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..
Page
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3
4
5
5
6
12
17
18
21
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.
-------
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
1
i
1
* i
I
*O
,..,/
f
K
'o
/
/--... •«
-n
,
/ i
/ ^
SCALE
60 0 60
•••==••
u
B
0 '
. 9
r» i
100 1
•i
i
i
!/
/'* **
GRAJ
/ ,.,.
•
It. »•
•
3
0
or
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o
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.^
CM
P
U :,
A ^ -
i
INSTF
1 . PAVEM
1 FORME
LEACH
POOL
1 /
_&-^P
. /
i ,. n
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
-------
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
-------
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
-------
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
-------
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
-------
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
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APPENDIX
TABLES
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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
-------
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-
-------
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.
-------
-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
-------
-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.
-------
-4-
DATED: September 5, 1989
ictfully submitted,
& KREINDLER
Attorneys for SMS Instruments,
Inc.
100 Park Avenue
New York, New York 10017
212-687-8181
-------
APPENDIX V
RESPONSIVENESS SUMMARY
-------
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.
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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.
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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
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-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
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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.
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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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CALCULATION NO. 2
REG. VEL. INPUTS
HYD . COMIX GPD/FT2 ) •
lor in FT/DAY)-
(or in CM/DAYI-
HYD.GRADlFT/m-
EFF. POROSITY (DEC) -
REG. VELOCITY (FT/DAY)
(CM/PAY) 106.641
VEL.DSTR. INPUTS
REG.VEL. ( FT/DAY )-
REG. FLOW DIRECTION
(COMPASS DEGREES > -
E.~F. SAT. THICK (FT) -
EFF. POROSITY (PEC) -
WELL NO. 1
FLOW RATE(GPM)-
WELL X-COORD. (FT)-
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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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