United States
           Environmental Protection
           Agency
              Office of
              Emergency and
              Remedial Response
E PA/ROD/R02-89/083
September 1989
&EPA
Superfund
Record of Decision
           SMS Instruments, NY

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50272-101
 REPORT DOCUMENTATION
        PAGE
1. REPORT NO.
     EPA/ROD/R02-89/083
                                           X Recipient1 • Accession No.
 4. Tide and Subtitle
 '  SUPERFUND  RECORD OF DECISION
J       Instruments  (Deer  Park) ,  NY
      st Remedial Action	
      r(«) '
                                           S. Report Date-
                                             09/29/89
                                                                    a. Performing Organization Rept No.
 9. Performing Organization Nam* and Address
                                                                    10. ProjscVTaak/Work Unit No.
                                                                    11. Contract(C) or Gr*nt(G) No.

                                                                    (C)

                                                                    (G)
 12. Sponsoring Organization Nama and Addrma
   U.S.  Environmental  Protection Agency
   401 M Street, S.W.
   Washington, D.C.  20460
                                           13. Typa o< Report ft Period Covered

                                               800/000
                                                                    14.
 IS. Supplementary Note!
 16. Abstract (Limit: 200 worda)
  The 1.5-acre  SMS Instruments  site is in a  light industrial and residential area of Deer
 Park,  Suffolk  County, New York.   Since 1967  the site has  been operated  as  an industrial
 facility which overhauls military aircraft  components.  Past waste disposal practices
 included discharging untreated wastewater from degreasing and other refurbishing
 operations to  an underground leaching pool.   In 1980 the  site owner removed 800 gallons
     VOC- and metal-contaminated wastewater from the pool,  and subsequently  filled it with
     d and sealed all drain pipes.  In 1981 the county required the site owner to leak test
   "6,000 gallon underground  storage tank  (UST)  used to  store jet fuel.   Because tests
 indicated leakage,  the tank was emptied and,  in 1988,  was excavated and removed. This
 Record of Decision represents  the first of  two operable units at the site  and addresses
 ground water and soil contamination.  Source areas include the former UST  area, the
 leaching pool,  and spill areas where wastes  were formerly stored in drums.  A subsequent
 operable unit  will investigate suspected sources of upgradient contamination.  The
 primary contaminants of concern affecting the soil and ground water are VOCs including
 PCE,  TCE, and  xylenes; and  metals including  chromium and  lead.

  The selected  remedial action  for this site  includes treating approximately 1,250 cubic
 yards of soil  using in situ steam stripping  or air stripping depending  on  the results  of
 a planned treatabilitv study;  and around water Dumping and (Continued on next oaae)	
 17. Document Analyeis a. Descriptors
   Record of Decision - SMS  Instruments  (Deer Park), NY
   First Remedial Action
   Contaminated  Media: soil, gw
   Key Contaminants:  VOCs  (PCE,  TCE, xylenes),  metals  (chromium, lead)
   b. (dentifiera/Open-Endsd Terms
   C. COSATI RoM/Group
    .vsilaoilty Statsnwnt
                            18. Sscurtty Oaas (This Rsport)
                                   None
                                                      20. Secutty CUss (This Psgs)
                                                     	None	
21. No. o< Pages
  98
                                                                                22. Pries
(See ANS*-Z39.18)
                                      See Instruction* an Aenrse
                                                      OPTIONAL FORM 272 (4-77)
                                                      (Formerly NTIS-3S)
                                                      Department o< Commerce

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 EPA/ROD/R02-89/083
 SMS Instruments  (Deer Park), NY
1
     Abstract  (Continued)
  eatment using air stripping followed by reinjection through onsite wells.   The
contingency plan for soil remediation includes excavation and offsite incineration of
contaminated soil.  The estimated present worth cost for the selected remedial action is
$1,195,800, which includes an annual present worth O&M cost of $437,576.

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              DECLARATION FOR THE RECORD OF DECISION

 SITE  NAME AND LOCATION

-SMS Instruments,  Deer Park,  Suffolk County, New York

 STATEMENT OF BASIS  AND PURPOSE

 This  decision document presents  the selected  remedial action  for
 the SMS  Instruments site,  chosen in accordance with the
 Comprehensive Environmental  Response,  Compensation and Liability
 Act,  42  USC §9601,  et seq.,  and,  to the  extent applicable, the
 National Contingency Plan, 40 CFR Part 300.   This decision is
 based on the administrative  record for the  site.  The attached
 index identifies  the items that  comprise the  administrative
 record upon which the selection  of the remedial action is based.

 The State of New  York concurs on the selected remedy.

 ASSESSMENT OF THE SITE

 Actual or threatened releases of hazardous  substances from this
 site,  if not addressed by  implementing the  .response action
 selected in this  Record of Decision (ROD),  may present an
 imminent and substantial endangerment to public health or the
 environment.


 DESCRIPTION OF THE  SELECTED  REMEDY

 This  operable unit  represents the first  of  two planned for the
 site.  The remedy presented  in this document  addresses the
 treatment of the  contaminated groundwater and soils at the SMS
 Instruments site.  The second operable unit will  investigate
 suspected sources of upgradient  contamination.

 The major components of the  selected remedy include:

         - In situ steam or air stripping of the contaminated
           soil, approximately 1250 cubic yards;

         - Groundwater extraction, treatment and reinjection,  to
           restore the aquifer to cleanup levels identified in the
           decision  summary.

 Treatability studies will  be undertaken  to  confirm  the
 effectiveness of  the in situ steam stripping  technology  in
 treating the contaminated  soils.   If these  studies  indicate that
 the steam (or air)  stripping of  the soil is ineffective, a
 contingency remedy  involving the removal and  offsite  incineration
 of the contaminated soil will be implemented.

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STATUTORY DETERMINATIONS

Both the selected remedy and the contingency remedy are
protective of human health and the environment and are cost-
effective.  The total remedial action, consisting of both this
first operable unit and a future second operable unit, when fully
completed will comply with Federal and State requirements that
are legally applicable or relevant and appropriate.  Both the
selected remedy and the contingency remedy utilize permanent
solutions and alternative treatment technologies to the maximum
extent practicable and satisfy the statutory preference for
remedies that employ treatment  that reduce toxicity, mobility,
or volume as a principal element.  Due to the existence of an
upgradient source area, the selected remedy, by itself, will not
meet chemical-specific ARARs or be capable of restoring the area
ground water to applicable ground water quality standards until
that upgradient source area is removed.  The upgradient source
area will be addressed as part of the second operable unit.
Although the remedial action selected, the first operable unit,
will not meet chemical-specific ARARs, it is only part of a total
remedial action that will attain clean-up levels when fully
completed.  In the event the second operable unit fails to
identify or control the source area, a waiver for technical
impracticability will be sought.

The need for conducting a five-year review will be evaluated upon
completion of the second operable unit.
William J.MuszynsJd/^.E.                      Date
Acting Regional Administrator

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              DECISION SUMMARY




            SMS INSTRUMENTS, INC.




             DEER PARK,  NEW YORK
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY




                  REGION II




                   NEW YORK

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                        TABLE OF CONTENTS
SECTION

  I. Site Location and Description	
 II. Site History and Enforcement Activities,
III. Highlights of Community Participation...
 IV. Scope and Role of Operable Unit Within
            Site Strategy	,
   V. Site Characteristics	
  VI. Summary of Site Risks	,
 VII. Description of Alternatives	,
VIII. Summary of Comparative Analysis
          of Alternatives	
  IX. Selected Remedy	
   X. Statutory Determinations	
  XI. Documentation of Significant Changes..
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ATTACHMENTS

Appendix I
Appendix II
Appendix III
Appendix IV
Appendix V
Figures
Tables
Administrative Record Index
NYSDEC Letter of Concurrence
Responsiveness Summary

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SITE LOCATION AND DESCRIPTION

The SMS Instruments site is located at 120 Marcus Boulevard, Deer
Park, in Suffolk County, New York,  as shown in Figure 1.   It is
located in a light industrial and residential area of Deer Park
and is an active industrial facility that consists of a 34,000
square-foot (ft )  building  on a 1.5-acre  lot.  About  90%  of the
lot is paved with asphalt.   The immediate vicinity also includes
more than 50 industrial facilities within a one-mile radius, and
a large groundwater recharge basin located directly adjacent to
the SMS Instruments site on the east side (see Figure 2).  The
site is located in the recharge zone of the Magothy aquifer, a
sole-source aquifer for Long Island, which is the only source of
drinking water for the surrounding residential population,
estimated to be more than 124,000 persons.

All residents are supplied with public water and the use of
private wells for potable water is not necessary at the present
time.  If any residents in the vicinity of the site choose to
maintain private wells, it is believed that they do so for
irrigation purposes and not as a source of drinking water. The
nearest public well is located approximately one mile southwest
and downgradient from the site.

Three sources of groundwater and soil contamination were found at
the SMS Instruments site.  The first major source is industrial
waste generated from degreasing and other metal refurbishing
operations.  These wastes were routinely discharged to a leaching
pool on the south side of the building.  The leaching pool was
pumped out, filled with sand, and sealed in 1983.  The other
source was a 6,000-gallon (gal)  underground storage tank (UST)
used for storage of jet fuel until 1981.  The UST was removed
from the site by SMS Instruments on February 17, 1988, during the
Remedial Investigation  (RI).  Another source of surface soil
contamination was documented from spillage and from leaking waste
drums stored in the back lot of the property, east of the
building.


SITE HISTORY AND ENFORCEMENT ACTIVITIES

Operations on the site started in early 1967 when Mr. Sol
Schusheim rented the property from Marcus Associates of
Farmingdale, New York.  On September 21, 1973, Mr. Schusheim
purchased SMS Instruments,  Inc.,  from Ogden Technology and, later
that year, purchased the property at 120 Marcus Boulevard in Deer
Park.  Mr. Schusheim still owns and operates the SMS Instruments
facility.

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The primary operation at the site has been the overhauling of
military aircraft components.  Overhauling operations include
cleaning, painting, degreasing, refurbishing, metal machining,
and testing.  These operations required the generation, storage,
and disposal of hazardous waste as well as the purchase, storage,
and use of new chemical products.  New chemical products are
currently transported to the site by truck in 55-gal drums and
stored outside in an enclosed area on the east side of the
property.  Several incidents of waste drum leakage were noted
from 1976 to 1980 prior to construction of the enclosed drum
storage area in 1981, according to Suffolk County Department of
Health Services (SCDHS) inspection reports.

Until January 1980, wastewater from rinsing and painting opera-
tions within the building was discharged directly without treat-
ment to the underground leaching pool on the south side of the
property (see Figure 2).  Samples collected from the leaching
pool by SCDHS in 1979 and 1980 revealed the presence of several
metals such as copper, chromium, lead, cadmium, silver, nickel
and zinc, as well as the presence of aromatic hydrocarbons such
as benzene (350 parts per billion (ppb)), toluene (3,200 ppb) and
xylene (12,000 ppb). Halogenated aliphatic hydrocarbons such as
1,1,1-trichloroethane  (2,380 ppb), trichloroethene (2,200 ppb),
and methylene chloride (200 ppb) were also found.

In February, 1980 the New York State Department of Environmental
Conservation (NYSDEC) required SMS to install five monitoring
wells on the site, discontinue the outside storage of drummed
waste, design an enclosed storage area and develop a hazardous
waste management plan for NYSDEC approval.

In August 1980, SMS was again notified by the State to obtain a
State Pollutant Discharge Elimination System (SPDES) permit for
the wastewater discharge to the leaching pool.

In May 1980, Chemical Pollution Control, Inc., removed about 800
gallons of waste from the leaching pool, filled the pool with
sand, and filled the discharge drains and pipes with concrete.
Currently, wastewater is drummed for offsite disposal.

SCDHS issued a notice to SMS Instruments to leak test the 6,000-
gallon UST.  The test, performed in 1981, showed leakage, and
SCDHS subsequently required the tank to be taken out of service.
The UST was emptied of all liquids in 1981, and the tank was
taken out of the ground in February, 1988.

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The site was referred to EPA on October 1984  by the NYSDEC.   SMS
Instruments is the only identified Potentially Responsible Party
(PRP) .   EPA sent an information request to the PRP on April  8,
1987.  On June 8, 1987 a notice letter was sent to the PRP.   The
site was proposed for the National Priorities List (NPL)  in
October 1984 and finalized in June 1986.   The remedial
investigation and feasibility study (RI/FS) was initiated in May
1987, and the field wcrk started in December  of that year.

HIGHLIGHTS OF COMMUNITY PARTICIPATION

The RI/FS and Proposed Plan Remedial Action for the SMS
Instruments site were released to the public  on July 10,  1989 and
July 14, 1989, respectively.  These two documents were made
available to the public, in both the administrative record and an
information repository maintained at the Deer Park, New York
Library.  A second information repository is  maintained at the
Babylon Town Hall.  The notice of availability for these two
documents was published in Newsday as well as in the Babylon
Beach Beacon.  A public comment period was held from July 10,
1989 to August 10, 1989.  In addition, a public meeting was held
on August 2, 1989.  At this meeting representatives from EPA and
the contractor Environmental Science and Engineering (ESE)
answered questions about problems at the site  and the remedial
alternatives under consideration.  A response to the comments
received during the comment period is included in the Responsive-
ness Summary, which is a part of this Record  of Decision  (ROD).
This decision document presents the selected  remedial action for
the SMS Instruments Site in Deer Park, New York, chosen in
accordance with the Comprehensive Environmental Response,
Compensation and Liability Act (CERCLA),  as amended by the
Superfund Amendments and Reauthorization Act  (SARA) and,  to the
extent practicable, the National Contingency Plan  (NCP).   The
decision for the site is based on the administrative record.

Public concern regarding the SMS Instruments  site was highest in
1984 when the site was first nominated by the State of New York
for inclusion on the NPL.  Several local newspaper articles
appeared in the spring of 1984 about the SMS  Instruments site and
other hazardous waste sites on Long Island that were proposed for
the NPL.  Community interviews were conducted about the same
period.  A public meeting was also held in December 1987.

SCOPE AND ROLE OF OPERABLE UNIT WITHIN SITE STRATEGY

This ROD addresses the first of two operable units planned for
the site.  It specifically addresses the major sources of
contamination at the SMS Instruments site, the leaching pool, the
UST area, and the drum storage area located at the vicinity of
the drum storage shed (see Figure 2) , as well as groundwater
contamination attributable to the site.  The major areas of soil
contamination are considered collectively, since 1) the areas are

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within 60  feet of one another, 2) the major contaminants of
concern in all areas are volatile organic compounds, and 3) the
remedial alternatives addressing these areas are similar.  The
contaminated soil and groundwater at the site are addressed as
one operable unit since the organic contamination is migrating
directly from the unsaturated soil into groundwater which
migrates to potential receptors offsite.

Since offsite contamination, upgradient of the SMS Instruments
site, is suspected to be contributing to the groundwater con-
tamination at the site, a second operable unit will be initiated
to investigate those sources and alternatives for their
remediation.

SITE CHARACTERISTICS

The results of the investigation conducted by EPA at the site are
discussed  in detail in the RI/FS documents.  It describes the
nature and extent of contaminants in onsite surface soils,
subsurface soils, and in onsite and offsite groundwater.  The
highest concentration of contaminants was found in the leaching
pool, underground storage tank, and in the drum storage area, as
shown in Figure 2.  As shown in Table I, for groundwater the most
prevalent  volatile organic chemical (VOC) was trichloroethene at
a maximum  concentration of 24,000 ppb.

This was the highest level of contamination found in the ground-
water onsite.  Other prevalent VOC's included xylenes (2,200
ppb) , ethylbenzene (240 ppb) and chlorobenzene (670 ppb).
Samples from upgradient offsite monitoring wells showed a maximum
level of 14 ppb of trichloroethene (monitoring well location MW-
09) and from downgradient offsite wells  (monitoring well location
MW-13) a maximum level of 60 ppb of trichloroethene.  The upper
glacial aquifer is classified lib (federal classification) and GA
(NYSDEC classification), i.e. a potential source of drinking
water.  The groundwater flow is in a southerly direction.

Table I shows also contamination levels  found in surface as well
as subsurface soil.  The highest level detected was 1,200,000 ppb
of xylene  found in the subsurface soil near the leaching pool
(sample location BH-16).  Subsurface soil in the same vicinity
showed a maximum level of contamination  of 340,000 ppb of
chlorobenzene.  A high contaminant level of 10,000 ppb of
volatile organics was found in subsurface soil samples in the
vicinity of the underground tank storage area as well as a high
of 1,000,000 ppb xylenes.  A surface sample from the drum storage
area showed a maximum level of 16,000 ppb of trichloroethene.
All sample locations are shown in Figure 3.  Locations of the
offsite monitoring wells are shown in Figure 4.  Contaminant
levels detected in various media are shown in Table I.  The
surface and subsurface soil at the site  is classified as a RCRA
hazardous  waste.

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SUMMARY OF SITE RISKS

The results of the exposure and risk evaluations for the SMS
Instruments site indicate a potential for adverse health impacts
by the contaminants present only for the potable groundwater use
scenario.  Health risks associated with nonpotable use of ground-
water for all current and future scenarios are below EPA accept-
able levels.  Table II presents a summary of carcinogenic risks
and noncarcinogenic hazard levels for the SMS Instruments site.

Potential concern for noncarcinogenic effects of a single medium
is expressed as the hazard quotient (HQ) - or the ratio of the
estimated intake derived from the contaminant concentration in a
given medium to the contaminant's reference dose.  By adding the
HQs for all contaminants within a medium or across all media to
which a given population may reasonably be exposed, the Hazard
Index (HI) can be generated.  The HI provides a useful reference
point for gauging the potential significance of multiple
contaminants exposures within a single medium or across media.
EPA considers an HI of one or more to be an unacceptable risk to
human health.

Excess lifetime cancer risks are determined by multiplying the
intake level by the cancer potency factor.  These risks are
generally expressed in scientific notation, (e.g. IxlO"6.  An
excess lifetime cancer risk of IxlO"6 indicates that, as a
plausible upper bound, an individual has a one in a million
chance of developing cancer as a result of site-related exposure
to a carcinogen over a 70-year lifetime under the specific
exposure conditions at a site.  EPA has determined that a risk
range of 10" to 10   is generally protective of human health.
EPA also uses a risk level of 10"6 as a point of departure,  i.e.
a goal for site remediation.

Groundwater use from nonpotable private wells downgradient of SMS
Instruments does not appear to pose unacceptable health risks
under the exposure conditions considered and for the contaminants
present.  Carcinogenic risks resulting from occasionally drinking
water, dermal contact with water, and consumption of vegetables
irrigated with contaminated water are on the order of 10"7 to
10"  , which  is below the 10"6 point of departure risk level.  The
total noncarcinogenic health His are several orders of magnitude
lower than unity and indicate the low potential for adverse
health impacts.  Table II summarizes these risk indicators.

Potential use of groundwater downgradient from SMS Instruments
for a potable domestic water supply was evaluated in the risk
analysis as a hypothetical scenario.  While the presence of
private wells has been documented, all residents potentially
impacted by contaminated groundwater are assumed to be connected
to public water supply wells.  This pathway was developed to

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evaluate the threat to public health from this hypothetical use.
Noncarcinogenic health His for potable use of groundwater are
6.86 x 10"1 and 8.55 x 10  , using measured  and modeled data,
respectively.  However, estimated cancer risks of 2.27 x 10"5 and
1.34 x 10  were calculated for the measured and modeled data,
respectively.  The contaminants used to determine this were
trans 1,2 dichloroethene, tetrachloroethene, and trichloroethene
because they are among the most toxic components and, thus,
represent the worst case scenario.  These estimates indicate that
potable use of groundwater may pose an unacceptable health risk
to offsite residents.  In addition, the measured and predicted
exposure point concentrations of trans-l,2-dichloroethene,
tetrachloroethene, and trichloroethene exceed the available
applicable or relevant and appropriate requirements  (ARARs), as
shown in Table I, for drinking water use.

This evaluation suggests that some type of remedial action is
warranted if residents in the affected area were to use water
from private wells for potable purposes.  Since the SMS site is
located over a deep recharge zone, the potential for cross-
contamination of the aquifer is very real.  This suggests that
action is necessary in order to protect residents from consump-
tion of potable water from the Magothy Aquifer, which is the
primary source of drinking water.  Therefore, protective measures
should be implemented.

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 or the environment.

DESCRIPTION OF ALTERNATIVES

Two media-specific remedial actions are required to protect human
health and the environment because of the nature of contamination
at the SMS Instruments site.  Soil has been determined to be a
source of contamination.  Contaminants transfer from the un-
saturated soil to groundwater.  Once in the groundwater, the
contaminants, under the influence of the groundwater gradient,
migrate from the site to potential receptors.

Specific remedial action objectives for this site include:

Groundwater - Restoration of groundwater quality to its intend-
ed use (class lib and GA-potential source of drinking water) by
reducing contaminant levels below State and Federal drinking
water standards where possible (See Table I).  In the case where
upgradient contributions prohibit such restoration for a
particular compound, the contaminant level will be reduced to the
upgradient level.

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Soil - In order for the soil not to be a contributor to ground-
water contamination, the degree to which the contaminants have to
be reduced is different for each component.   For the components
of interest, however, the contaminants such  as trichloroethylene,
xylenes, tetrachloroethylene and 1,2 trans dichloroethylene have
to be reduced below 10 ppb.  These contaminants are considered to
be the most mobile and most toxic.

The alternatives considered are presented below:

Migration Management

          Alternative la:  No Action   (source untreated)
          Alternative lb:  No Action   (source treated)

          Alternative 2a;  Groundwater Extraction,  Treatment and
                           Discharge   (source untreated)
          Alternative 2b:  Groundwater Extraction,  Treatment and
                           Reinjection  (source treated)

Source Control

          Alternative 3:  No Action
          Alternative 4a: Source Removal and Offsite Disposal
          Alternative 4b: Source Removal and Offsite Incineration
          Alternative 5:  Low Temperature Soil Stripping
          Alternative 6:  In Situ Steam Treatment
The costs for the alternatives considered are shown in Table III.


Migration Management Alternatives

Two management of migration alternatives are discussed: a no
action alternative and a groundwater treatment alternative.
Since the source of contamination (i.e., soil) directly impacts
the extent of contamination in the ground water, the actual
implementation of these alternatives will vary depending on
whether or not the source of contamination is remedied.  Two
areas of implementation that are significantly impacted are the
location and means of discharging the treated groundwater, and
the time required to remediate the groundwater (restoration time
frame).

Therefore, the management of migration alternatives were evalu-
ated under two scenarios, the first one (a)  assumes that the
source has not been remedied while the second one (b)  assumes
that the source has been remedied by any one of the source
control remedies (alternatives 4-6).

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Alternative la;  No Action  (source untreated)

The no-action alternative is required by the National Contingency
Plan  (NCP) to be considered through the detailed analysis.  It
provides a baseline for comparison of other alternatives.
No remedial action will be implemented under this alternative.  A
long-term monitoring program to provide information on the extent
of contaminant migration over time will be conducted.  Five wells
will be monitored semiannually for volatiles, semivolatiles, and
various metals.  This action involves the implementation of
institutional controls for water use restrictions to prevent the
use of the contaminated groundwater as a potable water source.
These controls would be imposed on any residences or businesses
up to one-half mile downgradient of the site that may be poten-
tial receptors.  A capital cost of $70,400 will be required and
the annual operation and maintenance (O&M) cost will be $13,600.
The periodic cost, which consists of monitoring and reviewing the
performance of the unit and also evaluating the public health
risk every five years, is evaluated at $7,500.  The restoration
time frame will be of a very long duration, probably more than 20
years.

Alternative Ib:  No Action  (source treated)

This alternative is the same as Alternative la, except that the
source will be treated by one of the four alternatives, 4a, 4b, 5
or 6.  This is significant in that the restoration time frame
will be reduced by approximately 10 years.

Alternative 2a; Groundwater Extraction. Treatment, and Discharge
                (source untreated)

An extraction well will capture the plume of contaminated ground-
water emanating from the SMS Instruments site.  Using the average
hydraulic conductivity obtained from slug tests performed during
the RI, a pumping rate of 500 gpm was estimated to capture the
contaminant plume.  The approximate location of the extraction
well is on the right-of-way of Commack Road, as shown in Figure
5. The location was selected based on the plot of the contaminant
plume generated from the computer modeling conducted in the RI.
The extracted groundwater will be conveyed under pressure via an
underground pipe installed in the road right-of-way.  The
pressurized main consisting of an 8-inch polyvinyl chloride (PVC)
pipe will deliver the groundwater to the treatment system at the
location shown in Figure 6.  A computer model was used to size an
air stripping treatment system.

The conceptual design of this system is based upon representative
concentrations of contaminants in the ground water as determined
during the RI.  Two air stripping towers handling 250 gpm each
with packing depths of 15.5 ft were selected to reduce the

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influent concentrations of volatiles to less than the selected
chemical-specific ARAR values listed in Table I and to include
also surface water and State Pollutant Discharge Elimination
System (SPDES) discharge requirements.  The water from the air
stripping system will then be filtered using multimedia deep bed
filters to remove iron, as well as other suspended solids.  Iron
will be removed to meet action-specific ARARs for surface water
discharge.  The groundwater will then be discharged to surface
water.  The closest surface water is at Birchwood Park which is
approximately one half mile southeast of the site.  A schematic
of an air stripper is shown in Figure 7.  In addition, air
emissions from the air stripper will be treated using a carbon
system.

The capital cost for the project will be $544,100 and the annual
O&M will be $128,200.  A periodic cost of $7,500 will be also re-
quired. Residual filters will be treated as hazardous waste and
will be disposed of accordingly.  The estimated timeframe to
restore the aquifer to action levels is 12 years.

Alternative 2b: Groundwater Extraction. Treatment and Reinfection
                (source treated)

This alternative is the same as alternative 2a, except that the
source will be treated by one of the four alternatives: 4a, 4b,
5, or 6 and the groundwater will be reinjected through wells
located onsite below NYS groundwater injection standards.  The
restoration time frame is thereby significantly reduced and is
estimated to take 4 years.  The costs for this alternative are
$365,300 for capital cost, $123,400 for annual O&M and $7,500 for
periodic costs.

Source Control Alternatives

Alternative 3; Source Control — No Action

This no action alternative was developed for source control
measures.  Implementation of this alternative is achieved by
incorporating monitoring and land use/deed restrictions on the
site proper.  The elements necessary for this implementation
alternative are:
     o    Installation of monitoring wells,
     o    Obtaining land use and deed restrictions,
     o    Periodic sampling of groundwater from monitoring wells,
     o    Periodic subsurface soil sampling,
     o    Patching and sealing of asphalt pavement above source
          areas, and
     o    Five-year review of the site conditions.

Costs are approximately the same as alternative la.

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                                10


Alternative 4a; Source Removal and Offsite Disposal

This alternative involves the excavation and offsite disposal of
the contaminated soil present at the former leaching pool and UST
areas.  Approximately 1,250 cubic yards (yd3)  of soil,  involving
an area of 1700 square feet by 20 feet deep, contaminated with
volatile and semivolatile organics will be excavated and then
transported to an offsite RCRA-permitted landfill for disposal.
The estimated quantity of soil requiring treatment will be
refined during the remedial design and will include additional
soil from the drum storage area.  Action levels in the soil will
be met by reducing the VOC contamination to 10 ppb.  Prior to
excavation of the contaminated soil, the existing pavement will
be removed.  The pavement would then be loaded into covered
trucks and transported to a debris landfill for disposal.  If
necessary, the pavement will be decontaminated before being
transported to an offsite RCRA-permitted landfill.  It is also
anticipated that a small quantity of soil will need to be ex-
cavated from the drum storage area.

If this remedy can be implemented prior to November 1990, no
treatment of the soil will be required prior to disposal.
However, after that date the soil must be treated before disposal
to comply with the RCRA land disposal restriction.  The capital
cost for this alternative is $520,200 and the actual excavation
work is expected to take approximately 30 days.

Alternative 4b: Source Removal and Offsite Incineration

This alternative involves the same excavation of contaminated
soil described in Alternative 4a.  Once the contaminated soil is
excavated, it will be placed in fiber drums.  Each fiber drum
will be filled with approximately 300 Ibs. of contaminated soil.
The drums will be loaded onto trucks and transported to an
offsite incinerator.  For costing purposes, it is assumed that an
incinerator in Bridgeport, Logan Township, New Jersey will be
used.  The excavated areas will be then filled with clean soil.
The soil will be treated to comply with the land disposal re-
strictons.  The capital cost for this alternative is estimated to
be $2,036,500 and the actual construction time is the same as
alternative 4a (30 days).

Alternative 5: Low Temperature Soil Stripping

In this alternative, contaminated soil would be excavated accord-
ing to the procedures previously outlined and then stockpiled in
an area adjacent to the thermal treatment unit for feeding into a
screen to remove oversize (+2 inch) material and debris.  Screen-
ed material will then be transported by a conveyor to a hopper
that directly feeds the thermal processor.  After processing, the
soil would be transferred by enclosed screw conveyors for use

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                               11

onsite as backfill.  The vaporized contaminants  could either be
destroyed through a secondary high-temperature combuster or
collected through condensate or adsorbed  onto activated carbon.
Stack emissions would be monitored to verify that they were in
compliance with Federal and State regulations, including those
for volatile organic compounds (VOCs), hydrogen  chloride (HCL) ,
carbon monoxide (CO) and particulates. Prior to returning the
treated soil it must be tested using the  Toxicity Characteristic
Leaching Procedure (TCLP)  to ensure that  land disposal treatment
levels are met.  At this point in time, it cannot be determined
whether these levels can be met.   If levels cannot be met, a
treatability variance may be required. Unless the material is
delisted (i.e., certified as non-hazardous), the material would
have to be covered in accordance with landfill closure require-
ments.  Monitoring would also be required.  A treatability study
will be required for this alternative. Capital  costs are
estimated to be $629,800,  and annual O&M  at $14,100.  Time
required for onsite construction and treatment activities is less
than 90 days.

Alternative 6; In Situ Steam Stripping

A typical in situ steam stripping system  involves the introduc-
tion of steam into the contaminated soils followed by air and
vapor extraction in a vacuum.  In Figure  8, a typical schematic
of an in situ stripping setup is shown.  The injection wells and
the extraction wells are separately manifolded.   An air and steam
mixture is introduced into the contaminated soil and a vacuum
extraction pump provides the necessary pressure  difference to
insure the passage of the mixture through the soil.  The conden-
sate is separated from the vapor in a treatment  unit and the air
is further treated by means of a carbon filter.   Spent carbon
from the treatment unit, as well as the condensate, would be
treated/disposed as hazardous waste.  Due to the proximity of the
locations of contaminated soil (UST, leaching pool and storage
drum areas), one common aboveground injection system, extraction
system, and vapor phase separation system will be used.  After
organic emissions rates have decreased to negligible levels, soil
samples would be collected to confirm that soil  contaminant-
specific action levels have been met.  Upon completion of the in
situ steam stripping operations,  all equipment would be decon-
taminated and removed from the site.  Wastes generated during
decontamination would be collected and transported to a licensed
facility for treatment/disposal.

The condition of the soil at the SMS site (homogeneity, high
porosity, absence of clays) lends itself ideally to steam stripp-
ing.  A study at a superfund site in San Jose, California, con-
ducted by the University of California at Berkeley, showed that
the organics in the soil were reduced by as much as 99.3%, at a
faster rate than air (alone) stripping.  It is estimated that
this procedure would reduce the contaminant levels in the soil by

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                                12

more than 99%.  If this is the case, it will result in an average
soil contaminant level of less than 10 ppb for all contaminants
of concern.  A treatability study will be conducted to establish
different process variables such as steam and air ratio,  tempera-
tures and pressures, for a successful implementation of this
alternative.  It should be made clear that if any difficulties
are encountered, the same equipment can be used to treat the soil
with air only.  The latter one, although innovative, is a proven
technology and has been used with success during actual field
remediation.  The capital cost for this alternative is $353,200.
The time required to construct and treat the contaminated soils
is approximately five months.  Using air only will result in a
similar, but lower, capital cost but will require three to six
months longer to complete the remediation.


SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES

The alternatives were evaluated based on the following nine
criteria:

      - Overall protection of human health and the environment;
      - Compliance with all federal and state applicable or
        relevant and appropriate requirements (ARARs);
      - Long-term effectiveness and permanence;
      - Short-term effectiveness;
      - Reduction of toxicity, mobility, or volume of
         contaminants;
      - Implementability;
      - Cost;
      - Community acceptance; and,
      - State acceptance.

A summary of the relative performance of the alternatives with
respect to each of the nine criteria is provided in the next
section.


1. Overall Protection of Human Health and the Environment

a) Migration Management

All Migration Management alternatives are considered to be
protective over the long term; however, both groundwater extrac-
tion and treatment alternatives afford greater protection should
the ground water ever be used for potable purposes.  Alternative
2b provides the highest overall protection to human health and
the environment in the shortest period of time (4 yrs.) versus no
action which would require more than 20 years for action levels
to be achieved through natural attenuation.

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                               13
b) Source Control

All the source control alternatives are considered to be protec-
tive of human health and the environment.   Alternatives 4a,  4b,
5, and 6, in that order, are considered protective since they
remove and destroy the contaminants at the SMS Instruments site.
Alternatives 4a, 4b, 5 and 6,  in that order,  are considered
protective since they remove and destroy the  contaminants at the
SMS Instruments site.  Alternatives 4a, 4b, and 6 would not
require any long term maintenance or deed restrictions.  Alterna-
tive 5 would require some monitoring and maintenance, as required
under landfill closure.  Alternative 3 does not provide any
additional level of protection above that defined in the baseline
risk assessment.  This alternative would require that the level
of protection be maintained by preventing future activities at
the site, such as excavations, which may cause worker exposure.

2. Compliance with ARARs

a) Migration Management

None of the alternatives will achieve all chemical-specific ARARs
for groundwater rated lib, potential drinking water, unless off-
site upgradient sources are removed.  Although the selected
remedial action for the first operable unit will not meet
chemical-specific ARARs, it is only part of a total remedial
action that will attain such clean-up levels  when fully com-
pleted.  A second operable unit will be conducted in an attempt
to identify upgradient sources of contamination.  In the event
the second operable unit fails to identify or control upgradient
sources, a waiver for technical impracticability (under SARA
section 12(d)4(C)) will be sought.

Until the time that upgradient contributions  can be treated,
cleanup levels for trichloroethylene (TCE), 1,1 dichloroethane,
trans 1,2 dichloroethane, and 1,1,1 trichloroethane will be set
at the upgradient levels, as determined from  additional
monitoring to be conducted during the remedial design and/or
remedial action.  The treatment unit discharge will meet all
ARARs.  Air emissions from the air stripper will also be treated
to meet all ARARs.

b) Source Control

There are no chemical-specific ARARs applicable for soils.  All
alternatives, except no action, will meet action specific ARARs
if performed prior to November 1990.  After that date only
alternatives 4b and 6 will meet ARARs.  Alternative 4a could not
be implemented due to land disposal restrictions.  Alternative  5
will require that treated soil be tested using Toxicity Charac-
teristic Leaching Procedure (TCLP), prior to  backfilling, to

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                                14

insure that land disposal levels are met.  At this point in time,
it cannot be determined whether these levels can be met.  If
levels cannot be met, a treatability variance may be required.

3. Long-Term Effectiveness

a) Migration Management

Alternative 2b, groundwater and source remediation, will.provide
the greatest protection to the community, since it removes and/or
treats all contamination at the site.  Alternative 2a is less
effective, since it leaves the source untreated and would require
land use restrictions onsite in order to be protective.  Similar-
ly, under alternatives la and Ib, if groundwater and land use
restrictions are completely implemented and enforced, these
alternatives will be effective in protecting public health and
the environment, since no receptor or exposure points will exist.
However, the upper aquifer will be restored only by natural
attenuation, a process which will take over 20 years to reach
action levels, according to results obtained from groundwater
modeling.

b) Source Control.

Alternatives 4a, 4b, 5 and 6 remove contaminants from the site
and do not leave any untreated waste.  Alternatives 4a, 4b and 6
do not leave any residuals that require managing to ensure an
adequate level of protection.  Alternative 3, however, leaves the
contaminants in place and requires management beyond the im-
plementation phase to monitor the remaining level of risk, as
well as maintenance of the asphalt cover.  Alternative 5 would
also require some post closure care to comply with landfill
closure requirements.

4. Short-Term Effectiveness

a) Migration Management

Alternative 2b, groundwater and source remediation, will achieve
action levels protection for the community in four years.
Alternatives 2a wll take ten years to achieve action levels due
to the lack of source control measures.  Both alternatives create
potentially new migration and exposure pathways by extracting
groundwater, but the remedial treatment processes are considered
to keep the risk of exposure below significant levels.
Alternatives la and Ib, the no action alternatives, will take
significantly longer, e.g., twenty years or more, to achieve
action levels.  There are no risks involved during
implementation, since no action would be taken.

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                               15

b) Source Control

Alternatives 4a, 4b, 5 and 6,  the source removal/treatment
alternatives, may potentially increase the risk to the community
during their implementation because they extract contaminants and
create new potential exposure routes not identified in the
baseline risk assessment.   Proper safety procedures and onsite
monitoring, however, are expected to ensure that the community is
not subjected to any significant risk from exposure to the
contaminants.  Alternative 6 will have the least negative impact
on the community during implementation, since it will be con-
ducted in situ.  Similarly, alternative 5 will be conducted
onsite and will have minimal impact on the outside community.
The community will also be impacted to a minor degree by truck
traffic.  The truck traffic for Alternatives 4a and 4b has been
estimated to be 10 trucks per day for approximately 20 days.


5. Reduction of Toxicity.  Mobility, or Volume of Contaminants

a) Migration Management

Alternatives 2a and 2b, groundwater remediation, will reduce the
toxicity of contaminated groundwater by removing the contaminants
and adsorbing them on activated carbon.  The mobility of con-
taminated groundwater will be reduced to the area influenced by
the extraction well.  In Alternative 2a, as well as Alternative
2b, the treatment unit will be provided with air controls to
eliminate the migration of contaminants to the atmosphere even
though the air emissions are expected to be minimal, less than 1
Ib. per day.  The filtered solids and the activated carbon in the
treatment unit during remediation will be considered hazardous
waste and disposed of accordingly.

Alternatives la and Ib, on the other hand, will not afford any
reduction in the mobility, toxicity, or volume of contaminated
groundwater.

b) Source Control

Alternative 4b, excavation and offsite incineration, will provide
the greatest degree of destruction of contaminants and,
therefore, the greatest degree of reduction of toxicity,
mobility, and volume.  Alternative 5 will provide the same or
very close to the same reduction as Alternative 4b.  Alternative
4b will produce ash that will require disposal.  Alternative 6
will not provide as great a degree of contaminant destruction or
reduction in contaminant mobility as alternatives 4b and 5.
However, it is expected to provide an adequate degree of
contaminant destruction and be protective of human health and the
environment.  Alternative 3 does nothing to reduce the mobility,

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                                16

toxicity, or volume of contaminants, and Alternative 4a merely
transfers the problem elsewhere.

6. Implementability

a) Migration Management

All alternatives are technically feasible and relatively easy to
implement; however, each alternative requires a different amount
of time to construct or implement.  Alternative la requires the
least time to construct and implement, since only monitoring
wells need to be installed.  However, under alternative la, and,
to a lesser extent, alternatives 2a and Ib, in that order, it
will be difficult to enforce the administrative/institutional
controls, such as restrictions on new private wells development.
Similarly, alternatives 2a and 2b may present some implementation
problems.  For alternative 2a, the requisition of right-of-way
and/or easement for the piping network needed for groundwater
transport from the onsite treatment system to the discharge point
may be particularly difficult and complicated.  Both Alternatives
2a and 2b require installation of an offsite extraction well as
well as a piping network connecting this well to the onsite
treatment unit.

b) Source control

Of the source control alternatives, Alternatives 4a and 4b would
require the least time to implement.  Alternatives 3, 5 and 6 are
considered to take relatively the same amount of time to con-
struct and implement (i.e., 70 to 150 days).  Alternative 6 has
been implemented with success in a preliminary study conducted at
a proppsed Superfund Site near San Jose, California.  It is a
novel but very effective way for soil remediation and suited
ideally for the soil present at SMS Instruments.  Alternatives 5
and 6 would take more time to implement since both will require a
treatability study.  A potential difficulty for alternative 6
implementation may be the availability of the technology for this
process since it is a novel technology.  Should some difficulties
arise, the same equipment can be used for air stripping the soil,
which is a proven technology.

7. Cost

The present worth and capital costs for each alternative are
shown in Table III.

8. Community Acceptance

The community supports the preferred alternative (Alternatives 2b
and 6).  Community comments can be reviewed in the public meeting
transcript which is included in the administrative record.  A

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                               17

Responsiveness Summary which summarizes all comments received
during the public comment period is attached to this document.

9. State Acceptance

The State of New York, through the New York State Department of
Environmental Conservation (NYSDEC),  concurs with the selected
remedy.

THE SELECTED REMEDY

Based upon consideration of the requirements of CERCLA,  the
detailed analysis of alternatives, and public comments,  both EPA
and the State of New York have determined that a combination of
Alternative 2b, Groundwater Extraction, Treatment and Reinjec-
tion, and Alternative 6, In Situ Steam Stripping of the Con-
taminated Soil, is the most appropriate remedy for the SMS
Instruments Site in Deer Park, New York.

Approximately twelve hundred fifty (1250) cubic yards of
contaminated soil will be treated by in situ steam stripping.
VOCs will be removed by this treatment process to an average
level of approximately 10 ppb.  The actual VOC contaminant to be
utilized as an indicator and the appropriate clean up concentra-
tion will be determined during the treatability study.  The
groundwater will be remediated by extraction, treatment and
reinjection to meet either Federal or State drinking water levels
except in those cases where the upgradient concentration are
above such standards.  In such a case, the contamination will be
reduced to upgradient levels so as to eliminate any significant
contribution from the SMS site.  The treated groundwater will
meet all State and Federal drinking water standards prior to
reinjection.  This is the most protective alternative in terms of
the toxicity, mobility and volume reduction and for the
permanence and long-term effectiveness they achieve.  These
techniques would permanently reduce the contaminants of concern
at the site, such as volatile organic compounds in the soil as
well as in the ground water.  Groundwater remediation under this
alternative can be expected in 4 years, as opposed to more than
20 years for the no-action alternative  (la) and 15 years and 10
years for Alternatives 2a and Ib, respectively.

The estimated cost for the selected remediation alternative
(i.e., alternatives 2b and 6) is $1,195,800.  A detailed cost
summary of the selected remedy is shown in Tables IV and V.

A treatability study will be conducted during the design stage of
the remedy to ensure that the in situ steam stripping technology
can be utilized effectively.  Also, during design, additional
sampling will be conducted to further refine the treatment area
(i.e. those areas above the action levels specified in the FS)
and will include sampling in the former drum storage area.

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                                18


Should any problems arise with this technology, however,  one can
switch to soil stripping with hot air which is a variation of
this method and uses exactly the same equipment.  Soil stripping
with hot air, although innovative,  is a proven technology and has
been used in actual remediations.

Steam and air stripping are innovative technologies and require
treatability studies.  Since a certain degree of uncertainty
exists regarding the.implementability of these technologies, a
contingency plan for the remediation of the soils will be imple-
mented if the treatability studies indicate that these tech-
nologies would not be effective.  The contingency for soil
remediation is Alternative 4b, source removal and offsite in-
cineration.  Although more costly,  this alternative is fully
protective and will achieve the remedial goals specified in this
decision summary.


STATUTORY DETERMINATIONS

Under its legal authority, EPA's primary responsibility at Super-
fund sites is to undertake remedial actions that protect human
health and the environment.  When complete, the selected remedial
action for this site will comply with applicable or relevent and
appropriate  environmental standards established under Federal
and State environmental laws unless a statutory waiver is jus-
tified.  The selected remedy is cost effective and utilizes
permanent solutions and alternative treatment technologies or
resource recovery technologies to the maximum extent practicable.
Finally, the remedy employs treatment that permanently and
significantly reduces the volume, toxicity, or mobility of
hazardous wastes as its principal element.


Protection of Human Health and the Environment

The selected remedy and contingency remedy eliminate all
outstanding threats posed by the site.  Both reduce contamination
of site materials down to health based levels except in those
cases were the upgradient concentrations exceed these levels.  It
is assumed that the remedy for the 2nd operable unit will reduce
the upgradient contaminant concentrations.  Both the selected
remedy and the contingency remedy remove a continuing threat to
groundwater posed by the on-site contaminated soils.

Compliance with ARARs

At the completion of response actions, the selected remedy and
the contingency remedy will both have complied with the following
ARARs and considerations:

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                               19

Action-specific ARARs:

SDWA Maximum Contaminant Levels (40 CFR 141.11-141.16)  and 6
NYCRR Groundwater Quality Regulations (Part 703.5,  703.6, 703.7)
provide standards for toxic compounds for public drinking
systems.  The reinjection process for the treated groundwater
will meet underground injection well regulations by its status
as a Superfund remedial action under 40 CFR 147.  The extracted
groundwater will be treated to meet the above referenced drinking
water standards prior to reinjection.

Spent carbon from the ground water treatment system for removal
.of organics will be disposed of offsite, as well as any
treatment residuals, consistent with applicable RCRA land
disposal restrictions under 40 CFR 268.

The treatment unit will comply with the requirements of 40 CFR
Part 264, Subpart X (Miscellaneous Units).

If, after remediation, any hazardous waste constituents remaining
in the groundwater and soil are above health based standards,
then closure of the leaching pool under 40 CFR Part 264, Subpart
G and Section 264.228 of Subpart K will be applicable.

If it is determined that the contingency remedy will be
implemented, the remedy will comply with the following additional
ARARs:

              RCRA 40 CFR Part 263 - Standards Applicable to
              Transport of Hazardous Wastes

              RCRA 40 CFR Part 264 - Standards for Owners and
              Operators of Hazardous Waste Treatment, Storage,
              and Disposal Facilities

              6 NYCRR Part 372 - Hazardous Waste Manifest System
              & Related Standards for Generators, Transporters
              and Facilities

              6 NYCRR Subpart 373-2 - Final State Standards for
              Owners and Operators of Hazardous Waste Treatment,
              Storage, and Disposal Facilities

Chemical-specific ARARs:

Since the ground water at the site is classified as lib  (GA by
NYSDEC), drinking water standards are relevant and appropriate.
Again, these include, SWDA MCLs and 6NYCRR Groundwater Quality
Regulations.

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                                20

All air emissions will be in compliance with 6 NYCRR Parts 200,
201, 202, 211, 212 and 231.

Location-specific ARARs:

None applicable

Other Criteria, Advisories, or Guidance To Be Considered:

NY TOGS 2.1.2 and 1.1.1 provide standards for reinjection of
treated groundwater and are to be considered.


Cost Effectiveness

The selected remedy is cost effective because it provides overall
effectiveness proportional to its cost.  The present worth is
$1,195,800.  The estimated costs of the selected remedy are half
as much, as the soil incineration alternative; and, yet, it is as
effective in the long run for it provides a permanent solution by
significantly reducing the toxicity and mobility of the
contaminants.

Utilization of Permanent Solutions and Alternative Treatment
Technologies or Resource Recovery Technologies to the Maximum
Extent Possible

EPA has determined that the selected remedy, as well as the
contingency remedy, represent the maximum extent to which
permanent solutions and alternative treatment technologies can be
utilized in a cost effective manner for the SMS site.  This is
evident by the selection of in situ steam stripping, clearly an
innovative technology.  The selected remedy represents the best
balance of the nine evaluation criteria used to judge all
alternatives.

The groundwater treatment used in both the selected and
contingency remedies will reduce the contaminants of concern to
health protective levels prior to reinjection.  After treatment
is complete, the site will no longer be contributing contaminants
to the underlying aquifer.

Preference for Treatment as a Principal Element

By treating the VOC contaminated soils and groundwater via in
situ steam stripping and air stripping respectively, the selected
remedy addresses the principal threat posed by the site through
the use of treatment technologies.  Therefore, the statutory
preference for remedies that employ treatment as a principal
element is satisfied.

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                               21


DOCUMENTATION OF SIGNIFICANT CHANGES

The Proposed Plan for the SMS Instruments Site was released to
the public in July 1989.  The Proposed Plan identified
Alternative 2b and Alternative 6 as the preferred groundwater and
soil remedies, respectively.  EPA reviewed all comments submitted
during the public comment period.  Upon review of these comments,
it was determined that no significant changes to the selected
remedy, as it was originally identified in the Proposed Plan,
were necessary.  However, based on the public concern regarding
the innovative nature of Alternative 6, EPA has decided that
Alternative 4  (excavation and off-site thermal destruction)
should be added as a contingency remedy for soils treatment in
the event Alternative 6'is not effective.  The public was
confident that Alternative 6 would be effective and was
supportive of the contingency remedy concept.

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APPENDIX I




 FIGURES

-------
*tH III SMS CMc*
                                           WtST)
                                         /« we

                                     SCALE 1:24000
                                         8
     Figure 1


     SITE LOCATION MAP,  SMS INSTRUMENTS
     DEER PARK, NEW YORK
US ENVIRONMENTAL

PROTECTION AGENCY

-------
1
^t»4i*'i" *
• **
• *v
i
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i
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* i
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Figure 2
SITEDESCRIPTION, SMS INSTRUMENTS
DEE^VIRK, NEW YORK
GROUNDWATER RECHARGE
  ']  .'
   KEY

O  STORM DRAIN
®  SANITARY POOL
A  PREVIOUS WELL POINTS
. . FENCE
             US ENVIRONMENTAL
             PROTECTION AGE

-------
    , «£*••
 *<-%/'*
  »>&'c //
                                                                                                        •14
                      „, J/ ;'J
                    I/ •  JO
                    V
                                            ^Ji.
                                                 .. •Awl i
                                                                    V^ROUNDWATER RECHARGED
                                            •/  Pft/]B«n-\..'B 6,
                                            /  4&JhHi)->»'eiNl
                                            A   ^•'•-••f. *  .MW5
                                      "*     /   •»»   MweoV0 ,,o'
                                     	L	JH**5
                                                                                                             ~1 •-
(0
       SCALE
           60    100 FEET
                                                                              • MONITOR WELL (MW1 lo MW7)
                                                                              • BOREHOLE (BH9 lo BH20)
                                                                              O SURFACE SOIL SAMPLE (SS01  lo SS08)
                                                                              A SEDIMENT SAMPLE (SO)
                                                                              A SURFACE WATER SAMPLE (SWOl lo SW03)
Figure  3
ONSITE SAMPLE LOCATION MAP,
SMS INSTRUMENTS


SOURCE: E8E. KM.
                                                                                     US ENVIRONMENTAL
                                                                                     PROTECTION AGENCY

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                   MW-08 ... » MW.Q9
 • MONITOR WELLS MW-OS to MW-U
Figure  4
OFFSITE MONITOR WELL LOCATIONS,
SMS INSTRUMENTS
SOURCE: ESE. 1fU.
US  ENVIRONMENTAL
PROTECTION AGENCY

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                                                   TO TREATMENT 8Y8TEMIBE  FIGURE 7
                                                   --
                                                     PROPOSED PRESSURIZED
                                                     DELIVERY PIPE
          APPROXIMATE IMPACT AREA FOR
          PUBLIC NOTIFICATION AND EDUCATION
          AND WATER USE RESTRICTIONS
                                                     PROPOSED 8-INCH EXTRACTION WELL

                                                                 __     •  I

                                                      PROPOSED MOmTOR*WELLT£fi=c=^  BJrchw
Figure 5
LOCATION OF EXTRACTION WELL AND AREA IMPACTED BY
GROUNDWATER EXTRACTION ALTERNATIVE
US ENVIRONMENTAL
PROTECTION AGENCY

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                               INJECTION WELLS '
                                                                 LOCATION OF GROUNDWATER
                                                                 TREATMENT SYSTEM
                        .-M*   .-'   %     L
                               FROM EXTRACTION WELL
Figure 6
LOCATION OF QROUNDWATER TREATMENT
SYSTEM AND ONSITE DISCHARGE SYSTEM
US ENVIRONMENTAL
PROTECTION AGEN

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                                                                                          OFF GAS
                                                   AIR OUTLET
                     WATER INLET
                                  AIR INLET
EXTRACTION WELLS
                                                                      AIR FILTER
                                                              AIR STRIPPER
                                                        WATER OUTLET
                                                                                             WATER
                                                                                             FILTER
                                                                                                       REINJECTION WELLS

Figure 7
AIR STRIPPER SCHEMATIC

US ENVIRONMENTAL
PROTECTION AGENCY



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                                                                        r>—r_^
                                                                        L^^vl -*   ^ __ _
                                                                        7 Slotted Vertical Extraction Vent Pipe
                                                                        8 Slotted Vertical Injection Vent Pipe
                                                                        9 Extraction Air Sampling Port
                                                                       10 Extraction Air Flow Meter
                                                                       11 Exlraction Air Bypass Valve
                                                                       12 Vacuum Extraction Pump
                                                                       13 Vapor/Stparalion Treatment Unit
1 SUam Generator
2'Injection Air Bypass Valve
3 Injection Air Sampling Port
4 Injection Air Flow Meter
5 Extraction Manifold
6 Injection Manifold
Figure  8
TYPICAL SCHEMATIC OF \# SITU
STEAM STRIPPING APPARATUS
                                                     US  ENVIRONMENTAL
                                                     PROTECTION AGENCY

-------
APPENDIX




  TABLES

-------
                                                       Table 1
       Contamination and Concentrations Detected  in  Various Media at SMS instruments site


Contaminant
Volatiles
Trans-1,2
dicliioroethane
Tetrachloroethene
Tricliloroetliene
Total Xyienae
Ethylbenzene
Chiorobenzene
1, 1-Dichioroethane
Semi-Volatiles
1 , 4-Dichlorobenzene
1 , 3-Uichlorobenzene
1 , 2-Uichlorobenzene
Naphtheiene
Inorganics
Chromium
Lead
Media
Source Area
Soii
Surface Subsurface

	 1.500 (456)

540 (198) 6,500 (1,099)
16,000 (5,388) 51 (20)
1,500 (1,450) 1,200,000 (306,139)
720 (374) 150,000 (63,400)
	 340,000 (152,286)
	 	
	 330,000 (68,900)
	 , 64,000 (74,980)
98,000 (1) 1,800,000 (356,700)
	 16,000 (7,044)

16,000 (11,000) 52,000 (20,000)
50,000 (25,500) 7,900 (3,100)

Croundwater
Offsite***** Qnsite
Upgradient

35(28) 1,600 (530)

5(-) 47 (20.8)
14(11.5) 24,000 (4,396)
	 2,200 (1,750)
	 240 (215)
	 670 (568)
80(35) 12(7-2)
	 78 (59)
	 28 (22.5)
	 68 (60.5)
	 45 (34.5)

28(21.3) 47 (23)
37(20.8) 190 (33.0)


Offsite*
Oowngradient

180 (35)

25 (10.4)
60 (24)
69 (34.6)
13 (6.8)
493 (289.5)
110 (40.3)
63 (46.5)
11 (8.5)
188 (140)
7 (6.5)

38 (24.7)*
70 (24.6)
Chemical-
Specific
ARAR for
Water


5**

0. 7****
5
5**
5**
5**
5**
4.7***
5**
4. 7***
5**

50
25**
Note:  All concentrations reported as micrograms per liter (ta/L)  for water  samples  and  tnicrograms per
       kilogram  (^g/kg) f°r soils.
       Haxium detected concentrations and representative values  in parentheses.
       ARARs are MCLs or MCLCs unless Indicated differently.
       	 below detection limit.
*Downgradient offslte groundwater samples taken from wells identified as  the exposure point for the PHE.
*CluMmium concentrations at the exposure point do not exceed  ARARs.
          State standard, NYS Sanitary Code, Part 5-1, January,  IS
          State standard, 6NYCRR Part 703.5
 **»*Hew York State  standard,  TOGS 1.1.1.
*****Uatu. M,j_nR «nH MU-09  fsee  Fieure 4)
Rs^^^
"•

-------
                               Table II
             Summary of Carcinogenic Risk and Noncarcinogenic
             Hazard Levels for SMS Instruments Site Indicator
             Chemicals
    Exposure
Pathway/Receptor
Carcinogenic
 Risk (CRL)
Noncarcinogenic
  Hazard  (HI)
Measured Data

Potable Use
Casual Ingestion
Dermal Absorption
Vegetable Consumption

Modeled Data
                              2.27 x
                              2.27 x 10
                              •1.80 x 10
                              3.66 X 10

                     6.86 X
                     6.86 X
                     5.44 X 10
                     5.70 X 10
            ,
           ~J
Potable Use
Casual Ingestion
.Dermal Absorption
Vegetable Consumption
1.34 x lO'l:
1.34 x 10"'
1.06 x 10,
2.37 x 10"7
8.55 X 10"J
8.55 X 10";!
6.76 X 10,
8.00 X 10"J
CRL - cancer risk level,
 HI - hazard index.

-------
                   TABLE III
 Present Worth Cost for Remedial Alternatives
                   SMS Site
(Costs are rounded off to the nearest $100.00)
1
Alternative
la:
Ib:
2a:
2b:
3:
4a:
4b:
5 :
6 :
No action (source untreated)
No action (source treated)
Groundwater Extraction, Treatment
and Surface Water Discharge
Groundwater Extraction, Treatment
and Reinjection
Source Control/No action
Source Removal and Offsite Disposal
Source Removal and Offsite
Incineration
Low Temperature Soil Stripping
In situ Steam Stripping
Present Worth Capital Cost
$
$
$
$
$
$
$
$
$
300,300
300,000
1,888,800
809,000
330,400
520,200
2,036,500
887,000
386,800
$
$
$
$
$
$
$
$
$
70,400
70,400
544,000
365,300
73,200
520,200
2,036,500
629,800
386,800
Annual
O&M
$
$
$
$
$
$
$
$
$
13,600
13,600
128,200
123,400
14,100
0
0
0
0
Periodic
Costs
$
$
$
$
$
$
$
$
$
7,500
7,500
7,500
7,500
14,600
0
0
0
0

-------
                                        Table  IV

                          COST StmABY  FOB  THE SELECTED ROOT

                    Groundwater Extraction  Treatment and Reinjection
Element/I tern
                  Quantity  Unit  Unit Cost    Total Cost
CAPITAL:
Direct Cost
  Well Construction
   Drilling - 10" 00
HSA
   Casing - Low Carbon Steel 8"
   Screen - LCS wire wound 8"
   Casing - Low Carbon Steel 6"
   Screen • LCS wire wound 6"
   Filter Pack - 100/weight
   Bentonite Pelets
   Surface Pad - Concrete
   Submersible Pump - 15HP
   Well Development
   Water Tank
   Mobilization
  Treatment System
   Site Preparation
   Air Stripping Towers
   Control Panel, Conduit, & Appurt.
   Integrating Controls for Well
   Deep Bed Filters & Integ. Controls
   Backwash Tank & Apputenances
   Discharge Pump & Appurtenances
   Wet Well
   Road Crossing and Payment RepI cement
   Electrical Connection
   Vapor Collection Connection
 Total Direct Cost:

Indirect Cost
  Well Locating
   Review Documents
   Model ing
   Pump Test
  Survey
  Right-of-Way/Easement Aquisition
  License and Permit ing
  Startup 4'Shakedown Cost
  Contigencies - 15X
  Engineering - 15X
TOTAL CAPITAL COST:
500 FT
70 FT
30 FT
200 FT
200 FT
250 CF
35 L8S
35 CF
1 EA
30 HR
10 DAY
1 LS
$95.00
S80.00
S125.00
S65.00
$100.00
$18.00
$23.00
$20.00
$4,000.00
$150.00
$250.00
$5,000.00
$47,500.00
$5,600.00
$3,750.00
$13,000.00
$20,000.00
$4,500.00
$805.00
$700.00
$4,000.00
$4,500.00
$2,500.00
$5,000.00
                         50 HR
                        120 HR
                          1 LS
                          2 AC
                        0.5 AC
                          1 LS
                          2 UK
                                                       SUB  TOTAL
                                               $111,855.00
0.5 AC
2 EA
1 EA
1 LS
2 EA
1 EA
. 1 EA
1 EA
1 LS
1 LS
1 LS


$1,100.00
$25,000.00
$10,000.00
$3,500.00
$13,000.00
$8,000.00
$14,000.00
$2,200.00
$10,000.00
$1,200.00
$1.000.00
SUB TOTAL
SUB TOTAL
$550.00
$50,000.00
$10,000.00
$3,500.00
$26,000.00
$8,000.00
$14,000.00
$2,200.00
$10,000.00
$1,200.00
$1,000.00
$126,450.00
$238,305.00
    $50.00
    $60.00
 $6,000.00
 $2,400.00
$30,000.00
$12,000.00
 $4,000.00
                                                       SUB TOTAL
   $2,500.00
   $7,200.00
   $6,000.00
   $4,800.00
  $15,000.00
  $12,000.00
   $8,000.00
  $35,745.75
  $35,745.75

 $126,991.50
B3S33SSSSSSSS
 $365,296.50

-------
                                Table IV (Cont'd)
Element/Item
Quantity  Unit  Unit  Cost     Total Cost
O&M
Annual
   Labor
   Electricity
   Materials
   Vapor Treartment Packs
  Monitoring
   Sampling - Analytical
   Sampling - Labor
   Report
Periodic Costs (every 5 years)
   Site Review and Public Health Assmht.
312 HR
12 MNTH
12 MNTH
6 UNITS
52 EA
52 HR
24 HR
$50.00
$2,600.00
$100.00
$5,000.00
$800.00
$50.00
$50.00
$15,600.00
$31,200.00
$1,200.00
$30,000.00
$41.600.00
$2,600.00
$1,200.00
               SUB TOTAL


     125 HR         $60.00

               SUB TOTAL
                                                                    $123,400.00
$7,500.00

$7,500.00
PRESENT WORTH: (5X over 4 years)
  Present Worth Capital
  Present Worth Annual O&M
  Present Worth Periodic O&M
                             $365,296.50
                             $437,576.40
                               $6.170.25
TOTAL PRESENT WORTH
                             $809,043.15

-------
19/28/89                             Index Chronological  Order                                                 Page:  1
                                     SMS INSTRUCTS Documents
Document Number: SKS-W1-6518 To 8519                                                Date: 66/68/67

Title:  (Special Notice Letter stating that EM requires responsible parties to take response action
       at the site)

     Type: CORRESPONDENCE
   Author: Luftig, Stephen D:  US EM
Recipient: Schusheia, Sol H:  SMS Instruments Inc
Document Nuaber: SMS-eei-8858 To 8943                                                Date: 66/81/67

Title: Work Plan for Renedial Investigation/Feasibility Study - SMS Instruments Site

     Type: PUN
   Author: none:  Ebasco Services
Recipient: none:  US EPfl


Document Number: SHS-Wi-6580 To 8588                                                Date: 11/16/86

Title: (Memo regarding comments on the Draft Remedial Investigation Report)

     Type: CORRESPONDENCE
   Author: Johnson,  Denise:  Agency for Toxic Substances I Disease Registry (ATSDR)
Recipient: Fayon, Abram Miko:  US EPA


Document Number: SNS-481-8579 To 8579                                                Date: 11/21/86

Title: (Letter regarding comments on the Draft Remedial Investigation Report)

     Type: CORRESPONDENCE
   Author: Lindsay,  John A:  National Oceanic ( Atmospheric Administration (NOPfl)
Recipient: Fayon, flbrai Miko:  US EPA


Document Number: 5X5-881-4576 To 6577                                                Date: 11/23/88

Title: (Memo regarding geologist comments on the Draft Remedial Investigation Report)

     Type: CORRESPONDENCE
   Aothor: yillis, Kevin:  US EPA
Recipient: Fayon, Abram Miko:  US EPA

-------
W/38/89
Index Chronological Order
SMS INSTRUMENTS Documents
                        Page:
Document Nuiber: SHS-001-0578 To 8578                                              Date: 11/83/88

Title:  (Mew regarding Federal Activities Section covents on the Draft Remedial  Investigation Report)

     Type: CORRESPONDENCE
   Author: Kelly, Robert F:  US EPfl
Recipient: KcCabe, Hilliai:  US EM


Document Nuiber: SNSH»l-0567 To 9575                                              Date: 11/28/88

Title:  (Heno forwarding attached Draft Preliminary Health Assessient for review and cement)

     Type: CORRESPONDENCE
   Author: Nelson, Williai Q:  Agency for Toxic Substances i Disease Registry (ATSOR)
Recipient: Fayon, Abrai Niko:  US EPA
Document Nuiber: SHS-W1-0744 To 0745

Title:  (Letter forwarding the Final Comnity Relations Plan)

     Type: CORRESPONDENCE
   Author: Sachdev, Dev R:  Ebasco Services
Recipient: Johnson, Lillian 0:  US EPA
 Attached: SMS-001-0742
                                               Date: 11/30/88
DocuKnt Nuiber: SMS-001-0565 To 0566                                              Date: 12/01/88

Title: (New> regarding Air Prograis Branch  coaents on the Draft Rewdial Investigation Report)

     Type: CORRESPONDENCE
   Author: Barrett, Uilliai J:  US EPA
Recipient: Fayon, Abrai Hiko:  US EPA
Docuxnt Nuiber: SXSHWH3742 To 0766

Title: Final Coawnity Relations Plan

     Type: PLAN
   Author: Corotay, Sheila:  Ebasco Services
Recipient: none:  US EPA
                 Parent: 96-001-0744
Date: 12/01/88

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89/28/89                             Index Chronological Order                                                Page: 3
                                     SMS INSTRUMENTS Documents
Document Nuiber: SNS-W1-0560 To 6564                 Parent: 5X5-001-9558          Date: 12/15/88

Title: (Letter regarding coaents on the Draft Remedial  Investigation Report)

     Type: CORRESPONDENCE
   Author: Hither,  Robert:  NY Dept of Environmental Conservation
Recipient: Fayon, flbraa Miko:  US EPA


Document Nuioer: SMS-001-0556 To 0559                                               Date: 12/27/88

Title: (Letter regarding additional cowents on the Draft  Remedial Investigation Report)

     Type: CORRESPONDENCE
   Author: Wither,  Robert:  NY Dept of Environmental Conservation
Recipient: Fayon, flbran Miko:  US EPA
 Attached: SNS-001-0560

Document Nuiber: SMS-001-0W1 To 0352                 Parent: SMS-001-0003          Date: 02/01/89

Title: Final Remedial Investigation Report for RI/FS at  site

     Type: PLAN
   Author: Byroade,  Jon D:  Ebasco Services
Recipient: none:  US EPA


Document Nuiber: SMS-001-0003 To 0003                                               Date: 02/24/89

Title: (Letter forwarding Final Remedial Investigation Report)

     Type: CORRESPONDENCE
   Author: Sachdev,  Dev R:  Ebasco Services
Recipient: Alvi, M Shaheer:  US EPA
 Attached: SMS-001-W81

Document Nuiber: SMS-«l-«557 To 0557                                               Date: 03/31/89

Title: (New regarding Environmental Iipacts Branch cooents on the Draft Workplan for the remedial
       design/rewdial action for the site)

     Type: CORRESPONDENCE
   Author: Arerwald,  Joanne R:  US EPA
Recipient: Fayon, Afarai Miko:  US EPA

-------
09/28/89                             Index Chronological  Order                                               Page:  4
                                     SMS INSTRUMENTS Documents
Document Number: SKS-«l-0353 To 6504                                               Date: 84/01/89

Title: Draft Feasibility Study Report

     Type: PLAN
Condition: DRAFT
   Author: Byroads, Jon 0:  Ebasco Services
Recipient: none:  US EPA


Document Number: 9G-001-0556 To 6556                                               Date: 04/84/89

Title: (Memo regarding Environmental Impacts Branch comments on the  Draft Feasibility Study)

     Type: CORRESPONDENCE
   Author: Arenwald, Joanne R:  US EPA
Recipient: Fayon, flora* Hiko:  US EPA


Document Number: SHS-W1-0553 To 0555                  Parent:  SHS-001-0509          Date: 05/03/89

    e: (Meno regarding Water Management Division comments on the Draft Feasibility Study)
     Type: CORRESPONDENCE
   Author: Nalleck, John S:  US EPA
Recipient: NcCabe, UilliM:  US EPA
Document Number: SHS-001-0551 To 0552                                               Date: 05/05/89

Title:  (New regarding Air Programs I Air Coapliance Branch cooKnts on the Draft Feasibility Study)

     Type: CORRESPONDENCE
   Author: Barrett, Uilliai J:  US EPA
Recipient: Fayon, Abrai Miko:  US EPA


Document Nuiber: SNS-001-0548 To 0550                  Parent:  SHS-001-0520          Date: 05/17/89

Title:  (Letter cownting on the Draft Feasibility Study)

     Type: CORRESPONDENCE
   Author: Mann, Kii L:  NY Dept of Health
Recipient: Hither, Robert:  NY Dept of Environmental Conservation

-------
09/28/89                             Index Chronological Order                                                Page: 5
                                     SMS INSTRUMENTS Documents
Document Number: SHS-001-0536 To 0540                 Parent: SMS-«l-0528          Date: 05/18/89

Title: (Letter commenting on the Draft Feasibility Study)

     Type: CORRESPONDENCE
   Author: Hither,  Robert:  NY Oept of Environmental Conservation
Recipient: Fayon, Abram Miko:  US EPA


Docuwnt Number: SHS-001-0541 To 0542                 Parent: SHS-001-0514          Date: 05/18/89

Title: (Nemo regarding Hazardous Waste Facilities Branch comments on the Draft Feasibility Study)

     Type: CORRESPONDENCE
   Author: Bellina,  Andrew:  US EPA
Recipient: NcCabe,  Uilliam:  US EPA


Document Nuiber: SNS-0ei-0543 To 0547                                               Date: 05/18/89

Title: (Letter commenting on the Draft Feasibility Study)

     Type: CORRESPONDENCE
   Author: Hither,  Robert:  NY Dept of Environmental Conservation
Recipient: Fayon, Abram Hike:  US EPA


Document Nuiber: SMS-W1-4535 To 0535                                               Date: 05/32/89

Title? (Neno regarding SMS ARARs)

     Type: CORRESPONDENCE
   Author: Barrett,  Williai J:  US EPA
Recipient: Fayon, Abrai Niko:  US EPA


Dbnaent fcaber: SMS-«l-fl595 To 0741                                               Date: 06/01/89

Title:.Final Feasibility Study Report for SMS Instruments  Site Volume  II

     Types PLAN
Conditions DRAFT
   Author:-, Byroade,  Jon D:  Ebasco Services
Recipient^ none:  US EPA

-------
 99/28/89                            Index Chronological Order                                               Page:  6
                                     SMS INSTRUMENTS Documents
Document Nuiber: SHS-801-8532 To 8534                                               Date: 86/85/89

Title:  (Letter forwarding attached ups showing the location of water distribution  piping and public
       water supply wellfields in the vicinity of the site)

     Type: CORRESPONDENCE
   Author: Santino, Alexander N:  Suffolk NY,  County of
Recipient: Fayon, Abrai Hike:  US EPA
Document Nuiber: SHS-801-85£8 To 8531                                               Date: 86/86/89

Title:  (Letter forwarding attached response to NYSDEC 85/18/89 cownts  and  NYSOOH 85/17/89 consents
       on the Draft Feasibility Study)

     Type: CORRESPONDENCE
   Author: Fayon, Abrae Miko:  US EPA
Recipient: Wither, Robert:  NY Dept of Environmental Conservation
 Attached: SHS-881-8536   SMS-881-8546
Document Nuiber: SKS-881-8586 To 8508                                               Date: 86/15/89

     »:  (tew forwarding attached response to 85/85/89 eowents regarding  the Draft Feasibility Study)

     Type: CORRESPONDENCE
   Author: Garbarini, Douglas R:  US EPA
Recipient: Truchan, Paul R:  US EPA


Document Nuiber: 5X5-881-8589 To 8513                                               Date: 86/15/89

Title:  (New forwarding attached response to 85/83/89 owents regarding  the Draft Feasibility Study)

     Type: CORRESPONDENCE
   Author: fcCabe, Uilliai:  US EPA
Recipient: Ma Heck, John S:  US EPA
 Attached: SNS-881-8553

Document Niofaer: SMS-881-0514 To 8517                                               Date: 86/15/89

Title:  (few forwarding attached response to 05/18/89 coaents regarding  the Draft Feasibility Study)

     Type: CORRESPONDENCE
   Author: NcCabe, Uilliu:  US EPA
Recipient: Bellina, Andrew:  US EPA
 Attached: SNS-«81-8541

-------
09/28/89
Index Chronological Order
SMS INSTRUMENTS Documents
Page: 7
Document Number: SMS-Wl-«05 To 0505
                                               Date: 07/10/89
Title: (New regarding Air Programs Branch comments on the Proposed Remedial Action Plan for the
       site)

     Type: CORRESPONDENCE
   Author: Barrett,  William J:  US EPA
Recipient: Fayon,  Abraa Miko:  US EPA
Document Number: SMS-«1-0581 To 0594

Title: Proposed Remedial Action Plan - SMS Instruments Superfund Site

     Type: PLAN
   Author: Fayon,  Abram Miko:  US EPA
Recipient: none:  none
                                               Date: 07/14/89
Document Nun her: SMS-401-0767 To 0780

Title: Proposed Remedial Action Plan - SMS Instruments Superfund Site

     Type: PLAN
   Author: Fayon, Abrai Miko:  US EPA
Recipient: none:  none
                                               Date: 07/14/89
Document Nuaber; SMS-W1-0782 To 0820                 Parent: SMS-001-0781

Title: Final Responsiveness Summary - SMS Instruments Site

     Type: PLAN
   Author: Uinfield,  Julie:  ICF Incorporated
Recipient: none:  US EPA
                                               Date: 08/01/89
Document Number: SMS-ttl-9822 To 0857                  Parent: SMS-001-0821

Title: Final Responsiveness Summary - SMS Instruments Site

     Type: PLAN
   Author: Uinfield, Julie:  ICF Incorporated
Recipient: none:  US EPA
                                               Date:  08/01/83

-------
99/23/89                             Index Chronological  Order                                                Page: 8
                                     SMS INSTRUMENTS Documents
Document Nuaber: SXS-081-0781 To 8781                                               Date: 88/85/89

Title:  (Letter submitting Final Responsiveness Stuaary)

     Type: CORRESPONDENCE
   Author: Sachdev,  Dev R:  Ebasco Services
Recipient: Fayon,  flbra« Miko:  US EPfl
 Attached: SMS-881-8782

Document Nuiber: SMS-W1-8821 To 8821                                               Date: 89/89/89

Title:  (Mew forwarding the «ost recent  copy of the Final  Responsiveness Sunoary, ccapleted 89/88/89
       and incorporating Doug Garbarini's cowents)

     Type: CORRESPONDENCE
   Author: Uinfield, Julie:  ICF Incorporated
Recipient: Sarbarini, Douglas R:  US EPA
 Attached: SMS-Wl-8822

-------
        APPENDIX IV




NYSDEC LETTER OF CONCURRENCE

-------
              L^'-±±  Fr'Ql-1   (I i i . El •' 'IP. 'I Or i'EE?1 'nT I .jt 1     TC     E—. rlr E~I: II'i-T-E M    r . C'-i
New York State Department of Environmental Conservation
  Wolf Road, Albany, New York 1223^7010
                                                                         Thomas C. Jortlng
                                                                         CommlMlontr
                                                 SEP 2 8
    Mr. William J. Muszynski, P.E.
    Acting Regional Administrator
    Emergency and Remedial Response Division
    U.S. Environmental Protection Agency
    Region II
    26 Federal Plaza
    New York, NY  1027S
    Dear Mr. Muszynski:
                             RE:  Record of Decision (ROD)
                                  SMS  Instruments #152026
    The New York State Department cf Environmental Conservation  (N'/SDEC) has
    reviewed the draft Record of Decision, dated August 28, 198S, for tha SMS
    Instruments site and  concurs with  the selected remedy as fellows:

    1.   Contaminated soil will be treated by in-situ steam stripping.  Volatile
         organics will be removed to action levels identified  in Table 10-3 of the-/
         Final SMS Instruments Feasibility Study report dated  Jure, 198S. This
         treatment will also be utilized for contaminated soil in the drum storage
         area.

    2.   Groundwater will be remediated by extraction, treatment and reinject-'on
         to meet State drinking water  standards and guidance values.

    3.   A treatability study will be  conducted during the design stage of the
         remedy to ensure that the technology can be utilized  effectively.

    4.   SDWA Maximum Contaminant Levels (40 CFR 141.11-141.16), SDWA MCL Goals
         (40 CFR 141.50-141.51), and 6 NYCRR Groundwater Quality Regulations
         (Parts 703.5, 703.6, 703.7) standards and goals for toxic compounds for
         public drinking  systems will  be met.  The reinjection process for treated
         groundwater will meet underground injection well regulations as a
         Superfund remedial action under 40 CFR 147.  The extracted groundwater
         will be treated  to meet all drinking water standards  prior to reinjection.

    5.   Spent carbon from the groundwater treatment system for  removal of organics
         will be disposed of off site, as well as any treatment  residuals,
         consistent with  applfcatTTl" RCRA land disposal restrictions under 40 CFR
         268.

-------
Mr. William J. Muszynski,  P.E.                                           Page 2
6.   The groundwater at the site is classified as  lib,  and  drinking watsr
     standards are applicable:   SOWA MCLs,  SDWA MCL Goals,  Water Quality
     Criteria under CWA and 6 NYCRR Groundwater Quality Regulations.

New York State concurrence with the final  ROD is contingent upcn inclusion of
the following:

7.   Additional sampling of soil and groundwater will  be conducted to further
     define plume parameters (plume depth,  length,  width and direction of
     vertical flow).

8.   Additional monitoring will be done to ensure that extraction wells are
     properly placed and that they are remediating the total extant of the
     plume.  Design study will  include a survey of which homes near the site
     have wells and how those wells are used.

9.   Alternatives involving air stripping will contain provisions for
     monitoring and treating the air discharges.  Additional information
     including cost estimates,  length of time for cleanup and any effects
     on start-up of groundwater remediation will be developed for use cf air
     stripping as backup technology to in-situ steam stripping.

10.  At the completion of the response actions, the selected remedy and the
     contingency remedy will comply with ARARs noted above.  Since grcundwater
     extraction, treatment and reinjection and in-situ steam stripping are
     "processes" as defined by 6 NYCRR Part 200, the performance standards set
     by 6 NYCRR Part 212 must be met.  Parts 201,  202, 211  and 231 are   also
     relevant, since the site is in a non-attainment area for ozone.

Should you have any questions on these issues, please call  Mr. Michael J.
O'Toole, Jr., P.E., at (518) 457-5861.
                                       Sincerely,
                                       Edw4r>j 0. SuTTTvan
                                       Deputy Commissioner
cc:  W. McCabe
     A. M. Fayon
     D. Garbarini
                                                                        TOTHL P. Of-

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                BEFORE THE REGIONAL ADMINISTRATOR
                          UNITED STATES
                 ENVIRONMENTAL PROTECTION AGENCY
                            REGION  II
                        26 Federal Plaza
                    New York, New York  10278
In the Matter of                :
S.M.5. Instruments, Inc.        :
                                        ADDENDUM TO
Uncontrolled Hazardous Substance:  COMMENTS IN RESPONSE TO
Release Facility,                      EPA's PROPOSED
                                :    RJ-yFfllAL ACTION PLAN
Deer Park, New York
        ADDENDUM TO COMMENTS, SUGGESTIONS AND OBJECTIONS
                    OF SMS INSTRUMENTS, INC.
         ON EPA REGION II's PROPOSED REMEDIAL ACTION PLAN
          PLEASE TAKE NOTICE that SMS Instruments, Inc.,
appearing through its counsel, Kreindler & Kreindler, Henry
Gluckstem, of counsel, hereby submits the following addendum to
its comments initially submitted August 11, 1989 with respect to
EPA's Final Remedial Investigation Report and Final Feasibility
Study, respectively dated February 1989 and June 1989, for the
SMS Instruments, Inc. uncontrolled hazardous substance release
facility, Deer Park, New York (hereinafter, "the facility").
          The facility owner hereby requests that EPA take the
following additional information into consideration prior to
finalization of its Remedial Action Plan for the facility.  The
additional observation and comment expressed herein vas brought
to the attention of the facility owner by a consultant during the
week of August 28, 1989 and was therefore not submitted as part
of the facility owner's August 11, 1989 submittal.

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                               -2-
          Hhile the comment herein  submitted does  not directly
impact on remedy selection issues,  SMS Instruments,  Inc.
nevertheless believes that the failure of the Final  Remedial
Investigation Report and Final Feasibility Study to  have  taken
into account the information contained herein constitutes a
serious deficiency of documents which repeatedly identify
activities conducted at SMS Instruments, Inc. as the exclusive
source of certain pollutants claimed to have been  detected on
property owned by SMS Instruments,  Inc..
          Specifically, consultants for SMS Instruments,  Inc.
have noted, as part of a just-completed site inspection,  that
property operated by Applied Coating, Inc./Margin  International,
located immediately to the south of SMS Instruments, Inc.'s
property, at 90 Marcus Boulevard, shows visible and  long-
established evidence of the release of organic  substances to the
environment.  In addition, the property at 90 Marcus Boulevard is
so configured that hazardous substances which may  have been
released in the vicinity of the loading dock at the  eastern
perimeter of the Applied Coating, Inc. facility structure would
flow above ground onto property owned by SMS Instruments, Inc. to
a point essentially co-terminus with the area in which ground-
water was sampled by EPA's contractor's wells placed in the
location of the former SMS Instruments, Inc. leaching field.
          In addition, a piped, below-grade dry well (leaching)
field maintained by the owner or operator of 90 Marcus Boulevard
terminates at a point within 2. fTWOl feet from  the point at which

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                               -3-
the releases alleged to have originated from the SMS Instruments,
Inc. leaching field were sampled through monitoring veils
installed by EPA's contractor.
          Nowhere does the Final Remedial Investigation Report
or Final Feasibility Study discuss the impact which such an
obvious foreign source of contamination would have on groundwater
sampled physically on property of SMS Instruments, Inc..  SMS
Instruments, Inc. believes that conclusions drawn from sampling
which EPA found to contain one of the major contaminant
concentrations on the SMS Instruments, Inc. site, but which
failed to mention, let alone investigate and analyze, possible
significant contributions from an otherwise "downgradient"
source of contamination, makes any conclusion identifying SMS
Instruments, Inc. as the sole source of contamination found
along the southern portion of the SMS facility seriously suspect.
          SMS Instruments, Inc. respectfully requests and
petitions the Regional Administrator to re-evaluate the portion
of EPA's RI/FS dealing with the origin of contaminants detected
in the area of the SMS Instruments, Inc. leaching field and
further requests that the role of the owners and operators of 90
Marcus Boulevard as potentially responsible parties for releases
to the environment allegedly occurring from 120 Marcus Boulevard
                                                                 *
be fully and properly assessed prior to any final determination
being made of potentially responsible parties at the SMS
Instruments, Inc. facility.

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                              -4-
DATED:  September 5,  1989
                                    ictfully submitted,
                                         & KREINDLER
                               Attorneys for SMS Instruments,
                                 Inc.
                               100 Park Avenue
                               New York, New York   10017
                               212-687-8181

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      APPENDIX V




RESPONSIVENESS SUMMARY

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                  FINAL RESPONSIVENESS SUMMARY
                       SMS INSTRUMENTS SITE
                       DEER PARK,  NEW YORK
The U.S. Environmental Protection Agency (EPA)  held a public
comment period from July 10,  1989 through August 10, 1989 for
interested parties to comment on EPA's final Remedial
Investigation/Feasibility Study (RI/FS)  and Proposed Remedial
Action Plan (PRAP) for the SMS Instruments Site, located in Deer
Park, New York.

EPA held a public meeting at  7:00 pm.  on August 2,  1989 at the
Deer Park Library in Deer Park, New York to outline the remedial
alternatives described in the RI/FS and present EPA's proposed
remedial alternatives for the SMS Instruments Site.

The responsiveness summary is required by Superfund policy.  It
provides a summary of citizen's comments and concerns received
during the public comment period, and  EPA's responses to those
concerns.  All comments summarized in  this document have been
factored into EPA's final decision for selection of the remedial
alternatives for cleanup of the SMS Instruments Site.

This responsiveness summary is organized in five sections.  Each
of these sections is described briefly below.

     I.   RESPONSIVENESS SUMMARY OVERVIEW.  This section briefly
          describes the background of  the SMS Instruments Site
          and outlines the proposed remedial alternatives for the
          Site.

     II.  BACKGROUND ON COMMUNITY INVOLVEMENT AND CONCERNS.  This
          section provides a  brief history of community concerns
          and interests regarding the  SMS Instruments Site.

     III. SUMMARY OF MAJOR QUESTIONS AND COMMENTS RECEIVED DURING
          THE PUBLIC COMMENT  PERIOD AND EPA RESPONSES TO THESE
          COMMENTS.  This section summarizes oral comments
          received by EPA at  the August 2, 1989 public meeting
          and provides EPA's  responses to these comments.

     IV.  REMAINING CONCERNS.  This section discusses community
          concerns to be considered as EPA prepares to undertake
          the remedial designs and remedial actions at the SMS
          Instruments Site.

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     V.   WRITTEN COMMENTS RECEIVED BY EPA AND EPA RESPONSES TO
          THESE COMMENTS.  This section contains the written
          comments received by EPA during the public comment
          period, and EPA's written responses to these comments.

I.   RESPONSIVENESS SUMMARY OVERVIEW

The SMS Instruments Site is located at 120 Marcus Boulevard, Deer
Park in Suffolk County, New York.  It is in a light industrial
and residential area.  The site is an active industrial facility
that consists of a 34,000 square foot building on a 1.5 acre lot.
Approximately 80% of the lot is paved with asphalt.  More than 50
industrial facilities are located within a one-mile radius, and a
large groundwater recharge basin is located directly adjacent to
the east side of the SMS Instruments Site.

EPA conducted a Remedial Investigation (RI) from July 1987 to May
1989 to characterize the extent and nature of contamination of
the site.  The RI found extensive soil and groundwater
contamination at the site.  The major source of groundwater and
soil contamination is believed to be industrial waste generated
from metal degreasing and other metal finishing operations
conducted from 1967 to the present.  These wastes were routinely
discharged to a leaching pool on the south side of the building
until 1980.  Another source was a 6,000 gallon underground
storage tank used for jet fuel storage.  The leaching pool was
pumped out, filled with sand, and sealed in 1983.  The
underground tank was removed from the site by the owner on
February 17, 1988 during the RI.

The results of the RI are summarized below:

     •    Groundwater Contamination
               Groundwater below the site is highly contaminated.
               The chemicals of concern are mainly chlorinated
               hydrocarbons and some aromatics, such as xylenes.

          -    Groundwater upgradient of the site is contaminated
               with volatile organic compounds (VOCs).

               Contamination in the soil is continually released
               into the groundwater.  Levels of contamination
               indicate that groundwater treatment will be
               required in the upper glacial aquifer.

     •    Soil Contamination

          -    Gross contamination of surface and subsurface
               soils is present around the leaching pool and
               underground storage tank areas.

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               The primary soil contaminants include xylene,
               chlorobenzene,  ethylbenzene,  trans-1,2
               dichloroethene,  and tetrachloroethene.

The remedial alternatives evaluated by EPA in the Feasibility
Study are summarized in the following section.  The final
alternative has been selected after evaluating public comments
and any other additional information gathered during the public
comment period on the RI/FS and the Proposed Remedial Action
Plan.

Cleanup alternatives have been selected to address groundwater
and soil remediation.  The alternatives for groundwater cleanup
are categorized as management of migration alternatives.
Alternatives for remediating contaminated soils are categorized
as source control alternatives.  The alternatives for these two
categories are as follows:

MANAGEMENT OF MIGRATION ALTERNATIVES

Alternative la;  No Action ( source untreated)

Capital Cost:                      $70,400
Annual Operations
  and  Maintenance (O&M) :          $13,600
Periodic O&M:                      $ 7,500
Construction Time Frame:           45 Days
Restoration Time Frame:            More than 20 Years

No remedial action would be implemented under this alternative.
A long-term monitoring program would be conducted to provide
information on the extent of contaminant migration over time.
Five wells would be monitored semi-annually for volatiles, semi
volatiles, and various metals.   This alternative would require
the implementation of water use restrictions to prevent the use
of contaminated groundwater as a potable water source.  The
restrictions would be imposed on any residence, business or
future plans for well installations within one-half mile
downgradient of the site.

Alternative Ib:  No Action    nce treated
Capital Cost:                      $70,400
Annual O&M:                        $13,600
Periodic O&M (Every 5 Years):       $ 7,500
Construction Time Frame:           150 Days
Restoration Time Frame:            10 Years

This alternative is the same as Alternative la, except that the
source would be treated by one of the four alternatives: 4A, 4B,

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5 or 6.  If source treatment is implemented the aquifer
restoration time frame would be reduced by approximately 10
years.


(source untreated)
Capital Cost:
Annual O&M:
Periodic O&M:
Construction Time Frame:
Restoration Time Frame:
                                   $544,100
                                   $128,200
                                   $ 7,500
                                   45 Days
                                   More than 15 Years
An extraction well located off-site would capture the plume of
contaminated groundwater emanating from the SMS Instruments Site.
The extracted groundwater would treated in air stripping towers
to reduce the level of contamination to meet or exceed the
selected cleanup standards.  The treated water would then be
discharged to a surface water body, specifically, the pond in
Birchwood Park, 1/2 mile southeast of the site.
Alternative 2b;
ReiniectioT
                    treated
Capital Cost:
Annual O&M:
Periodic O&M  (Every 5 Years) :
Construction Time Frame:
Restoration Time Frame:
                                   $365,300
                                   $123,400
                                   $ 7,500
                                   45 Days
                                   4 Years
This alternative is the same as alternative 2a, except that the
source would be treated by one of the four alternatives: 4a, 4b,
5 or 6 and the groundwater would be reinjected through wells
located on-site.  The restoration time frame would thereby be
significantly reduced as a result of concurrent source treatment.
This is EPA's preferred alternative for treating the contaminant
migration

SOURCE CONTROL ALTERNATIVES

Alternative 3:  Source Control ~~ No Action

Capital Cost:                           $73,200
Annual O&M:                             $14,100
Periodic O&M (Every 5 Years):           $14,600
Construction to Completion of Cleanup:  90 Days

Implementation of this alternative would be achieved by
incorporating monitoring and land use/deed restrictions on the
site.  The elements necessary for its implementation are:
Installing monitoring wells; Obtaining land use and deed
restrictions; Sampling of groundwater from monitoring wells

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periodically; Sampling subsurface soils  periodically; Patching
and sealing of asphalt pavement above the source areas; and
Reviewing the site conditions after five years.
Capital Cost:                           $520,200
Annual O&M:                             0
Construction to Completion of Cleanup:   30 Days

This alternative would involve the excavation and off -site
disposal of the contaminated soil present at the former leaching
pool and underground storage tank areas.   Approximately 1,250
cubic yards of soil contaminated with volatile and semi-volatile
organics would be excavated and transported to an off-site
Federally approved landfill for disposal.

Prior to excavation of the contaminated soil, the existing
pavement would be removed, loaded into  covered trucks and
transported to a debris landfill for disposal.  If necessary, the
pavement would be decontaminated before being transported off-
site or transported to an off -site Federally approved landfill.

If this remedy can be implemented prior to November 1990, when
the new Land Band Regulations go into effect, no treatment of the
soil will be required prior to disposal.   However, after that
date, the treatment of soil would be required before disposal.

Alternative 4b;  Songg Removal and Of f — Site Incineration
Capital Cost:                           $2,036,500
Annual O&M:                             0
Construction to Completion of Cleanup:   30 Days

This alternative would involve the excavation of contaminated
soil described in Alternative 4a.   Once the contaminated soil is
excavated, it would be placed in fiber drums.  Each fiber drum
would be filled with approximately 300 pounds of contaminated
soil.  The drums would be loaded onto trucks and transported to
an off -site incinerator.  To determine costs, EPA assumed that an
incinerator in Bridgeport, Logan Township, New Jersey would be
used.  The excavated areas would be backfilled with clean soil.

Alternative 5;  Low Temperature Soil Stripping

Capital Cost:                           $629,800
Annual O&M:                             $14,000
Periodic O&M:                           $14,000
Construction to Completion of Cleanup:   70 Days

Contaminated soil would be excavated as described in Alternatives
4a and 4b.  It would then be stockpiled in an area adjacent to

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the treatment unit where it would be fed into a screen to remove
oversized (greater than a 2 inch diameter)  material and debris.
The screened material would be transported to use on-site as
backfill.  The vaporized contaminants could either be destroyed
through a secondary high-temperature combuster or collected
through condensate or adsorbed onto activated carbon.  Stack
emissions would be monitored to verify compliance with Federal
and State regulations, including those for volatile organic
compounds (VOCs) , hydrogen chloride (HCL) ,  carbon monoxide (CO)
and particulates.

Prior to backfilling the treated soil, the soil would be tested
using the Toxic Characteristic Leaching Procedure (TCLP) to
ensure that land disposal levels are achieved.  At this point in
time it cannot be determined whether these levels can be
achieved.  If levels cannot be achieved, a treatability variance
may be required.  Unless the material is delisted (i.e. certified
as non-hazardous) , the material would have to be covered in
accordance with Federal landfill closure requirements.
Monitoring would also be required.

Alternative 6:  In-Situ Steam
Capital Cost:                           $386,800
Annual O&M:                             0
Construction to Completion of Cleanup:  150 Days

A typical in situ steam stripping system would involve the
introduction of steam into the contaminated soils, followed by
air and vapor extraction using vacuum pumps.  In order to comply
with air emission requirements, an aboveground vapor phase
treatment unit would be required to remove organics from the off
gases.  Spent carbon from the treatment unit would be treated and
disposed as hazardous waste.  Due to the close proximity of the
two on-site sources (underground storage tanks and leaching pool
area) , one common aboveground injection system, extraction
system, and vapor phase separation system would be used.  After
organic emission rates have decreased to negligible levels, soil
samples would be collected to confirm that soil contaminant-
specific action levels are achieved.  Upon completion of the in-
situ steam stripping operations, all equipment would be
decontaminated and removed from the site.  Wastes generated
during decontamination would be collected and transported to a
licensed facility for treatment and disposal.

The soil conditions at the SMS Site (homogeneous, have a high
porosity, and clay lenses are absent)  are ideally suited for
steam stripping.  A study at a Superfund site in San Jose,
California conducted by the University of California at Berkeley,
showed that the organics in soil were reduced by as much as 99.3%
and at a rate forty times faster than air stripping.  EPA would
conduct a volatilization pilot study before the actual

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remediation.  If any difficulties are encountered implementing
this alternative, the same equipment can be used to treat the
soil with air only.  The latter process is a proven technology
and has been used successfully during actual remediation.  This
is EPA's preferred alternative for source control.

Evaluation of Alternatives

EPA's selection for remediation at the SMS Instruments Site is
based on the requirements of CERCLA, which provides that a
selected site remedy be protective of human health and of the
environment, cost effective, and in accordance with other
statutory requirements.

EPA policy also emphasizes permanent solutions incorporating on-
site remediation of hazardous waste contamination whenever
possible.

EPA's final decision on the remedial alternative is documented in
the Record of Decision (ROD) .  The public will be kept informed
of the ROD through a press release and fact sheet that will be
distributed to recipients on the current mailing list.  The fact
sheet will also be placed with a copy of the ROD at the
information repositories developed for the site.  The information
repositories are documented in Appendix C.


II.  BACKGROUND ON COMMUNITY INVOLVEMENT AND CONCERNS

There was high public concern regarding the SMS Instruments Site
in 1984 when the site was first nominated by the State of New
York for inclusion on the National Priorities List (NPL) .  About
the same time, the New York Citizen Action Network (NYCAN) began
canvassing in Deer Park for funds.  The Deer Park Community
Action Network, an organization associated with NYCAN, sponsored
several meetings.  In the summer of 1984 a "Community Health
Forum" was held and approximately 120 citizens attended.

Community interest declined from the summer of 1984 to the
present.  According to local officials and residents who were
interviewed, the major reason for the reduced level of community
concern was the announcement that EPA had officially designated
the site as a Federal Superfund site and that a cleanup would be
conducted.

Levels of public concern have recently risen due to concerns
about the effectiveness of the preferred alternatives recommended
by EPA for cleanup of the SMS Instruments Site.  The primary
concerns of residents and local officials as cited in the
Community Relations Plan are as follows:

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      •     There is a  general concern about protecting groundwater
           resources and the potential for regional groundwater
           contamination.

      •     Residents are concerned about the  length of time from
           the initial site discovery to the  completion of the
           final remedy at the SMS Instruments Site.

      •     Businesses  surrounding the site are concerned with the
           potential disruption of daily business activities
           during remediation of the site.

      •     Officials,  civic leaders, and residents stated that
           they would  like "EPA to inform them of all EPA meetings
           and site activities.

      •     Local officials raised concerns about the potential
           negative effects on property values.

III.  SUMMARY OF MAJOR QUESTIONS AND COMMENTS RECEIVED DURING THE
      PUBLIC COMMENT PERIOD AND EPA RESPONSES TO THESE COMMENTS

Oral  comments raised  during the August 10, 1989 public meeting
and comments received during the public comment period for the
'SMS Instruments Site  remediation are summarized below.  The
public  comment period was held from July 10, 1989 through August
10, 1989.   Comments received during this time were organized into
three categories:   Technical Questions/Concerns; Cost/Funding
Issues; and Health Risk Assessments.

TECHNICAL  QUESTIONS AND/OR CONCERNS RAISED
AT AUGUST  2. 1989 PUBLIC MEETING

COMMENT:   One resident was interested in the process EPA used to
determine  the effects the reinjection system would have on the
recharge basin and if the reinjection system was implemented,
would there be any detrimental effects on the recharge basin.

EPA's RESPONSE:  EPA  replied that groundwater modeling was used
to determine the effects of the rein ject ion  system.  EPA also
stated  that groundwater modeling indicated that the reinjection
system  would not have detrimental effects on the recharge basin.
The location of the wells would be far enough away that when the
basin is recharging,  which it normally does, there would be
enough  force to drive the newly injected water past the recharge
basin.  In addition,  EPA would conduct further tests during the
Remedial Design phase to delineate groundwater flow
characteristics.  This information would be  used to define EPA's
jpresent choice for the location of the extraction wells,
pein ject ion wells and/or the size of the air stripper.


                                8

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COMMENT:  One resident wanted to know the size of the reinjection
wells.

EPA's RESPONSE:  EPA stated that details of the remedy would be
finalized during remedial design but current plans call for
reinjection wells to be six inches in diameter.  The wells would
be screened at 20-30 feet below the water table.

COMMENT:  Several residents inquired whether the water would be
tested for contaminants prior to reinjection.

EPA's RESPONSE:  EPA stated that the water would be monitored
prior to reinjection.  The treated groundwater would only be
reinjected if monitoring results met cleanup standards.

COMMENT:  A resident noted that EPA had stated there were a
number of volatile and semi-volatile contaminants in the soil and
groundwater.  The resident asked if EPA also found inorganics
such as metals in the soil and/or groundwater.

EPA's RESPONSE:  EPA responded that it found levels of chromium
and lead in on-site soils and in groundwater.  The representative
values for the concentration levels of chromium and lead detected
in the groundwater on-site were 23 and 33.0 micrograms/liter,
respectively.  Concentrations of these chemicals in the extracted
groundwater are not expected to exceed ARARs.  Similar
concentrations of these metals were found both downgradient and
upgradient of the site.  This indicated, there was not a "hot-
spot" of the metals on the SMS Instruments Site.

COMMENT:  One resident wanted to know what method EPA proposed to
filter metals such as iron from the groundwater at the site.

EPA's RESPONSE:  EPA stated that a multi-media filtration process
would remove the iron from the groundwater to meet the action
specific ARAR levels.

COMMENT:  One resident asked why EPA prefers the in-situ steam
stripping alternative for soil remediation.

EPA's RESPONSE:  EPA indicated that, because of the sandy nature
of the soil, steam stripping would be an innovative, effective
technology, permitting rapid, effective transmission of the
stream through the soil.  If the soils contained a lot of clays
or finer silts, this method might not be effective.

COMMENT:  A citizen inquired whether the in-situ steam stripping
method for soil remediation has ever been used before.

EPA's RESPONSE:  EPA replied in-situ air stripping has been
successful at Superfund sites.  Steam stripping is an innovative
variation of a technology that has been tested at the University

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of California at Berkeley.  The test results showed steam
stripping could be completed forty times faster than air
stripping given the soil conditions at the site.

COMMENT:  Several residents were concerned that the steam
stripping alternative was selected because it is one of the less
expensive alternatives presented by EPA.

EPA's RESPONSE:  EPA agreed that this alternative was one of the
least expensive alternatives it presented.  However, EPA
responded by assuring residents that the alternative would be
protective of public health and the environment and would provide
the best balance of the nine Superfund criteria evaluated to
select a remedial alternative.  This is consistent with statutory
requirements of CERCLA for' utilization of permanent solutions and
alternative treatment technologies to the maximum extent
practicable.

The nine criteria used to evaluate remedial alternatives include:
overall protection of human health and environment; compliance
with ARARs; long-term effectiveness; substantial reduction of
toxicity, mobility, or volume of contaminants; short-term
effectiveness; implementability; cost; state acceptance; and
community acceptance.  A discussion of these criteria is
documented in the Feasibility Study Report and the ROD, which can
be reviewed at the information repositories.  The location of the
information repositories is listed in Appendix C.

COST/FUNDING ISSUES

COMMENT:  A resident asked who is going to pay for the cleanup.

EPA's RESPONSE:  In general, EPA replied where viable PRP's
exist, they are offered the option of paying for the cleanup
and/or may be required to perform the cleanup.  EPA has used
federal Superfund monies for the RI/FS at the SMS Instruments
Site.  In the event that the PRP here does not perform or fund
the selected remedy, EPA will pay 90% of the cost and the state
will pay for the remaining 10%.  EPA may also pursue legal action
for cost recovery.

COMMENT:  One resident wanted to know if the PRP was paying for
the cleanup, would EPA have chosen another, more expensive
alternative.

EPA's RESPONSE:  EPA responded that the preferred alternatives
were based on nine criteria EPA uses for selecting remedial
alternatives for all Superfund Sites and that the remedy
selection would not be different.

          One resident inquired whether the PRP will eventually
  ve to pay for damages at the site.

                                10

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2. WRITTEN COMMENTS RECEIVED BY EPA

The Office  of Regional  Counsel  and the  Emergency and  Remedial
Response  Division  have  reviewed  comments  received  from  Mr.
Gluckstern's dated August 11,  1989 and  September 5, 1989 (letters
attached) .   It  should be noted that both sets of comments were
reveived after the August 10, 1989  closing  date for public comment.
Mr. Gluckstern did,  however, receive a four day extension from EPA
to respond.   Therefore,  only the second set of comments were late.

A. Response to August 11. 1989 Gluckstern  Letter

Response to Comment 3.a.

This  comment suggests  that EPA's implemention  of the  selected
remedy will  not  meet the requirements  of  Section  121(b)(l)  of
the   Comprehensive   Environmental  Response,   Compensation  and
Liability Act of 1980,  as  amended  ("CERCLA") ,  42 U.S.C.  §9621
(b) (1)  and   that   costs  incurred  by  EPA  are  therefore  not
recoverable.  Section 9621(b)(l) requires  that remedial actions in
which treatment  which permanently and significantly  reduces the
volume,   toxicity   or   mobility   of  the   hazardous  substances,
pollutants  and  contaminants  is a principal  element, are  to be
preferred over remedial  actions not involving such treatment.  This
Section  also requires  EPA   to  assess   alternative  treatment
technologies  and select a cost effective remedy that is protective
of human health and the environment.

EPA maintains that the remedy  selected, and the contingency remedy
employ treatment that permanently and significantly  reduces the
volume,  toxicity, or mobility of  the hazardous substances as its
principal element.  The volume and  toxicity of hazardous substances
at  the   Site will  be  reduced by  in  situ  steam stripping of
contaminated  soils  and groundwater  extraction,  treatment  and
reinjection.  Volatile Organic Compounds  ("VOCs") will be removed
to an average level of  10  ppb, a reduction of more  than 99% of
comtaminant levels in the soil.  The groundwater will be remediated
to meet  Federal  or State drinking water  levels,  except in those
cases where upgradient concentrations  are  above  such standards.
In such  a case,  the  contaminants will be  reduced to upgradient
levels so as to eliminate any significant contribution from the SMS
Site.

The selected  remedy, as well as the contingency remedy, represent
the maximum extent to which  permanent  solutions  and alternative
treatment technologies can be used in a cost-effective manner for
the SMS Site.  In situ steam stripping and hot air soil stripping
are innovative technologies.  Both are cost effective when compared
to other permanent  treatment  alternatives.   Based on the ROD and
the  above explanation,  EPA maintains  that the  requirements of
§9621(b)(1)  are  satisfied and that EPA costs associated with the
Remedial Design/Remedial Action at this Site are fully recoverable
pursuant to  §9607(a).

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Response to Comment 3.b.

This  comment  suggests  that EPA's  implemention  of the  selected
remedy  does  not  comply  with Section  121(d)(l)  of  CERCLA,  is
inconsistent with this Section and that costs incurred by EPA are
therefore not  recoverable.   Section 121(d)(1) requires  that the
remedial  action  selected by  EPA attain a degree of cleanup  of
hazardous substances,  pollutants and contaminants  released into the
environment and of control  of further  release at a minimum which
assures  protection  of  human  health and the environment.   This
Section  also  requires  such  remedial  actions  be relevant  and
appropriate under the circumstances presented by  the  release  or
threatened release.

The selected remedy  and the contingency remedy outlined in the ROD
eliminate all outstanding threats posed to the groundwater by the
on-site contaminated soils.  Both remedies reduce contamination of
on-site  materials to health  based  levels  except  in  those cases
where upgradient concentrations  exceed those levels.   The remedy
for  the  second  operable   unit  will  identify  and  address  any
upgradient contamination.

Based on the  ROD and the rest of teh  administrative  record, EPA
maintains that the requirements  of  §9621(d)(1)  are satisfied and
that EPA costs associated with the Remedial Design/Remedial Action
at this Site are fully recoverable pursuant to §9607(a).

Response to Comment 3.c.

This  comment  suggests  that EPA's  implemention  of the selected
remedy  will not  comply with  Section  9621(d) of CERCLA  and  is
inconsistent with this Section and that costs incurred by EPA are
therefore  not recoverable.   Section  9621(d)  requires  that EPA
consider  the  designated  or  potential  use  of   the  surface  or
groundwater,  the  environmental media affected,  the  purposes for
which such criteria  were developed and  the latest information when
deciding  whether  or not water quality criteria  under  the Clean
Water Act are relevant and  appropriate under the circumstances of
the  release or threatened  release.   This Section also outlines
criteria for establishing alternate concentration  limits to those
otherwise applicable for hazardous constituents.

The specific remedial action objectives for this Site include the
restoration  of groundwater quality  to its intended  use  as  a
potential source of drinking water by reducing contaminant levels
below State and  Federal drinking water standards where possible.
In   the  case  where   upgradient  contributions  prohibit  such
restoration for a peticular compound,  the  contaminent level will
be reduced to the upgradient level.   None of the residents in the
vicinity of the Site rely on private wells for potable water.  The
nearest public well  is located approximately one mile southwest and

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downgradient from the  Site.  Since the Site is located over a deep
recharge zone, there is the potential for cross-contamination of
the Magothy aquifer, which is the primary source of drinking water
for this area.  The possibility of contaminating the recharge basin
and driving  the  contaminants into  the  Magothy  aquifer  will  be
prevented by placing the reinjection wells into a relatively clean
upper aquifer and installing several  reinjection wells, so that the
treated water will be distributed over a larger  area.   This will
eliminate the excessive re-injection flow and will also prevent the
creation of a downward gradient.

Based on the ROD  and the above explanation, EPA maintains that the
requirements of §9621 (d) (2) (B) have been considered  and that EPA
costs associated  with the  Remedial Design/Remedial Action at this
Site are fully recoverable pursuant  to §9607(a).

Response to Comment 3.d.

This  comment suggests that  EPA's   implemention  of  the selected
remedy  fails  to  consider and implement Section  121(d)(4)(E)  of
CERCLA  and  that  costs  incurred  by  EPA   are  therefore  not
recoverable.  Section 121(d)(4)(E) enables  EPA to select  a remedial
action that does not attain a State standard  where the State has
not consistently  applied the standard.

The basis  for this comment  is  unclear.  The commenter  did not
identify any  particular state standard  which it believes EPA is
applying or  not  applying  here but  which  New York State  has not
consistently  applied.  The   selected remedial  action  and  the
contingency remedy, when complete, will meet ARARs as .specified in
the ROD.  EPA maintains that the requirements of §121(d) are being
complied with here and that EPA costs associated with the Remedial
Design/Remedial Action at  this Site are fully recoverable pursuant
to §9607(a).

Response to Comment 3.e.

This  comment suggests that  EPA's  implemention  of  the selected
remedy  fails  to  consider  and implement Section  9621(d)(4) (F) of
CERCLA  and  that  costs  incurred  by  EPA   are  therefore  not
recoverable.  Section  121(d)(4)(F) enables EPA to  select  a remedial
action that does not attain ARARs where  the remedial action is to
be paid for by the Hazardous Substance Superfund (the "FUND") and
the selection of a remedial  action that  attains  ARARs will not
provide  a balance between  the  need to  protect  public  health,
welfare and  the  environment and  the availabliity of amounts from
the Fund to respond to other sites which  prevent a threat to public
health, welfare or the environment.

The  selected remedial action and  the  contingency  remedy,  when
complete, will comply with applicable or relevant and appropriate
environmental standards set  forth  in the ROD.   In selecting the
remedial  action  for  this site,   it  was  not necessary  for EPA to
apply  less  stringent  cleanup standards  in order  to increase the

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availability of amounts  from  the  Fund  to respond to other sites.
EPA maintains that the requirements of §121(d)  are being complied
with   here  that   EPA  costs  associated   with   the   Remedial
Design/Remedial Action at this Site are fully recoverable pursuant
to §9607(a).

Response to Comment 3.f.

This  comment  suggests  that   the selected  remedial  action  is
inconsistent  with  the  National  Oil  and  Hazardous  Substance
Pollution  Contingency  Plan ("NCP") ,  40 C.F.R.  Part 300  and that
costs incurred by EPA in implementing the remedy are therefore not
recoverable.    As  is.  the case  with  respect  to many  of  the
commenter's other comments, no basis is provided for this comment.
The comment simply makes a conclusory statement without identifying
particular provisions of the NCP with which the selected remedy is
allegedly inconsistent.

EPA maintains that the selected Remedial  Action has  been chosen in
accordance, to  the extent  practible,  with  the NCP  and  that EPA
costs associated with the Remedial Design/Remedial Action at this
Site are fully recoverable pursuant to §9607(a).

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Response to Comments 4. 5.  and 6

EPA believes that the basis for calculating the pumping rates
outlined in the ROD is reasonable.   In addition, a margin of
safety is built in to ensure that the plume is captured.
Additional pumping tests during the remedial design phase will
yield data by which a more  accurate estimate of the pumping rates
can be obtained (see Feasibility Study report of June 1989, page
61) .  EPA would like to see any documentation of calculations for
the pump rates set forth in the August 11,  1989 comments.

Response to Comments 7,a. and 7.b.

The possibility of contaminating the recharge basin and driving
contaminants into the Magothy aquifer will  be prevented by
placing the reinjection wells into  a relatively clean upper
aquifer area and installing several reinjection wells, so that
the treated water will be evenly distributed over a larger area.
This will eliminate the excessive re-injection flow and will also
prevent the creation of a downward  gradient as mentioned in
Comment 7.b.

Response to Comment 8

All reinjected groundwater  will be  below ARARs.

Response to Comment 9

Prior to groundwater reinjection, the iron  will be removed
through multimedia filters.  There  are many ways of doing this,
(e.g. pH change, flocculation, etc.).  At any rate, the
reinjection groundwater will meet ARARs.

Response to Comment 10

The value of 1.1 ppb of trans-l,2-dichloroethene is the
equilibrium value as calculated from partition coefficients.  The
actual value to achieve groundwater standards will be in the
vicinity of 10 ppb as specified in  the ROD, but this can only be
established during permeability studies. One cannot compare the
contaminants in the soil to that of the groundwater on a one to
one basis.  The former values are given on  a mass basis, whereas
the latter are expressed as mass per volume.  The detection limit
for VOCs is less than 1 ppb.

Response to Comment 11

Originally the source of contaminants existed above the water
table.  The model used this initial condition to simulate the
source of contaminants currently in the glacial aquifer.
Analytical results during the remedial investigation were used to
calibrate the groundwater model. The predicted results were
consistent with actual data.  Natural attenuation, such as
dilution and degradation have not been considered in determining

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the soil action levels.  However, adsorption and dispersion have
been modeled to determine contaminant plume concentration.  The
value of i.l ppb of trans-l,2-dichloroethene is the equilibrium
value calculated from the partition coefficient.  See response to
Comment 10 above.

Response to Comments 12 and 13

Since most of the site is paved, volatilization of VOCs will be
minimal.  It is unlikely that there will be a substantial upward
migration of the contaminants from the groundwater through the
soils to the surroundings.  Specific cleanup levels for the
contaminated soils on site will be established during the
remedial design of the remedy.  These action levels will be
established using site-specific information generated during the
treatability studies.  It is envisioned that the establishment of
such levels will consider attenuation and dilution of
contaminants and the impact of such factors on the loading to the
groundwater.

Response to Comment 14

The private wells mentioned in this comment are downgradient of
the site, not upgradient.  The second operable unit will address
upgradient sources of contamination.

Response to Comments 15 through 17

Since offsite contamination upgradient of the SMS Instruments
site is suspected to be contributing to the groundwater
contamination at the site, a second operable unit will be
initiated to investigate those sources and alternatives for their
remediation.  This will also identify additional PRPs if any and
may also provide additional information regarding SMS's
contribution to the groundwater contamination in the area.  The
upgradient concentration of trans-1,2 dichloroethene has been
incorporated into Table 1 of the ROD and was considered when
selecting the remedy.

Response to Comments 18. and 19

In conducting the remedial action, EPA must meet specific action
levels including Safe Drinking Water Act Maximum Contaminant
Levels (40 CFR 141.11-141.16) outlined in the ROD which are not
based on classes or categories of compounds, but rather on
specific chemicals.

Response to Comment 20

Since this a Superfund site located in New York State, and
because the groundwater at the site is classified as lib, the
drinking water standards established by New York State are ARARs

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and should be adhered to unless a waiver is justified.   Due to
the existence of an upgradient source,  the remedial action
selected will not meet chemical-specific ARARs or be capable of
restoring the area groundwater to applicable groundwater quality
standards.  The upgradient source area  will be addressed as part
of the second operable unit.

Response to Comment 21

As mentioned before, the remedial design study will yield
additional data, by which a more accurate design of the treatment
system can be obtained.  See also response to Comment 3.c.  It is
EPA and NYSOEC policy to remedy groundwater classified as a Class
I or II aquifer.  If treated, the upper aquifer could be used as
a potable water source.

Response to Comment 22

Treatability studies will be conducted  to determine the time and
effectiveness involved in the soil remediation.  The capital cost
for soil remediation via air stripping  will be similar or
slightly lower than the one using steam as a stripping agent.
The estimated 9 month remediation time  for air stripping is
longer than the five month estimated time for steam stripping.

Response to Comments 23 and 24

The remediation times are approximate and provide for reasonable
margins of error.  The remediation time of 29.5 years mentioned
in Comment 24 assumes a 1400 ppb trans-1,2 dichloroethene
concentration throughout the plume.  This contaminant
concentration  is a "hot spot"; it was  detected in one location.
EPA's calculations were performed using a representative value of
580 ppb.  The remediation times specified in the ROD are
therefore reasonable.

Response to Consents 25 and 26

The 4 years remediation time for the selected remedy as predicted
by groundwater modeling are based on best available current data.
New data to be obtained during the remedial design and additional
groundwater modeling will yield better  data by which a more
accurate estimate of the remediation time can be made.   EPA
believes that remediation times as indicated in the PRAP are
fairly accurate.  The No-Action option  cannot be selected, since
it will take an unacceptable amount of  time, well over 20 years,
for the groundwater to reach health based levels.  EPA is
required to remedy the soil as well as  the groundwater to protect
human health and the environment.  The  selected remedy will
achieve this goal.

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Response to the Concluding Section

EPA believes that the calculated pumping rates,  soil action
levels to achieve groundwater ARARs, remediation times, capital
and present worth costs, operation and maintenance costs are
reasonable based on the data obtained during the remedial
investigation conducted at the site.  However, the RI/FS is not
intended to be a design document and as such these estimates may
be refined during the design stage of the remedial action.

B.   RESPONSE TO SEPTEMBER 5. 1989 LETTER

A second operable unit -is planned which will address suspected
upgradient sources of contamination.

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EPA's RESPONSE:  EPA stated that,  through administrative and/or
legal actions, EPA may attempt to  recover the costs of both the
study and the cleanup from the Potentially Responsible Party
(PRP).

COMMENT:  A citizen asked EPA what the estimated cost is for the
site cleanup.

EPA's RESPONSE:  EPA estimates that,  at this  time,  remediation
would cost 1.1 million dollars.

HEALTH/RISK ASSESSMFMT

COMMENT:  Several residents were concerned whether  private wells
were affected by the contamination and to what extent private
well water could be used.

EPA's RESPONSE:  EPA responded that private well owners 1/2 mile
south of the site should be aware  that their  wells  are within the
areas of concern.  Private wells drawing water from the upper
glacial aquifer, 30-50 feet deep,  which are not generally used
for drinking water, are likely to  be contaminated.   EPA also
stated that private wells within 1/2 mile downgradient of the
site are not considered potable water sources.   According to the
Department of Health, all residents and businesses  in the
vicinity of the site are served by public water. If residents
choose to maintain private wells,  they should do so for
irrigation purposes and not as a source of drinking water.

COMMENT:  A citizen inquired whether the air  emissions levels
will be within current State and Federal regulatory standards
using the in-situ steam stripping  method.

EPA's RESPONSE:  EPA stated that in order to  comply with air
emission requirements, an above ground vapor-phase  treatment unit
would be used to remove organics from the emissions.  Spent
carbon would be treated and disposed of an approved hazardous
waste facility.
                               11

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IV.  REMAINING CONCERNS

Citizens and local officials remain concerned about the
innovative aspects of the in-situ steam stripping technology.
The citizens' greatest concern was the possibility of unexpected
problems associated with this method and stressed their concern
that it could cause extensive delays in site remediation.

COMMENT:  A concerned citizen asked if the steam stripping
alternative proves unsuccessful, does EPA have an alternate
remediation plan to avoid further cleanup delays.

EPA's RESPONSE:  Innovative air stripping has proven successful
on Superfund sites.  Therefore, EPA does not expect steam
stripping to be unsuccessful.  In the event that steam stripping
is unsuccessful, stripping of the soil with air could be
performed with the same equipment.  Since the residents were
concerned with potential problems with both air and steam
stripping, EPA has decided to incorporate a contingency plan into
the remedy selections.  EPA has selected Alternative 4b  (Source
Removal and Off-Site Incineration) as a contingency remedy.  This
contingency remedy would eliminate any unnecessary delays in the
remediation at the SMS Instruments Site and would still achieve
remediation of the soils.
                                12

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V.   WRITTEN COMMENTS RECEIVED BY EPA AND EPA RESPONSES TO THESE
     COMMENTS.

This section contains the written letters received by EPA during
the public comment period, and EPA's written responses to these
comments.
                                13

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                                                                    AUG 1 6 1989
HARRY E.KRCINOLCR (1919-1984)
LEE S KREINOLER
PAUL S. EDELMAN
MELVIN I. FRIEDMAN
MARC S. HOLLER
FRANCIS G.FLEMING*
STEVEN R. POUNIAN
JAMES P. KREINOLER
DAVIO C. COOK
                        KREINDLER & KREINDLER
                              IOO PARK AVENUE
                           NEW YORK, NY IOOI7-559O
                        CABLC"KMC1NOLAIR NCW YORK"
                         TCLCCOPICM (212) B72-0432
MILTON G. SINCOFF
DONALD DREW GOLDBERG
STANLEY D. BERNSTEIN
     COUMSCL
                          August 11, 1989

CERTIFIED MAIL - RETURN RECEIPT REQUESTED
ARTHUR H. ROSENBERG
DAVID BEEKMAN
MARYANN RYAN
HENRY A. GLUCKSTERN '
LORI B. LASSON
NOAH H. KUSHLErSKY*
DANIEL M. KOLKO
• LANCA I. RODRIGUEZ*
DAVID FIOL '
TOOO J. KROUNER

•ALSO AOHrrrto IN NCW JCMSCY
PCNNSYLVANIA AMO ADIZOM*
•ALSO AOMrrrto IN NCW jcnscr
   Elena Kissel,  Esq.
   Assistant Regional  Counsel
   United States  Environmental Protection Agency
   26 Federal Plaza
   New York, New  York   10278

   Re:  S.M.S. Instruments,  Inc. Uncontrolled Hazardous
        Substance Facility;  Comments, Suggestions and
        Objections of  SMS Instruments, Inc.  on EPA's RI/FS
        and Proposed Remedial A'ction Plan dated 7/14/89
   Dear Ms. Kissel:

        Enclosed  please find triplicate counterpart originals of SMS
   Instruments, Inc.'s comments, suggestions and objections to the
   RI/FS and Proposed  Remedial Action Plan.
        Once the  Agency has  formulated its responses to the comments
   considered during the comment period, I would appreciate, and am
   now requesting, an  opportunity to review  the entire Agency
   administrative file on SMS Instruments, Inc. prior to the Record
   of Decision being sent to the Regional Administrator for his
   consideration.  Please write me to suggest some times and a
   location where I can perform such a review.
                                    Sincerely yours,
                                                     NDLER
   Enclosures

   HG:mm

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               BEFORE THE REGIONAL ADMINISTRATOR
                         UNITED STATES
                ENVIRONMENTAL PROTECTION AGENCY
                           REGION II
                        26 Federal  Plaza
                    New York, New York 10278
In the Matter of                :
S.M.S. Instruments, Inc.        :
Uncontrolled Hazardous Substance:   COMMENTS IN RESPONSE TO
Release Facility,                      EPA's PROPOSED
                                :     REMEDIAL ACTION PLAN
Deer Park, New York
  COMMENTS, SUGGESTIONS AND OBJECTIONS OF SMS INSTRUMENTS,  INC.
        ON EPA REGION II's PROPOSED REMEDIAL ACTION PLAN
          PLEASE TAKE NOTICE that SMS  Instruments, Inc.,
appearing through its counsel,  Kreindler & Kreindler, Henry
Gluckstem, of counsel, hereby submits its comments with respect
to EPA's Final Remedial Investigation  Report and Final
Feasibility Study, respectively dated  February 1989 and June
1989, for the SMS Instruments,  Inc.  uncontrolled hazardous
substance release facility,  Deer Park, New York (hereinafter,
"the facility").
          By submitting these comments, SMS Instruments, Inc.
neither admits nor acknowledges that it is the source of
contaminants allegedly identified on property it currently owns
in Deer Park, New York.  Furthermore,  SMS Instruments, Inc.
admits no liability to the United States or to any other entity
for any condition alleged to currently constitute a release to
the environment of hazardous substances, pollutants or contam-

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                               -2-
inants under the Comprehensive Environmental Response, Compensa-
tion, and Liability Act, 42 U.S.C. §9601 et sea..  identified in
connection with property it owns in Deer Park, New York.
Moreover, SMS Instruments, Inc. denies that any condition
occurring on its property presents an imminent and substantial
endangerment to human health, welfare or the environment.
          SMS Instruments, Inc. reserves all rights to further
comment upon or object to actions taken by the United States at
its facility as permitted by law, regulation or Agency practice,
and to defend against any claims made with respect to such
alleged releases of hazardous substances, pollutants or
contaminants or to any claims made for costs alleged to have been
incurred by the United States or any other entity in removing,
remedying, or otherwise responding to any such alleged releases.
          Comments, Suggestions and Objections With
          Respect to EPA's Proposed Migration
          Management Alternative	
          1.   On the basis of its RI/FS, EPA has elected to
approach the contamination attributed to the site activities of
SMS Instruments, Inc. by instituting controls based partially
upon migration management.  To accomplish this goal, EPA proposes
to design, install, operate and monitor a groundwater extraction,
treatment and re-injection system, "Alternative 2b" of the
numerous remedial alternatives scoped for the site.
          2.   An extraction well located offsite will
purportedly capture the contaminated groundwater plume and convey

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                               -3-
the water so obtained to air  stripping  towers which will  reduce
the level of contaminants of  the  influent  concentration to levels
below selected ARARs.  Groundwater  obtained  in  this manner is
proposed to be re-injected to soils overlying the  upper glacial
aquifer through wells located generally at or near the northern
perimeter of the facility.
          3.   SMS Instruments, Inc.  respectfully  suggests that
the implementation of the migration management  system currently
proposed by EPA will result in a  remedy which
               a.   fails to  meet the requirements of, or to
               consider the decisional  elements required  to be
               taken into account under, 42  U.S.C. §9621(b)(l),
               thereby rendering  un-recoverable, pursuant to the
               limitations on cost  recovery  imposed upon
               responses to releases taken by the  United  States
               in 42 U.S.C. §9607(a)(4)(A),  those  costs incurred
               at the facility;
               b.   fails to  comply with,  and is inconsistent
               with, 42 U.S.C.  §9621(d)(l),  thereby rendering un-
               recoverable, pursuant to the  limitations on cost
               recovery imposed upon responses  to  releases taken
               by the United  States in  42  U.S.C. §9607(a)(4)(A),
               those costs incurred at  the facility;
               c.   fails to  comply with,  and is inconsistent
               with, the decisional factors  set forth in
               42 U.S.C. §9621(d)(2)(B), thereby rendering un-

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                               -4-
               recoverable, pursuant to the limitations on cost
               recovery imposed upon responses to releases taken
               by the United States in 42 U.S.C. §9607(a)(4)(A),
               those costs incurred at the facility;
               d.   fails to consider and implement 42 U.S.C.
               §9621(d)(4)(E), thereby rendering un-recoverable,
               pursuant- to the limitations on cost recovery
               imposed upon responses to releases taken by the
               United States in 42 U.S.C. §9607(a)(4)(A), those
               costs incurred at the facility;
               e.   fails to consider and implement 42 U.S.C.
               §9621(d)(4)(F), thereby rendering un-recoverable,
               pursuant to the limitations on cost recovery
               imposed upon responses to releases taken by the
               United States in 42 U.S.C. §9607(a)(4)(A), those
               costs incurred at the facility; and
               f.   is inconsistent with the National Contingency
               Plan, 40 C.F.R. Part 300, thereby rendering un-
               recoverable, pursuant to the limitations on cost
               recovery imposed upon responses to releases taken
               by the United States in 42 U.S.C. §9607(a)(4)(A),
               those costs incurred at the facility.
          4.   As part of its migration management plan, EPA has
proposed to implement an excessive, inappropriate and unsuitable
groundwater pumping regime.  As a result of EPA's error in
calculating groundwater pumping quantities appropriate to the

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                              -5-
cleanup goals which EPA believes should be attained  at the  site,
the zone of influence which will be developed will capture  a
total of approximately 900  (NINE HUNDRED) feet of extraneous
water lateral to the center line of the modeled plume.   Through
well borings, EPA has contended that it has confirmed that  the
extent of the contaminant plume has been accurately  modeled.
Under the Proposed Remedial Action Plan, however, more water will
be drawn from outside the plume than inside the plume.   This is
clearly improper and will lead to selection and implementation of
an inappropriate remedy.
          5.   EPA's serious  error will result in
               a.   oversizing of all piping, pumping, and
               related equipment;
               b.   consumption and waste of several times  as
               much electricity as is actually needed to properly
               cleanse the upper glacial aquifer;
               c.   construction, operation, and maintenance of
               unnecessary air stripping and related residuals
               collection and disposal equipment for treatment;
               d.   construction, operation and maintenance of an
               inappropriately sized groundwater re-injection
               system; and
               e.   possible  entrainment into the treatment
               regime of unknown glacial contaminants, with
               attendant potential for exposure of the unconfined
               Magothy aquifer to contaminants.

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                               -6-
          6.   Calculations indicate that pumping of groundwater
removed from the plume at a rate of approximately 180 gpm maximum
would capture the plume under ideal conditions, which conditions
EPA has apparently assumed to exist in the soils typical of the
affected area.  By utilizing more than one pumping well, an idea
which EPA has considered already with respect to its improperly
sized groundwater treatment scheme, even a lower pumping rate
could be sufficient to accomplish EPA's stated goals.
Calculations and modeling on which SMS Instruments, Inc. basis
these comments are attached as Exhibit A, appended hereto and
made a part hereof.
          7.   By pumping at the rate currently projected by EPA
and re-injecting water withdrawn at the southern perimeter of the
facility boundary, EPA raises the possibility of
               a.   the excessive re-injection flow disturbing
               and contaminating the adjacent recharge basin
               system by driving upgradient pollutants from their
               currently understood course of flow; and/or
               b.   creating an unknown hydraulic gradient which
               may have the potential for driving both upgradient
               and facility-originated contaminants into the
               Magothy aquifer.
          8.   The apparent lack of a confining zone between the
upper glacial and Magothy Aquifer in the vicinity of the facility
requires that the management of re-injected water containing
contaminants above ARAR levels be especially carefully

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                               -7-
scrutinized and conservatively managed so that no drinking water
supply is subjected to the possibility of cross-contamination.
The oversized re-injection system, as presently proposed to be
operated, may pose a threat to the Magothy system.
          9.   SMS Instruments, Inc.  takes the position that
heavy groundwater iron burdens recognized by EPA in its RI/FS as
prevailing in the Long Island upper glacial aquifer generally,
and in the geographic region occupied by the SMS Instruments,
Inc. facility in particular, will require an infiltration-
percolation lagoon to avoid interference with successful re-
injection through clogging of well screens.  Treatment of iron
proposed by EPA will not necessarily  eliminate the problem of
adequately handling re-injection flows,  as was noted during the
public hearing on the proposed remedial action plan.  The sheer
volumes of water involved in the projected pumping regime, when
compared to the realistic potential methods of accomplishing re-
injection, could render an injection  well infeasible.

          Comments, Suggestions and Objections
          With Respect to EPA's Proposed
          Soil Cleanup Criteria, Action Levels
          and Application of ARARs	
          10.  EPA has established excessively and unnecessarily
restrictive and conservative soil cleanup levels for the SMS
Instruments, Inc. facility.  EPA's theoretical partitioning
coefficients approach for estimating  maximum permissible soil
concentrations, when reduced to action levels, yield ridiculous
results.  For example, establishment  of a trans-1,2-

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                               -8-
dichloroethene action level at 1 ppb is inconsistent with the
actual representative detection limit of that contaminant in
soils, which, for established GC/MS methodologies, is in the
range of 100 ppb.  Additionally, the calculations made in the
RI/FS are incorrect.  Using the method described in the RI/FS to
determine soil action levels, soil action levels must be higher
than groundwater action levels.  The groundwater action level is
5 ppb; the soil action level must be above that.
          11.  EPA's approach incorrectly assumes that the entire
site contaminant loading is situated directly over the water
table.  EPA's approach furthermore fails to take into con-
sideration natural attenuation, dilution, and biodegradation
effects.  Calculations performed by EPA in support of the FS
failed to consider the effects of infiltrating rainwater in the
unsaturated zone.  As a result, EPA has incorrectly characterized
the actual distribution of soil contaminants with respect to the
glacial aquifer.  The 1 ppb level established as an action level
for trans-l,2-dichloroethene is unachievable, because it is
unmeasureable by any precise fi.e.. scientifically repeatable
with a suitable degree of accuracy) method known to SMS
Instruments, Inc..
          12.  Additionally, EPA has failed to take into
consideration the effects of the volatility of each of the VOCs
alleged to be present on the facility.  A certain loss of the
alleged contaminant loading will occur over time as a result of
-the volatilization process, and such natural loss mechanisms

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                               -9-
must be accounted for in evaluating  an  element  of a preferred
remedy.
          13.  Additional dilution of contaminant loadings occurs
at such time as contaminants reach groundwater.   A point of
compliance for purposes of evaluating performance of the selected
remedy needs to be established in light of  the  above-referenced
attenuation and loss factors.  After that is  accomplished,
modeling of the movement of pollutants  through  the unsaturated
zone can be performed, and rational  (i.e.,  measurable and
attainable) soil cleanup criteria can be established.
          14.  The SMS Instruments,  Inc. facility has been
acknowledged by EPA to be located in an area  of Deer Park which
experiences area-wide upper glacial  aquifer groundwater volatile
organic contamination.  The contamination which EPA contends it
has documented at the SMS Instruments,  Inc. facility is actually
attributable to a variety of off-premises release sources.  The
average upgradient total volatile organic contaminant level is
approximately 115 ppb, based upon the results of sampling potable
private veils (veils 1-8 as reflected in Table  5-2 of the RI)
upgradient of the SMS Instruments, Inc.  site.
          15.  Despite the fact that EPA has  documented numerous
sources of upper glacial aquifer contamination  uparadient to SMS
Instruments, Inc., EPA has, to date, chosen to  consider SMS
Instruments, Inc. as a single PRP site.  If EPA persists in
maintaining this position as a matter of enforcement strategy,
financial resources which ovners or  operators of other

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                               -10-
contaminan-b sources may be aisle to bring to bear on
implementation of a remedy will not be tapped in the course of
addressing attainment of ARARs as applied to the release
allegedly occurring from within the SMS Instruments, Inc.
property boundaries.
          16.  Accordingly, the upgradient contamination which
has been detected and which is a not insignificant contributing
source to the total in-ground pollutants alleged to exist at the
SMS Instruments, Inc. site should be appropriately reflected in
all final action levels applied to, and expected to be attained
by, a remedy implemented at the SMS Instruments, Inc. site.
          17.  While Table 10-2 of the FS reflects an action
level for trichloroethene of 14 ppb representative of detected
offsite upgradient background levels, other contaminants of
interest, such as trans-l,2-dichloroethene, are not similarly
compensated for.  Trans-l,2-dichloroethene should have been
reflected at no less than 35 ppb under a more reasonable
approach, as applied to a sole PRP whose site is receiving more
than negligible contamination from upgradient sources.
          18.  SMS Instruments, Inc. objects to the action levels
currently expressed in the FS and suggests adoption of a total
volatile oraanics action level equal to 100 ppb.  Existing
pollutant sources independent of SMS Instruments, Inc. have
rendered the upper glacial aquifer unsuitable as a. source gjf
potable water.  Application of SMS Instruments, Inc.'s recom-
mendation of a total volatile organic level of 100 ppb will, at

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                              -li-
the same time (a) establish a fair burden on the sole area PRP
from which EPA will be demanding cleanup of an aquifer admittedly
polluted by other entities and (b)  also assure full protection of
the public health, welfare and the environment,  including
prevention of further degradation of the upper glacial aquifer
and prevention of any intrusion into the Magothy aquifer.
          19.  Furthermore, if a 100 ppb total volatile organic
constituent goal is selected, it may be possible to capture the
relevant plume with a pump and treat system downscaled to a
pumping rate of 100 gpm,  capturing a plume approximately 150
feet wide.  Both re-injection costs and technical re-injection
hurdles stemming from residual groundwater iron will be reduced.
Only a single stripping tower will be needed.   Fewer final
irreducible wastes requiring ultimate disposal will be created.
Cleanup time will be reduced significantly.  Dispersion effects
will decrease the concentration of the plume over a relatively
short distance.   No incremental degradation of the upper glacial
aquifer will result as compared to the selected remedial
alternative resulting from the present FS.  No impact on the
Magothy Aquifer at a level exceeding a maximum contaminant level
(MCL) for drinking water is projected from such a re-scaling of
the groundwater treatment system, but costs and system complexity
would be markedly reduced.
        ~ 20.  Xylene is a non-carcinogenic volatile organic
constituent of the in-ground pollutant loadings which EPA claims
to have detected at the SMS Instruments, Inc.  facility.  The

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                               -12-
5 ppb action level selected for this constituent is based upon a
New York State standard.  Considering health-based criteria.
however, an appropriate level for xylene in drinking water would
be 44 ppb.  Forty-four parts per billion xylene is the health-
based level established by the State of New Jersey, for example.
If the basis for establishment of the action level for xylene is
claimed to be related to potential for migration of that
constituent to the Magothy Aquifer,  or to human health effects,
then selection of a more stringent criterion, as presently is the
case, is unwarranted.
          21.  The upper glacial aquifer has been established by
the RI to be unused as a potable water source.  Its natural
properties, exclusive of any pollutant loadings, render the upper
glacial aquifer unusable as a potable water source.  The TDS
maximum in an upgradient off site well were at 3980 ppm, rendering
the source non-potable.  The process of establishment of levels
of residual contaminants resulting from implementation of a
groundwater cleansing program in the vicinity of the SMS
Instruments, Inc. site should accomplish two goals:  first, it
should be protective of the Magothy Aquifer; second, it should be
protective of any surface waters to which discharge of the upper
glacial aquifer may occur.  Both these goals may be met with less
stringent contaminant action levels, while at the same time
lowering the cost of performing the projected remedial option and
increasing the probability that costs incurred by the United
States meet the legal requirements for recoverability.

-------
                              -13-
          22.  As EPA readily admits,  the preferred EPA soil
remedial alternative for the SMS Instruments,  Inc.  site is not a
proven technology.  Time estimates for completion are impossible
to calculate at the present time.   O&M costs of such a system are
relatively high.  The system may not be capable of attaining the
unusually low (and, SMS Instruments, Inc. contends, improperly
imposed) soil remediation criteria established by the FS.  An
incremental cost factor equal to the projected cost of the vapor
extraction O&M, without addition of steam, should have been
added to the project cost and considered when comparing the
screened alternatives to accommodate the cost factor of unknown
efficacy of the proposed alternative.

          Comments, Suggestions and Objections With
          Respect to EPA's Projected Time Frame for
          Accomplishing Remedial Goals at the SMS
          Instruments. Inc. Superfund  Site	
          23.  EPA has established an unrealistic projection of
the time required to accomplish the remedial objective through
the proposed alternative selection.  As a result, EPA has
compared and ranked remedial alternatives under a set of false
premises related to cost-effectiveness.  Re-assessment of actual
costs and projected effects on the resource desired to be
protected, the Magothy Aquifer, could result in selection of a
lower cost option as the proposed remedial alternative.
          24.  That EPA has misjudged the effect of operation of
the proposed system is easy to see.  A total area-wide volume
calculation of the trans-l,2-dichloroethene plume shows that the

-------
                               -14-
capture area of the proposed groundwater control well system is
64 million cubic feet.  Adjusting for porosity at the porosity
assumption used in the RJ yields 22.4 million cubic feet of water
per pore volume for the trans-l,2-dichloroethene plume.  Ad-
justing the pump rate to 182.25 gpm to allow for capture of the
actual plume of contaminants of concern, and dividing the
resulting 35,083 ft3 of "daily flow through the system into the
volume which the scheme must address for a pore volume yields a
pump time of 635 days.  Under the retardation factor for trans-
1,2-dichloroethene assumed by EPA in its RI, 29% will be in the
dissolved phase.  Alternatively, 71% will be attenuated in a pore
volume.  Therefore, it may require up to 17 such pore volumes to
reduce a 1,400 ppb plume concentration of trans-1,2-
dichloroethene to the selected ARAR for that constituent.
Multiplying the two quantities, it is seen that it could take
29.5 years to accomplish this goal in a reasonably designed
system sized to the actual plume conditions.
          25.  Furthermore, EPA's own research into pump and
treat remedies has revealed that such technologies often take
substantially longer to accomplish than is revealed by
calculations.
          26.  If the O&M costs of such a system are recalculated
and the time consumed in completing the goals under the selected
alternative is compared to the upper glacial aquifer cleansing
accomplished with the no action alternative (Alternatives la, 3),
it is clear that before the Regional Administrator can be in a

-------
                              -15-
position to select a factually-based remedy for the SMS Instru-
ments, Inc. site, the remedial options must be re-appraised to
determine whether another option,  such as the no action
alternative, is equally suitable or even preferential to the
currently proposed remedy for dealing with the pollutant
situation which EPA believes to be present at the site.

                           CONCLUSION
          EPA must take into account two major factors prior to
finalizing the RI/FS and entering the ROD stage.  First, the
area-wide groundwater contamination problem must be fully
integrated into any choice of remedial alternatives.  Clearly,
what we are dealing with here — the upper glacial aquifer —  is
not a potable water aquifer,  due to naturally high TDS levels and
off-site anthropogenic sources.   Setting groundwater and soil
cleanup criteria to be at or below existing background water
quality and health-based drinking water standards is neither
cost-effective, realistic or attainable.  Pursuing such a course
will result only in unnecessary expense, while at the same time
creating false and unjustified expectations in the public.
     SMS Instruments, Inc.'s second concern is that the FS has
several major important technical errors.  These include
incorrect soil action levels as well as incorrect pumping rate
design for plume remediation.  This, along with the formerly
mentioned FS errors, will result in the expenditures of large
sums for unattainable results.

-------
                               -16-

          SMS  Instruments, Inc. respectfully requests that the

Regional Administrator consider the comments, suggestions and

objections set forth herein, and that appropriate reconsideration

be given to, and re-evaluation made with respect to, the proposed

remedial action prior to the Regional Administrator's selection

of a remedial  action and its embodiment in a Record of Decision

for the SMS Instruments, Inc. site.

                                Respectfully submitted,



DATED:  August 11, 1989
                                Aenrv x£luc  .

                                KREINDLER & KREINDLER
                                Attorneys for SMS Instruments,
                                  Inc.
                                100  Park Avenue
                                New York, New York  10017
                                212-687-8181

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                        KREINDLER & KREINDLER
                              IOO PARK AVENUE
                           NEW YORK, NY IOOI7-559O
MARRY C. KREINOLER (1010- I9W>  -           .                         ARTHUR M. ROSENBERG
LEE S. KREINOLER                   (212) 687-8181                 DAVID BEEKMAN
PAUL S. EOELMAN                         	    '                 MARYANN RYAN
MELVIN I. FRIEDMAN               CABLC"KRKINDLAIR NCW YORK"             HENRY A. GLUCKSTERN •
MARC 5. HOLLER                         	                     LORI B. LASSON
FRANCIS G. FLEMING*                  TCLCx:i*-83O3                 NOAM M. KUSHLEFSKY •
STEVEN R. POUNIAN                       	                    . DANIEL M. KOLKO
JAMES P. KREINOLER               TKLCCOPICR (212) 8T2-BO2              8LANCA I. RODRIGUEZ'
OAVIO C COOK                                                 DAVID riOL '
    	                                                    TOOD J. KROUNER
MILTON G. SINCOFF                                             -
DONALD DREW GOLDBERG                                          *LSO *8"IT™«» '" «*»
STANLEY D. BERNSTE.N             September 5, 1989
     COUNSEL

   CERTIFIED MAIL  - RETURN RECEIPT REQUESTED

   Elena Kissel, Esq.
   Assistant Regional  Counsel
   United States Environmental  Protection Agency
   26 Federal  Plaza
   New York, New York   10278

   Re:  S.M.S.  Instruments,  Inc. Uncontrolled
        Hazardous  Substance Facility	

   Dear Ms. Kissel:

        Enclosed please find an addendum to SMS Instruments, Inc.'s
   comments on the EPA's RI/FS  and Proposed Remedial  Action.  This
   late comment is submitted based upon information just brought to
   SMS'  attention  through a consultant.  Although  it  is submitted
   out of time with respect to the closing date for comments on the
   substantive matter  of remedy selection, since it does not
   directly affect the remedy issue in the same manner as SMS
   Instruments, Inc.'s August 11,   1989 comments, I believe that EPA
   will not be prejudiced if it gives the comment  full considera-
   tion.  My client, however, will be greatly  prejudiced if today's
   comment is  not  taken into consideration before  EPA proceeds to
   demand implementation of a remedy at the site from identified
   PRFs.

                                    Sincerely yours,

                                         IDLER
   Enclosure

   HG:mm

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