Alternatives GW-l and GW-2 would not reduce the toxicity, mobility,
or volume of contaminants. Alternatives GW-3, GW-4, GW-S, and GW-
6 would provide significant overall reduction in toxicity, mobil-
ity, and volume of the contaminants in the groundwater through the
extraction and treatment of the groundwater.
D.
Im~lementability
All of the alternatives are technically feasible, but differ in the
complexity of implementation. All components of Alternatives GW-
1 and GW-2 could be easily implemented.
The treatment technologies associated with Alternatives GW-3 and
GW-4 employ reliable operations. All components (extraction,
treatment and reinjection) of these two alternatives utilize
relatively common construction equipment and materials and could
be easily implemented. Additionally, the processes included in
Alternatives GW-3 and GW-4 are proven and widely used methods of
removing the contaminants of concern in the groundwater, and are
readily available.
In contrast, the treatment technology in Alternative GW-S (UV
oxidation), although successful in pilot runs, has had limited full
scale use to date. Therefore, site-specific pilot scale studies
would be required to confirm its adequacy for the Site.
Furthermore, the UV oxidation units are currently available from
two vendors nationwide, and the sludge units of Alternative GW-6
are available from one vendor who holds the patent.
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E.
Lona-Term Effectiveness and Permanence
"
Alternatives GW-l and GW-2 allow risks from the long-term migration
of contaminants to continue. Alternative GW-2 includes monitoring
to track the spread of contamination and instituting groundwater
use restrictions to prevent potential exposure.... Achievement of
concentrations below MCLs and risk~based ARARs would be approached
at a rate gove~ned by natural attenuation.
'"
Alternatives GW-3, GW-4, GW-5, and GW-6 would effectively reduce
the potential risks associated with the contaminated groundwater
by extracting and treating the contaminated groundwater, and
returning the treated water to the aquifer.
F.
Short-Term Effectiveness
Alternative GW-l presents no additional short-term risks to workers
or the community during implementation. Alternative GW-2 presents
minimal short-term risks to workers during the sampling of the
monitoring wells. The preferred alternative, Alternative GW-4, as
well as Alternatives GW-3, GW-5, and GW-6 present short-term risks
to workers and the community due to potential fug i ti ve dust
emissions during construction of the treatment plants, extraction
systems, and associated piping. However, mitigative measures would
be implemented to reduce the potential risk of exposure during
re~edial activities.
The annual sampl ing of moni tor-.ng wells and implementation of
groundwater use restrictions that are contained in Alternative GW-
2 could be implemented within 6 months. However, Alternative GW-
2 would only reduce the potential for ingestion of groundwater and
not directly address remediation of contaminated groundwater. The
systems installed in Alternatives GW-3, GW-4, GW-5, and GW-6 would
be operational within 18 months following the start of construc-
tion. The estimated time for aquifer restoration for all four
alternatives is approximately 20 years.
G.
Cost
The present worth cost for the preferred groundwater alternative,
Alternative GW-4, is $9,934,000. The lowest cost alternative is
Alternative GW-1 at $42,000. The highest cost alternative is
Alternative GW-5 at $15,094,000. The present worth costs for
Alternatives GW-2, GW-3, and GW-6 are $985,000, $14,279,000 and
$5,739,000, respectively.
The total capital, annual operation and maintenance, and present
worth costs for all groundwater alternatives are presented in Table
1 for comparison purposes.
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.
state AcceDtance
NYSDEC concurs with the preferred soil and groundwater alterna-
tives. .
Community AcceDtance
Community acceptance of the preferred alternatives will be assessed
in the ROD following a review of the pubic comments received on the
RI/FS report and the Proposed Plan.
CONCLUSION
EPA believes that the preferred remedy described above is fully
. protective of human health and the environment, meets all the
ARARs, offers the best balance among the evaluation criteria
discussed above and satisfies the statutory preference for
treatment as a principal element in remedy selection.
COMMUNITY ROLE IN SELECTION PROCESS
EPA and NYSDEC rely on public input to ensure that the concerns of
the community are considered in selecting an effective remedy for
each Superfund site.
To this end, the RI/FS report has been distributed to the public
for a comment period which concludes on August 23, 1990. The
Proposed Plan is being provided as a supplement to the RI/FS report
and to inform the public of EPA's and NYSDEC's preferred remedy.
Pursuant to Section 117 (a) of CERCLA, a public meeting will be
held during the comment period at the Lincklaen Town Hall, Chenango
County, New York on August 13, 1990 at 7:30 p.m., to allow EPA to
present the conclusions of the RI/FS, to further elaborate on the
reasons for recommending the preferred remedy and to receive public
comments. Written and oral comments will be documented in the
Responsiveness Summary section of the subsequent ROD, the document
which formalizes the selection of the remedy.
All written comments should be addressed to:
Lisa K. Wong, Project Manager
Western New York Remedial Action
u.S. Environmental Protection
Agency
26 Federal Plaza, Room 29-102
New York, N.Y. 10278
Section
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It is important to note that the remedy described above is the
preferred remedy for the Site. The final selection will be
documented in the ROD only after consideration of all comments on
any' of the remedial alternatives addressed in the Proposed Plan
and the RI/FS report.
"
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. .
TABLE 1
COST ESTIMATE SUMMARY OF ALTERNATIVES
SOIL ALTERNATIVES
Capi tell
Annual O&M
Tot~l Present Worth
(30-yr, ~~ dIscount rate)
SC-l :
SC-2:
SC-3:
SC-4:
SC-5:
SC-6:
SC-7:
No Action
Limited Action
site capping
In-Situ Vapor Extraction
ixcavati~n/LoWtTemgerature
hermali ¥trac ~on7on-s1te
edepos Ion
Off-site Incineration
In-situ Soil Flushing
$ 0
$ 54,000
$ 562,500
$ 7,887,000
$19,416,000
$96,800,000
$ 981,000
$ 15,000
$ 23,800
$ 16,800
$ 0
$ 0
$ 42,000
$ 4.62,000
$ 862,000
$ 7,887,000
$19,416,000
$
$
$96,800,000
$ 1,076,000
o
6,200
GROUNDWATBR ALTBRNATIVES
GW-l: No Action $ 0 $ 15,000 $ 42,000
GW-2: Limited Action $ 48,000 $ 58,000 $ 985,000
GW-3: g~ouDdwlt~r E¥tr@c~ion~ $ 1,618,000 $821,000 $14,279,000
e~lca d rect~~ a Ion
ar on sorp on
GW-4: ~~OUDdWtt~r E¥tr@c~ion~ $ 1,855,000 $523,000 $ 9,934,000
em~~a rec}~~ g Ion
~r [lRRlng ar on
sorp ~
GW-5: g60uDdWtt~r E¥tr@c~ionl. $ 3,138,000 $775,000 $15,094,000
e81ca t rec1p~ a 10n{
Xl a Ion
GW-6: ~~OUDdWtt!r E¥tr@c~ionl. $ 2,300,000 $220,000 $ 5,739,000
eT~ca r,c1gt a ton{
10 oglca re men
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