United States
Environmental Protection
Agency
Off ice of
Emergency and
Remedial Response
EPA/ROD/R02-93/196
March 1993
SEPA Superfund
Record of Decision:
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50272-101
REPORT DOCUMENTATION 11. REPORT NO.
PAGE EPA/ROD/R02-93/196
2.
3. Reclpllnt'l Acc88aIon No.
~;
4.
T"'I and Subt"11
SUPERFUND RECORD OF DECISION
FMC-Dublin Road, NY
First Remedial Action - Final
Author(.)
5.
Rlport DatI
03/31/93
6.
7.
8.
Performing Organization Rlpt. No.
9.
Plrtormlng Organization Nama and Addr...
10 ProJlct Ta.klWork Unit No.
11. Contract(C) or Grant(G) No.
(C)
(G)
12. Spon.ortng Organization Nama and Add.....
U. S. Envi'ronrnental Protection
401 M Street, S.W.
Washington, D.C. 20460
13. Type of Rlport. Period eovlrad
Agency
800/800
14.
15. Suppllmlntary Notl'
PB94-963833
16. Abatract (Llm": 200 words)
The 30~acre FMC Dublin Road site is located partly in the Town of Ridgeway and the Town
of Shelby, Orleans County, New York. The site is subdivided by Dublin Road into a
21-acre northern rectangular portion, which contains inactive rock quarries and wooded
areas; and a triangular southern property of approximately nine acres, which contains a
waste pile, a rectangular pond, and a swamp. The portion of the site containing the
waste pile is bounded by the New York State Barge Canal to~he southwest, Dublin Road
to the north, and a municipal landfill to the east. Land use in the area is
predominantly agricultural, with a wetlands area located onsite. The site overlies
both an overburdened and bedrock aquifer, and the estimated 23 people who reside within
one-half mile of the site use domestic wells to obtain their drinking water supply.
From 1933 to 1968, approximately 6 acres of the site was used to dispose of coal ash,
cinders, laboratory wastes, chemical and pesticide residuals, and building debris. In
or about 1974, FMC Corporation purchased the site. Onsite investigations conducted at
the direction of the State from 1981 through 1984, documented'elevated levels of
organics and pesticides in the 10,000 yd3 waste pile onsite, and in soil, sediment,
ground water, and surface water. Contamination appears to have been ,the result of both
contaminant migration through the bedrock aquifer and surface water runoff. The ROD
(See Attached Page)
17. Documlnt Analyall a. O8Icrlptora
Record of Decision - FMC-Dublin Road, NY
First Remedial Action - Final
Contaminated Media: soil, sediment, debris, gw,
Key Contaminants: organics (pesticides), metals
b. IdlntlfllralOpan-Endld Tlrms
sw
(arsenic, lead)
c.
COSATI FllldlGroup
18. AVlllablllty Statlmlnt
19. Slcur"y Clau (Thll Rlport)
None
20. Security Class (ThIs Page)
None
21. No. of Pag..
46
22. Price
(Sla ANSI.Z39.18)
S..lnstructJons on Reve,..
OPTIONAL FORM 272 (4-77)
(Formlrty NTI5-35)
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~
f
EPA/ROD/R02-93/~96
FMC-Dublin Road, NY
First Remedial Action - Final
Abstract (Continued)
addresses contaminated onsite soil, sediment, debris, ground water, and surface water, as
OU1. The primary contaminants of concern affecting the soil, sediment, debris, ground
water, and surface water are organics, including pesticides; and metals, including arsenic
and lead.
The selected remedial action for this site includes excavating, consolidating, screening,
and stabilizing onsite approximately 10,000 yd3 of contaminated soil, sediment, and debris
from the waste pile, rectangular pond, swamp, drainage swell, quarries, and other site
areas; temporarily stockpiling the material onsite, and testing it to ensure that it
passes TCLP testing; constructing a customized disposal cell onsite, which includes both
leachate collection and removal systems; depositing the treated material in the onsite
cell, installing a soil cap, and revegetating the area; rinsing, dewatering, and treating,
if needed, all material greater than 2 inches in diameter, with subsequent onsite
disposal; collecting and treating onsite 126,000,000 gallons of contaminated ground water
and surface water using electrochemical treatment, pH adjustment, sedimentation,
filtration, and carbon adsorption, with onsite discharge of the treated water to surface
water; backfilling and grading excavated areas, as needed; restoring any affected
wetlands; monitoring sediment, ground water, surface water, air, and downgradient domestic
wells; and implementing institutional controls, including deed restrictions; and site
access restrictions, such as fencing. The estimated present worth cost for this remedial
action is $8,416,457, which includes an annual O&M cost of $218,470 for 20-30 years.
PERFORMANCE STANDARDS OR GOALS:
Remedial goals are based on State ARARs or State RAOs for soil, sediment, ground water,
and surface water. Chemical-specific soil cleanup goals include arsenic 35 mg/kg; copper
25 mg/kg; mercury 0.1 mg/kg; zinc 30 mg/kg; DDT and DDE 8.8 rng/kg; DDD 12.4 rng/kg; lead 93
mg/kg; alpha-BHC 0.46 rng/kg; beta-BHC 1.6 mg/kg; and gamma-BHC 2.3 mg/kg.
Chemical-specific sediment cleanup goals include arsenic 5 mg/kg; copper 19 mg/kg; lead 27
mg/kg; mercury 0.11 mg/kg; and zinc 85 mg/kg. Chemical-specific ground water cleanup goals
include arsenic 0.25 mg/l; copper 0.2 mg/l; lead 0.015 mg/l; and zinc 0.3 mg/l.
Chemical-specific surface water cleanup goals include arsenic 0.19 rng/l; copper 0.027
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ROD FACT SHEET
SITE
FMC, Dublin Road
Towns of Shelby and Ridgeway, Orleans County/New York
EPA Region II
HRS Score (date): 32.89 (10/84)
ROD
Date signed: March 31, 1993
Remedies: Soil and sediment stabilization followed by d.isposal in
an on-site NYS Regulated, Part 360 Celli groundwater and surface
water treatment.
Capital Cost: $5,693,838
o & M Cost: $2,722,619
Present Worth Cost: $8,416,457
LEAD
This site has been a State enforcement lead with EPA enforcement
oversight. The PRP has been conducting the work.
Primary contact: Shive Mittal, NYSDEC, (518) 457-0315
Secondary contact: Dale J. Carpenter, EPA, (212) 264-9342
Main PRP: FMC corporation
PRP Contact:
Mark Diamond, FMC corporation, Environmental
Affairs, (716) 735-3761
WASTE
Type: Pesticides and metals
Medium: Soil, Sediments, Surface Water and Groundwater
Origin: Waste Disposal site used by FMC
Est. quantity: Approximately 25,000 cubic yards of sediments and
soils will be treated and disposed. It is estimated that
126,000,000 gallons of water .will need to be treated over a 20 to
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New York State Department of Environmental Conservation
50 Wolf Road, Albany, New York 12233
~
...
~
April 12, 1993
Thoma. C. JortlnG
Commluloner
Mr. Dale J. Carpenter
Project Manager
New York Caribbean Compliance Branch
U.S. Environmental Protection Agency
Region II
26 Federal Plaza
New York, New York 10278
Dear Mr. Carpenter:
RE: FMC Dublin Road Site,
Orleans County, New York,
Site No. 8-37-001
Enclosed please find one 3.5 inch disk containing the Record of Decision (ROD) files
for the above-referenced site, as requested by you. The disk contains the following four files
on Wordperfect (version 5.1) format:
1) FMCROD1
2) FMCRESP1
3) FMCOVER 1
4) FMCOVER2
Please note the disk does not contain figures, tables and exhibit B, which are part of
the ROD. If you have any Questions, please feel free to call me at (5t8) 457-0315.
Sincerely,
- .
- ~ R. \w.L....C
Shive R. Mittal, P.E.
Environmental Engineer
Bureau of Western Remedial Action
Division of Hazardous Waste Remediation
Enclosure
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D
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION II
DATE:
"
.. j
SUBJECT: Record of Decision (ROD) for the FMC, Dublin Road Site
FROM: George Pavlou, Acting Director
Emergency and Remedial Response Division
TO: William J. Muszynski, P.E. .
Acting Regional Administrator.
Attached for your approval is the ROD for the FMC, Dublin Road site, located in the
Towns of Shelby and Ridgeway, Orleans County, New York. The selected remedial action
addresses the soils, sediments, surface water and groundwater contaminated with metals
and pesticides. A portion of the site was used for disposal of various wastes and debris
by the FMC Corporation in Middleport, N.Y. The resultant waste pile created is acting as
a source of contamination for the soils, sediments, surface water and groundwater.
The selected remedy calls for:
a) Excavation, screening and stabilizing all the contaminated materials (soils and
sediments) from the waste pile and other areas of the site that are contaminated above
the remedial action objectives (RAOs);
b) storing the stabilized material in a temporary stock pile and testing it to ensure that it
passes the TCLP test, and other tests for those site specific compounds not included in
the TCLP test;
c) construction of the composite liner(s), leachate collection and removal systems(s) of
the customized cell, consistent with 6 NYCRR Part 360 regulations of the State of New
York;
d) redepositing the treated material in the customized cell;
e) rinsing, dewatering, treating if needed, all material greater than two inches in diameter
and depositing in the proposed on-site cell; and
f) installing a cover consisting of a geomembrane, cover soil, top soil, and vegetation for
erosion control consistent with NYCRR Part 360 Regulations;
g) collection of contaminated groundwater from a series of groundwater extraction wells;
h) treatment of collected groundwater and contaminated surface water, and discharge to
Jeddo Creek;
i) restoration of the wetlands; and
j) installation of fencing, inclusion of deed restrictions and institution of operation and
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I .
The estimated costs of the selected remedy are:
- Capital cost - $ 5,693,838
- Present worth of O&M cost - $ 2,722,619
.- Total cost - $ 8,416,457
The remedy is the same as the preferred alternative presented in the Proposed Plan.
The remedial investigation and feasibility study report and the Proposed Plan were
released to the public for comment on January 26; 1993. A public comment period on
these documents was held from January 26, 1993 through March 15, 1993. In addition,
a public meeting to discuss these documents and the preferred remedy was held on
February 4, 1993. Comments received during the public comment period generally
supported' the preferred remedial alternative, and are addressed in the attached
Responsiveness Summary.
The New York State Department of Environmental Conservation (NYSDEC) has been the
lead agency for this site. NYSDEC has written, reviewed and signed this ROD. The New
York State Department of Health (NYSDOH) and the appropriate program offices within
Region II have also reviewed this ROD. Their input and comments are reflected in this
document. NYSDEC and NYSDOH have concurred with the selected remedy for the
FMC, Dublin Road site.
If you have questions or comments on this document, I would be happy to discuss them
with you at your convenience.
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[)
RECORD OF DECISION
FMC DUBLIN ROAD SITE
"
ORLEANS COUNTY, NEW. YORK
SITE ID NUMBER 8-37-001
PREPARED BY
NEW YORK STATE DEPARTMENT OF ENVIRONMENTAL CONSERVATION
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
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DE~ION POR TB!: RECORD or DECISION
SIft: IIANB AIm LOCATION
FMC Dublin Road Site
Towns of ,Shelby ,and Ridgeway
Orleans COunty, New York
New York State Site COde: 8-37-001
STATEMEHT or BASIS AIm PURPOSE
This decision document presents the selected remedial action for the FMC
Dublin Road Site located in the Town of Shelby and the Town of Ridgeway,
Orleans County, New York. The selected remedial action was chosen in
accordance with the New York State Environmental COnservation Law (ECL), with
the COmprehensive Environmental Response, Compensation, and Liability Act of
1980 (CERCLA), as amended by the Superfund Amendments and Reauthorization Act
of 1986 (SARA), and to the extent practicable with the National Oil and
Hazardous Substances Pollution Contingency Plan ("NCP"). This decision
document summarizes the factual and legal basis for selecting the remedy for
this site.
The information supporting this Remedial Action Decision is contained in the
Administrative Record for the site. The Administrative Record Index is
attached as Exhibit A.
ASSESSMEHT or THE SITE
Actual or threatened releases of hazardous substances from or at this site,
if not addressed by implementing the response action selected in this Record
of Decision ("ROD"), may present an imminent and substantial threat to public
health, welfare, or the environment.
DESCRIPTION or THE SJ:LJ:CTJ:D REMEDY
The selected remedy addresses the principal threats posed by the site by
stabilizing and containing the waste materials (waste pile, soils and
sediments) and by removing contaminants from the groundwater.
The major elements of the selected remedy include:
(a)
excavate, screen and stabilize All the contaminated materials.
(soils and sediments) from the waste pile, rectangular pond, swamp,
drainage swale, the quarries and the other areas that are contami-
nated above the remedial action objec~ives;
(b)
store the stabilized material in a temporary stock pile and test it
to ensure that it passes the TCLP, and other tests for those site
specific compounds not included in TCLP;
construct the composite liner(s), leachate collection and removal
system(s) of the customized cell, consistent with 6 NYCRR Part 360
regulations of the State of New York;
(C)
Cd)
(e)
redeposit the treated material in the customized cell;
rinse, dewater, treat if needed, all material greater than 2 inches
in diameter and deposit it in the proposed on-site cell;
(f)
install a ~over consisting of geomembrane, cover soil, top soil,
and vegetation for erosion control consistent with 6NYCRR Part 360
Regulations.
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(g)
collect contaminated groundwater from a series of overburden and
uppEr bedrock groundwater extraction wells;
treat collected groundwater and contaminated surface water, and
discharge to the Jeddo Creek;
(h)
(i)
(j )
restore the wetlands; and
install fencing, include deed restriction. and institute operation
and maintenance (O&M) and monitoring.
DECLARATION
The selected remedy is protective of human health and the environment,
complies with State and Federal requirements that are legally applicable or
relevant and appropriate to the remedial action, and is cost effective. This
remedy utili~es 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 result in contaminants remaining on-site above
health based levels, a five year review will be conducted. This Level I
evaluation will be conducted within five year. after the commencement of
remedial action to ensure that the remedy continues to provide adequate
protection of human health and the environment.
/17" L (1-;) 7. 14 '1 ~3
Date .
~ AJ«~£...
Ann DeBarbieri
Deputy Commissioner
Office of Environmental Remediation
New York State Department of Environmental
Conservation
-
*~t!f;f/3
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RECORD OF DECISION
DECISION SUl\1MARY
FMC CORP. DUBLIN ROAD SITE
TOWN OF SHELBY AND TOWN OF RIDGEWAY
ORLEANS COUNTY, NEW YORK
SITE ID NUMBER 8-37-001
PREPARED BY
NEW YORK STATE DEPARTMENT OF ENVIRONMENTAL CONSERVATION
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
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2>
I.
II.
III.
IV.
V.
VI.
VII.
VI II .
IX.
x.
TABLE OF CON'l'EN'rS
Site
Location and Description................................
Site History and Enforcement Status...........................
Highlights of Community Participation........................
Scope and Role of Response Action..........."................
Summary of Site
Summary of Site
Character istics. . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
Risks. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
Description of the Remedial Alternatives.....................
Summary of the Comparative Analysis of the Alternatives...... 11
Selected Remedy.............................................. 16
Statutory Determinations..................................... 17
Piau res
1.1
1.2
3.7
3.8
Location of the Dublin Road Site
Dublin Road Site Features
Dublin Road Proposed Containment Cell Location
conceptual Design of Proposed Containment Cell
Tabl..
1.1
1.2
1.4
1.6
1.7
2.4
4.16
Summary of Contaminants in Dublin Road Waste Pile
contaminant Concentrations in Surface Water
Contaminant Concentrations in Sediments
Contaminant Concentrations in OVerburden Groundwater
Contaminant Concentrations in Upper Bedrock Aquifer
Remedial Action Objectives for the Dublin Road Site
Cost Comparison of Remedial Alternatives
A.
B.
C.
Bxhibits
Admini.trative Record Index
Regi.try Excerpt
Responsiveness summary
Hi
~
1
1
1
2
2
3
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RECORD or DECISION
FMC DUBLIN ROAD SIn
SIn HUMBER 8-37-001
I.
SIn LOCATION AND DESCRIPTION
The FHC Dublin Road Site is locatecl in northwestern New York in Orleans
County, and is situated partly in the Town of Ridgeway and partly in the Town
of Shelby. The 30 acre site is divided by Dublin Road into a northern
rectangular portion consisting of approximately 21 acres containing two
inactive rock quarries and wooded property and a southern triangular portion
of approximately nine acres containing a waste pile, a rectangular pond and a
swamp. Jeddo Creek runs in a northerly direction through the northeast
corner of the site. See Figure 1.1 for site location and Figure 1.2 for site
features. The site was added to the Federal National Priorities List (NPL)
in May 1986. The site is currently classified as a class "2" site in the
Registry of Inactive Hazardous Waste Sites, maintained by the New York State
Department of Environmental Conservation (NYSDEC) ancl the New York State
Department of Health (NYSDOH). The class 2 designation means that the site
poses a significant threat to public health or the environment and requires
action.
'The portion of the site containing the waste pile is bounded by the New York
State Barge Canal to the southwest, Dublin Road to the north, and a municipal
landfill to the east. Land uses immediately adjacent to the site and within
the county are predominantly agricultural. An active sandstone quarry exists
north of the site.
The principal hydrogeologic units beneath the site include: Overburden,
Upper Bedrock, Lower Bedrock, and the Queenston Formation. These units have
moderate to low permeabilities with very limited quantities of groundwater
suitable for domestic utilization. The area around the Dublin Road site is
sparsely populated with about 23 households within 1/2 mile radius (USGS,
1980). These households obtain their drinking water from domestic wells.
II. SYTE HI S'1'ORY AND ENP'ORCEMENT STATUS
In or about 1944, the FMC corporation purchased the 30-acre Dublin Road site
as part of its acquisition of the Niagara Sprayer and Chemical Company, Inc.
From about 1933 to 1968, approximately six acres of the site south of Dublin
Road were used for the disposal of coal ash cinders, laboratory wastes
consisting of glass bottles and chemical residues, residues from lime sulfur
solution filtration, building debris, and residues from the cleanup of the
pesticide production areas and equipment. The wastes, other than the
laboratory wastes, were generated at the FMC's Middleport, New York
manufactur~ng plant. The laboratory wastes came from FMC's Tonawanda
laboratory.
Previous investigations at the site include: a preliminary assessment of the
groundwater contamination performed by Geraghty and Miller, Inc., for FMC in
1978; and a field investigation conducted by Bechtel National Inc., (BNI)
for FHC during 1981-84 under a 1982 Order on Consent between NYSDEC and FKC.
These investigations have indicated the presence of heavy metals and
pesticides in the waste pile, groundwater, 8urface water, .oi18 and .ediments
at the site. A second Order on Consent was signed between NYSDEC and FHC on
February 9, 1988 to further define the extent of contamination at the site by
performing additional investigations, completing the Remedial
Investigation/Feasibility Study (RI/FS) and performing the remedial action.
III. HIGHLIGHTS or COMMUNITY PARTICIPATION
Concurrent with the investigations performed at the site, there has been
significant community involvement and input into the project. A public
-------
meeting was conducted by the FKC Corporation in Kedina, New York, on Kay 26,
1988 to discuss the RI Report and respond to questions from the community. A
second public meeting was held by FKC in Kedina on June 13, 1989 to discuss
the supplemental RI Report and to respond to questions from the community.
At both meetings, representatives from NYSDEC and NYSDOH were present to
respond to questions from the community. A site specific Citizen
Participation Plan (CPP) was developed and released to the public in June
1990. As a part of the plan, a public contact list was developed and used to
disseminate fact sheets, meeting announcements and other information. A
local information repository was established at Lee-Whedon Kemorial Library,
620 West Avenue, Medina, Hew York. Pertinent documents were placed in the
repository. A fact sheet was issued to the public in July, 1990 to announce
the availability of the documents in the repositories, the CPP, and the
public availability session. Another fact sheet was issued in July 1992.
A notice of the availability of the final drafts of the RIll'S Reports and the
Proposed Remedial Action Plan (Proposed Plan) was published on January 26,
1993 in a local newspaper. Additional methods used to encourage public
participation included publishing a series of announcements ~n. local
newspapers, announcements on local television stations, and mailing notices
and fact sheets to the public contact list. The RIll'S reports, the Proposed
Plan, and other pertinent documents were placed int::o the repository. A
formal public meeting was held on February 4, 1993 to present the Proposed
Plan and seek public comment. A public comment period was held from January
26, .1993 to February 25, 1993 which was 8ubsequently extended to March 15,
1993. A responsiveness summary has been prepared containing NYSDEC's and
EPA's responses to comments received during the public meeting, and comment
period (Exhibit C).
IV.
SCOPE Arm ROLE 0,. RESPONSE ACTION
The remedial action selected in this decision document addresses the entire
site. As will be discussed in 'Section V below, the primary media
contaminated include the site loils and groundwater. Surface water (Swamp
and Quarries) and surface water sediments have also been contaminated as a
result of contaminants migrating through surface run-off.
By isolating contaminated soils and sediments from the site and removing and
treating' contaminants from the site groundwater and site surface water, the
response action will isolate andlor remove the source of contaminants from
the site. The contaminated soils and sediments will be stabilized and
contained in a cell.
v.
SUMMARY OF SITE CHARACTERISTICS
For ease of reference, tables attached to this document summarize the main
characteristics of the Dublin Road Site.
SU88Arv of Field Investiaation8
The RI report prepared by BNI under it's new name Bechtel Environmental Inc.,
(BEl) for FMC was approved by NYSDEC in Kay 1990. The following paragraphs
8ummarize the components and conclusions of the field investigations
performed at the site. For more detailed information regarding the
individual investigations or for additional regional information, refer to
the RI report listed in the Administrative Record Index (Exhibit A).
(i)Site aeoloav: OVerburden at the site ranges from 0 to 2S feet in thickness
and consists of natural soils, fill and waste material. The underlying
Gr~sby Formation, which i8 up to S2 feet in thickness, consists of red and
white sandstone with the upper 2S feet of the formation having intense
fracturing. The major hyrdogeologic formation consists of an overburden
-------
aquifer, upper bedrock aquifer, and lower bedrock aquifer.
flow is generally towards the northeast.
(ii) Nature and extent of contamination: The investigations have indicated
the presence of various chemicals in the waste pile above background
concentrations. These chemicals include: arsenic (As); copper (Cu); lead
(Pb); mercury (Hg); zinc (Zn); benzenehexachloride (BHC) and isomers; and DDT
(and metabolites). Some of these 8ubstances have been detected in groun-
dwater, surface water, soils and 8ediments on-site. The compounds 2,4-
Dichlorophenoxypropionic acid (2,4-D) and 2,4,5-Trichlorophenoxyacetic acid
( 2 , 4 , 5-T) have been detected in groundwater. The mean and the range of
concentrations of these chemicals in the waste pile, 8urface water, 8edi-
ments, groundwater (overburden) and groundwater (upper bedrock) are shown in
Tables 1.1, 1.2, 1.4, 1.6 and 1. 7 (attached) respectively. Based on the
toxic characteristic leaching procedure (TCLP) test for lead, the waste
material in the waste pile has been classified as characteristic hazardous
waste. The volume of this waste material is approximately 10,000 cubic
yards (5,000 cubic yards of waste in the pile above original grade and an
additional 5,000 cubic yards of waste and contaminated soil below grade).
The groundwater
The run-off of surface water at the site has resulted in migration of
contaminants from the waste pile to the rectangular pond, swamp, drainage
swale, and east & west quarries. Although the analytical results performed
on the soils. and sediments from these areas did not fail TCLP tests, they
were above the remedial action objectives (RAOs). The media specific RAOs
are summarized in Table 2-4. Therefore, an estimated 15,000 cubic yards of
contaminated soils and sediments from these areas which are above the RAOs,
will need remediation. The media specific RAOs were developed during FS.
(iii) Contaminant fate and transport: The transport and fate of the
contaminants from a source are dependent upon the physical and chemical prop-
erties of the waste constituents and characteristics of the environmental me-
dia. The migration pathways at the Dublin Road site appear to be surface
water run-off and leaching of the chemicals in the groundwater. The salts
detected at the Dublin Road site are of low 801ubility in water. Volatil-
ization is not considered an important mechanism under existing conditions
due to the very low concentrations of volatile compounds at the site.
Significant chemical and biological transformations of the compounds
.associated with the Dublin Road site are not likely.
VI. SUMMJUtY or SIft RISXS
Based upon the results of the RI, a baseline
estimate the risks associated with current
r':'s"lt assessment estimates the human health
relult from the contamination at the site if
risk assessment was conducted to
site conditions. The baseline
and ecological risk which could
no remedial action is taken.
Human Hea1th Risk Assessment
The component8 of the baseline health risk assessment for this site include:
-Identification of indicator chemicals;
-A8sessment of the exposure pathways;
. -Identification and comparison of Applicable or Relevant and Appropriate
Requirement8 (ARARs) to exposure point concentrations.
The indicator chemicals selected for this 8ite based on persistence,
mobility, and toxicity include As, cu, Zn, Pb, BHC (4 isomers), and DDT (and
2 metabolites). Mercury was not included because the concentration of
mercury ~as not significant in the 1988 data. However, the cleanup level for
mercury has been specified. Several of these contaminants are known to cause
cancer in laboratory animals and are 8uspected to be human carcinogens.
-------
The exposure routes are the mechanisms by which contaminants enter the body
(e.g., inhalation, ingestion, absorption). Exposure pathways are the
environmental media (e.g., soil, surface water, groundwater, air, etc.)
through which contaminants are carried. Several potentially. significant
exposure pathways were identified for this site. These pathways are:
-Surface water pathways for an on-site intruder;
-Surface water and groundwater pathways for the hypothetical
residents at the site boundary;
future
-Groundwater pathway for the nearest current potential receptor;
and
-Surface water and 80il pathways for the Dublin Road user. The part of Dublin
Road adjoining the 8ite has recently been closed to the public.
A numerical model was used to estimate the contaminant concentrations at
varying distances fro~ the waste pile. At the same time ARARs were
identified which would be protective of human health and the environment at
the identified points. The results of these activities are presented in the
1988 RI report (Section 6 & Appendix C) and the 1989 supplemental RI report
. (Section 3). The results of the comparisons indicate that the predicted
concentrations of various chemicals at the corresponding exposure points
would exceed the identified ARARs and would pose an unacceptable risk to
human health. Arsenic and zinc concentrations would exceed the recommended
requirements for groundwater usage for a receptor at the site boundary. The
concentrations of As, CU, Pb, Zn, BHC, and DDT exceeded the identified ARAR
values corresponding to the protectiveness of aquatic life at the rectangular
pond and the swamp.
The. report was prepared in 1988 and used the -Superfund Public Health
Evaluation Manual- (SPHEM, 1986) as guidance. The risk assessment followed
the process outlined in SPHEM for groundwater and surface water exposures and
compared exposure concentrations to ARARs. In the guidance currently used,
-Risk Assessment Guidance for Superfund" (RAGS, 1989), baseline evaluations
are not considered complete based on comparisons to ARARs. It should be
noted, that the cancer risk calculated using RAGS for ingestion of site
groundwater contaminated with arsenic would exceed EPA' s acceptable risk
range.
Actual or threatened releases of hazardous substances from this site, if not
addressed by implementing the response action selected in this ROD, may
present an imminent and substantial endangerment to public -health, welfare,
or the environment.
The ARARs.and the RAOs for this site are summarized in section 2.0
report. The media specificRAOs are given in Table 2-4.
of the FS
Ecoloaical Risk Assessment
For the ecological assessment, a comparison was conducted between estimated
exposure point concentrations and ARAR values corresponding to protectiveness
of the resident aquatic and terrestrial biological communities. Additional
chemical, physical and biological data and information were obtained through
site-specific 8ampling and a literature 8earch to asse8S bioaccumulation
potential and environmental impacts. A habitat based aS8essment was com-
pleted.
The results of the ecological assessment are presented in Section 4.0 of the
1989 supplemental RI report and Section 1 and. Appendix J of the 1992 FS
report. The rectangular pond had contaminant concentrations exceeding water
quality standards for all contaminants of concern. The remaining water
bodies at the site exceeded the water quality standards for a fewer number
of compounds. The sediments exceeded the criteria for pesticides in all the
-------
surface water bodies. There are no known endangered species on the Dublin
Road site or in the immediate area for which the site would pose a potential
threat.
VII. DESCRIPTION or TIlE REMEDIAL ALTERNATIVES
To determine the most appropriate method for remediating 'the site, the FS
completed a process that can be described in three parts. The first step
identified and -screened- a large number of technologies that could be
employed at the site to treat, contain, or dispose of the _contaminants.
Technologies that passed the initial screening phase were then grouped into
different combinations to form remedial alternative8 for further evaluation.
After an initial analysi8 to identify the most promising alternatives, a
detailed analysis was performed to 8erve as the basia for selecting a
preferred alternative. This process i. de8cribed in more detail in the
following subsections.
CoapilatioD aDd ScreeDiDg of the Technologie.
The results of the RI indicate that
been contaminated as a result of
materials and wastes. These media
sediments, and surface water (from
inactive quarries).
To generate alternatives capable of addressing the contamination of each
medium, the three progressively more specific categories of -general response
actions, - -remedial technologies," and -process - options" were identified.
For example, regarding soil, one of ,the general response actions considered
was containment. This was then subdivided into the two remedial technologies
of capping and vertical barriers which was further 8ubdivided into the
process options of clay, asphaltic, concrete, and multimedia caps along with
sheet piling, slurry walls, cutoff walls, and subsurface drains as vertical
barriers. A summary of the general response action8 for soils, surface
water and the groundwater is given in Table 2-6 through Table 2-11 of the FS
Report .
four media in and around the 8ite have
the improper management of hazardous
are site soils, site groundwater, the
the rectangular pond, swamp area, and
The initial screening process essentially consists of evaluating all of the
identified process options against the three balancing criteria of technical
implementability, effectiveness and cost. This also includes the evaluation
of the -No Action" alternative which is carried through the entire process to
demonstrate the need for remediation at the site and as a r~quirement of the
National Contingency Plan (NCP). '
A detailed discussion and evaluation of the initial screening process can be
found in Chapter 3 of the FS.
"aluatioD of the Alternati"e.
Initial Screenina
The remedial technologies and process options that passed the screening
process were then assembled into eight different combinations or remedial
alternatives. Theoretically, an immense number of combinations are possible
but the NCP provides guidance (40 CPR 300.430(e) (3» on how to assemble
suitable technologies into alternative remedial actions for evaluation.
The following eight groups of remedial alternatives were constructed and
evaluated against the short and long-term aspects of three of the balancing
criteria; effectiveness, implementability, and cost (see Section VIII below
for descriptions of the criteria).
Initial List of Remedial Alternatives
-------
"
1.
2A.
28.
3A.
38.
4A.
48.
SA.
58.
6A.
68.
7A.
78.
8A.
ss.
No Action/Monitoring.
Soil Washing, Off-site Water Treatment.
Soil Washing, On-site Water Treatment
In Situ Vitrification, Off-site Water Treatment.
In Situ Vitrification, On-site Water Treatment.
Stabilization, Off-site Water Treatment.
Stabilization, On-site Water Treatment.
Stabilization/On-site Disposal in Part 360 Cell, Off-site Water
Treatment.
Stabilization/On-site Disposal in Part 360 Cell, On-site Water
Treatment.
Stabilization/On-site Disposal in Customized Part 360 Cell, Off-
site Water Treatment.
Stabilization/On-site Disposal in Customized Part 360 Cell, On-site
Water Treatment.
Stabilization/Off-site Disposal, Off-site Water Treatment.
Stabilization/Off-site Disposal, On-site Water Treatment.
Containment, Off-site Water Treatment.
Containment, On-site Water Treatment.
The initial screening of these alternatives against the three balancing
criteria mentioned above took the following factors into consideration.
The effectiveness evaluation considers:
a.
the degree to which the alternative under consideration reduces
the toxicity, mobility, or volume of the contaminants through
treatment;
b.
how residual risks are minimized;
c.
how long-term protection is provided;
d.
how ARARs are complied with;
e.
how short-term risks are minimized; and
f.
how quickly the alternative achieves protection.
The imDlementabilitv evaluation considers:
a.
technical feasibility (ability to design, construct, and operate
the alternative); and
administrative feasibility (availability and capacity of services,
equipment, and personnel along with the ability to obtain the
necessary approvals from involved regulatory agencies).
b.
The cost evaluation considers:
a.
capital costs for design and construction;
b.
operation and maintenance costs; and
the present worth of all costs for comparison purposes.
c.
The result of the initial 8creening process was to reject two of the eight
alternatives. The reasons for rejecting these two are given below.
Treatability studies performed on soils from the Dublin Road Site indicate 45
to 82~ fines. Soils with high silt and clay content are difficult to
decontaminate by a soil washing technology. Therefore alternatives 2A & 28
associated with soil washing were deleted from detailed evaluations.
Alternatives 3A & 38 involving in situ vitrification (ISV) were also deleted
from detailed evaluations because ISV is. undergoing review by the vendor
-------
following a fire during field testing and is not expected to be available in
the near future.
Detailed Analvsis
The goal of the detailed analysis, as defined by the NCP, is to evaluate each
of the viable alternatives against each of the nine criteria given in Section
VIII below (Summary of the Comparative Analysis of the Alternatives). These
criteria are overall protection of human health and the environment;
compliance with ARARs; 8hort-term impacts and effectiveness; long-term
effectiveness and permanence; reduction of toxicity, .mobility, and volume;
implementability; cost; community acceptance; and state acceptance.
The information below briefly describes each of the alternatives retained for
the detailed analysis. Following the descriptions is a discussion that
compares the alternatives with respect to each of the criteria, including
State and Community acceptance. It should be noted that the costs and
implementation times given are initial estimates. The design time is
estimated at 12 months for all the alternatives except the No-action
alternative. The present worth values below estimate how much money is
needed today. to finance projects that will take place over several years.
The present worth of each alternative has been calculated based on the time
to implement that particular alternative and assuming an interest rate of 5'.
Alternati"e 11 110 ACTIOR
Capital Cost: $0
o & M Cost: $58,000/yr (for 20 years)
Present Worth O&M: $722,808 (at 5\)
Total Project Costs: $722,808
Construction Time: 1 month
The Superfund program requires that the -no-action" alternative be considered
as a baseline for comparison of other alternatives. This alternative
involves taking no remedial action to remove or treat the contaminants~ The
alternative would include: maintain the existing fence; implement institu-
tional controls to limit the use of the site and groundwater; provide for
quarterly site inspections; develop and implement a surface water and ground-
water monitoring program; and publish a monitoring report.
Altenaati"e 4A: S~ABII.IZA~IOR, OFF-SID: WADR TREADIEHT
Capital Cost: $4,049,500
o & M Cost: $394,800/yr (for 20 years)
Present Worth O&K: $4,920,081 (at 5')
Total Project Costs: $8,969,581
Construction Time: 12 months.
The groundwater extraction and treatment
years. .
is likely to continue for 20 to 30
This alternative involves stabilization of all the contaminated material from
the Waste Pile and any. 80ils/sediments from other areas of the site which
fail TCLP; redepositing the stabilized material in the area of the waste pile
along with any soils/sediments contaminated above the RAOs; and covering the
redeposited material with a 60 mil synthetic geomembrane, 18 inches of cover
soil, 6 inches of top soil and a vegetative cover. The stabilization would
involve excavation; screening; decontamination and disposal of large objects;
and stabilizing the waste with lime in a pug mill. Under this alternative
.pproximately 10,000. cubic yards of the waste material from the waste pile
area would be stabilized and redeposited in the waste pile area. Addition of
lime would increase the volume of the stabilized material by approximately
-------
u
30\. An additional 15,000 cubic yards of contaminated soils/sediments above
the RAOs from the other areas of the site would be excavated and placed in
the waste pile area before capping. The site would be backfilled and graded.
The surface water, process water and the groundwater would be collected and
transported to the FMC Middleport plant for treatment before disposal. The
.contaminated water would be transported to the FMC Middleport Plant via a
pipeline or by trucking.
A1ternati.. 48: S~ILI~IOII, Oil-SID WA9R. ~
Capital Cost: $4,049,500
o & M Cost: $218,470/yr (for 20 years)
Present Worth O&M: $2,722,619 (at 5\)
Total Project Costs: $6,772,119
Construction Time: 12 months.
The groundwater extraction and treatment
years.
is likely to continue for 20 to 30
This alternative is identical to Alternative 4A except that the groundwater,
process water, and contaminated on-site surface water would be treated on-
site and discharged to Jeddo Creek. The on-site water treatment would
include electrochemical treatment, coagulation, pH adjustment, sedimentation,
filtration, carbon adsorption and/or other process treatment to meet the
regulatory requirements for disposal to the Jeddo Creek. A full scale
treatment plant would be installed on-site to treat an estimated 126,000,000
gallons of contaminated water over 20 t~ 30 years. The seasonal average rate
of flow from the groundwater extraction 8ystem i8 estimated to be 12 gpm. Any
8ludge generated would be fed to a filter press for removal of solids.
Disposal of the filter cake would be off-site in a RCRA facility, if
necessary.
a,1ternati.. SA: STABILI~IOII, 01l-SI9 DISPOSAL IR PAR.~ 360 CELL, 0""-SI9
WADR. TREM:MEH'r
Capital Cost: $5,989,750
o & M COst: $394,800/yr (for 20 years)
Present Worth O&M: $4,920,081 (at 5\).
Total Project Costs: $10,909,831
Construction Time: 14 months.
The groundwater extraction and treatment is
years.
This alternative involves the stabilization of all the contaminated material
from the waste pile area and any sOils/8ediments from other parts of the site
which fail TCLP. The 8tabilized material along with. remaining
Boil8/sediments .which are above RAOs would be deposited in an on-site
containment cell designed in accordaJ\ce with 6NYCRR. Part 360 (NYS
regulation). The key features of the Part 360 cell are: a bottom liner
system consisting of primary and secondary composite liners and primary and
secondary leachate collection system and a cap consisting of a 40 mil liner
with 24 in. of soil cover, 6 in. of top soil and vegetative cover. Under
this alternative, approximately 10,000 cubic yards of waste would be
stabilized and deposited in a containment cell along with approximately
15,000 cubic yards of unstabil1zed soils/sediments from other parts of the
site.
likely to continue for 20 to 30
Groundwater, process water and the surface wat~r would be transported to the
FMC Middleport plant for treatment and disposal.
Alternatbe 58: S%ABILI~IOII, OR-SID DISPOSAL IR PART 360 CELL, OIl-Sn~B
-------
WATER DEA'l'MEHT
Capital Cost: $5,989,750
o & K Cost: $218,470/yr (for 20 years)
Present Worth O&K: $2,722,619 (at 5\)
Total Project Costs: $8,712,369
Construction Time: 14 months.
The groundwater extraction and treatment
years.
i8 likely to continue for 20 to 30
This alternative is identical to Alternative SA except that the groundwater,
process water and contaminated on-site surface water would be treated on-site
and discharged to Jeddo Creek as described in Alternative 48 above.
Alternative 6A: S~ABILIZA~ION, ON-SIft: DISPOSAL IN CUSTONIZED PAR~ 360 CELL,
OFF-SITE WADR TREATMl!:In
Capital Cost: $5,693,838
o & K Cost: $394,800/yr (for 20 years)
Present Worth O&K: $4,920,081 (at 5\)
Total Project Costs: $10,613,918
Construction Time: 13 months.
The groundwater extraction and treatment
years.
This alternative includes the stabilization of all the contaminated materials
from the waste pile area and _11 the contaminated soils/sediments from other
parts of the site which are above the RAOs. The stabilized material would be
deposited in a customized cell designed to meet the 6NYCRR Part 360
regulations. New York State Regulations 6NYCRR Part 360 allows modifications
to a landfill used solely for the disposal of 80lid waste resulting from
industrial or commercial operations. The key features (shown conceptually in
Figure 3-8) of the customized Part 360 cell are: a bottom liner system, a
leachate collection system and a cap consisting of a liner with a soil cover,
six inches of top soil, and a vegetative cover. Under this alternative, all
the waste from waste pile area and all the soils/sediments above RAOs from
other areas of the site (estimated at 25,000 cubic yards) would be stabilized
before placing in a customized Part 360 cell.
is likely to. continue for 20 to 30
Groundwater, process water and the surface water would be transported to the
FKC Kiddleport plant for treatment and disposal.
Alternative 68: S~ABILIZA~ION, ON-SIft: DISPOSAL IN CUSTOMIZED PAR~ 360 CELL,
ON-SITE WADR ~TMl!:In (Selected R...dy) .
Capital Cost: $5,693,838
o , M Cost: $218,470/yr (for 20 years)
Present Worth O&M: $2,722,619
-------
D
Total Project Costs: $13,382,398
Construction Time: 12 months.
The groundwater extraction and treatment
years.
This alternative includes the stabilization of all the contaminated mat$rial
in the' waste pile and soils/sediments from the rectangular pond, swamp,
drainage swale, the quarries, and other areas that are above remedial action
objectives. Stabilized material would be transported to an off-site permit-
ted Part 360 landfill.
is likely to continue for 20 to 30
Groundwater, process water and the surface water would be transported to the
PMC Hiddleport plant for treatment and disposal.
Alternative 78: S~ABILIZA~IOH ARD OFF-SIB DISPOSAL, OR-SIB WABR ~
capital Cost: $8,462,318
o & H Cost: $218,470/yr (for 20 years)
Present Worth O&H: $2,722,619 (at 5')
rotal Project Costs: $11,184,937
Construction Time: 12 months.
The groundwater extraction and treatment is
years.
likely to continue for 20 to 30
This alternative is identical to Alternative 7A except that the groundwater,
process water, and contaminated on-site surface water would be treated on-
site and discharged to Jeddo Creek as described in Alternative 48 above.
Alternative 8A: COHTAIMMEH'r, OPP-SIB WABR TRBADIEla
Capital:Cost: $2,921,880
o & M Cost: $394,800/yr (for 20 years)
Present Worth O&H: $4,920,081
-------
Because alternatives 1, 4A, 4B, SA, SB, 6A, 6B, 8A and 8B would result in
contaminants remaining on-site above health based levels, CERCLA requires
that the site conditions be reviewed every five years. If justified by the
review, remedial actions may be implemented to remove or treat the wastes or
take other actions.
VIII.
SUMMARY OF TIlE COMPARATIVE ANALYSIS OF mz ALTERNATIVES
The remedial alternative selected for the 8ite by the NYSDEC and the USEPA
was developed in accordance with the New York State Environmental
Conservation Law (ECL) and is consistent with the COmprehensive Environmental
Response, Compensation, and Liability Act of 1980 (CERCLA), 42 use Section
9601, et. sea., as amended by the Superfund Amendments and Reauthorization
Act of 1986 (SARA). The criteria used in evaluating the potential remedial
alternatives can be summarized as follows:
Threshold Criteria - The first two criteria must be satisfied in order for an
alternative to be eligible for .election.
1.
Protection of Human Health and the Environment--This criterion is an
overall and final evaluation of the health and environmental impacts to
assess whether each alternative is protective. This evaluation i8 based
upon a composite of factors assessed under other criteria, especially
short/long-term effectiveness and compliance with ARARs/SCGs (see
below) .
2.
Compliance with Applicable or Relevant and Anpropriate New York State
and Federal Reauirements (ARARs)--ARARs are divided into the categories
of chemical-specific (e.g. groundwater 8tandards), action-specific (e.g.
design of a landfill), and location-specific (e.g. protection of
wetlands). To distinguish between state and federal requirement8, New
York State refers to its ARARs a8 Standards, Criteria, and Guidelines
(SCGS). Certain policies and guidance that do not have the status of
ARARs/SCGs that are considered to be important to the remedy selection
process are identified as To-Be-Considered (TBC) criteria. At this site,
groundwater is contaminated at levels above New York State standards
thereby contributing to the need for site remediation. Table 2-4
summarizes the remedial action objectives (identified ARARs/SCGs/TBCs).
PrimarY Balancina Criteria - The next five .primary balancing criteria" are
to be used to weigh major trade-offs among the different - hazardous waste
management strategies.
3.
Short-term Imnacts and Effectiveness--The potential short-term adverse
impacts of the remedial action upon the community, the workers, and the
environment i8 evaluated. The 'length of time needed to achieve the
remedial objective8 i8 estimated and compared with other alternatives.
4.
Lona-term Effectiveness and Permanence--If wastes or residuals will
remain at the site after the selected remedy has been implemented, the
following items are evaluated: 1) the magnitude and nature of the risk
presented by the remaining wastes; 2) the adequacy of the controls
intended to limit the risk to protective levels; and 3) the reliability
of these controls.
5.
Reduction of Toxicitv. Mobilitv. or Volume--Preference i. given to
alternatives that permanently and by treatment significantly reduce the
toxicity, mobility, or volume of the wastes at the site. This includes
assessing the fate of the residues generated from treating the wastes at
the site.
Implementabilitv--The technical and administrative feasibility of
implementing the alternative is evaluated. Technically, this includes
6.
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D
the difficulties associated with the construction and operation of the
alternative, the reliability of the technology, and the ability to
effectively monitor the effectiveness of the remedy. Administratively,
the availability of the necessary personnel and material is evaluated
along with potential difficulties in obtaining special permits, rights-
of-way for. construction, etc~ .
7.
~--Capital and operation and maintenance costs are estimated for the
alternatives and compared on a present worth basis.
Modifvina Criteria - These final criteria are. taken into account after
evaluation of those above. They are focused upon after public comments have
been received.
8.
Communitv AcceDtance--COncerns of the community regarding the
. Reports and the Proposed Remedial Action Plan are evaluated.
Responsiveness Summary (Exhibit C) for this project identifies
concerns and presents the agencies responses to those concerns.
State AcceDtance--In this case, New York State is the .lead agency. for
the project and the USEPA is the .support agency.. Therefore, .State
acceptance" is understood to refer to the concurrence between the
agencies on the proposed remedy.
RIfFS
The
those
01
9.
Remedial action objectives are specific goals to protect human health and the
environment. These objectives are based on available information and
standards such as ARARs.
The following general remedial objectives were identified for the Dublin Road
site:
Adequately protect against
contaminated soil;
ingestion of,
or contact with,
.Minimize damage to and provide adequate protection of the
saturated zone from contaminants migrating from soil;
Minimize damage from and adequately protect against the spread
of the contaminated groundwater;
Adequately protect against future ingestion of,
with, contaminated groundwater;
or contact
Adequately protect against contamination of surface water and
sediments in the site vicinity; and
Adequately protect against contaminated dust emissions into
ambient air.
The ARARs and media specific RAOs for the Dublin Road site are given in Table
2-4 (attached) of the 1992 FS report.
The following section addresses the alternatives that have been evaluated to
achieve these goals.
As discussed above, the NCP requires that when evaluating potential remedial
alternatives, the threshold criteria of overall protectiveness of human
health and the environment along with compliance with Applicable or Relevant
and Appropriate Requirements (ARARs) must be met. The five primary balancing
criteria are then used to weigh trade-offs between the alternatives.
o
OVerall Protection of Human Health and the Environment
Alternative 7, Stabilization and Off-site Disposal, would likely offer the
-------
highest overall protection of human health and the environment due to the
elimination of the source from the site. Alternatives 4, S, 6, and 8 would
offer lesser protection as compared to Alternative 7. Under Alternatives 4
and 5, only part of the waste material would be stabilized. Under
Alternative 6, all the waste material would be stabilized resulting in
reduced contaminants leaching. Under Alternative 4,. 8tabilized and
unstabilized. waste would be placed on the ground surface without bottom a
liner and leachate collection system, whereas under Alternatives 5 and 6,
stabilized and/or unstabilized waste would be placed in a properly designed
and constructed cell. Under Alternative 8, no stabilization would be done.
The No-Action alternative (Alt. 1) would not be protective of human health or
the environment because the only contaminant removal process available would
be natural attenuation. It would take decades to reduce the concentrations
to acceptable levels.
Under alternative 68 the waste material would be 8tabilized and contained in
a cell, and contaminated 8urface and groundwater would be removed "and
treated. This would result in eliminating the expo8ure pathways. Therefore
alternative 68 would be protective of human health and the environment. .
o
ComDliance with ARARs
The most significant of the ARARs at the site is the New York State
groundwater standards. State regulations define the best usage of
groundwater"as a source of drinking water. Therefore, the assigned standards
are stringent. Alternatives 4A, 48, SA, 58, 6A, 68, 7A, 78, 8A," and 88
include provisions for directly addressing groundwater and surface water
contamination and are capable of achieving ARAR's for groundwater and surface
water. These alternatives also address soil contamination as a source of
contaminants to the groundwater by leaching.
Chemical-specific ARARs
alternative.
(see Table
2-4)
are
not met
by
the No
Action
"Action-Specific ARARs (6NYCRR Part 360 requirements) are satisfied under
Alternatives SA, 58, 6A, 68, 7A, 78, 8A, and 88. Action-specific ARARs are
not met by Alternative 4A or 48 .
The location-specific ARAR identified for the Dublin Road Site (namely,
protection of wetlands) is satisfied under all Alternatives, except the No
Action Alternative.
CUrrently, there are no ARARs for contaminated sediments, but the State of
New York has developed guidance values for evaluating sediment contamination.
These values are "T8Cs" as defined on page 11. The concentration of several
contaminants in sediments at the site somewhat exceed these guidance values.
~lternatives 4A, 48, SA, 58, 6A, 68, 7A, 78 8A, and 88 would directly clean
up 8ediments by removing the sediments from the site. Because low
concentration. of contaminants in Jeddo Creek 8ediments would not pose a
8ignificant ecological ri8k, these sediments would not be di8turbed. A
monitoring program of Jeddo creek sediments would be required to ensure that
the sediment contamination does naturally degrade.
o
Lona-Term Effectiveness and Permanenc~
Alternative 1 (No Action) is not considered reliable for the long term due to
the continued presence of contaminants above health based levels on-site.
Alternatives 8A and 88 (containment) do not stabilize the waste and are con-
sidered to be less reliable in providing long-term effectiveness as compared
to the other remaining alternatives. The state-of~the-art has not defined
-------
..
the long-te~ effectiveness of stabilization (Alternatives 4 through 7). The
stabilization process is a chemical reaction characterized by the generation
of heat, a change in physical and chemical properties, and a reduction in
moisture content. This reaction is not reversible, but may be affected by
exposure to the environment. The proposed stabilization technique is
expected to be effective indefinitely. This is especially true in the case
of Alternatives S, 6, and 7, since the treated material would be protected
from the environment and other destructive forces by a containment cell de-
signed to meet the perfo~nce standards.
Upon completion of the source 'remediation, implementation of either on-site
or off-site contaminated water treatment would provide long-term effec-
tiveness and permanence.
o
Reduction in Toxicitv. Mobilitv. or Volume
Waste treatment by stabilization (Alternative. 4 through 7) would result in
reducing the mobility of the contaminants. However, no reduction in volume
or toxicity of the contaminants already present in the waste pile materials
, or soils/sed~ents would result. Stabilization would actually result in an
, increase in volume due to the addition of l~e kiln dust. For Alternatives
8A and 8B, the mobility of contaminants would be reduced due to the provision
of the cap and the cut-off wall, but to a lesser degree. For these alterna-
tives, no reduction in toxicity or volume would occur. Treatment of the
surface water and groundwater would result in a permanent reduction in volume
of contaminated water, ,contaminant mobility, and off-site migration.
Alternative 1 (No Action) would not result in the reduction of the toxic~ty,
mobility, or volume of contaminants.
o
Short-Term Effectiveness
Alternatives 4A, SA, 6A, 7A, and 8A which involve off-site transportation of
contaminated water pose some risk to the community and workers during
handling and transportation operations. Each of the potential short-term
effects can be controlled using proper engineering and transportation
practices.
Alternatives 4A, 48, SA, 58, 6A, 6B, 7A, and 78 involve significant soil
excavations which would expose heavily contaminated soils. Controlling the
emissions of vapors and contaminated particulates would be difficult but
could be done using engineering controls. Transportation o{ excavated soil
(Alt. 7A, and 7B) would present additional risk associated with the
transportation of the waste material. '
Alternative 1 would have no short-term effectiveness and existing impacts
would continue.
o
ImDlementabilitv
Alternative 1 18 easily implementable and results in no change in the ex-
isting conditions. Stabilization of the waste material (Alternatives 4
through 7) is straightforward and uses 8tandard construction equipment. Site
specific treataDility studies indicate that staDilization using 10' lime
kiln dust by weight would reduce the leachaDility of lead by 93' in soil from
the waste pile. Many vendors would be available to provide these services.
COnstruction of a cap (Alternatives 4, S, 6 and 8) can be implement using
standard construction equipment. A cap can be constructed relatively quickly
, if the ground is not frozen or saturated. Material for the cap 1s available'
locally. Liner material is readily available from the manufacturers. Long-
term monitoring and maintenance of the cap would be required. Landfill
capacity for Alternative 7A or 78, which would require disposal of approxi-
mately 32,000 cubic yards of treated waste material to a permitted sanitary
-------
landfill in the area, is available.
o
~
The total cost of remediation varies from $722,808 for the No Action
alternative to $13,382,399 for Stabilization, Off-site Disposal, and Off-site
Water Treatment. The comparison of the estimated capital cost, present worth
~ost, and the total project cost of all of the alternatives is given in the
attached Table 4-16 from the FS report. .The following table summarize the
total present worth cost of the various alternatives. All alternatives
include monitoring.
Alt.
Alt.
Alt.
Alt.
Alt.
Alt.
Alt.
Alt.
Alt.
Alt.
Alt.
o
Estimated Present Worth of Costs of Alternatives
1 - No action............................................$722,808
4A - Stabilization, Off-site WaterTreatment.............$8,969,S81
48 - Stabilization, On-site Water Treatment.............$6,772,119
SA - Stabilization, On-site Disposal in Part 360 cell,
OffsiteWaterTreatment........ .................. .$10,909,831
58 - Stabilization, On-site Disposal in ~art 360 Cell,
On-site Water Treatment. ......................$8,712,369
6A - Stabilization, On-site Disposal in Customized
Part 360 Cell, Off-site Water Treatment..........$10,613,919
68 - Stabilization, On-site Disposal in CUstomized
Part 360 Cell, On-site Water Treatment..........$8,416,4S7
7A - stabilization, Off-site Disposal,
Off-site Water Treatment.......................$13,382,399
78 - Stabilization, Off-site Disposal,
On-site Water Treatment........................$11,184,937
8A - Containment, Off-site Water Treatment..............$7,841,961
88 - Containment, On-site Water Treatment...............$S,644,499
State Accentance
Based on its review of the RIfFS reports the NYSDEC concurs with the .elected
remedy identified below.
The New York State Department of Health (NYSDOH) has reviewed the supporting
documents and concurs with the selected remedy.
o
Communitv Accentance
-------
The re8ponsiveness 8ummary (Exhibit C) for this project identifies community
concerns and presents responses to those concerns.
11:.
IIIP.T ."C'1'EI) REMEDY
Based upon the results of the RI/FS, and the criteria for selecting a remedy
under the applicable laws and regulations, the NYSDEC and USEPA have selected
Alternative 68 (Stabilization, On-site Disposal in Customized Part 360 Cell,
On-site Water Treatment) to remediate the site. The NYSDOHconcurs with the
selected remedy. The estimated present worth and capital costs for the
remedy are, respectively, $8,416,457 and $5,693,838.
The essential elements of this alternative for source control are as follQWs:
(a)
excavate, .creen and .tabilize All the contaminated materials
(soils and sediments) from the waste pile, rectangular pond, .wamp,
drainage swale, the quarries and the other areas that are contami-
nated above the remedial action objectives;
(b)
store the stabilized material in a temporary stock pile and test it
to ensure that it passes the TCLP, and other tests for thOse site
specific compounds not included in TCLP;
(C)
construct the composite liner (s), leachate collection and removal
system(s) of the customized Part 360 cell;
redeposit the treated material in the customized cell;
(d)
(e)
rinse, dewater, treat if needed, all material greater than 2 inches
in diameter and deposit it in the proposed on-site celli and
install a cover consisting of geomembrane, cover soil, top soil,
and vegetation for erosion control consistent with Part 360
Regulations.
(f)
This alternative includes on-site treatment of the process water, groundwater
from the overburden and upper bedrock aquifers, 8urface water from the
, rectangular pond, swamp, drainage areas, east and west quarries, and disposal
of the treated water to Jeddo Creek. A groundwater extraction system will be
designed and installed. The water treatment will include electrochemical
treatment, pH adjustment, sedimentation, filtration, ca~on adsorption,
and/or any other processes which may be necessary to achieve the required
water quality for disposal to the Creek.
VQder, the selected alternative, wetlands will be restored at the .wamp and
east and west quarry locations. The site will be backfilled and graded where
necessary. The .elected alternative will limit access and use of the .ite
utilizing the exi.ting fence and .igns and by providing new .igns where nec-
essary. A new fence will be installed around the customized cell and around
part or all of the groundwater treatment and extraction 8ystem. The
alternative will include provisions for precluding future use of the .ite and
on-.ite groundwater by deed restrictions.
An operation and maintenance (O&M) program will be' part of this alternative
and will be developed during the design phase of this alternative. The O&M
program will include operation and maintenance of the pump and treat system,
and leachate collection system, and the containment cell. A monitoring
program will also be developed during the design phase and will include
groundwater, surface water, air (during construction), and .ediment
,monitoring. A list of sampling parameters will be developed during design
which will include all the compounds detected in site soils/sediments and
groundwater.
-------
The conceptual design of the customized Part 360 containment cell is shown in
Figure 3-8. Section 360-2.14 of 6NYCRR Part 360 allows modification to the
Part 360 containment cell, if a containment cell is solely used for the
disposal of the solid waste resulting from commercial or industrial opera-
tions. This .ection states that the requirements of Subpart 360-2 can be
modified on a case specific basis if the applicant can demonstrate that a
.pecific. landfill requirement is not necessary. The final details of
containment cell design will be determined during the design phase of the
.elected remedy. .
The .elected alternative achieves the ARARs and RAOs more quickly, or as
quickly, and at less cost than the other options. The general RAOs are given
on page 12 and media specific RAOs are given in Table 2-4. Therefore, the
preferred alternative will provide the best balance of trade-offs among
alternatives with respect to the evaluating criteria. EPA, NYSDOH and the
NYSDEC beliE::ve that the preferred alternative will be protective of human
health and the environment, comply with ARARs, be cost effective, and
utilize permanent eolutions and alternative treatment technologies or re-
.ource recovery technologies to the maximum extent practicable. The remedy
also will meet the statutory preference for the u.e of treatment as a princi-
pal element.
If monitoring indicates that continued operation of the remedy is not
producing significant reductions in the concentrations of contaminants in
groundwater, in accordance with the NCP, the NYSDEC and the tJSEPA will
evaluate whether discontinuance or revision of the remedy is warranted. The
criteria for discontinuation will include an evaluation of the operating
conditions and parameters as well as a statistical determination that the
remedy has attained the feasible limit of contaminant reduction and that
further reductions would be impracticable. .
The selected alternative will include annual monitoring of the downgradient
domestic wells for site specific compounds, for a period of five years
begining in 1994. Residential Downgradient wells will include all wells on
Dublin Road between the site and the Fruit Avenue, and all wells on Fruit
Avenue within one mile north of Dublin Road. Based on the evaluation of the
data, the monitoring may be extended beyond five years.
I.
STATUTORY DETERMINATIONS
The following discussion describes how the remedy complies with the decision
criteria in the laws and regulations.
1.
Prot8ction of BU8&n B8al~h and ~h8 EDvirona8nt
The proposed remedy is protective of human health and the environment.
COntaminated .oils/sediments will be removed, stabilized and contained in a
controlled cell. This will provide adequate protection against inge8tion of,
or contact with, the contamina;ed aoila/sediments; minimize damage to and
provide adequate protection of, the .aturated zone from contaminants
migrating from ~he .oil, and adequately protect against contaminated du.t
emissions into ambient air. Groundwater will be extracted and treated along.
with the surface water. The water treatment will include electrochemical
treatment, pH adjustment, sedimentation, filtration, and/or carbon ab8orption
to achieve the required water quality for disposal to the Creek. This will
adequately protect against future ingestion of, contact with, or .pread of
the contaminated groundwater. No unacceptable short-term risks or cross-
media impacts will be caused by implementation of the remedy.
2.
COaplianc8 .i~h &RARe
Alternative 6B, will result incompliance with all applicable or relevant and
appropriate federal and state requirements.
-------
The remedy will continue to be operated and improved as necessary until such
time that compliance with all ARARs has been obtained or a determination i8
made that no further reductions in contaminant concentrations are feasible.
3.
COat-Effectiveness
Of the alternatives that can achieve the remedial goals and meet the
threshold evaluation criteria (Alt. SA, 58, 6A, 68, 7A, and 78), Alternative
68 has the lowest cost.
t.
Utili.ation of Peraanent Solutions and Alteruative ~reataent
~echDologies or "source aecovery ~echDologies to the llaxiaua Bxtent
Practical:lle.
The NYSDEC and the USEPA have determined that the. selected remedy provides
the best balance of tradeoffs among the alternatives for r81118diating the
site. Of the alternatives that met the threshold criteria of .overall
protection of human health and the environment. and 8compliance with ARARa,.
the balancing criteria of .short-term impacts and effectiveness,.
8implementability,. and .cost. were the most critical criteria for selecting
the remedy. The remaining alternatives were comparable in their ability to
meet the remaining criteria (.long-term effectiveness and permanence., and
8reduction of toxicity, mobility, or volume"). The treatment of water will
result in a permanent remedy for groundwater.
Alternatives SA and 88 are considered less reliable for long-term effective-
nesa as compared to the other remaining alternatives. Alternatives 7A and 78
offer higher overall protection to human heal~h and the environment but
scored low due to the higher cost and short-term effectiveness (increased
ehort-term risk to the community due to transportation of the hazardous
material). Containment cells under Alternatives 5A, 58, 6A and 68 can be
designed to comply with the latest performance standards. However, Alterna-
tives 6A and 68 are considered more reliable over .the long-term as compared
to Alternatives SA and 58, since under Alternatives 6A and 68 all the
material will be stabilized resulting in lesser potential of future leaching
and release of contaminants to the environment.
5.
Preference for ~reataent aa Principal El..enta
The principal threat is posed by contaminated 80ils and the contaminants that
leach from the soils to the groundwater. As discussed above, stabilization
and containment of soils and treatment of contaminated water are the
principal elements of the remedy.
-------
/ Am ./r7f.~ 'r'!' '''/~j- r-l Ji. .--\U(~~~- 1)4 t;; -::..c-
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("
Fagure 1.1 '
Location 01 the Dublin Road Site
-------
..
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WEST
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-
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100
200
SCA~E IN FEEi
FJaare 1.2
DabliD Ro8d Site Featuns
24
-
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1
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I
DUBLIN ROAD
I L£5 !
i I
I DRAIJIACE I
! C) "'TER BODY I
I c:::> LIMIT Of WAST£ AR£A I
- SITE 80UNDARY , I
-x- FENCE .
i
-------
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too aDO
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.... In Feet
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48 --....
--......,
-----
Figure 3-7
Dublin Road Containment Cell Loe.tlon
-------
, .
TABLE I-I
SUMMARY OF CHEMICALS IN THE DUBLIN ROAD SITE WASTE PlLEN
,"
Conce"''''- <..Ita)
,.. C8 H, Zn " a-IHC 8-IHe ~IHC ,.IHC
.......- 2,569 168 I.n 162 6.157 1.11 0.41 cUt 0.31
Muhnu... 20,400 19' IS 1,120 41,- 2J 4 U U
.,....... <10 II <0.1000 16 31 <0.0092 <0.0092 <0.0092 <0.009J
...... ol V"'" 14 14 24 24 24 24 24 24 24
......, of V"'" ..... I 0 3 0 0 II 21 20 19
..... DatIctIi. .....
"~'- ......
...,..... V"'" 4f1" 100'" 3M 300'" 2OCP't NA[JIII MAD MAD 2M
........ ol V"" McM
.... '-n .......
...,..... V" 2J I 3 .. 12 NAD MAD MAD 1
,,p'.DOI) ,..'.DD8 ,.p'-DM
...... 0.'" 1.43 31
... - U 21 400
r- . <2.01.. <0.0110 <0.0110
......ol V"" 24 11 12
...... of V"'" ... I HAD MAD r-e
..... DetIctII8 u.II
...... olV.... AMn
...... IT ....... MAD HAD 6
......... V""
."..... - ..... hit... 11-..
-V"""".'" .. ~~... Htnil -.. 18""'" Ih8 ....,.......1hNi ror c.Ieu...", die IIIUIII.
."..... ........ ...... 1911 ... Ande-. cUI., 1911. 11Ie conc.lllntioa or - Chemlc"1 -, be hip' ror -1111 wIIlch ..1I1c1cle1 -.. ."rlld""...we or hit CIOpI.
"'AD . Mo A""" 0118 .lIIbll"'. _1Ilmum llee""'" nlue.. .
.."... 6a81PA. 191'.
.....: III, I"';
-------
TABLE 1.2
CHEMICAL CONCENTRATION OF INDICATOR
ANALYI1CAL PARAMETERS IN SURFACE WATER
WI' ..... .,.a&ed)
"""'r .... I..... &all Qua")'
c-~ NIIIIIIIIr N1IIIIII8r NUIIIb8r
U8IJiII ..... or ..... .... or ..... ..... or
v..... v..... Valua
M (rIc/l) 31.9 5.C~I30 S 1.5 0.2-C.4 S 0.08 0.00400.11 1
CU (r1J81 I) 1.2 1.1-20.0 5 1.0 0.6-1.1 5 0.2 0.1.0.6 1
JIb (IDI' t) 0.9 0.1-1.5 5 0.01 ND.o.021 2 0.008 ND $III
%II (lDI/t) 29.2. 5.3-14.0 5 1.1 0.2-3.3 .5 0.6 ~.1-1.4 7
o-BHC 2,«)4.5 JIDIII-I2.ooo 5 I." N!).4.4 5 0.09 MD-O.35 7
6-BHC 1."52.5 0.63-5,100 .. 0.4 ND-1.0 4 0.01 MD-O.11 5
"BHC 1.503.0 1.1 0.6,000 .. 0.6 ND-I.9 4 0.04 NDoO.II 5
,..8HC 1,363.1 0.11-6,100 5 0.1 0.GS-2.1 5 0.01 MD-O.25 1
o,,'DDD 11.6 0.11-10 4 0.01 ND.o.025 .. 0.003 ND #PI
",'DDD 23.0 0.31-90 4 0.01 ND-O.025 .. 0.003 ND #PI
o,p'DDE 1.6 ND-30 .. 0.01 ND-O.025 4 0.003 ND ..,..
",'DDE 37.6 ND-15O 4 0.02 ND-O.OPO .. 0.003 ND ..,..
o,,'DDT 1.5 1.01).30 .. 0.01 ND-O.025 .. 0.003 ND ..,..
,,p'DDT 119.4 1.90.750 .. 0.02 ND-O.QZS .. 0.003 ND #PI
2.4-0 96,6 N!).4'7O 5 0.11 NJ).3.61 5 0.21 JlD.I.21 1
2.4,5-T 10.3 ND-50 5 0.51 111).2.4'7 5 0.21 ND.o.'4 ,
,H (..e.) 2.2 1.9-2.4 5 1.9 2."'3.3 5 3.5 3.1-4.1 9
EC ~~) 10.612 5.'701).20,000 4 2.625 l.tCJ0.4.400 4 1.020 510-1 ,150 I
Sa8rce: 8EZ. 1911.
NOTE:
~ ..... wlaicb "ftI'C npoNd U .... Ibu .... IIIItbocI c5It8etioa IiIiIit "ftI'C divided by 2 ror c:akullUao or eIIe _.
C8NI) . Noc ~
18y' u ... IIII8c8Id It .... abcwc 1IIc IIIIIbod dIIKIioo 1iIIIi1.
-------
TABLE 1-2
(coatiDued)
J8ddo C.-k. DowMnam I8ddo o.t. U"""III
w.. Quarry otEut Qua", DiIcbuJe of EuI Quarry DiKulJC
e-..a...-... NIIIIIbIr NIIIIIIIer NIIIIIIIIr
IUufll .... or ..... ..... or Mea .... or
Valua v.... Valua
AM"'f) 0.01 JIDI8.o.CM 4 0.016 NDo4.1J9 , O.GQS ND4.o.1 ..
Cu (""/f) 0.02 JID.OJD 4 0.00'1 NDoO.Oll S O.CIO'7 NDoO.CIOI ..
Jib ("'f) 0.01 ND .. 0.00'7 NDoO.OlS 3 0.003 ND 2'"
%II (..,/f) 0.22 0.02.0.46 .. 0.037 0.002.0.1' 1 , 0.021 0.003-0.02.1 ..
o-8HC 0.02 NDoO.04 .. 0.011 ND.o.04 ,. 0.004 NDoO.OIO ..
a..HC 0.018 ND.o.04 .. 0.004 ND.o.OOS . 0.003 NDoO.OOS ..
f.8HC 0.03 ND.o.06 .. 0.009 ND.o.030 I 0.003 ND-O.OOS ..
.,.8HC 0.01 NDoO.02 .. 0.G07 ND.o.02O , 0.003 ND-O.OOS ..
o,p'DD)) 0.005 ND 2'8 0.003 ND " 0.0Q3 ND .""
p,p'))D)) 0.005 ND 2'8 0.003 ND p 0.003 ND P
o,p'DDE 0.005 ND 2'8 0.003 ND " 0.003 ND ..,.
,,p'DDE O.OOS ND fit 0.003 NO ~ O.OCM NO ~
o,p'DDT 0.005 ND 2'8 0.G04 ND-O.OIO .. 0.004 NI>O.OIO ..
p,,'DDT 0.005 ND P 0.003 .. ND . " 0.003 NDoO.OOS
..
1,"0 0.13 NDoO.3OI) .. 0.G21 ND-O.l00 1 0.210 NDoO.40 3
l,...s-T 0.16 ND.o.3Ol) .. O.CIM ND.o.I95 . o.oa NDoO.20 3
,H (L8.) 7.0 6.3-7.6 2 7.1 7.N.2 S 1.2 7."'.0 ..
Ie ~;m) 491 42.S-S70 2 551 46Go6SO 5 54' ~20 ..
SauKc: am. 19U
HOlE:
"'1..' a~ .u-. .... .... npart8d u ... diu ... IIIIIbod dII8C1ioD IiIIIh WI'I dMd8d 117 2 ror ',','-,1.,:- 0' die _.
8NI). NaI~ .
l8Wu 8DC cII&8cI8d 81 ..,. 8bcM Ibe ..... d8tKIiaD limit.
-------
TABLE 1.2
(coDtinued)
hddo CrMt I' Jeddo CrMt at HilbW8131E lie""""
Dublia Road
~'"'P' N""'" or N"""r or
"am" Raap VI1u8a .,.. Rup VaIuu .
ItA (..'f) 0.G04 NI)I8~.QZ2 ., 0.002 ND-O.OCD 4
01 (88If) O._ ~.CIOI , NO DATA-
" (..If) 0.- NJ).O.015 , NO DATA
Za (rIC/l) 0.013 NJ).O,023 ., 0.012 0.0064.022 4
a-BHC 0.030 0.01~.170 ., 0.052 NJ).O.IIO 4
I-BHC 0.005 NJ) fill 0.005 NJ) 418
"aRC 0.012 N%).O.050 6 0.011 ND-O.06O 4
,..BHC 0.018 N%).O,050 ., 0.020 N%).O.050 4
o,p"DDD 0.005 NJ) P NO DATA
"p"DDD 0.005 NJ) P NO DATA
o,p'DDE 0.005 NJ) P NO DATA
p,p"DDE 0.005 NJ) 2111 NO DATA
o,p'DM 0.005 NJ) P NO DATA
p,p"DM 0.005 NJ) P NO DATA
2,.D 0.056 NJ).O.2OI) ., 0.- ND-O.IO 4
2,4,5-T 0.011 NJ).O.610 ., 0.014 NJ).O.050 4
,H (....) 1.3 1.3-'.4 3 NO DATA
IC Clllllalca) 590 5»650 3 NO DATA
ScIaRc: 8EI, 1911
NC7I'E:
IID{., J I.,.~.... -1WpCIft8d u.......... 8IIIIOII---Ii8iIWWt 4i¥ill8ll1Iy2 for 1:I'-'-orlll8_.
8NJ) - .... DI88c88d
...... .. ..... . ....,. 8bow .. IIIIdaod ....... 1iIIIit.
-su..- WWt .. coUIct8d or 88IJZ8d for tIIiI p8J8IDIIer II dIia IIIIIpIiDa kxa&ioa.
-------
, .
1
"
18" of cover loR
and 6" 'op,oll
--
- -
-
-
- -
=
-
--
-
-
-
- .
-
-
-
-
=
-
-
-
-
--
--
-- --
-
- - -
- -
-
- -
-
-
-
-
-
--
- -
-
--
- -
--
-
-
-
-
- -
-
-
-
-
-
-
-
-
No8 to Ie."
,."..
Figure 3.8 .
Customized Part 360 Containment Cell .
(Conceptual Sketch - Final Details~ Consi~tent With 6 NYCRR Part 360 Regulations,
-------
TABLE 1-4
CHEMICAL CONCENTRATION OF INDICAroR
ANALmCAL PARAMETERS IN SEDIMENT
(UNIT . ..,...
lOCATION
~.
E8tI QuI", at PoIftI 01' 'edclo a.t ."..... of 'edclo Creek II
18Ct8""', ... S....., .11 QuInJ Well QIII", Dildtarp ,- Jedclo Creek Eall QII8nJ 01"'" Dublin R084I
A8 640.0 ",ISO.O :1,600.0 110.0 19.0 U 6."
01 1,020.0 HO.O 2,6:10.0 2,480.0 81.0 :IS.O 11.0
.. 400.0 250.0 1,240.0 74.0 29.0 1:10.0 '.9
Za 40.0 100.0 190.0 2,510.0 200.0 n.o 49.0
.IRC 10.0 0.:10 US ND ND 0.01 ND
8-IRC '.2 0.19 0.86 NO ND 0.01 ND
"IRe U 0.56 ND ND ND 0.14 ND
,..IRC 4.1 0.09 0.04 NO ND NO ND
-..'DDD 24.0 0.26 US NO ND NO ND
...'DDD "'.0 0."7 0.55 ND ND NO ND
..,'1JD8 U 0.07 NO NO NO 0.09 ND
,..'DOl U o.n 0.51 ND ND 0.06 ND
-..'DOl' 55.0 0.11 0.72 ND ND NO ND
,..'our 100.0 IUS 0.)) ND ND O.M ND
2.4-0 NO NO ND ND ND NO NO
2,",5.T ND ND NO NO NO NO NO
lIMe: III, I-
NIn'I:
NO . Na8 ~ IIIIIIthod 4etec11oe Rmll.
-------
TABLE 1-'
CHEMICAL CONCENTRATION OF INDICATOR
ANALYTICAL PARAMETERS IN THE OVERBURDEN GROUNDWATER
f1cJt ..... ,,...:~
lactpoualll W... PUc AftaO ~o(Pilelll
e--~~ NUlllber NudI8r Nlllllbcr
~ au,. or M8u au,. or .... ..... or
v... v.. VIluc8
,.. <""1) 0.020 ~~.n2 12 37.4 ND-366.0 19 0.34 N1).6.79 36
Oa <",,11) 0.006 NI).4.014 12 2.5 ND-3"7.2 16 0.3"7 ND-4.32 34
JIb <.../1) 0.006 NI).4.015 12 0.02 NI).().090 10 0.009 ND-O.050 23
ZD <.../1) 0.035 0.023-4.010 12 7.2 ND-38.9 19 5.1 ND-86.0 36
0-8HC 0.02.5 NI).().210 16 14.23 ND-240.0 24 0.169 ND-1.400 45
~BHC 0.012 NI).().060 16 1.09 NJ).6.60 23 0.064 ND-O.330 45
~BHC 0.011 NI).().060 16 3.31 NJ).39.00 23 0.016 ND- J.6OO 45
,..DC 0.001 NJ).().040 16 3.13 ND-2UO 23 0.095 ND-1.200 45
o,p"l)1)1) 0.009 NJ).().040 I 0.016 NI).().040 5 0.026 ND-O.I40 10
"p"l)l)l) 0.006 NJ).().020 12 0.179 NJ).1.490 10 0.0.2 ND-O.330 19
o,p "1)1)£ 0.005 NJ).().005 12 0.061 NI).().400 10 0.016 ND-O.09O 19
,.."1)1)£ 0.001 NJ).O.040 12 0.015 ND-O.07O 10 0.011 ND-O.04O 19
0,p'l)17I' 0.015 ND-O.09O 12 0.20'7 ND-J.l50 10 O.CMO N1).().2S0 19
"p"l)I)T 0.005 NDoO.OIO 12 0.163 NJ).1.260 10 0.153 ND-1.290 19
2,4-1) 3.7P7 ND-2A.100 12 12.05 ND-S3.50 . 5.17 NJ)Q.30 17
2,4,s. T 1.075 NJ).I.S30 12 2.20 ND-1I.30 . 2.93 ND-JUO 11
pH (I.aa.) 7.0 3."'.0 16 5.2 1.1-1.1 27 5.4 2.1-11.7 54
Ie ~C1D) 1,131 ~3,OOO 16 4.554 530-20,000 27 J.176 315-5.000 55
1aunII: 8IiI. 1911
NOTE:
IIIJIctpamd Wclb: 25.26.27.21
-w... PUID Ana W8l1a: 1.2.5,6,7,8
~~T ~.... WI1II: 3A,4.9.10,11,12.14,16.1I,19.20.21.23,30,57.59
....., I JIICII ..... wIUda - npcIft8d u ... daaD .. ..... II8I8CIioo limit -- dMd8d by 2 Cor caku1a&ioa of" _.
C8N!) - M- DII8eted
-------
. .
TABLE 1-7
CHEMICAL CONCENTRATION OF INDICATOR
ANALYTICAL PARAMETERS IN THE UPPER BEDROCK AQUIFER
flefl ..... I)III:iIIId)
8Icta'rauDd"' w... Pile Alum Dowa,ndiclll or Pilcl8
"'~;""'DI. NUIIIbIr N8IIIb8r NlI1IIbcr
....... .... 01 .... .... of Maa au,. 01
v...... v...... Valuel
,., CfII8If) 0.004 ND"O.OII 6 U, ~.O , 5060 ND-UO 55
CIa (..If) 0.004 NI).O.OO6 , 0.23 ~1.6 , 0.31 ND-6.57 49
JIb (..If) 0.003 NI).O.OO3 6 0.007 ND4.015 3 0.004 NI).().015 2S
ZA (..If) 0.010 NI).O.Ol1 6 0.13 0.017~.2C 6 5.51 ND-7I 55
Cl-IHC 0.030 NI).O.11O 7 4.'4 ND-32.0 9 2.61. NJ>.31.9 69
&-'HC 0.023 NI).O.130 7 0.59 NJ>.3.1 9 0.43 ND-I J.6 69
~IHC 0.019 NI).O.loo 7 0.77 NJ>.3.6 9 0.09 NJ>.1.0 69
,..8HC 0.001 NI).O.02$ 7 1.60 NJ>.14.0 9 0.19 NJ>.4.2 69
o,p'DDD 0.0Q5 NI).O.OO.5 6 0.0.4 ND4.0s0 4 0.009 NI).().013 29
",'DDD 0.005 NI).O.OO.5 6 0.006 NJ).().020 5 0.006 NI).().OI 31
o,,'DDE 0.011 NI).O.04O 6 0.003 NJ).().005 5 0.004 NI).().03 31
",'DDE 0.005 NI).O.OO.5 6 0.006 ND4.020 5 0.005 NI).().03 31
o,,'D1n' 0.005 NDoO.OO.5 6 0.035 NI).O.16 5 0.022 NI).().26 31
",'Din' 0.005 NI).O.OOS 6 0.006 ND4.020 5 0.012 NI).().021 31
2.4-D 0.157 NI).().5OC) 6 2.'4 ND-13.40 .5 0.293 NJ>.2.94 21
2.4,s. T 0.071 0.~.2S0 ' 0.03 NJ).O.05 5 0.540 NJ>. 7.57 21
,H (1.8.) 7.3 6..s.a.1 7 6.0 3.N.0 . 6.5 4.2.11.5 75
EC (,aabo8Ic:m) 610 26C).1.350 6 4,148 410-1,000 6 2,404 300.7,5C)O 59 I
~: 8&1, 19U
NOTE:
~W.u.:40.I7,..
mw.., Pill ArM W8lll: 37,53
cano....t- Wc1I8: 15.2',35,36,42,43,",45,46,.',41,49,50,51,52,54,.55,56,.51,61,63,65.66
I8t di a~ Y8Iue wbidlMI'IIWpOIII8CI.."'1baa 1M ~ dIIcctioD IiIDit - dmded by 2 for calculalioa orllle_.
-NO . Nell D8tKted
-------
. r
TAnl.~ 2.4
ImlUEUlAI. A(."ION OIlJF.CTlVES t'OK TIII~ IJtJIII.IN ROAU SITE
Mt.di.
Conl.lI\in.lIl~
(;round"'.lu' Surr.ce W.In-8 Soils' Sedimenls"
("'K/I.) Clus C ('"R/ka) (mRfka)
(111111.)
Arsenic 0.02~ 0.19 3S 5
Correr 0.2 0.021 2S 19
Lad . 0.02S** 0.011 93 27
Mercur, HE NE 0.1 0.11
Zinc 0.3 0.030 30 85
BHC (10111)" ND' 0.00001' NR NE
C!I.BIIC .. n 0.48 NE
If.BIIC .. n 1.6 NE
.,..BIIC .. -- 2.3 NE
DDT ND' 0.000001' 8.8 NE
DDE NO' 0.000001' 8.8 NE
DDD ND" 0.000001. 12.4 NE
. AlAI. (NYSDEC. '""1''''' 6 Myell I""" 70.1 r... n... GA 1....IId....,.
, AIAII . (NYSDEC. 1"1' tl... 6 Myell I""" 701 ror I".., C -,. C8I,,,....d b-.I OIl . _u",d !lord.... rrll". ppm ror Irddo Cm:' tribulll)' J.
'(8E1. 1990) lmaIII A.,IDn ~)f(1IY" (IIAlh' en"'"'hrd I. .11< f~ O..tline ..... orp'CII'ed ., NYSI>EC.
. (IIFJ. 1990, IIAOw e""'li,1Ied I. .1Ie fS ("'tli. IIId IIfIp'DYed ., NY51JF.C.
. Tile 1IfIp'~ IAO tor Hill" ......,...nct, I. O.ooon~ "'III II""" on ",,'Irol conllninu IIEI. 1990,.
" tile """'"" IAO tor 11111'. 11111: one! I>DI> I. O.UCJOI mill "-d an 0IIII)'1;..., en...I8I.II (BEl. 1990).
ND . ..... drte.-,...
NE. 1"0. tor '!wee __I..... .... etl""n.lIed. I. i. ..Udptled 'Ilol d.....up '0 .he R"O. ror lhe ",mllninl aontamlnl'u will ",mewe 01. or mOIl of .111.. Sedi..... In .he "'elMl.'" .....nlle .Ieone.. tD.he RAO. ror ...11,
ller- .....nlll....
Nil . VII. IICII ..,..1,.,... RAOs rill l04i.....01 hilt' men,....,nct, will In.....
. AppIIt..o II. of oIll_n.
**Effective February 1993, the action level for lead has been revised to now be 0.015
mg/l by'USEPA (40CFR Part 131)(Rev. 3/93, NYSDEC).
60
-------
TABLE 4-16
COST COMPARISON OF REMEDIAL ALTERNATIVES
RemediaJ Alternative Capital Cost Present Worth Total Cost
(1992 $) of O&M Cost (1992 $)
(1992 $)
1: No Action 0 722.808 722,808
4A: Stabilization, Offsite WT 4.049,500 4,920,081 8,969,581
4B: Stabilization. Onsite WT 4.049,500 2,722.619 6.772.119
5A: Stabilization/Onsite
Disposal in Pan 360 Ce1~. 5,989,750 4,920,081 10.909,831
OOsite WT
5B: Stabilization/Onsite .
DisposaJ in Pan 360 Cell, 5.989,750 2,722.619 8.712.369
Onsite WT
6A: Stabilization/Onsite
DisposaJ in Customized 5,693.838 4,920,081 10.613.919
pin 360 Cell. Offsite WT
6B: Stabilization/Onsite
Disposal in Customized 5,693,838 2,722.619 8,416,457
Part 360 Cell. Onsite WT
7 A: Stabilization/OOsite 8,462,318 4,920.081 13,382,399
Disposal. OOsite WT
18: Stabilization/Off site 8.462.318 2,722,619 11,184,937 -
Disposal, Onsite WT
SA: Containment, OOsite WT 2,921,880 4.920.081 7,841,961
8B: Containment, Onsite WT 2.921,880 2.722,619 5.644.499
(
-------
(.
EXHIBIT A
ADMINISTRATIVE RECORD INDEX
rMC DUBLIN ROAD SITE
SITE ID NUMBER 8-37-001
1. Orders OD CODsen~
a.
Order On Consent No. 837'1'021282 signed February 17,
1982. .
Order On Consent No. B8-0013-84-01, site no. 837001
signed February 9, 1988 for the remediation of the site.
Amendment to Order On Consent no. B8-0013-84-01, Site
. No. 837001 signed January 16,1992.
b.
c.
2. IDves~iqa~ioD Reports
a.
"Investigation of Ground Water Contamination on FMC
Property, Middleport, New York," Dated February 1979,
prepared by Geraghty & Miller, Inc.
"Preliminary Investigation of Ground Water Contamination
in Bedrock underlyi~g the Dublin Road Site at
Middleport, New York," Dated October 1979, prepared by
Geraghty and Miller, Inc.. .
"Dublin Road Waste site Field Investigation Report,"
Dated September, 1984, prepared by Bechtel National,
Inc. .'
"Remedial Investigation Report for the FMC Dublin Road
Site Volume I", Dated May 1988, including August 9,1988
revisions, prepared by Bechtel Environmental, Inc.
"Remedial Investigation Report for the FMC Dublin Road
Site Volume II," Dated May 1988, prepared by Bechtel
Environmental, Inc.
"Remedial Investigation Supplemental Report for the FMC
Dublin Road Site Volume I," dated May 1989, including
January 31,1990 revisions, prepared by Bechtel
Environmental, Inc. .
"Remedial Investigation Report for the FMC Dublin. Road
Site Volume II, Analytical Results," Dated May 1989,
prepared by Bechtel Environmental,Inc.
b.
c.
d.
e.
f.
g.
3. commUDi~y Rela~ions
a.
"Citizen Participation Plan FMC Dublin Road Site, Site
no. 8-37-001, Orleans County, New York" issued June
1990, prepared by" NYSDEC.
Site Information Sheet FMC Dublin Road Site, issued July.
1990, prepared by NYSDEC.
Site Information Sheet FMC Dublin Road Site, issued July
1992, prepared by NYSDEC.
Summary Report issued by the U.S. Environmental
Protection Agency, Region 2, for the FMC Dublin Road
b.
c.
d.
-------
Site, dated March 1990.
4. Miscellaneous Reports and Correspondences
a.
"Preliminary Health Assessment FMC - Dublin Road Site,
dated June 1989," prepared by N.Y.S. Department of
Health under a cooperative agreement with the ATSDR.
"NYSDOH Human Exposure Potential Ranking Model for the
FMC Dublin Road Site," May 23, 1988, draft.
b.
5. Feasi~ility study Report
a.
"Feasibility Study Report for the FMC Dublin Road Site,
Volumes 1 & 2" dated September 1992 (including January
1993.revisions), prepared by Bechtel Environmental Inc.
6. Proposed Plan
a.
"Proposed Remedial Action Plan for the FMC Dublin Road
Site," dated January 1993, prepared by NYSDEC in
consultation with USEPA. .
Public Notice of the availability of the administrative
records, Public meeting, and of the opportunity to
comment on the Proposed Plan.
Transcript of the February 4, 1993 public meeting to
present the Proposed Action Plan, prepared by Trio
Reporting Service, Rochester, New York, dated February
24, 1993.
b.
c.
d.
Responsiveness. Summary,
Record of Decision.
Exhibi t C of the
included as
Note: Literatures, guidance documents and correspondence
referenced in various documents mentioned above are part of the
Administrative Records.
-------
"
EXHIBIT A
ADMINISTRATIVE RECORD INDEX
PMC DUBLIN ROAD SITE
SITE ID NUMBER 8-37-001
1. Orders On Consent
a.
Order On Consent No. 837T021282 signed February 17,
1982.
Order On Consent No. B8-0013-84-01, site no. 837001
signed February 9, 1988 for the remediation of the site.
Amendment to Order On Consent no. B8-0013-84-01, Site
No. 837001 signed January 16, 1992.
b.
c.
2. Investigation Reports
a.
"Investigation of Ground Water contamination on FMC
Property, Middleport, New York," Dated February 1979,
prepared by Geraghty & Miller, Inc.
"Preliminary Investigation of Ground Water contamination
in Bedrock underlying the Dublin Road site at
Middleport, New York," Dated October 1979, prepared by
Geraghty and Miller, Inc. .
"Dublin Road Waste Site Field' Investigation Report,"
Dated September, 1984, prepared by Bechtel National,
Inc.
"Remedial Investigation Report for the FMC Dublin Road
site Volume I", Dated May 1988, including August 9,1988
revisions, prepared by Bechtel Environmental, Inc.
"Remedial Investigation Report for the FMC Dublin Road
Site Volume II," Dated May 1988, prepared by Bechtel
Environmental, Inc.
"Remedial' Investigation Supplemental Report for the FMC
Dublin Road Si te Volume I," dated May 1989, including
January 31,1990 revisions, prepared by Bechtel
Environmental, Inc. .
"Remedial Investigation Report for the FMC Dublin Road
'Site Volume II, Analytical Results," Dated May 1989,
prepared by Bechtel Environmental,Inc.
b.
c~
d.
e.
f.
g.
3. Community .elations
a.
"Citizen Participation Plan FMC Dublin Road Site, site
no. 8-37-001, Orleans County, New York" issued June
1990, prepared by NYSDEC.
Site Information Sheet FMC Dublin Road Site, issued July
1990, prepared by NYSDEC.
Site Information Sheet FMC Dublin Road site, issued July
1992, prepared by NYSDEC.
Summary Report issued by the U.S.Environmental
Protection Agency, Region 2, for the FMC Dublin Road
b.
c.
d.
-------
Site, dated March 1990.
4. Miscellaneous Reports and correspondences
a.
"Preliminary Health Assessment FMC - Dublin Road Site,
dated June 1989," prepared by N.Y.S. Department of
Health under a cooperative agreement with the ATSDR.
"NYSDOH Human Exposure Potential Ranking Model for the
FMC Dublin Road Site," May 23, 1988, draft.
b.
5. Peasibi1ity study Report
a.
"Feasibility Study Report for the FMC Dublin Road site,
Volumes 1 & 2" dated September 1992 (including January
1993 revisions), prepared by Bechtel Environmental Inc.
6. Proposed Plan
a.
"Proposed Remedial Action Plan for the FMC Dublin Road
Site," dated January 1993, prepared by NYSDEC in
consultation with USEPA.
Public Notice of the availability of the administrative
records, Public meeting, and of the opportunity to
comment on the Proposed Plan.
Transcript of the February 4, 1993 public meeting to
present the Proposed Action Plan, prepared by Trio
Reporting Service, Rochester, New York, dated February
24, 1993.
b.
c.
d.
Responsiveness Summary,
Record of Decision.
included as
Exhibit C of the
Note: Literatures, guidance documents and correspondence
referenced in various documents mentioned above are part of the
Administrative Records.
-------
o
DIVISION OF HAZARDOUS WASTE REMEDIATION
INACTIVE HAZARDOUS WASTE DISPOSAL REPORT
.
"
CLASSIFICATION CODE:
2
REGION: 8
SITE CODE: 837001
EPA ID: NYD000511857
NAME OF SITE:
STREET ADDRESS:
TOWN/CITY:
Shelby
FMC Corporation
Dublin Road
COUNTY:
Orleans
ZIP:
14103
SITE TYPE: Open Dump-
ESTIMATED SIZE: 6
Structure-
Acres
Lagoon-
Landfill-X Treatment Pond-
SITE OWNER/OPERATOR INFORMATION:
CURRENT OWNER NAME....: FMC Corporation
CURRENT OWNER ADDRESS.: 2000 Market St., Philadelphia. PA
OWNER(S) DURING USE...: FMC
OPERATOR DURING USE...: FMC Corporation
OPERATOR ADDRESS......: 2000 Market St., Philadelphia, PA
PERIOD ASSOCIATED WITH HAZARDOUS WASTE: From 1933 To
1968
SITE DESCRIPTION:
Lat. 43 12'55"N
Flat topography:
Nearest waterbody:
Long.
Rural
Jeddo
Barge
78 26'30"W
area with the nearest dwelling 1500 feet
Creek (Class D); 50 feet east of site
Canal (Class B); 75 feet south of site
This is an inactive site at which the previous owner. Niagara Sprayer
Corp.. and the present owner. FHC Corp., disposed approx. 5.000 cu. yds.
of hazardous waste. FMC and DEC entered into a Consent Order in 1982
in ~ich FMC agreed to conduct a field investigation. They submitted
a field investigation report to the DEC in September of 1984. A Remedial
Investigation (RI) was started in April of 1986. The preliminary report for
the RI was submitted under a DEC Consent Order signed in February of 1988.
& has since been reviewed. An additional supplemental RI report was required
and was submitted to the DEC in May of 1989. The RI report was reviewed
and approved in May of 1990. A proposed draft Feasibility Study (FS) was
submitted by FMC in January of 1991. The FS identified the need for treat-
. ability studies of soil. sediment and groundwater. In April of 1991. FMC
began to implement the treatability study. In July of 1991. FMC took
sediment samples from nearby Jeddo Creek in order to determine the extent
of contamination in it. FHC has also performed a pump test to develop a
groundwater extraction system. A finalized Feasabi1ity Study (FS) report was
submitted in December of 1992. A Record-or-Decision (ROD) is anticipated
~n the spring of 1993.' A remedial design is scheduled to begin afterwards.
and should continue into 1994. .
HAZARDOUS WASTE DISPOSED:
TYPE
Confirmed-X
Suspected-
QUANTITY (units)
----------------------------------------
----------------------------
Coal ash with iron. chlorides, arsenic
and unknown wastes
Sulfur and sulfur lime residues
Pesticides
Lab chemical wastes
unknown
unknown
unknown
unknown
Page 8
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ANALYTICAL DATA AVAILABLE:
Air- Surface ~ater-X Groundwater-X
CONTRAVENTION OF STANDARDS:
Groundwater-X Drinking Water-
LEGAL ACTION:
TYPE..:
STATUS:
Consent Order State- X
Negotiation in progress-
REMEDIAL ACTION:
SITE CODE: 837001
Soil-X
Sediment-X
Surface Water-
Air-
Federal-
Order Signed- X
Proposed- Under design-
NATURE OF ACTION: RI-FS
In Progress-X
Completed-
GEOTECHNICAL INFORMATION:
SOIL TYPE: Cazenovia gravelly silt loam
GROUNDWATER DEPTH: Approximately 5-15 feet
ASSESSMENT OF ENVIRONMENTAL PROBLEMS:
Groundwater monitoring has confirmed contamination above standards.
Surface water contamination has also been confirmed.
ASSESSMENT OF HEALTH PROBLEMS:
Chemicals found in on-site waste pile were found to contain elevated
levels of arsenic. lead. mercury. hexachlorocyclohexanes and DDT.
Some of these substances have also been detected in groundwater and
surface water samples in excess of the NYS Groundwater Standards.
Groundwater is used as a primary source of drinking water in the
vicinity of the site. DOH has sampled residential wells in the
vicinity and no contaminants in excess of State drinking water
standards were detected. Site access and potential exposure to
contaminated surface water runoff from the site on Dublin Road was
restricted QY construction of a fence.
Page 8
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