United States         Office of
Environmental Protection   Emergency and
Agency            Remedial Response
                                           EPA/ROD/R02-91/161
                                           September 1991
x°/EPA
Superfund
Record of Decision
           Sinclair Refinery, NY

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50272-101
REPORT DOCUMENTATION i. REPORT NCX 2.
PAGE EPA/ROD/R02-91/161
4. TMemdSuMMe
SUPERFUND RECORD OF DECISION
Sinclair Refinery, NY
Second Remedial Action - Final
7. Author)*)



U.S. Environmental Protection Agency
401 M Street, S.W.
Washington, D.C. 20460
3. RedpimT* Accmtion No.
5. Report D«te
09/30/91
6.
8. Performing Organization Rept No.
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11. Corrtr»ct
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EPA/ROD/R02-91/161
Sinclair Refinery, NY
Second Remedial Action - Final

Abstract (Continued)

ROD addresses OU2, remediation of the remaining contaminated areas at the site located
within the 90-acre refinery area and the offsite tank farm including the contaminated
ground water beneath the refinery.  Data collected during the OU2 RI have not shown
contaminant levels in landfill ground water to be in excess of Federal and State
standards;  therefore, EPA has chosen not to address landfill ground water remediation
under this OU2 ROD.  The primary contaminants of concern affecting the soil and ground
water are VOCs including benzene and xylenes, semi-volatile compounds including
naphthalene and nitrobenzene, and metals including arsenic and lead.

The selected remedial action for this site includes excavating soil contaminated in
excess of arsenic 25 mg/1 and lead 1,000 mg/1 to a depth of 1 foot; treating excavated
soil onsite prior to consolidation in the landfill; capping the landfill, and filling and
revegetating excavated areas; conducting long-term monitoring of biota, surface water,
ground water, and soil-gas to track any potential contaminant migration from the
sub-surface soil; onsite pumping and treatment of contaminated ground water followed by
discharging the treated ground water onsite to the Genesee River or offsite to the
publicly owned treatment works (POTW); and implementing institutional controls in the
form of local zoning ordinances.   This ROD also provides contingency measures for ground
water all or some of which may be implemented based on the monitoring data colleted.
These measures include variations in pumping rates, implementing engineering or
institutional controls, monitoring specified wells, reevaluation of remedial
technologies, and invoking chemical-specific ARAR waivers.  The estimated present worth
cost for this remedial action is $15,549,700, which includes an annual O&M cost of
$750,183 for 30 years.

PERFORMANCE STANDARDS OR GOALS:  Chemical-specific goals for soil include arsenic 25 mg/1
and lead 1,000 mg/1.  Ground water will be treated to attain Federal MCLs or State
standards.

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                          ROD FACT SHEET
SITE

Name:
Location/State:
EPA Region:
HRS Score  (date) :
NPL Rank  (date):

ROD

Date Signed:

Selected Remedy

Surface soils:
Subsurface soils:
Groundwater:
Capital Cost:
0 & M:
Present Worth:

LEAD

Enforcement, PRP Lead
Primary Contact (phone):
Secondary Contact  (phone)

WASTE

Type:
Sinclair Refinery
Wellsville, Allegany Co., New York
II
53.90 (6/83)
119 (9/83)
September 30, 1991
Excavate, treat, and dispose of in on-
site landfill surface soils that exceed
cleanup criteria for arsenic and lead.

Public awareness program and
institutional controls to manage
excavation scenarios that open exposure
pathway.

Pump and treat groundwater with goal of
achieving ARARs.  Treated groundwater to
be discharged into Genesee River.

$  3,897,500
$    750,183
$ 15,549,700
  Michael Negrelli (212-264-1375)
:  Kevin Lynch (212-264-6194)
Medium:
Origin:
Surface soil - metals.
Subsurface soil - VOCs, semi-volatiles,
metals.
Groundwater - VOCs, semi-volatiles,
metals.

Surface soil, subsurface soil,
groundwater.

Pollution originated as a result of
refinery operations from approximately
1901-1958.

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               DECLARATION FOR RECORD OF DECISION

SITE NAME AND LOCATION

Sinclair Refinery
Wellsville
Allegany County,  New York

STATEMENT OF BASIS AND PURPOSE

This decision document presents the selected remedial  action for
Operable  Unit 2  for  the Sinclair  Refinery  site,  located  in
Wellsville,  Allegany  County,  New  York,  which  was  chosen  in
accordance   with   the   Comprehensive   Environmental   Response,
Compensation,  and Liability  Act  of  1980,  as  amended  by  the
Superfund  Amendments  and Reauthorization  Act  of  1986, and  the
National Oil and Hazardous Substances Pollution Contingency Plan.
This decision document summarizes the factual and legal basis for
selecting the remedy for this  site.

The State of New York concurs with the selected remedy; a letter of
concurrence is attached.  The information supporting this remedial
action decision is contained in the administrative record for this
site, an index of which is attached as  Appendix F.

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, may present an imminent and substantial
threat to public health,  welfare,  or  the environment.

DESCRIPTION OF THE SELECTED REMEDY

The remedy selected for this operable unit at the Sinclair Refinery
site  is  a  final  remedy  for the  contaminated  surface  soils,
subsurface soils,  and groundwater  at the site.  The site soils and
groundwater contain elevated levels of volatile organic compounds,
semi-volatile organic compounds,  and  metals.

The major components  of the selected remedy include the following:

•    Excavation of surface soils  in excess of  25 ppm  arsenic and
     1000  ppm lead  to a depth of one (1) foot  to ensure that
     cleanup  goals are met.    The excavated soils will then be
     treated on-site to comply with the Resource Conservation and
     Recovery Act  (RCRA) Land Disposal Restriction (LDR) regulatory
     levels prior to consolidation into the on-site landfill.  A
     treatment option  will be chosen  and  incorporated  into the
     remedial design  after a pilot study is undertaken to determine
     the effectiveness and feasibility of several technologies.
     The landfill will then be capped  under an  ongoing remedial
     action, and the excavated area will.be backfilled with six (6)
     inches of clean  soil followed by  six (6) inches of topsoil and

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     revegetated.  Confirmatory sampling will be performed prior to
     backfilling to  ensure  that  the soils that  remain  after the
     excavation will have arsenic and lead concentrations that do
     not exceed the cleanup criteria.  Institutional controls, in
     the fcrm of local  zoning ordinances,  will be recommended to
     account for any construction activity that would alter present
     site use.   If such construction activity were to  occur, an
     evaluation  of the impacts of  the proposed  construction in
     regard to  site  contamination and exposure  pathways  will be
     provided to the New York State Department of Health for their
     review and comment.

•    Long-term surface water,  groundwater,  and soil-gas monitoring
     to  track  any  potential  contaminant  migration  from  the
     subsurface  soils.   Institutional controls,  in the  form of
     local zoning ordinances,  will be recommended in an attempt to
     control  any  future  site use  that  could  open an  exposure
     pathway to subsurface  soils, and  a  public awareness program
     will be implemented, including public meetings if requested by
     the public.

     Treatment  of  contaminated   groundwater with the  goal  of
     achieving applicable or relevant and appropriate requirements.
     Contaminated  groundwater  will  be  extracted and stored  in a
     central  collection tank  for treatment  in  an  above-ground
     system.  A treatment system to meet  discharge requirements
     will be developed  during  the design  phase following a pilot
     study to determine its effectiveness and feasibility.   The
     treated groundwater will  be discharged either  directly to the
     Genesee  River or  via  the Publicly  Owned  Treatment Works.
     Institutional  controls,  in  the  form  of  local  zoning
     ordinances, will be recommended to be implemented during the
     period of  remediation, and monitoring of the surface water,
     groundwater, groundwater seeps, and indigenous biota will take
     place to track any potential contaminant migration.

DECLARATION OP STATUTORY DETERMINATIONS

The  selected  remedy  is protective  of   human  health  and  the
environment, complies with Federal and  State requirements that are
legally applicable or  relevant and  appropriate to the remedial
action, and  is  cost effective.   This remedy  utilizes  permanent
solutions and alternative  treatment technologies  to the maximum
extent practicable for this  site.  Because  treatment is being used
to address the principal threats at the  site, this remedy satisfies
the statutory preference for  treatment as  a  principal  element of
the remedy.

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As the  remedy for  this  Operable Unit will  result  in  hazardous
substances remaining  on the  site above  health-based  levels,  a
review will be conducted within five (5)  years after commencement
of the remedial action, and every five years thereafter, to ensure
that the remedy continues to provide adequate protection of human
health and the environment.
    X
Cohstantine Sidamon-Eristof
Regional Administrator

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               DECISION SUMMARY

            SINCLAIR REFINERY  SITE
             WELLSVILLE,  NEW YORK
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

                  REGION II

                   NEW YORK

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                        TABLE OP CONTENTS



DECISION SUMMARY                                              PAGE

I.    SITE LOCATION AND DESCRIPTION	  1

II.   SITE HISTORY AND ENFORCEMENT ACTIVITIES	..  2

III.  HIGHLIGHTS OF COMMUNITY PARTICIPATION	  3

IV.   SCOPE AND ROLE OF OPERABLE UNIT	  4

V.    SUMMARY OF SITE CHARACTERISTICS	  5

VI.   SUMMARY OF SITE RISKS	  6

VII.  DESCRIPTION OF ALTERNATIVES	 10

VIII. SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES	 17

IX.   SELECTED REMEDY	 25

X.    STATUTORY DETERMINATIONS	 27



ATTACHMENTS

APPENDIX A - FIGURES

FIGURE 1.  SITE LOCATION MAP
FIGURE 2.  SITE MAP
FIGURE 3.  SURFACE SOILS ABOVE CLEANUP LEVELS

APPENDIX B - TABLES

TABLE 1.  CHEMICALS DETECTED IN SURFACE SOILS
TABLE 2.  CHEMICALS DETECTED IN SUBSURFACE SOILS
TABLE 3.  CHEMICALS DETECTED IN GROUNDWATER
TABLE 4.  RISK ASSESSMENT CHEMICALS OF POTENTIAL CONCERN
TABLE 5.  POTENTIAL MIGRATION PATHWAY AND EXPOSURE ROUTE
          EVALUATION
TABLE 6.  CRITICAL TOXICITY VALUES
TABLE 7.  SUMMARY OF NON-CARCINOGENIC RISKS
TABLE 8.  SUMMARY OF CARCINOGENIC RISKS
TABLE 9.  CHEMICAL-SPECIFIC ARARs
TABLE 10. ACTION-SPECIFIC ARARs
TABLE 11. LOCATION-SPECIFIC ARARs

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APPENDIX C - GUIDANCE DOCUMENTS

DOCUMENT 1.  DETERMINING WHEN LDRs ARE APPLICABLE TO CERCLA
             RESPONSE ACTIONS
DOCUMENT 2.  INTERIM GUIDANCE ON ESTABLISHING SOIL LEAD CLEANUP
             LEVELS AT SUPERFUND SITES
DOCUMENT 3.  RISK BASED SOIL CLEANUP LEVELS FOR THE SINCLAIR SITE
DOCUMENT 4.  NEW YORK STATE AMBIENT WATER QUALITY STANDARDS AND
             GUIDANCE VALUES
DOCUMENT 5.  FEDERAL AND STATE MAXIMUM CONTAMINANT LEVELS FOR
             DRINKING WATER

APPENDIX D - NYSDEC LETTER OF CONCURRENCE

APPENDIX E - RESPONSIVENESS SUMMARY

APPENDIX F - ADMINISTRATIVE RECORD INDEX

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I.  SITE LOCATION AND DESCRIPTION

The Sinclair Refinery site is situated between the  Genesee River
and  South  Brooklyn Avenue,  one-half  mile  south  of  downtown
Wellsville, in Allegany County,  New  York (see Figures 1  and 2).
According  to  1989 estimates, the  population of  the Village  of
Wellsville  is  5,070 persons.  The  site can  be  viewed as three
separate areas comprised  of a 90-acre  refinery  area, a  10-acre
landfill  area,  and  a  14-acre  off-site  tank  farm,   located
approximately one-quarter mile west of the  site.

The refinery area is characterized by generally flat land sloping
gently towards the Genesee River  on the  eastern side of the site.
The former  off-site tank farm is located on a sloping area of a
hill west of the site.  Site geology  is  dominated by fluvial and
glacial sediments, namely highly  variable unconsolidated deposits
beneath the site composed  of sands, clays,  and gravel.   Fill
material is also present  in site  soils,  similarly composed  of
sands,  clays,  and gravel.   Within  the unconsolidated  deposits
beneath the site  are at least three  hydrologic  units: an upper
aquifer comprised of recent fluvial deposits, an aquitard comprised
of  glaciolacustrine  clay,   and  a poorly defined  lower  aquifer
comprised of glacial sands.  Similar soils were encountered at the
off-site tank farm with depth to bedrock measured between 9 and 27
feet.  Depths to the glaciolacustrine clay layer at the  refinery
range on  average between  15 and 30  feet  from  the surface and
average depth to the water table ranges between 5 and 10 feet from
the surface.   Groundwater  flow  at the  site  is generally to the
north and east, discharging directly  into the  Genesee River.  The
Genesee River is a local  source of drinking water, and the intake
for the Village of  Wellsville municipal water supply  is  located
approximately one-quarter mile upstream of the site.   Water on the
site is supplied by the Village municipal system.

The area where the  site  is located is  not known to  contain any
ecologically  significant  habitat,  wetlands,  agricultural  land,
historic or landmark  sites,  which  are impacted by  the site.   A
wetland assessment and restoration plan will,  however, be required
for any  wetlands  impacted by  remedial   activity.   Similarly,  a
floodplain  assessment and cultural  resources survey will  also be
required prior to remedial  activity.

Currently,   seven companies and the State University of New York
occupy the site.   Approximately 40 structures  exist  on-site, made
of  either  brick  or  corrugated  aluminum   and   steel  frame
construction.    Other site  features  include  a stormwater sewer
system,  including  four oil-water  separators, a  sanitary sewer
system,  a drainage swale  which runs parallel to the  river between
the refinery and a flood-control dike,  and a shallow drainage swale
running perpendicular to the river near the  site's north boundary.
Features at the  landfill portion of the site  include a single
recently consolidated landfill and a  recently  built  flood-control
dike.   The former  off-site  tank farm  is  an open  area  with  no

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discemable features.

II.  SITE HISTORY AND ENFORCEMENT ACTIVITIES

The refinery was built in 1901 for the processing of Pennsylvania
grade  crude  oil.   The Sinclair  Refining Company  purchased  the
refinery in 1919 and operated it through 1958, when a fire halted
operations.  The Sinclair Refining Company then  transferred  the
majority of the  property  to  the Village of Wellsville,  which, in
turn, conveyed some of the parcels to various companies and other
entities, most of whom currently occupy the refinery portion of the
site.   In 1969, the Sinclair Refining Company merged with  the
Atlantic Richfield Company (ARCO).

In 1981, debris  from the Sinclair landfill was reported  to have
washed into the Genesee River due  to erosion. The Genesee River is
the primary drinking water source for the Village of Wellsville.
Reports from the community and site  inspections conducted by  the
New York State Department of Environmental Conservation (NYSDEC)
indicated  that  the site warranted  proposal  for the  National
Priorities List  (NPL).  In September, 1983, the Sinclair Refinery
site was placed on the NPL.

For  purposes ' of  investigation   and  remediation,  the  Sinclair
Refinery site is  being addressed in two distinct operable units, or
sub-sites. Operable Unit  1 (OU1),  also referred to as the Landfill
sub-site, is concerned  with  the  10-acre  landfill  portion of  the
site, consisting of the Central Elevated Landfill Area (CELA),  the
South Landfill Area (SLA), and the area  between the two landfills.
Operable Unit 2  (OU2), also referred to as the Refinery sub-site,
is concerned with the 90-acre refinery and what is referred to as
the 14-acre off-site tank farm portions of the site.

In 1983, the United States Environmental  Protection Agency (EPA)
and NYSDEC signed a cooperative agreement that  identified NYSDEC as
the lead  agency  responsible  for  overseeing the remedial  cleanup
activities at  the  site.   In 1984,  NYSDEC initiated  a  Remedial
Investigation/Feasibility Study (RI/FS)  to determine the extent and
nature of contamination at the site and evaluate alternatives for
the long-term remediation of  the landfill  portion  of the site.   In
1985,  EPA  authorized an  initial   remedial  measure at the  site,
consisting of the relocation of the  surface water intake  for  the
Village of Wellsville's public water  supply.  The  intake was moved
to a location one-quarter  of  a mile upstream from the site in order
to eliminate the possibility of landfill wastes contaminating the
Village's drinking water  supply.   The relocation  of the drinking
water intake was completed in the Spring of  1988.   In 1987,  EPA
took over lead agency status from NYSDEC.

As a result of the OU1 RI/FS, EPA selected a cleanup plan for the
landfill portion of the site. This cleanup plan was embodied in a
September 26, 1985 Record of  Decision (ROD)  for OU1.  The remedial

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                                3

actions  identified in  the  1985 ROD  included  the removal  and
disposal of drums from the surface of the CELA, the excavation of
the  SLA  and  its consolidation onto the CELA,  backfilling of the
excavated area with clean fill, the construction of a cap over the
consolidated CELA, partial channelization of the Genesee River to
protect  the   landfill   from  erosion  and  flooding,   and  the
construction of a fence around  the  entire landfill site.   ARCO
agreed to  implement these remedial actions as memorialized in a
judicial Consent Decree entered into between the United States and
ARCO in  1988,  and entered by  the Western  District  of New York on
May 19, 1989.  Currently, all intact drums have been removed from
the  CELA surface and  the remaining drums have been shredded and
consolidated into  the landfill,  the SLA  has been  excavated and
consolidated onto the CELA, and  the  partial  river  channelization
project  is 95%  complete.  The landfill cap design  is in progress
and  preparatory work  will  commence once  the  design  has  been
completed.

The 1985 ROD also called for an evaluation of the refinery portion
of the site and the  groundwater underlying the landfill portion of
the site through a supplemental  (OU2) RI/FS.  ARCO  also agreed to
perform  this RI/FS  as memorialized in an Administrative Consent
Order issued by EPA  in 1988.  ARCO submitted the draft Final RI and
FS reports to EPA in March, 1991.  EPA approved these documents in
May, 1991, and the respective  Addenda in June, 1991.  In addition,
in June,  1991,  EPA and ARCO entered  into an Administrative Order on
Consent  for  the removal of asbestos-containing material  from an
abandoned building on  the refinery portion of the site and for the
removal of material  from, and the  subsequent decommissioning of, an
oil separator located in the northern area of the site.

III.  HIGHLIGHTS OP COMMUNITY PARTICIPATION

The RI/FS reports and the Proposed  Plan for the Sinclair Refinery
site were  released  to the public  for  comment  on July  26,  1991.
These documents were placed in the public information repositories
which are maintained at the EPA Region II offices and the David A.
Howe Library in  Wellsville.   The notice of availability of these
documents was published  in the Clean Times-Herald  and Wellsville
Reporter on July 26, 1991.  A 30-day public comment period on the
documents was held from July 26,  1991 through August 24, 1991.  At
ARCO's request,  EPA extended the  public  comment period  through
September 6,  1991.  EPA notified  the public of  the  comment period
extension in the two periodicals  mentioned above.  In addition, a
public meeting was held  on August  1,  1991.   At   this meeting,
representatives  from  EPA presented the Proposed Plan,  and later
answered questions concerning such  plan and other details related
to the RI/FS reports.  Responses.to comments and questions received
during this  period are  included in the Responsiveness Summary,
which is appended to this ROD.

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IV.  SCOPE AND ROLE O7 OPERABLE UNIT OR RESPONSE ACTION WITHIN SITE
STRATEGY

As previously stated, the Sinclair Refinery site is being addressed
in two distinct operable units, or sub-sites.  OU1, also referred
to as the Landfill sub-site,  includes  the 10-acre landfill portion
of the site, consisting of the CELA, the SLA, and the area between
the two landfills. OU2, also referred to as the Refinery sub-site,
includes  the 90-acre  refinery  and  14-acre  off-site tank  farm
portions of the site.

In 1985, EPA signed a ROD for OUl, based on an RI/FS performed by
New York State.   Following the signing of a ROD, a remedial design
is developed to meet the requirements of the ROD.  After completion
of the remedial design, the remedial action is implemented to carry
out the requirements of the ROD.  As previously mentioned, in 1988,
ARCO agreed to implement the  provisions of the OUl ROD.   The ROD
components were divided into  the river channelization phase,  the
landfill  consolidation  phase,  and the  landfill  capping  phase.
Presently, construction of the river  channelization and landfill
consolidation phases are near completion  and the remedial design
for the landfill  cap is also near completion.  In addition, the OUl
ROD called for an evaluation  of the refinery portion of the site
and the groundwater underlying the landfill portion of the site, to
be designated as OU2.   The  landfill  groundwater  data collected
during the OU2 remedial investigation has  not  shown the landfill
groundwater to exceed the  applicable  or relevant and appropriate
requirements (ARARs)  of federal and State environmental laws, and,
therefore,  EPA  has chosen not  to address  landfill groundwater
remediation under the OU2 ROD.  However, during OUl construction,
some pockets of oil were observed on top of the water table in an
isolated  area outside  the  landfill  boundary.    Since  landfill
groundwater management and monitoring  is an important component of
the OUl  operation and  maintenance (O&M)  phase  of  the  remedial
action for the landfill remediation, a slurry wall has been added
as a design constituent to better manage the groundwater associated
with the landfill  and landfill groundwater monitoring will continue
indefinitely  as   per  the  landfill remediation  O&M  Plan.    The
landfill O&M monitoring wells will be installed such that the top
of  the water  table can  be  adequately sampled.    If a  future
monitoring event  indicates that ARARs have been  exceeded  in the
landfill groundwater, the appropriate action will then be taken.
Therefore, this OU2 ROD focuses on cleanup  methods for remediating
the remaining contaminated areas at the site located on the 90-acre
refinery  area   and   the   off-site   tank  farm,   including  the
contaminated groundwater beneath the refinery.  ARCO will be given
the opportunity to carry out these requirements through a remedial
design and subsequent remedial action. This ROD thereby addresses
OU2 and will form the basis for final remediation of the site.

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V.  SUMMARY OF SITE CHARACTERISTICS

The  contamination  to  be  addressed by  this  OU2 ROD  has  been
identified  by the  affected site  media,  namely surface  soils,
subsurface soils, and groundwater.   As previously stated,  special
consideration has been given to groundwater underlying the landfill
in the area addressed by OU1.  Also previously noted,  the cleanup
of the Sinclair site has been separated into two distinct phases or
operable units.   EPA selected a cleanup  plan for the  landfill
portion of the site in its OU1 ROD on September 26,  1985.

In contaminated areas of the refinery, surface soils were found to
contain elevated concentrations of lead and arsenic.  The lead was
found at levels  up  to  1190 parts per million  (ppm) in  a  limited
area .near the location of the former tetraethyl lead sludge pits.
Lead at lower concentrations was also found aligned with the former
railroad tracks across the eastern border  of the site.   Elevated
levels of arsenic were also found in surface soils  along the former
railroad bed, with  the maximum concentration measured at  43 ppm.
No volatile organic compounds  (VOCs)  were found in surface soils,
with  the  exception of  two samples  showing  low  methyl  chloride
measurements.     Several   semi-volatile  compounds,   including
benzo(a)pyrene, were  found in  isolated  surface  soil samples  at
levels comparable to background.  A  summary of  site  surface soil
contamination is provided in Table 1 of Appendix B.

The subsurface soils at the  site showed  only a  few  elevated lead
concentrations, primarily  in the general area of the  tetraethyl
sludge pits, with a maximum measurement of 791  ppm.   Arsenic also
occurred at  only  a  few  elevated levels  in the  subsurface soils,
tentatively   identified  as   backfill  areas,   with  a   maximum
concentration measured at 88 ppm.  The VOCs detected in subsurface
soils include benzene, xylene,  and carbon  disulfide.   Benzene in
subsurface soils was measured up to 1450 ppb,  xylene up to 26,000
ppb, and carbon disulfide up to 190 ppb.   These were concentrated
in the  northern  and southern  areas of  the  refinery and  may  be
attributable to former refinery operations.  Several  chlorinated
compounds were  also detected  in subsurface soils.   More semi-
volatile compounds were found in subsurface soils than in surface
soils, including benzo(a)pyrene in concentrations  up to 19 ppm and
naphthalene  in concentrations up  to 3.3  ppm.   A  summary  of
chemicals found in site  subsurface soils  is provided in Table 2 of
Appendix B.

Contamination  is  also  prevalent  in  groundwater  beneath  the
refinery.  Benzene and xylene were the most commonly detected VOCs,
with maximum measured values of 1200 ppb for benzene and 1500 ppb
for  xylene.   There are  also isolated  areas  of  chlorinated
hydrocarbon  contamination   in   the  groundwater.    Semi-volatile
compound contamination includes elevated  levels of naphthalene and
nitrobenzene, measured in  concentrations up to 0.23 ppm  and 8.2

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ppm, respectively.  Elevated levels of metals detected in refinery
groundwater include arsenic,  measured at a maximum of 0.884 ppm,
chromium, measured at a maximum of 0.298 ppm, and lead, measured at
a maximum value of 0.249 ppm.  Arsenic, chromium, and lead exceeded
federal  maximum  contaminant  levels  (MCLs)  for  drinking  water;
levels of arsenic, chromium, lead, barium, copper,  iron, manganese,
sodium,  and  zinc were found  to  exceed  State  drinking  water
standards.  A summary  of chemicals detected in site groundwater can
be found in Table 3 of Appendix B.

Soils  at the  off-site  tank farm  contained benzene at very low
levels  (maximum reading of 1 part per  billion  (ppb))  and metals
were measured comparable to background conditions.  The groundwater
at the  off-site tank farm  was  found to be uncontaminated.   The
drainage swale  along  the eastern  border of the  site had a single
anomalous arsenic reading of 46 ppm in a sediment sample,  but was
otherwise uncontaminated.  The Genesee River was also found to be
generally free of contaminants;  a  single sediment  sample out of 15
total sediment samples analyzed for metals had an arsenic reading
of 98.3 ppm and two water samples  out  of 29 water samples analyzed
for metals exceeded State drinking water standards for iron.  Of
the  26 surface  water  samples  analyzed  for  VOCs,  four  samples
exceeded State guidance values for chlorinated hydrocarbons and one
sample exceeded the State guidance value for benzene.  Stormwater
sewers and the northern oil separator at the site were found to
contain  elevated  levels  of  certain VOCs,  semi-volatiles,  and
metals.   Discharges  from  the sewers at the outfalls,  however,
appear  to be  at  very  low concentrations,  indicating that the
separators may still be  functioning.  The northern  oil separator is
being addressed through a separate remedial (removal) action.

VI.  SUMMARY OF SITE RISKS

EPA conducted a baseline Risk  Assessment (sometimes referred to as
an Endangerment Assessment) to evaluate the  potential risks to
human  health  and  the environment  associated  with  the Sinclair
Refinery site in its current state.  The  Risk Assessment focused on
contaminants   in   the  surface  soils,   subsurface   soils,   and
groundwater which are likely  to pose significant  risks to human
health  and the  environment.   A summary  of  the chemicals  of
potential concern is listed in Table 4,  Appendix B.

EPA's  Risk  Assessment  identified  several  potential  exposure
pathways by which the public may be exposed to contaminant releases
at the site under current and  future land-use conditions.  Surface
soil, subsurface soil, and groundwater exposures were assessed for
both potential present and future land use scenarios.  A total of
4 exposure pathways were evaluated under possible on-site current
and  future  land  use  conditions;  potential  subchronic  risks
associated with the subsurface soil (i.e., an excavation scenario)
were assessed  only for a future  land use  scenario.   Reasonable
maximum  exposure  assumptions were  used  to  evaluate  the  risk

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associated with the pathways. These exposure pathways, illustrated
in Table 5, include:

   • Inhalation of volatile organic compounds by excavation workers
     exposed to subsurface soils;

   • Inhalation of  fugitive dust emissions of  metals and  semi-
     volatile organic contaminants by on-site  occupants;

   • Inadvertent ingestion of soil contaminants by both excavation
     workers and trespassing children (at the refinery and off-site
     tank farm);  and

   • Ingestion of dissolved contaminants in surface water by local
     residents.

Under  current EPA  guidelines,  the  likelihood  of  carcinogenic
(cancer causing)  and non-carcinogenic effects due  to  exposure to
site chemicals are considered separately.  It was assumed that the
toxic effects  of the site-related chemicals  would be  additive.
Thus,  carcinogenic  and  non-carcinogenic  risks  associated  with
exposures  to  individual  compounds   of  concern  were  summed  to
indicate the potential risks associated with mixtures of potential
carcinogens and non-carcinogens,  respectively.

Non-carcinogenic risks were assessed using a  hazard  index  (HI)
approach, based on a comparison of expected contaminant intakes and
safe levels of intake,  or Reference  Doses  (RfDs).   RfOs have been
developed by EPA for indicating the potential for  adverse health
effects.   RfDs,  which are expressed  in units of  mg/kg-day,  are
estimates of daily exposure levels for humans which are thought to
be  safe  over  a  lifetime  (including  sensitive  individuals).
Estimated intakes of chemicals from environmental media (e.g., the
amount of a chemical ingested from contaminated drinking water) are
compared  with the  RfD  to  derive the  hazard quotient   for  the
contaminant in the particular medium.   The HI is obtained by adding
the hazard quotients for  all compounds across  all  media.

An HI greater than 1 indicates that  the potential  exists for non-
carcinogenic health effects to occur as a result  of site-related
exposures.  The HI provides a useful  reference point  for gauging
the potential significance of multiple contaminant exposures within
a single medium or  across media.  The RfDs for the chemicals of
potential concern at the Sinclair Refinery site are presented in
Table 6.

A  summary of the  non-carcinogenic  risks  associated  with  the
chemicals of potential concern across various exposure pathways is
found in Table 7.  It can be seen from Table 7 that the greatest
non-carcinogenic risk from  the  site is associated  with  fugitive
dust inhalation by on-site occupants.  The HI  for  this pathway is
9.75X10"1 and is primarily attributable to barium detected in the

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                                8

surface soil.

Potential carcinogenic risks were evaluated using the cancer slope
factors  (SFs)  developed  by EPA  for  the  chemicals  of potential
concern.   Sfs  have been developed  by  EPA's  Carcinogenic  Risk
Assessment Verification Endeavor  (CRAVE)  for  estimating excess
lifetime  cancer risks  associated with  exposure to  potentially
carcinogenic  chemicals.   Sfs,  which are  expressed in  units of
(mg/kg-day)"1, are multiplied by the estimated intake  of a potential
carcinogen,  in mg/kg-day, to  generate an upper-bound estimate of
the excess lifetime cancer risk associated with exposure to the
compound at that intake  level.  The term "upper bound" reflects the
conservative estimate of the risks calculated  from the SF.  Use of
this  approach  makes  the  underestimation of  the  risk  highly
unlikely.  The SF for each indicator chemical is  presented in Table
6.

For known  or suspected  carcinogens,  EPA  considers  excess upper
bound individual lifetime cancer risks of between ICr* to  10* to be
acceptable.   This  level indicates  that  an  individual  has  not
greater than a one  in ten thousand to one in a  million chance of
developing cancer   as  a  result  of  site-related exposure to  a
carcinogen over a 70-year period under specific exposure conditions
at the site.   The total  cancer risks at the Sinclair Refinery site
are outlined in Table 8.    The  total  cancer  risk for on-site
occupants is 1.97X10"4, based  on the  inhalation  of  fugitive dust,
primarily due to arsenic,  and the  ingestion of surface water.  The
total  cancer risk  for  trespassing children  is 3.79x10"*  at  the
refinery and 4.25x10"* at the off-site  tank  farm,  based  on  the
ingestion of surface soil and surface water.

The cumulative upper  bound  cancer risk  at the  Sinclair Refinery
site  for  on-site occupants under a  current potential  land  use
scenario is  1.97x10"*, which is at  the high end  of  the acceptable
risk  range.    However,  EPA  has   determined  that  the  point  of
departure for cancer risks at the site should  be 10"6, based on the
sensitivity  of  the  on-site and neighboring  populations (on-site
students and residents in close proximity to the site).

UNCERTAINTIES

The procedures and  inputs used to  assess  risks in this evaluation,
as  in all such  assessments,  are  subject to a wide  variety of
uncertainties.   In general,  the  main  sources  of  uncertainty
include:

- environmental chemistry sampling and analysis
- environmental parameter measurement
- fate and transport modeling
- exposure parameter estimation
- toxicological data

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Uncertainty  in environmental sampling  arises in  part from  the
potentially uneven distribution  of chemicals in the media sampled.
Consequently,  there  is  significant  uncertainty as to  the actual
levels present.  Environmental  chemistry analysis  error can stem
from  several  sources  including the  errors  inherent  in  the
analytical methods and characteristics of the matrix being sampled.

Uncertainties in the exposure assessment are  related to estimates
of how often an individual would actually come in contact with the
chemicals of potential concern,  the period of time over which such
exposure  would occur,   and  in  the  models  used  to estimate  the
concentrations of the chemicals  of potential  concern at the point
of exposure.

Uncertainties  in  toxicological  data occur  in  extrapolating both
from animals to humans and from  high to low doses of exposure, as
well  as  from  the  difficulties  in  assessing the  toxicity of  a
mixture of chemicals. These uncertainties are addressed by making
conservative assumptions concerning risk and  exposure  parameters
throughout  the assessment.    As  a  result,  the  Risk  Assessment
provides upper bound  estimates of the risks to populations near the
site.

A  specific uncertainty inherent  in the Sinclair Refinery risk
assessment is that the methodology used to calculate the site risks
are site-wide averages, which give a  clear overall understanding of
site  risks.   However,  as previously  stated,  EPA has  taken into
account the sensitivity  of the on-site and neighboring populations
and has determined that the  target risk for the site should be on
the order of 10*.

Therefore, actual  or threatened releases of  hazardous  substances
from this site, if  not addressed  by the selected alternative or one
of the other remedial measures considered,  may present an imminent
and substantial endangerment to the public health, welfare, and the
environment.  Consequently, a risk-based arsenic cleanup number was
generated.   This  cleanup value,  along with  a  focused  sampling
program,  will ensure that the isolated high risk areas of the site
are properly  remediated  (a  discussion of  cleanup levels  for the
site follows).  More  specific information concerning public health
risks, including a quantitative evaluation of  the  degree  of risk
associated with various exposure pathways,  is presented in the RI
report.

CLEANUP LEVELS FOR TEE SITE

EPA has  chosen cleanup levels  for  the contaminants at the site
based on a number of  factors.  The cleanup  levels are derived from
the acceptable risk range and point  of departure  set forth in the
National Oil and Hazardous Substances  Pollution  Contingency Plan
(NCP), a published guidance  document,  and requirements  of federal
and  State laws and  regulations.    The levels are  chosen  to be

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                                10

protective of human health and the environment.

The cleanup  level  chosen  for arsenic in site surface soils is 25
ppm.  This cleanup goal, derived from the NCP, is based on the same
assumptions  used in the  risk assessment,  and  corresponds  to an
acceptable cancer  risk level.   Document 3  of Appendix C provides
the calculation of this cleanup level.

The cleanup  level  chosen  for lead in site  surface  soils  is 1000
ppm.  This cleanup goal is established in a published EPA guidance
document  entitled "Interim  Guidance on Establishing Soil  Lead
Cleanup Levels at  Superfund  Sites (OSWER Directive #9355.4-02)."
This guidance recommends setting cleanup goals for lead in dust and
soils at  levels  from 500-1000 ppm when  current or predicted land
use is residential.  EPA  has chosen  1000 ppm as the cleanup goal
for the site as  the site-specific conditions do not conform to a
residential  setting.  The areas of the  site where cleanup levels
for arsenic  and lead are exceeded are illustrated in Figure 3.

Cleanup levels for groundwater are established by federal and State
laws  and  regulations.     According  to  RI  data,  the  shallow
groundwater aquifer beneath the site is contaminated with a variety
of  chemicals.    Although  this  is not  a current drinking  water
source, the  aquifer is designated by New York State as a class GA
aquifer,  or  potential source of potable water.   This designation
requires that ARARs for drinking water be met.   Cleanup levels are
thereby driven by MCLs and ambient water  quality standards (AWQSs)
established by federal and State regulations.  Documents 4 and 5 of
Appendix C list AWQSs and MCLs for site groundwater.

VII.  DESCRIPTION OF ALTERNATIVES

The remedial alternatives are presented  by  the media of  the site
which they address.   They are numbered  to  correspond with their
presentation in the FS report.  The time to implement refers only
to the actual construction and  remedial  action time and excludes
the time  needed  to  design  the  remedy,  procure contracts,  and
negotiate with the Potentially Responsible Parties  (PRPs), all of
which can take 15-30 months.

MEDIUM It  SURFACE SOILS

An estimated 7700 cubic yards of surface  soils (defined as soils at
a  depth  from  the surface to one foot) with  arsenic and  lead
concentrations above the  cleanup  levels of 25  ppm  and  1000 ppm,
respectively, are located  in  isolated "hot spots11 of the site.  The
possible  remedial alternatives  for  surface  soils  include:  no
action, capping,  excavation with on-site  disposal after treatment,
excavation with  off-site  disposal after treatment,  and  in situ
fixation.   Figure  3  identifies the approximate aerial  extent of
surface soils which exceed the cleanup  criteria  for arsenic and
lead.

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                                11

Alternative 1A - No Action

Capital Cost: $46,700
Annual Operation & Maintenance (O&M)  Costs:  Year 1-5: $91,600
                                             Year 6-30: $28,500
Present Worth: $743,000
Time to Implement:  Construction: 2 Months
                    Remedial Action:  30 Years

The Superfund  program requires that  a no action  alternative be
evaluated at  every site to establish a baseline  for comparison.
Under  this  alternative,  a public  awareness program concerning
surface soil  contamination would  be  implemented,  including the
distribution of project fact sheets, conducting public meetings (if
requested),  and  posting  warning  signs.   Long term groundwater
monitoring  would  also   be included  to  track  any  contaminant
migration.   In accordance with  Section 121 of CERCLA,  remedial
actions that leave hazardous substances above health-based levels
at a  site are to be  reviewed  at  least once every  five  years to
assure  that the  action  is protective  of human  health  and the
environment.  The no action alternative would have to be reviewed
by EPA at least once every five years.

Alternative IB - Capping

Capital Cost: $700,300
Annual O&M Costs: Year 1-5: $104,100
                  Year 6-30: $41,000
Present Worth: $1,583,200
Time to Implement:  Construction: 6 Months
                    Remedial Action:  30 Years

This alternative involves capping of surface soils measured above
25 ppm arsenic and 1000 ppm lead to  eliminate the exposure pathway.
The cap would consist of one foot of clean soil and six inches of
topsoil, which would then be revegetated. Long-term monitoring and
maintenance of the cap  would be performed and  deed restrictions
would be  included to  protect  the integrity of the  cap.   Because
hazardous substances will remain on-site above health-based levels,
a five year review will be conducted.

Alternative 1C - Excavation and On-Site Disposal After Treatment

Capital Cost: $1,505,000
Annual O&M Costs: $0
Present Worth: $1,505,000
Time to Implement:  Construction: 6 Months
                    Remedial Action: 30 Years (OUl CELA Monitoring)

Under this alternative, surface soils measured above 25 ppm arsenic
and 1000  ppm  lead would be excavated  to  a depth of one foot to
ensure that cleanup goals are met.  The excavated soils would then

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                                12

be treated  to comply with the Resource Conservation and Recovery
Act (RCRA) Land Disposal Restriction (LDR) regulatory levels prior
to consolidation into the CELA located in the southern portion of
the site.  A treatment option will be chosen and incorporated into
the  remedial  design  after  a  pilot  study  to  determine  its
feasibility.  The treatment options, in order of preference, are as
follows:  solidification/fixation, a chemical process whereby soils
are  converted  into  a  stable,  cement-like  matrix  using  such
additives as  cement, lime, flyash,  sodium  silicate,  or asphalt;
thermoplastic solidification, a chemical process which mixes soils
with materials such as  asphalt, paraffin,  or polyethylene  in a
heated  mixer,   producing  a  rigid,  homogenous   end  product;
contaminant extraction, or "soil washing", whereby excavated soils
are flushed with a  solvent in an above-ground treatment system and
then rinsed with water.  The  cost estimate for this alternative is
based on  the  solidification/fixation treatment option.   The CELA
would then  be capped under  an on-going remedial action  and the
excavated area would be  backfilled  with six inches  of clean soil
followed  by six inches  of topsoil  and then revegetated.   This
alternative permanently  removes the contaminated surface soils,
eliminating  this exposure pathway.   Annual O&M  costs  are not
included under this alternative because they will be covered under
the remedy for the OU1 ROD.  Also,  although this alternative will
allow  for  use  and  exposure  at  its  completion  under  current
(industrial) site uses, a five year review is considered necessary,
since the cleanup criteria for lead is based on current site use,
and a five  year review would evaluate the  protectiveness of the
remedy should site use change.  Accordingly,  EPA will recommend the
implementation of a  local zoning ordinance that will require that
the New York  State Department of Health  (DOH)  be notified in the
event of  any  construction  activity  that would alter present site
use.  If such a construction  activity were to occur,  an evaluation
of the impacts of the proposed construction and its future use in
regard  to  site contaminantipn  and  exposure pathways  will  be
provided to DOH for  their review and comment.

Alternative ID - In  Situ Fixation

Capital Cost: $1,757,700
Annual O&M Costs: Year 1-5: $87,600
                  Year 6-30:  $24,500
Present Worth: $2,394,600
Time to Implement:    Construction:  6 Months
                     Remedial Action: 30 Years

In situ  fixation refers to  treatment  of surface soils measured
above 25  ppm  arsenic and 1000 ppm lead in  place  to solidify and
stabilize the contaminants.  This involves the use of conventional
construction  equipment  to  mix in  additives  to immobilize the
affected soils into an unleachable matrix without any soil removal.
The soils would be treated to a depth  of one foot and covered by
six inches of topsoil and vegetation.  This alternative would also

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                               13

require  land  use restrictions to maintain  the integrity  of the
fixated  material and  periodic maintenance  of the soil  cover.
Because hazardous substances will remain on-site above health-based
levels, a five year review will be conducted.

Alternative IE - Excavation and Off-Site  Disposal  After Treatment

Capital Cost: $4,110,700
Annual O&M costs: $0
Present Worth: $4,110,700
Time to Implement:   Construction:  6 Months
                    Remedial Action: 6 Months

This  alternative is  identical to  Alternative 1C,  except  that
excavated surface soils would be transported to an appropriate off-
site facility after treatment.  The treatment options are identical
to  those  detailed   in  Alternative  1C.    As  in  the  previous
alternative,  the surface  soil exposure  pathway  is  permanently
eliminated.   Also as in the previous  alternative,  although this
alternative will allow for unrestricted use and unlimited exposure
at its completion under current site  uses, a five year review is
considered necessary, since the cleanup criteria for lead is based
on current  site use, and a  five  year review would  evaluate the
protectiveness of the remedy should site  use change.

MEDIUM 2; SUBSURFACE SOILS

An estimated  44,000  cubic  yards of subsurface soils  (defined as
soils at a depth from one  foot to the water  table)  with elevated
levels of VOC (benzene,  xylene),  semi-volatile  (naphthalene), and
metal (arsenic and lead) contaminants have been measured in the RI.
However, no known pathway presently exists that would expose the
human population to  these  contaminants and  there is  no evidence
that subsurface  soils are any longer acting as a significant source
of  groundwater   contamination.    The   remedial  alternatives  for
subsurface  soils include:  no action, excavation with  off-site
disposal after treatment,  and in situ vapor  extraction.

Alternative 2A - No Action

Capital Cost: $81,300
Annual O&M Costs: Year 1-5: $108,700
                -  Year 6-30: $31,400
Present Worth: $882,100
Time to Implement:   Construction:  2 Months
                    Remedial Action: 30 Years

The no action  alternative provides the baseline against which other
alternatives  can  be   compared.      This  alternative  involves
implementation of a public awareness program concerning subsurface
soil  contamination,  including the  distribution  of project fact
sheets and conducting public meetings (if requested).   Long-term

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                                14

surface water, groundvater, and soil-gas monitoring would also be
included  to  track  any  contaminant  migration.    Institutional
controls, in  the  form of local zoning ordinances,  would also be
recommended to control  any future site uses which  could open an
exposure pathway.  The site would be reviewed every five years to
evaluate the protectiveness of the remedy.

Alternative 2B - Excavation and Off-Site Disposal After Treatment

Capital Cost: $22,869,800
Annual O&M Costs: $0
Present Worth: $22,869,800
Time to Implement:  Construction:  6-12 Months
                    Remedial Action: 6-12 Months

Under this alternative,  contaminated subsurface soils which exceed
the cleanup criteria, derived  from  soil  to groundwater modeling,
would  be excavated  and transported  to  an appropriate  off-site
facility  after  treatment  to comply   with   LDR  requirements.
Treatment options are identical to those presented in Alternative
1C.   The potential  cleanup criteria are  derived  from  a  model
included in Appendix F of the FS which calculates a cleanup value
based  on  a  chemical's  contributive effect to groundwater.   The
excavated areas would then be filled with clean soil brought from
off-site.  Temporary fencing would be  erected around areas of open
excavation.   There is no  need  for a five year review,  since this
alternative would allow  for unrestricted use and unlimited exposure
at its completion.

Alternative 2C - In Situ Vapor Extraction

Capital Cost: $1,998,000
Annual O&M Costs: Year 1-5: $106,500
                  Year 6-30: $29,200
Present Worth: $2,766,100
Time to Implement:  Construction:  24 Months (6 Months/Extraction)
                    Remedial Action: 30 Years

This alternative involves the  in place  treatment of contaminated
subsurface soils.  Areas of contamination are defined by subsurface
soils which exceed the  modeled cleanup  criteria,  detailed in the
FS.  Components  of this alternative  include the  installation of
extraction  wells  drilled  through  the  contaminated  zones  and
connected to high volume vacuum pumps  via a pipe system, treatment
of  gas emissions  to comply with air  quality regulations,  and
monitoring to assess  the effectiveness of the treatment.  Residuals
of  this  application  would  be  treated  off-site.    Long-term
groundwater monitoring  is also a component of  this alternative.
This  application  is  most  effective  in  the  removal  of  voc
contamination. There is no need for a  five year review, since this
alternative will  allow for unrestricted use and unlimited exposure
at its completion.

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                               15

MEDIUM 3; GROUNDWATER

The RI measured levels exceeding federal and state drinking water
standards for VOCs (benzene, ethylbenzene, 1,1-dichloroethane, 1,2-
dichloroethane, 1,1,1-trichloroethane, toluene, and xylene), semi-
volatiles (nitrobenzene), and metals  (arsenic,  barium, chromium,
copper,  iron,  lead,  manganese,  sodium,   and   zinc)  in  site
groundwater. The contamination is restricted to the upper aquifer,
which is approximately 10-20 feet thick and underlies the entire
site at  varying depths.   As  previously mentioned,  however,  the
groundwater beneath the landfill is being addressed under the OU1
action.

The  ultimate goal  of the  EPA  Superfund  Program's  approach  to
groundwater remediation as stated in the NCP (40 CFR Part 300)  is
to return usable groundwater to its beneficial use  within a time
frame that is reasonable.   Therefore, for  this  aquifer,  which is
classified by New York State as a potential drinking water source,
the  final  remediation goals will be  federal and State  drinking
water standards. The remedial alternatives  for groundwater include
no action and groundwater treatment.

Alternative 3A/B - No Action

Capital Cost: $307,000
Annual O&M Costs:  Year 1-5: $199,400
                  Year 6-30: $51,900
Present Worth:  $1,716,400
Time to Implement:  Construction:  2 Months
                    Remedial Action:  30  Years

As previously  stated,  the Superfund program requires that  a  no
action alternative  be  evaluated  at every site  to  establish  a
baseline  for  comparison.    Under  this  alternative,  a  public
awareness program concerning  groundwater contamination  would  be
implemented, including the  distribution  of project fact sheets and
conducting public meetings (if requested).  Institutional controls,
in the form  of local zoning ordinances, would be  recommended to
prevent groundwater use on the site.   Long-term surface water and
groundwater monitoring would be included to track any contaminant
migration.  The site would be reviewed every five years to evaluate
the protectiveness of the remedy.   (Note: This alternative combines
alternatives 3A and 3B,  as they are presented in the FS.)

Alternative 3C - Groundwater Treatment

Capital Cost: $2,311,200
Annual O&M Costs:  $705,900 (Consistent over 30 years)
Present Worth:  $13,162,600
Time to Implement:  Construction:  24 Months
                    Remedial Action:  30  Years

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This alternative involves the treatment of contaminated groundwater
with  the goal  of achieving  ARARs.    There are  numerous  design
options which would be analyzed in the remedial design phase.  This
alternative assumes approximately 11 wells strategically placed to
extract the bulk of the contaminated groundwater from the aquifer
and prevent  its migration  into  the Genesee  River.    The  pumped
groundwater  would be  stored in  a central collection tank  for
subsequent treatment in an above-ground system. A treatment system
would  be developed  during the  design  phase to meet discharge
requirements following a pilot study to determine its feasibility.
The cost of this  alternative  is  based  on treatment options which
include a solids removal step (such as a chemical feed/rapid mix
system followed by a  flocculation and clarification step) in order
to precipitate and filter out large suspended solids, air stripping
of the clarified  effluent  for  the removal of VOCs,  and  carbon
adsorption, which utilizes activated carbon to selectively adsorb
organic molecules  and some metals by  surface attraction  to  the
internal pores of carbon granules.  The treated groundwater would
then be either discharged directly to the Genesee River or via the
Publicly Owned Treatment Works (POTW).  Institutional controls, in
the form of local  zoning ordinances, would  be recommended during
the period of remediation.  Monitoring under this alternative will
include surface water, groundwater, groundwater seeps, and Genesee
River  biota.   The biota monitoring will entail the  sampling of
various indigenous species at points upstream and adjacent to the
site  and an  evaluation of  site-related impacts  on  the  biota.
Sampling will take place before any design implementation,  and if
no impacts are  found, the  biota  monitoring  will  be discontinued.
If significant impacts are found,  however, a  post-remedial interval
for further biota monitoring will be established.

Recent  studies   have  indicated  that  pumping   and  treatment
technologies  may  contain  uncertainties in   Achieving  the  ppb
concentrations required under ARARs  over a reasonable period of
time.   However, these studies also indicate significant decreases
in contaminant concentrations early in the system implementation,
followed by a leveling out.   For these reasons,  this alternative
stipulates contingency measures, whereby the  groundwater extraction
and treatment system's performance will be monitored on a regular
basis and adjusted as warranted by the performance data collected
during operation.   Modifications may  include any or  all  of  the
following:

     a)   at  individual wells   where  cleanup goals  have  been
          attained, pumping may be discontinued;

     b)   alternating pumping at wells  to eliminate  stagnation
          points;

     c)   pulse pumping to allow aquifer equilibration and to allow
          adsorbed contaminants to partition into groundwater; and

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                               17

     d)   installation of additional extraction wells to facilitate
          or accelerate cleanup of the contaminant plume.

If it is determined, on the basis of the preceding criteria and the
system  performance data,  that  certain portions  of the aquifer
cannot  be restored to their beneficial use in a  reasonable time
frame,  all or some of the  following measures  involving long-term
management may  occur, for  an indefinite  period of  time, as  a
modification of the existing system:

     a)   engineering controls such as physical  barriers,  source
          control measures,  or long-term gradient control provided
          by low level pumping,  as containment measures;

     b)   chemical-specific ARARs may be waived for the cleanup of
          those portions of the aquifer based  on the  technical
          impracticability  of   achieving   further   contaminant
          reduction;

     c)   institutional controls,  in the  form  of local  zoning
          ordinances,  may  be  recommended to  be  implemented  and
          maintained to restrict access to those  portions  of the
          aquifer which remain above  remediation goals;

     d)   continued monitoring of specified wells; and

     e)   periodic  reevaluation  of   remedial  technologies  for
          groundwater restoration.

The decision to invoke any  or all  of these measures may be made
during a periodic review of the remedial  action,  which will occur
at intervals  of no  less often than every five years.  At that time,
the State of New York will be  given  the opportunity  to review,
comment, and concur on all  contingency decisions.

VIII.  SUMMARY OP COMPARATIVE  ANALYSIS OF ALTERNATIVES

In accordance with  the NCP,  a detailed analysis of each alternative
is  required.   The  purpose  of  the  detailed  analysis  is  to
objectively assess  the alternatives with respect to nine evaluation
criteria that encompass statutory requirements and  include other
gauges  of the overall feasibility and acceptability  of remedial
alternatives.    This   analysis  is  comprised  of  an  individual
assessment of the alternatives  against each  criterion  and  a
comparative analysis designed to determine the relative performance
of  the  alternatives  and  identify major  trade-offs,  that  is,
relative advantages and disadvantages,  among them.

The nine evaluation criteria  against  which the  alternatives are
evaluated are as follows:

Threshold Criteria - The first two criteria must  be  satisfied in

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order for an alternative to be eligible for selection.

1.   Overall Protection of Human Health and the Environment:
     This  criterion addresses whether  or not a  remedy provides
     adequate protection and  describes  how risks are eliminated,
     reduced,   or  controlled  through   treatment,   engineering
     controls, or institutional controls.

2.   Compliance with ARARs:
     This criterion addresses  whether or not a remedy will meet all
     the ARARs  of other federal  or  State environmental statutes
     and/or provide grounds for invoking a waiver.

Primary  Balancing Criteria - The next five  "primary  balancing
criteria"  are  to  be  used  to weigh major trade-offs  among  the
different hazardous waste management strategies.

3.   Long-term Effectiveness and Permanence:
     This criterion refers to the ability of the remedy to maintain
     reliable protection of human health and the environment over
     time once cleanup goals have been met.

4.   Reduction of Toxicity, Mobility, or Volume:
     This criterion addresses  the degree to which a remedy utilizes
     treatment technologies to  reduce the toxicity,  mobility,  or
     volume of contaminants.

5.   Short-term Effectiveness:
     This criterion considers  the  period of time needed to achieve
     protection and any  adverse impacts on human health  and  the
     environment that  may be posed  during the  construction  and
     implementation period until cleanup goals are met.

6.   Implementability:
     This  criterion examines  the technical   and  administrative
     feasibility of a remedy,  including availability of materials
     and services needed to implement the chosen solution.

7.   Cost:
     This criterion includes capital and O&M costs.

Modifying  Criteria -  The  final  two  criteria  are   regarded  as
"modifying criteria," and are to  be  taken into account  after  the
above criteria  have been evaluated.   They  are generally  to  be
focused upon after public comment is received.

8.   State Acceptance:
     This criterion indicates whether,  based on its review of  the
     FS and Proposed Plan, the State  concurs with, opposes, or has
     no comment on the proposed alternative.

9.   Community Acceptance:

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     This criterion indicates whether, based  on  its  review of the
     FS and Proposed Plan, the public concurs with, opposes, or has
     no comment on the proposed alternative.

The following is a summary of the comparison of each  alternative's
strengths  and weaknesses with respect  to the  nine  evaluation
criteria.

1. Overall Protection

Surface Soils:   All  of the  alternatives,  with  the exception of
Alternative 1A, would provide adequate protection of human health
and the  environment  by eliminating or  controlling risk  through
containment, removal, or treatment.  Alternative  1C would remove
soils with arsenic contamination over 25 ppm and lead contamination
over 1000 ppm and consolidate these soils after treatment into the
on-site landfill,  thereby  eliminating  the risk  of exposure and
contaminant migration.

Alternative  1A is not  an  acceptable  remedial  option given the
calculated  risks.    EPA has  determined  that,  based  on  the
sensitivity of the on-site and neighboring populations, the current
risk from arsenic posed to site occupants is  unacceptable and the
guidance value for lead is exceeded in certain areas of the site.

Subsurface Soils:  Each of the alternatives  for  subsurface soils
provide adequate protection of human health and  the environment.
No risks presently exist from subsurface  soils due to  the lack of
a known exposure  pathway.   Alternative  2A  is protective  in that
potential sources of risk are  controlled through  containment (by
overlying soils)  and will remain protective  through monitoring and
the enforcement of the  institutional controls which will  address
any future site uses  which could open an  exposure pathway.

Groundwater:   Only Alternative  3C for  groundwater attempts to
provide adequate protection of human health and the environment by
reducing contaminant levels to ARARs.  Although there is no current
exposure pathway for  groundwater use on the site,  the  Alternative
3A/B is not protective of any future possible groundwater use since
ARARs  are  exceeded   in  a   potential  drinking  water  aquifer.
Furthermore, statistical evidence is not  strong  enough to support
the claim that groundwater discharge from the site to  the Genesee
River does  not exceed the New York State  Class A  Surface Water
Standards.  Alternative 3A/B offers limited protection provided the
institutional controls to restrict groundwater use are implemented
and enforced and that the Genesee  River  is adequately monitored,
but Alternative  3C  also  attempts to  reduce potential  risk by
actively  removing and treating contaminants  in the  groundwater
aquifer and prevent any migration  of these contaminants into the
Genesee  River.    Consequently,   and  in  accordance  with  EPA
groundwater policy as  set forth  in the  NCP,   site remediation is
warranted to restore  groundwater to its beneficial use.

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2. Compliance with ARARs

Surface Soils:   All  of the alternatives would meet  the  ARARs of
federal and State environmental laws.  Chemical-specific, Action-
specific, and Location-specific ARARs are outlined in  Tables 9, 10,
and 11 in Appendix B of this document.

LDRs are chemical- and action-specific ARARs that are triggered by
the placement of wastes regulated under  RCRA.   LDRs  require that
excavated hazardous wastes be treated to acceptable levels before
disposal.  On-site disposal of treated wastes is permitted provided
the wastes are not, after  treatment, RCRA listed or characteristic
hazardous wastes.  Wastes that are listed must be either delisted
or disposed  of off-site; wastes that are characteristic may be
disposed of  on-site  after they have been treated  to levels such
that they are no longer characteristic.   Soils containing arsenic
and lead must be treated to the extent whereby the concentration of
arsenic or lead remaining in the leachate (as determined by the
Toxicity Characteristic Leaching Procedure (TCLP)) is less than 5
ppm  in  order  to  no  longer  be considered  characteristic  and
therefore  eligible  for  on-site disposal.    Delisting  is  not
required, since it does not  appear  that  the  contaminated surface
soils are RCRA  listed  wastes.   Alternative 1C therefore complies
with the LDR ARAR.   Other action-specific and location-specific
ARARs that are applicable  or relevant and  appropriate  would also be
met under each of the alternatives.  Examples include Occupational
Safety and Health  Administration (OSHA)  Standards for Hazardous
Responses and New York RCRA Hazardous Waste Facility Requirements
for the handling and storage of hazardous wastes.

Subsurface Soils:  As with surface soils, all of the alternatives
would meet the applicable  or  relevant and appropriate requirements
of federal and State environmental laws.   Alternative 2A does not
trigger  any  action-specific  or location-specific ARARs and no
federal or State chemical-specific ARARs exist for soils.

Groundwater:   Safe  Drinking  Water Act  (SDWA)  MCLs  are federal
chemical-specific  ARARs  and NYSDEC  Class  GA  AWQSs are  State
chemical-specific ARARs that  apply  to the  groundwater underlying
the site.  New York State Class A Surface Water Quality Standards
(SWQSs) are State chemical-specific ARARs that apply to groundwater
discharges from the site into the Genesee River.  According to the
federal Site-Specific  Classification scheme, the  groundwater is
Class  2B,  which is  potential  drinking  water.   New  York  state
classifies the site groundwater "GA" and the Genesee River as class
"A", both drinking water sources.  Alternative 3A/B fails to meet
these ARARs.   Alternative  3C attempts to meet these ARARs; if ARARs
are demonstrated to be  unattainable after  implementation  of  a
groundwater extraction and treatment system, the contingency exists
for a waiver  of  these   ARARs,  as  outlined  in  the  Summary of
Alternatives section.

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                               21

Alternative 3C would also meet action-specific ARARs.   Location-
specific ARARs that are applicable or appropriate would also be met
under the preferred alternative.   Examples include OSHA Standards
for Hazardous  Responses  and New  York  State Pollutant  Discharge
Elimination System (SPDES) Requirements for Site  Runoff,  Surface
Water and Groundwater Discharge Limits.

3. Long-term Effectiveness and Permanence

Surface Soils:  Alternative 1C will be both effective and permanent
once the construction phase is complete.  The potential for direct
exposure to the contaminated surface soils will be removed and the
contaminated soil areas will  be restored to ambient conditions.
The soils consolidated in the CELA will  be capped and maintenance
and monitoring of the CELA will be  conducted in accordance with the
1985 ROD.

Alternative 1A is neither effective  nor permanent in maintaining
protection of human health and the environment over time since the
potential for contact with contaminated soils will not  have been
removed (although it will  have been  reduced by  fencing).  Each of
the  remaining  alternatives  offer  long-term  effectiveness  and
permanence by removing the exposure  pathway,  although Alternative
IB  and  Alternative  ID both require institutional  controls  for
current  land  use  which  need  to  be   enforced  for  complete
effectiveness.

Subsurface Soils:  No known risk exposure pathway currently exists
for contact with subsurface soils.   Based on the  available data,
the subsurface soils do not appear to be acting as a significant
source of groundwater contamination.  Alternative 2A is therefore
effective and permanent in maintaining reliable protection of human
health and the  environment, provided the institutional controls to
address any future site use scenario which could  open an exposure
pathway are enforced.

Alternative  2B  and  Alternative   2C   also   offer   long-term
effectiveness and permanence for the same  reasons.

Groundwater:  Alternative 3A/B is not effective and  permanent in
maintaining  reliable  protection  of  human  health  and  the
environment, since ARARs are exceeded in a drinking water aquifer.
Alternative 3C is effective and permanent in that the remedial goal
is to achieve ARARs and that the pumping and treatment would remove
the groundwater contamination, thereby lessening the impact on the
Genesee  River.    EPA  acknowledges,  however,  that  pumping-and-
treatment technologies may contain uncertainties in achieving ARARs
over a reasonable time period.

4. Reduction of Toxicity,  Mobility/  or  Volume

Surface Soils:   Alternative 1A provides no reduction in toxicity,

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                                22

nobility,  or  volume  of contaminants since there is no treatment.
Alternative IB also provides no reduction in toxicity or volume due
to no  treatment, but does reduce the mobility of contaminants in
the soil since they would be contained and no longer available for
transport  by  wind  or water erosion.  Alternative ID would reduce
contaminant mobility by reducing their solubility.  However, there
would  be no reduction in toxicity under this alternative and the
volume of  treated  material  would  increase  by roughly  thirty
percent.

Alternative  1C will  reduce the  mobility of  contaminants first
through treatment and then by placement in the CELA which will be
contained  by  a cap.  Alternative IE would also reduce contaminant
mobility for the same reasons.   No reduction in toxicity or volume
of  contaminated   soils  would  occur  under   either  of  these
alternatives.

Subsurface Soils:   No reduction in toxicity, mobility,  or volume is
provided   by   Alternative  2A.     Alternative  2B  would  reduce
contaminant mobility through treatment and landfill disposal, but
there  would  be  no  reduction  in  the   toxicity  or  volume  of
contaminants.   Alternative 2C  would  result  in  a  significant
reduction  in mobility of VOCs in subsurface soils through removal,
as well as a  reduction in toxicity  and volume as  the VOCs would
ultimately volatilize.   This technology,  however,  is ineffective
for the cleanup of metals.

Groundwaters  Alternative 3A/B for groundwater does not involve any
removal,  treatment,   or  disposal  of contaminants  and therefore
provides   no   reduction   in   toxicity,   mobility,   or   volume.
Alternative 3C would contain the groundwater contaminants, thereby
reducing mobility and the ability of contaminants to migrate into
the Genesee River.   The treatment process  would reduce contaminant
concentrations in  the treated  groundwater to below surface water
discharge or POTW pretreatment standards and would have the goal of
reducing contaminant concentrations in the aquifer to below ARARs,
effectively diminishing both toxicity and volume.

5. Short-term Effectiveness

Surface  Soils:     The  short-term   effectiveness   of  all  the
alternatives  is  high  since  each  alternative  involves  little
construction  and implementation.  Although the potential for dust
release is higher for Alternatives 1C and IE, both alternatives are
still  high  in regard  to  short-term  effectiveness.    Reliable
technologies will  be used in the  excavation, treatment, transport,
and consolidation phases to ensure that any dust releases will be
minimized.  The time  for implementation of the construction phase
of Alternative 1C is 6 months,  with a minimum of 30 years of CELA
monitoring (under OU1),  while Alternative IE would take 6 months
with no monitoring component.

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                               23

Subsurface Soils:  The short-term effectiveness of Alternative 2A
is high  since  the implementation of local zoning  ordinances and
monitoring will not disturb any potentially contaminated subsurface
soils.    Any  exposures  during  sampling  under  the  monitoring
activities  will  be  mitigated  by  proper  personal  protection
equipment  and  procedures.    The  implementation  time  for  the
construction component of this alternative is estimated to  be 2
months,  followed  by  a  minimum  of  30  years  of  monitoring.
Alternative 2B is slightly less  favorable  in  terms of short-term
effectiveness.  The affected areas under construction would require
dust control measures, air monitoring, erosion and sediment control
measures,  and  personal protection  equipment  and procedures  to
mitigate any exposures.  The  construction implementation period for
this  alternative would  take  6-12 months,  with- no  monitoring
component.   The  short-term  effectiveness of  Alternative 2C  is
measured against the short-term risk associated with the inhalation
of VOCs  during construction.   These risks are  mitigated through
proper operational procedures and health and  safety precautions.
The  estimated  implementation  time for  construction  of  this
alternative is 6 months for each extraction  area or 24  months
total, to be followed by at  least 30 years of monitoring.

Groundwater:  The short-term effectiveness of each alternative is
high since there is no exposure to contaminated groundwater during
implementation.   Any short-term  risks  are  derived  from  the
potential  of  constructing  and  using a  groundwater  well on-site
before institutional controls are  in place,  which  is considered
highly unlikely  since  the  site  is provided  with water  from the
Village municipal system.  The estimated  implementation  time for
Alternative 3A/B is 2 months for  construction and a minimum of 30
years monitoring.  Alternative  3C is also effective in the short-
term.    Any short-term  impact  is  also  measured  against  the
likelihood of any groundwater use  before the institutional controls
are in place.   Implementation of Alternative 3C would not result in
any exposures through proper operational procedures.  The estimated
time  for  implementation of  the  construction  phase  of  this
alternative is 24 months, with a minimum of 30 years of monitoring
and O&M to complete the remedial  action.

6. Implementability

Surface Soils:  Alternatives 1A, IB,  and ID are technically easy to
implement, although each requires maintenance to remain effective.

Alternative   1C   utilizes   technologies   that   are   readily
implementable.    The equipment and personnel  required  for  this
alternative are  readily  available.  Excavation of  contaminated
soils in the area of the flood control dike may require specialized
equipment  to maintain the integrity of  the  flood  control  berm.
Long-term monitoring of the  CELA,  which is part of the OU1 remedy,
is also a component of the implementation  of this alternative.  The
implementability of Alternative IE involves the same implementation

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requirements except that off-site transportation technology would
replace CELA monitoring.

Subsurface  Soils:    Alternative  2A  for  subsurface  soils  is
technically  easy  to  implement  and  would involve  implementing
institutional controls and annual inspections and public awareness
programs.    Alternative  2B  involves  proven  and  commercially
available technology.   However,  the available capacity of off-site
disposal and treatment facilities could pose a potential problem in
the implementation of this alternative and this option would also
require public  access restrictions to the  affected  areas during
remediation. Alternative 2C is a commercially available technology
that  has  been  demonstrated on  a  number  of  other  sites.   The
implementability of this technology  is questionable,  however,  in
regard to  achieving required cleanup levels due to  areas of low
permeability and low  porosity  in  the subsurface  soils.   This
technology  is  also  ineffective  for  the  cleanup  of  metals.
Extensive soil  sampling  and  long-term groundwater  monitoring are
also implementation components of this alternative.

Groundwater:     Alternative  3A/B  for  groundwater   is  easily
implemented since remedial activities are limited to posting signs,
conducting a public awareness  program,  and long-term monitoring.
Establishing well restriction areas through local zoning ordinances
are also part of the implementation of this alternative.

Alternative  3C  uses  standard equipment and well  developed
technologies  that  are   commercially  available.     Treatment
alternatives  for  the  extracted   groundwater  would  require
treatability testing during remedial design.  The small volume of
residuals  from  the  construction of  this  alternative would  be
transported off-site for  disposal.  Whether or  not ARARs  can be met
in  a  reasonable  time  frame  is an  unproven  component of  the
implementability of this  alternative.  However, contingencies will
be  included  to  maximize  the  pump  and  treatment  system's
effectiveness in realizing this goal.

7. Cost

Surface Soils:    The  present  worth  cost  of  Alternative  1C  for
surface  soils   is  approximately $1,505,000.    This  is  also  the
capital cost figure,  as  no O&M cost for the CELA  is included in
this remedial alternative.   (CELA O&M is  a component of the 1985
ROD.)  The  estimated  cost range of the alternatives for surface
soil  remediation  are  from  a  present  worth  of  $743,000  for
Alternative 1A to $4,110,700 for Alternative IE.  Individual cost
breakdowns are included in  the  Description of Alternatives section
of this ROD.

Subsurface Soils:   The  present worth cost  of Alternative 2A for
subsurface soils is approximately $882,100.  The capital cost for
this alternative  is $81,300 and annual  O&M is expected to cost

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                               25

$108,700 for years 1-5 and $31,400 for years  6-30.   The estimated
cost range of the  alternatives for subsurface soil remediation are
from a present worth of $882,100 for Alternative 2A to $22,869,800
for Alternative 2B.  Individual cost breakdowns are included in the
Description of Alternatives section of this ROD.

Groundvater:    The  present  worth  cost  of  Alternative  3C  for
groundwater is  approximately  $13,162,600.   The capital cost for
this alternative is $2,311,200 and annual O&M is  expected  to cost
$705,900.    The  actual  cost  of  this   alternative  could  be
considerably less depending on the contingency measures which may
be invoked after initial  implementation, and  could be more should
EPA decide that O&M should be conducted  for more than 30 years.
The  estimated  cost range of  the alternatives  for  groundwater
remediation are from a present worth of $1,716,400 for Alternative
3A/B to $13,162,600  for Alternative 3C.  Individual cost breakdowns
are included  in the Description  of Alternatives section  of this
ROD.

8. State Acceptance

The State of  New  York supports the selected remedy  presented in
this ROD.

9. Community Acceptance

The local community  accepts the selected remedy.  All comments that
were received from the public during the public comment period are
addressed in the attached Responsiveness Summary.

IX.  THE SELECTED REMEDY

In  summary,  Alternative  1C for  surface   soil  remediation  will
achieve substantial risk  reduction through  the removal of  surface
soils contaminated with arsenic above 25 ppm and  lead above 1000
ppm.  These soils would then be treated to  the extent whereby the
concentration of  arsenic  or lead remaining  in the  leachate (as
determined by the  TCLP) is less than 5 ppm.  The treated soils will
then be consolidated into the CELA,  located  in the southern portion
of  the  site.    The  CELA will  then be capped  under  an on-going
remedial action and the excavated area will be backfilled with six
inches of clean soil  followed  by  six  inches of topsoil and then
revegetated.   Although this alternative  will  allow for  use and
exposure at its completion  under  current  site uses,  a five year
review is considered necessary, since the cleanup criteria for lead
is based on current  site use, and a five year review would evaluate
the  protectiveness  of  the  remedy  should   site   use  change.
Accordingly,  EPA  will recommend  the  implementation  of  a  local
zoning . ordinance  that  will  require   that the  New  York  State
Department  of  Health  (DOH)  be  notified  in  the event  of  any
construction activity  that would alter present site use.   If such
a construction activity were to occur,  an evaluation of the impacts

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of the proposed construction and its future use in regard to site
contaminantion and exposure pathways will  be  provided to DOH for
their review and comment.

Alternative 2A  for  subsurface soils will  be  fully  protective of
human health  and  the environment through  no  action,  as  no known
risk pathway presently exists  for exposure  to contamination.  This
alternative entails implementation of a public awareness program,
long-term surface water,  groundwater, and soil-gas monitoring, and
the recommendation of institutional  controls,  in the form of local
zoning ordinances, to protect against any future activities or site
uses that may open  an exposure pathway.   Based on  the available
data,  the subsurface  soils  do not  appear  to  be acting as  a
significant source of groundwater contamination and, over time, the
predominant mass of contaminants affecting groundwater have already
migrated  into  the  aquifer.     Based  on  subsurface  soil  and
groundwater sampling data, no correlation has been found to suggest
discrete  subsurface  soil sources  of groundwater  contamination.
Under this alternative, the  site will be reviewed every five years
to evaluate the protectiveness of the remedy.

Alternative  3C  for  groundwater attempts to  return  a  usable
groundwater aquifer to its beneficial use,  as practicable, within
a  reasonable  'time  frame.   Groundwater  treatment also  prevents
migration of  contaminants into  the Genesee  River.   Under this
alternative, wells will be strategically placed to extract the bulk
of  the  contaminated  groundwater  from  the  aquifer;  the  exact
location and  pumping rates  will be determined during the design
stage.   The  pumped  groundwater will  be  stored  in a  central
collection tank  for subsequent treatment in  an above-ground system.
Treated groundwater will then  be either discharged directly to the
Genesee River or via the POTW.   Institutional controls, in the form
of local zoning  ordinances, would be recommended during the period
of remediation.   Monitoring under this alternative will include
surface water, groundwater, groundwater seeps, and  Genesee River
biota.  The biota monitoring  will entail the  sampling of various
indigenous species at points upstream and adjacent to the site and
an evaluation of site-related  impacts on the biota.  Sampling will
take place before any design implementation, and if no impacts are
found, the biota monitoring will be discontinued.   If  significant
impacts are found, however, a post-remedial interval  for further
biota  monitoring  will  be established.    This alternative also
stipulates contingency measures, outlined under Alternative 3C in
the Description of Alternatives  section of this ROD,  whereby the
groundwater extraction and treatment system's performance will be
monitored on  a  regular  basis and adjusted  as warranted  by  the
performance data collected during operation.   If it is  determined,
in spite of  any  contingency  measures  that  may  be  taken,  that
portions of the aquifer cannot be restored to its  beneficial use,
ARARs  may  be  waived based   on  technical  impracticability  of
achieving further contaminant  reduction.  The decision to invoke a
contingency measure  may be made during periodic  review  of  the

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remedy, which will occur at intervals of no less often than every
five years.  At that time, the State of New York will be given the
opportunity  to review,  comment,  and concur  on all  contingency
decisions.

Each of these  preferred alternatives are believed  to  provide the
best balance of trade-offs among the alternatives with respect to
the evaluation criteria.   Based on the information available at
this  time,  EPA  believes  the  preferred  alternatives  will  be
protective of human health and the environment, comply with ARARs,
be  cost effective,  and utilize  permanent technologies to  the
maximum extent practicable.  The preferred alternatives for surface
soils and groundwater also meet the  statutory preference for the
use of a remedy that involves treatment  as  a principal element.

X.  STATUTORY DETERMINATIONS

Under  its legal  authorities,  EPA's primary  responsibility  at
Superfund  sites is  to  undertake remedial  actions that achieve
adequate  protection of human  health and  the  environment.   In
addition, Section 121 of the Comprehensive Environmental Response,
Compensation, and Liability Act (CERCLA)  establishes several other
statutory requirements  and preferences.   These specify that, when
complete, the selected remedial action for a site must comply with
applicable or relevant and  appropriate environmental  standards
established under  federal and  State environmental laws  unless a
statutory waiver is  justified.  The  selected remedy also must be
cost effective and  utilize  permanent  solutions and  alternative
treatment technologies to the maximum extent practicable.  Finally,
the  statute  includes  a  preference  for  remedies  that  employ
treatment that permanently and significantly reduces  the volume,
toxicity, or mobility of hazardous substances as their principal
element.  The  following sections discuss how the selected remedy
meets these statutory requirements.

1.  Protection of Human Health and the Environment

The  selected  remedy is  protective  of  human  health  and  the
environment.   Surface soils with arsenic levels  above  25 ppm will
be excavated and treated, then disposed of in the on-site landfill
and capped.   With  a 25  ppm cleanup goal  for arsenic,  the risk
assessment  calculated   that  future-use scenarios  for  on-site
occupants exposed  to arsenic would represent an  ingestion based
risk of  1.0x10**, which is within EPA's  acceptable risk  range of
l.OxlO-1 to 1.0x10*.   It should be noted that the target risk level
of  10*  yielded  a  cleanup  level  for  arsenic  which  was  below
background concentrations.   Surface soils with  lead levels above
1000 ppm also  will  be excavated, treated, disposed of  in the on-
site landfill  and  capped.   The 1000 ppm cleanup goal  is derived
from guidance which adopts the  recommendation  contained in  a
Centers for Disease  Control  (CDC) statement concerning levels to
protect against childhood lead poisoning. The short-term  risk from

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excavating  the  contaminated  soil  is  considered  minimal  and
construction practices will employ dust control, if necessary, to
reduce the short-term risk even further.

The selected remedy for subsurface soils is also fully protective
of human health and the environment.  No risks presently exist from
subsurface soils due to the lack of a known exposure pathway.  The
no action remedy is protective  in  that potential sources of risk
are controlled  through containment (by overlying soils)  and will
remain protective through monitoring, assuming the enforcement of
the institutional controls which are recommended here to address
any future site uses which could open an exposure pathway.

Groundwater remediation with the goal  of  achieving ARARs is also
protective of human health and the  environment.  Although there is
no current exposure pathway for groundwater use on the site, the
pumping  and  treatment alternative attempts  to restore  a future
potential  drinking water source  to  drinking water  standards.
Additionally,  the  alternative  prevents  any   contamination  from
migrating to the Genesee River, the surface water body to which the
contaminated aquifer discharges, which is  a  local drinking water
source.  Although EPA acknowledges that MCLs may be unattainable,
by actively removing and treating contaminants in the groundwater
aquifer, human health and  the environment is fully protected under
the chosen remedy.

2.    Compliance with Applicable  or  Relevant  and  Appropriate
Requirements

The selected remedy will be designed to meet all ARARs (Tables 9-
11).    Additionally,  a  wetland  assessment  and restoration  or
mitigation plan will be  required for any wetlands  impacted or
disturbed by remedial activity.  A cultural  resources survey, to
comply  with  the  National  Historic  Preservation  Act,  and  a
floodplain assessment will also be required prior to any remedial
activity.

3.  Cost Effectiveness

The selected remedy  is  cost effective and provides the greatest
overall protectiveness proportionate to costs.   On-site disposal of
excavated surface soils, at a present worth of $1,505,000 is more
cost  effective than  off-site  disposal,  at  a present worth of
$4,110,700, and offers an equivalent degree of protectiveness.  The
present  worth   of  $882,tlOO for the  no  action subsurface  soil
alternative is cost effective in that it offers the same level of
protectiveness  as  the in situ vapor  extraction  and  excavation
alternatives, but at considerably less  cost.  The $13,162,600 cost
associated with groundwater treatment is cost effective in that the
remedy provides the greatest overall protectiveness compared with
the  $1,716,400 cost  associated with  no  action,  which is  not
considered to be protective.

-------
                               29

4.  Utilisation of Permanent Solutions and Alternative Treatment
    (or Resource Recovery)  Technologies to the Maximum Extent
    Practicable

The  selected  remedy represents  the  maximum  extent  to  which
permanent solutions and alternative  treatment technologies can be
utilized in a cost effective manner.   Of those alternatives which
are protective of human health and the environment and comply with
ARARs, EPA has  determined  that  the  selected remedy provides the
best balance of  trade-offs in terms of the five balancing criteria:
long-term effectiveness  and permanence;  reduction of  toxicity,
mobility, or volume  through treatment;  short-term effectiveness;
implementability; and cost.  The modifying considerations of state
and community acceptance also play a part in this determination.

The long-term effectiveness and  permanence of the selected remedy
is very high  in that the surface soils which exceed  the cleanup
criteria would be removed and the contaminated areas  restored to
ambient conditions.   As no  known risk  exposure pathway exists for
contact  with subsurface  soils,  the   no  action  alternative  is
effective and permanent in maintaining reliable protection of human
health and  the  environment.  Groundwater treatment  also  offers
long-term effectiveness and permanence in that the remedial goal is
to achieve ARARs and that the pumping  and  treatment would remove
the groundwater contamination, thereby lessening the impact on the
Genesee River.  Reduction of toxicity,  mobility, or volume is also
evident in the selected remedy.   The treatment and placement into
the on-site  landfill  of  affected surface soils will  effectively
reduce the mobility of contaminants in  surface soils.  Although the
no  action choice  for subsurface soils  has  no  effect  on  the
toxicity, mobility,  or  volume  of  contaminants,  it   is  a  cost
effective alternative that provides adequate protection of human
health and the environment.  Groundwater treatment has the goal of
reducing contaminant concentrations  in the aquifer to  meet ARARs,
effectively diminishing both toxicity  and volume.   The short-term
effectiveness and implementability of  the surface soil excavation
alternative is  high  in that it  involves simple construction and
implementation  using  proven   technologies.    The   short-term
effectiveness and implementation of  the no action alternative for
subsurface soils  is  similarly high  in that the subsurface soils
would essentially remain undisturbed.  The short-term effectiveness
and implementability of the groundwater treatment  alternative is
high  in  that there  is  no  exposure to contaminated  groundwater
during implementation and the remedy employs standard equipment and
well developed technologies.  As stated above, the cost associated
with the selected remedy is the least costly of each remedy that is
protective of human  health  and  the  environment and provides for
treatment of the most hazardous  materials.

5.  Preference for Treatment as  a Principal Element

The statutory preference for treatment as a  principal element is

-------
                                30

satisfied in the selected remedy for each media except subsurface
soils.  For subsurface soils, no action has been determined to be
as effective in the protection of human health and the environment
and  less  costly than treatment alternatives.   The  surface soil
excavation  alternative  requires  treatment  to comply  with  LDR
standards  and  the  groundwater treatment  alternative  requires
treatment to drinking water standards, to the extent practicable.

-------
APPENDIX A

-------
I
I
           ?.•' 'J 'ff %& WELLSVILLV
            I*"VY' !» •-v* • '•* >»**> *
            *             •
                             REFINERY AREA
                                                          SINCLAIR REFINERY SITE
                                                          WELLSVILLEJUEW YORK
                                    POOR QUALITY
                                       ORIGINAL
                                                        IIASCO StUVICES INCOK^OMATIO

-------
FIGURE  2

-------
            FIGURE   3
P" " ( «U
                                     •••»«•   •••
                                         •CMIMfUl
                                                                                                                  J
                                                                                                                 /

-------
APPENDIX B

-------
                                              TABLE  1




                             CHEMICALS DETECTED  IN REFINERY AREA SURFACE SOIlS<*>

                                       RANGE OF CONCENTRATIONS («g/kg)
                       Phase I
                        (1985)
                          14
                        0.076- 0.10 (2)<«>
                        1.0
                        1.7
                        1.0
                        1.5
                        2.0
                        2.0
                           NO
                           NO
-2.5
- 2.8
- 7.5
  5.0
  3.6
(1)
(2)
(3)
(4)
(2)
(2)
NA
0.68
13
NA
0.5 -
NA
NA
9.2 -
NA
14
NA
53 -1
NA
NA
0.07 -
15
NA
NA
NA
0. 47.
NA
58

(1)
31 (14)

1.2(4)


26 (14)

47 (14)

.190 (4)


1.9(14)
49 (14)



0.98(4)

244 (14)
fhase IIa
(1986)











12.





6.

10

28


0.
9.





41
10
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
5-182 (3)
NO
NA
NO
NA
NA
3- 29.6 (9)
NA
- S3 (10)
NA
-373 (9)
NA
NA
1 (D
1-26.1 (10)
NA
NA
NA
NO
NA
-131 (10)
Phase lib
(1988)
35«>
NO
0.38-13
0.27-
0.32
0.34-
NO
0.42
0.25-
0.13-
3470 -14
5.1 -
4.3 -
28 - 3
0.24-
1.1 -
1580 .53
6.8 -
5.1 -
9.6 -
13700 -43
7.5 - 1
486 -12
204 - 1
0.13-
7.2 -
353 - 1
1 -
42.5 -
2.0
7.8 -
45 -




(2)
0.37 (1)
(3)
0.46 (3)

(1)
0.72 (3)
0.88 (2)
.850 (35)
12 (4)
43 (32)
.130 (35)
51 (29)
3.5 (8)
.800 (20)
23 (26)
11.5 (35)
272 (34)
.600 (35)
.020 (35)
.000 (31)
.100 (35)
9.4 (13)
26 (3D
.460 (32)
2.4 (20)
314 (2)
(1)
19 (34)
586 (32)
 Nunber of
 Sample* Analyzed

 Volatile*
 Methyl  Chloride

 SNA*
 2-Hethylnapthalene
 Phe'nanthrene
 Fluoranthrene
 Pyrene
 Benzol a)anthracene
 Benzo(b)f1uoranthene
 8enzo(a)pyrene
 Oi-o-buty1phthalate

 Metal*
 A1 ufii nun
 Antimony
 Arsenic
 Barium
 Beryl 1 i un
 Cadni un
 Calcium
 Chrooi urn
 Cobalt
 Copper
 Iron
 Lead
Magnesium
Manganese
Mercury
Nickel
Potassium
Silver
Sodium
Thallium
Vanadi urn
Zinc

 (a) Compounds listed include all compounds detected two or more times in this Mdia,  in  any phase,  and  all
    indicator chemicals dttedted.
(c) Composite samples
    inclutf
(d) includes 10 near surface test pit samples analyzed for volatile*.  BNAs and
    for metals only
(e) Value in parenthesis indicates mater of samples with value above  detection Haiti.
NO s not detected, NA * aot analyzed
                                                    tals  and  22  surface  soils

-------
TABLE 2
                            CHEMICALS DETECTED IN SUBSURFACE  SOILS<«>
                                        ORGANIC COMPOUNDS
                                 RANGE OF CONCENTRATIONS  (ag/kg)

                           Phase I(e>
                             1965
          Phase IIa(c)
          Jan-Nov. 1986
                                                              Phase lib
                                                              Oet-Oee. 1988
    Total  Nuaber of
    Samples Analyzed
31
                                               35







2.1





NO
NO
NO
NO
NO
NO
NO
(D
NO
NO
NO
NO
NO
1.2 (1)
0.004 . 0.19 (19)
0.027 - 0.13 (3)
0.0001- 0.018 (6)
0.0009- 1.45 (21)
0.14 - 5.1 (8)
0.014 - 1.9 (8)
0.022 - 0.63 (6)
0.002 - 0.91 (5)
0.010 - 0.37 (6)
0.045 - 3.6 (8)
0.0017- 0.0018(2)
0.0003-26 (17)
                                                          (b)
                                                              0.018-0.12
                                                                 NO
                                                                 NO
                                                                 NO
                                                                 NO
                                                                 NO
                                                                 NO
                                                                 NO
                                                                 NO
                                                                 NO
                                                                 NO
                                                                 NO
                                                                 NO
                                           (2)
 COMPOUNDS

 Volatile*
 Acetone
 Carbon Disulfide
 2-6utanone
 1,1,1-Trichloroethane
 Benzene
 4-Hethy1-2-Pentanone
 2-Mexanone
 1,1,2,2-Tetrachloroethane
 Toluene
 Chlorobenzene
 Ethyl benzene
 Styrene
 Total  Xylenes

 BNAs
 Ni trobenzene
 2,4-Oiwthylphenol
 Napthalenc
 2-Hethylnapthalene
 Diwthylphthalate
 Acenapthylene
 Acenapthene
 Oibenzofuran
 Oiethylphthal ate  .
 Fluorene
 N-Ni trosodiphenyl anine
 Phenanthrene
 Anthracene
 Fluoranthrene
 Pyrene
 Butyl  Benzyl Phthalate
 BenzoU) Anthracene
 Chrysene
 Oi-W-OctylPhthalate
 Benzo(a)Pyrene
 Bi s(2-ethylhexyl)phthalate
 Phenol

 Metalt
 Aluminum
 Antimony
 Arsenic
 Bari urn
 Beryllium
 Cadni urn
 Calcium
 Chromium
 Cobalt
 Copper
 Iron
 Lead
 Magnesium
 Hanganese
 Mercury
 Nickel
 Potassium
 Silver
 SodiUN
 Thalliu*
 Vanadium
 Zinc

 (a) Compounds listed include all  compounds  detected  in  t«o or nor* sables in this mvdia. in any phase
    and all indicator chemicals detected.
 (b) Value in parenthesis indicates  nwaber of  samples with value above  detection  Jierits.
 (c) Coeposite samples.
 (d) Includes 3 samples analyzed for organics  and 52  for metals.

NO « not detected
NA * not analyzed
NO
NO
1.0 (1)
NO
NO
NO
NO
NO
NO
NO
NO
1.2-1.5 (2)
NO
1.0-1.6 (3)
2.6 (1)
NO
1.7 (1)
NO
NO
NO
NO
NO
0.076 - 0.24 (2)
0.02 - 0.19 (2)
0.029 - 3.3 (14)
0.018 -17 (21)
0.033 - 0.037 (3)
0.016 - 0.35 (2)
0.022 - 1.5 (4)
0.041 - O.S9 (6)
0.036 - 1.0 (14)
0.031 - 2.5 (12)
0.13 -0.58 (4)
0.005-6.1 (14)
0.024 - 1.5 (5)
0.04 - 0.58 (7)
0.06 - 1.5 (8)
0.026 - 1.9 (7)
0.014 - 0.57 (5)
0.14 - 0.8 (5)
0.007 - 0.4 (11)
0.026 - 1.0 (8)
NO
0.036 - 0.1 (4)
NO
NO
NO
37.1
NO
NO
NO
NO
NO
NO
NO
22
NO
33
30
NO
17
25
ND
0.44-19
0.48- 0.67
NO
(D

(1)

(D
(1)

(D
(1)

(2)
(2)

NA
ND
2.8- 88
NA
0.61- 0.65
NA
NA
3.3 - 23
NA
10 -1,020
NA
3.2 - 791
NA
NA
0.03- 1.95
9.1 - 39
ND
0.48- 1.5
NA
0.75- 0.95
NA
22- 158
(31)

(2)


(31)

(31)
(31)


(10)
(31)

(S)

(2)

(31)
NA
12. -134 (4)
3.8 - 50 (27)
NA
0.5 - 1.3 (S)
1 - 1.3 (4)
NA
3.3 - 54.4 (26)
NA
5.6 - 43.4 (32)
NA
1.5 - 77.2 (35)
NA
310 -386 (2)
0.1 - 0.11 (5)
8.0 - 57.7 (32)
NA
0.24- 30.7 (8)
NA
2.0 - 6.2 (3)
10.1 (1)
16.3 -165 (35)
4,230 -22,700 (46)
4.6 - 15 (5)
2.3 - 49 (44)
68-283 (4fi>
0.26- 1
1.1 - 2
632 -«8.800
6.7 - 23
4.6 - IS
S.5 - 38
215 -34,000
7.7 - 763
1.270 - 8,590
138 - 3.660
0.12- 0
9.6 - 31
221 - 1,850
0.89- 2
42-75
2.0
5.4 - 30
38 - 117
.1 (38)
.8 (6)
(25)
(32)
(46)
» •** /
(46)
(46)
(52)
(46)
(44)
.94 (4)
(38)
(41)
.5 (23)
(7)
» * /
(2)
(45)
(43)

-------
                                CHEMICALS DETECTED IN GROUNDWATER<*>
                                         ORGANIC COMPOUNDS
 Total Number of
 Staples Analyzed

 COMPOUNDS

 Volatile*

 Acetone
 1,1-Oichloroethan*
 1,1,1-Trichloroethane
 Benzene
 Toluene
 Ethyl benzene
 Total Xylenes

 BNAS

 Ni trobenzene
 Naphthalene
 2-Methylnaphthalene
 Phenanthrene

 Note:
                                   RANGE OF CONCENTRATIONS (ag/l)
                             Phase I
                              1985
           11
                       Phase IIa(b>
                        Dec. 1986
   22
         NO         .  .
     0.044-0.067 (2)
     0.113       (1)
     0.002-0.73  (6)
     0.0044.057 (6)
     0.004-0.07  (4)
     0.008-1.31  (5)
         NO
     0.001-0.075 (2)
         NO
         NO
      NO
  0.005       (1)
  0.001-0.24  (2)
  0.005-0.53 (IS)
  0.002-0.53  (7)
  0.006-0.83 (10)
  0.023-1.1   (11)
  0.011-1.7   (2)
  0.003-0.17  (6)
  0.007-0.34 (16)
  0.015-0.090 (4)
                   Phase  lib
                   Mov-Oee! 1988
                      23
                  0.016 -8.5   (8)
                  0.012 -0.69  (3)
                  0.035 -1.8   (2)
                  0.004 -1.2  (14)
                  0.001 -0.39 (12)
                  0.0004-0.17 (14)
                  0.001 -1.5  (17)
                  8.2          (1)
                  0.032 -4.23  (2)
                  0.008 -0.27  (9)
                  0.018 -4.053 (3)
 (a) Compounds listed include all  indicator chemicals  detected.

 (b) Does not include landfill area samples

 (c) Number in parenthesis indicates number of sables with value above  detection  limit

 NO = not detected

 NA = not analyzed
 METALS
 Total Number of
 Samples Analyzed

 Aluminum
 Arsenic
 Bari UK
 Beryllium
 Cadni un
 Calcium
 Chromium
 Cobalt
 Copper
 Iron
 Lead
 Magnesium
 Manganese
 Mercury
 Nickel
 Potassium
 Silver
 Sodium
 Vanadium
 Zinc
   Phasg I
    1985

     11

    NA
0.003-4.095
    NA
    ND
0.003-0.005
    NA
0.005-0.006
    NA
0.004-0.016
    NA
    NO
    NA
                                             Phase IIa
-------
           TABLE  4
 Chemicals of Potential Concern

  Volatile Organic Compound*

methyl chloride (chloromethane)
        trichloroethene
            benzene
            xylene
 Seaivolatile Organic
          nitrobenzene
  benzo(a)pyrene  (excluded for
     the  off site  tank farm)
        Inorganic Metals

            arsenic
             barium
              lead
             nickel
              zinc

-------
                                       TABLE 5
               POTENTIAL MIGRATION PATHWAY AND EXPOSURE ROUTE EVALUATION
MEDIUM
SUBSURFACE
SOIL*

SOIL

SURFACE
WATER
ROUTE
INHALATION
OFVOCs
INGESTION
INHALATION
OF FUGITIVE
DUST
INGESTION
INGESTION
POTENTIALLY EXPOSED POPULATIONS
EXCAVATION ONSITE TRESPASSING CHILDREN
WORKERS OCCUPANTS OFFSITETANK REFINERY
X
X





X

X



X
X



X
X
#    For a future potential land-use scenario only.

-------
                           TABLE 6
                              KITICAL TOttCm VALOtS
IMUUTIO*
MO** »re csTCtMOMt*
CmxtCAL P«t«ner fMtvr *
At*«nl« 0 0 9.00t«01 (•)
Mrtui t.OOI-OJ (k) 1. 001-04 CH 0
0*nt*n« 0 0 2.0W-01 (•)
0«nie|«]p7t«n« 0 0 4.1*1*0* (•)
L«ad 4. let-OS C4) 4.901-04 <•) 0
Ntthrl Cht»rU« 0 • 0
Rlcktl 0 0 l.T*t**0 (•)
•ltr*k«nt*n« •.OOt-01 (k) 0.001-04 (k) 0
ttlchUtMthtnt 2.COI-01 (4) 2. 001-01 (•) 1.901-02 (k)
IrUn* T.OOt-OJ (k) 4.001-01 (k) 0
tine 00 0
eoju.
•fD*« UD Canla»emi«
1.001-02(4) 1. 001-02 (•) 1.00X400 CO
S.OOC-02 (k) 9.001-02 CO * 0
0 0 2.0*1-02 (•)
0 0 i.istm to
1.401-02 (4) 1.401-01 CO ' 0
00 0
a. 001-02 (•) 2.001-02 c» o
9.00C-09 Ck) 9.001-04 (k) 0
l.OOt-01 C4) 1.001-02 C«) t. 101-02 Ck)
4.001*00 Ck) 2.00K+00 (•) 0
a. oot-oi ck) a.oot-oi ck> o
      t«t*i r«pr*ttnt •u«*ll»kU «t v
teuttitt  (•) IRIt
        (k) RU tuHMrr TckUt
        (c) t*tlMt*4 k«t«4 •• MCL
        (4) t«tlMt*4 
-------
                                          TABLE 7

      NONCARCINOGENIC HAZARD INDEX ESTIMATES FOR THE SINCLAIR REFINERY SITE
MEDIUM
SUBSURFACE
SOIL*

SOIL

SURFACE
WATER
TOTAL HI
ROUTE
INHALATION
OF VOCS
INGESTION
INHALATION
OF FUGITIVE
DUST
INGESTION
INGESTION*

POTENTIALLY EXPOSED POPULATIONS
EXCAVATION ONSITE TRESPASSING CHILDREN
WORKERS OCCUPANTS OFFSITE TANK REFINERY
1.22E-2
1.05E-1



1.17E-1


9.45E-1

3.02E-2
9.75E-1


,.
2.48E-2
3.45E-1
3.7E-1



3.02E-2
2.11E-1
2.41 E-1
#    For a future potential land-use scenario only.
*    Exposure calculations using monitored data (B calculations).

-------
                                    TABLE 8
            CARCINOGENIC RISK ESTIMATES FOR THE SINCLAIR REFINERY SITE
MEDIUM
SOIL

SURFACE
WATER
TOTAL CANCER
RISK
ROUTE
INHALATION
OF FUGITIVE
DUST
INGESTION
INGESTION*

POTENTIALLY EXPOSED POPULATIONS
ONSITE TRESPASSING CHILDREN
OCCUPANTS OFFSITE TANK REFINERY
1.64E-4
(Ar=1.53E-4)

3.3E-5
1.97E-4

9.4E-6
3.3E-5
4.25-5

4.89E-6
3.3E-5
3.79E-5
Exposure calculations using monitored data (B calculations).

-------
                                   TABLE 9
                            CHEMICAL-SPECIFIC ARARS

                        SINCLAIR REFINERY SITE.  NEH
 REQUIREMENT

 Safe Drinking Hater Act
 (SDHA) Maximum Contam-
 inant Levels (MCLs)
 (40 CFR 141.11-141.16)
    REQUIREMENT SYNOPSIS

 The SDHA MCLs establish
 maximum acceptable levels
 of organic chemicals and
 metals 1n drinking water
 at the tap.
APPLICABILITY/RELEVANCE
  AND APPROPRIATENESS

   EPA has determined
   that SDHA MCLs are
   ARARs for the
   Sinclair Refinery
   Site
 New York State
 Department of Environ-
 mental Conservation
 (NYSDEC) Class GA
 Groundwater Quality
 Standards (6 NYCRR
 703.5
-------
                                                                         TABLE  10


                                                                   ACTION-SPECIFIC ARARs
          Requi rement
                   Reauireaent Synopsis
       Applitabillty/Relavance and Appropriateness
 New Vorfc RCRA Hazardous
 Wastt Facility Requirements
 (6  NVCRP. 370 and 373J
 New York RCRA Closure and
 Post-Closure  Standards for
 Landfills
 (6 MVCRR 370  and 373)
New York RCRA Generator and
Transportation Standards
(6 NVCRR 372)
    York General Prohibition
en Air Emissions (6 NYCRR 211)
New York General Process Air
Emissions Standards and VOC
Guidance Values (6 NVCRR 212.
NY Air Guide 1)

New York State Pollution
Discharge Elimination System
(SPOCS) Requirements for
Site Runoff. Surface Water
and Groundwater Discharge
Limits (6 NYCRR 750-757)
The NY RCRA facility regulations govern the operation
and design of equipment and system treating or storing
hazardous waste.  Although RCRA is not applicable to the
site overall, requirements that apply to specific hazard-
ous waste handling activities, such as equipment design
and operating standards, are relevant and appropriate.

The NY RCRA closure standards provide requirements for
closing RCRA hazardous waste facilities.  The
requirements include waste removal or capping, site
maintenance, and groundwater monitoring.  The primary
closure goal is to "...minimize or eliminate maintenance
controls needed ... and minimize or eliminate, to the
extent necessary to protect human health and the environ-
ment, the post-closure escape of hazardous waste to
groundwater. air. or surface water."  This goal can be
attained using a combination of waste containment,
removal and site monitoring activities.

These standards require that a generator manifest
tracking form accompany all shipments of hazardous
waste off-site.

These prohibitions restrict the emission of particulate
matter, fumes, mist and smoke, among other visible
emissions.

These standards establish emissions levels for VOCs from
specific sources and methods for calculating VOC
emission levels' from unspecified sources.
The SPOES requirements provide for the control of site
runoff that would degrade surface water quality,  or
discharging to surface water from an on-site treatment
system.  Effluent limits are included in the regulations
as guidelines for the development of site-specific
effluent limits.
Although RCRA is not applicable to the site, requirements that
apply to specific hazardous waste handling activities, such
as equipment design and operating standards, are relevant and
appropriate.                            .                   ;
Although the Sinclair Refiner* Site was not • RCRA
treatment, storage or disposal facility, the presence of
contamination in site soils is sufficiently similar
to a RCRA landfill that the primary RCRA closure
goal is relevant and appropriate.
These requirements would be applicable to any offsite shipment
of a hazardous waste in a non-CERCLA context.
These requirements would be applicable to construction
activities that produce fugitive emissions.
These requirements would be applicable to remedial activities
using equipment or treatment systems that emit VOCs to the
atmosphere.
These requirements would be applicable to (1) site runoff
during remediation work and (2) discharges from any on-sito
treatment unit.

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                                                                  TABLE  10 (Cont'd)

                                                                   ACTION-SPECIFIC ARARs
          Requirement
                   Requirement Synopsis
       Applicability/Relavance and Anorooriatenesi
Local (Wellsville) POTW Waste-
water Pretreatment Requirements
RCRA Land Disposal Restriction*
(LOR) (40 CFR 268)
Occupational Safety anil Health
Administration (OSHA) Standards
For Hazardous Responses
(29 CFR 1904,. 1910. and 1926)

Department of Transportation
(DOT) Rules for Hazardous
Materials Transport  (49 CFR
107 and 171.1 to 171.500)

National Emission Standards for
Hazardous Air Pollutants
(NESHAPs) Asbestos Regulations
(40 CFR 61. Subpart N. Sections
61.140 to 61.156)

Occupational Safety and
Health Administration
The local POTW requires that all wastewaters be pretreated
prior to discharge, such that POTW-treated effluent does
not exceed permissable contaminant levels.   The "USEPA
Guidance on POTW Discharges". OSWER Directive 09330.2-04,
provides further information on how to evaluate and
pretreat wastewators for POTW discharges.

The RCRA LOR requires that RCRA hazardous waste be treated
to meet certain numeric or BOAT standards, prior to off-
site disposal or "placement" in a landfill.
The OSHA standards provide safety and protection
procedures for workers on hazardous waste sites.  The
standards include protective clothing, worker training,
medical surveillance, among other requirements.

The DOT transport rules set procedures for
manifesting, labeling, and packaging of waste for
off-site transport to disposal or treatment facilities.
The NESHAPs address handling, removal, disposal
and emissions of asbestos and asbestos-containing
material (ACH)
The Asbestos Standards establish ACH handling worker
safety requirements.  They are applicable to asbestos
abatement projects.
These requirements «ould be applicable to discharges of
wastewater, generated by the remedial activities, to the
Wellsville POTW.
These requirements may be applicable to disposal of sludge from
the separator, depending upon the characterization of the
sludge  and  the relevance  of  the RCRA petroleum  exclusion.
They  are            .      to b« oon*ldara4 for       contaminated
soil and debris disposal

These standards are applicable requirements.
Thest are applicable requirements.
These standards are applicable requirements.
These art applicable requirements.

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                                                                        TABLE 11
                                                                    LOCATION-SPECIFIC ARAfU
    Requirement
                                                        Requirement Synopsis
                                                                              Apptlcablltty/ReUvance and Appropriateness
 Location-Soccifli;

 USEPA  (Region  II) Policy on
 Floodplains and Wetlands
 (CERCLA/SARA Environmental
 Review Manual. January 1988)
 This policy outlines  procedures  for evaluating the adverse
 effects  of remediating in  floodplains and wetlands and
 presents SUM measures for minimi ling adverse impacts.
 To be considered during remedial design phase.
 Floodplain and Wetlands
 Executive Order #'s 11900 and
 11988

 USEPA's Statement of Policy on
 Wetlands and Floodplain
 Assessments for CERCLA Sites
These executive orders call for the protection.
preservation and mitigation of adverse impacts on
wetlands and floodplains.

This statement requires that wetlands and floodplain
assessments be conducted at Superfund Sites and that
measures be taken to protect the integrity of wetlands
and prevent floodplain damages.
 To be considered during remedial design phase.
 To be considered during remedial design phase.
 RCRA Land Disposal  Restrictions
 {LOR) (40 CFR 268)
The RCRA LOR requires that RCRA hazardous waste be treated
to meet certain numeric or BOAT standards, prior to off-
site disposal or "placement" in a landfill.
To be considered during remedial design phase.
National Historic Preservation Act
 Requirea that a cultural resources survey be completed

 prior to construction activities.
                                                                                                         To be considered during the remedial design phase.

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APPENDIX C

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ft EPA
                                               OH»o» of
                                                Emergency
                                                                           July 1969
                                                                                 9347.S-OSFS
                       Superfund LDR Guide #5
                       Determining When  Land
                       Disposal Restrictions  (LDRs)
                       Are Applicable to  CERCLA
                       Response Actions
    CERCLA Section 121(d)(2) specifies that on-rite Superfund remedial actions shaH attain 'other Federal standards,
 requirements, criteria, limitations, or more stringent State requirement* dot are determined to be kgaDy applicable
 or relevant and appropriate (ARAR) to the specified circumstances at the site.* In addition, the National Contingency
 Plan (NCP) requires that op-site removal actions attain ARAR* to the  extent practicable.  Off-rite removal and
 remedial actions must comply with legally applicable requirements.  This foide outlines the process used to determine
 whether the Resource Conservation and Recovery Act (RCRA) land disposal restrictions (LDRs) established under
 the Hazardous and Solid Waste Amendments (HSWA) are •applicable* to a CERCLA response action. More detailed
 guidance on Superfund compliance with the LDRs is being prepared by the Office of Solid Waste and Emergency
 Response (OSWER).
   For  the LDRs to be  applicable to  a CERCLA
response, the action  must constitute placement of a
                             Therefore, site
restricted RCRA
                       waste.
 managers (OSCs, RPMs) must answer three separate
 questions to determine if the LDRs are applicable:

    (1)    Does  the  response  action   constitute
          placement?

    (2)    Is the  CERCLA substance being placed
          also a RCRA hazardous waste? and if so

    (3)    Is the RCRA waste restricted under the
          LDRs?

    Sit; managers also must determine if the CERCLA
 substances are California  list wastes, which are  a
 distinct category  of RCRA hazardous wastes restricted
 under the LDRs (see Superfund LDR Guide f 2).

 (1) DOES  THE   RESPONSE  CONSTITUTE
    PLACEMENT?

    The LDRs place specific restrictions (e^, treatment
 of waste to concentration levels) on RCRA hazardous
 wastes prior to their placement in land disposal units.
 Therefore, a key a.       T* is whether the response
 action wilj constitute placement of wastes into a land
 disposal unit.  As defined by RCRA, land disposal
 units  include  landfills, surface impoundments, waste
 piles, injection wells, land treatment facilities, sab dome
 formations, underground mines or caves, and concrete
 bunkers or vaults.  If a CERCLA response includes
 disposal of wastes in any of these types of c&sjifi land
 disposal  units,  placement  will  occur.   However,
 uncontrolled  hazardous waste   sites often have
 widespread and  dispersed contamination, making the
concept of a RCRA nait less useful for  actions
involving on-rite disposal of wastes.  Therefore,  to
assist in defining when •placement* does and does not
occur for CERCLA actions involving on-site disposal
of wastes,  EPA uses  the concept of  'areas  of
contamination"  (AOCs), which may  be viewed  as
equivalent to RCRA units, for the purposes of LDRfl
applicability determinations.                    ™

   An AOC is delineated by the area! extent (or
boundary)  of  contiguous contamination.    Such
contamination must be continuous, but  may  contain
varying  types  and  concentrations  of  hazardous
substances.  Depending on site'characteristics, one or
more AOCs may be delineated. Highlight i provides
some examples of AOCs.
                                                  Highlight 1: EXAMPLES OF AREAS OF
                                                  CONTAMINATION (AOCs)
                                                      A waste source (e.g-, waste pit,
                                                      waste pile) and the surrounding
                                                                 soiL
                                                      A waste source, and the sediments in a
                                                      stream contaminated by the source, where
                                                      the contamination is continuous from the
                                                      source to the sMimrnts *

                                                      Several lagoons separated only by dikes,
                                                      where the dikes are contaminated and the
                                                            share a common oner.
                                                  • Tbt AOC dots act adud* lay eoeuaiMtcd surface
                                                  or ptwjsd wtter out may b* tnociated with the laad-

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   For on-site disposal, placement occurs when wastes
are moved from one AOC (or unit) into another AOC
(or unit).  Placement does not occur when wastes are
left in place, or moved within a single AOC. Highitght
2 provides scenarios of when placement does and does
not occur,  as  defined  is the proposed NCP.   The
Agency is  current  Devaluating  the definition  of
placement prior to the promulgation of the final NCP,
and therefore,  these scenarios are subject to change.
Highlight 2: PLACEMENT

Placement doe? occur when wastes are:

•    Consolidated from different
     AOCs into a single AOC;

a    Moved outside of an AOC (for
     treatment  or storage, for
     example) and returned to the
     same or a different AOC; or

a    Excavated from an AOC, placed
     in a separate unit, such  as an
     incinerator or tank that  is within
     the AOC, and  redeposited into
     the same AOC.

                21 occur when wastes


     Treated in situ:

     Capped in place;

     Consolidated within the AOC; or

     Processed within the AOC (but
     not in a separate  unit, such as a
     tank) to improve  its structural
     stability (e.g., for  capping or to
     support heavy machinery).
    In summary, if placement on-site or off-site does
not  occur,  the LDRs  art not applicable to  the
Superfund action.

(2) IS  THE   CERCLA  SUBSTANCE  A  RCRA
    HAZARDOUS WASTE?
   Because a  CERCLA  response
placement of a restricted RCRA
                            must
                                        constitute
                                              for
the LDRs to be applicable, site managers must evaluate
whether  the contaminants at the  CERCLA site  are
RCRA hazardous wastes. Highlight 3 briefly describes
                                                 die two types of RCRA hazardous wastes -listed and
                                                 characteristic wastes.
                                                          Highlight 3: RCRA HAZARDOUS WASTES
                                                          A RCRA solid waste* is hazardous if it is
                                                          fated or exhibits a hazardous
                                                          Listed RCRA
                                                                Any waste listed in Subpart D of 40
                                                          CFR 261, including:

                                                                •      F waste codes (Pan 26131)

                                                                •      K waste  codes (Pan 26L32)

                                                                •      P waste codes (Part 26L33(e))

                                                                •      U waste codes (Part 26L33(f))


                                                          Characteristic RCRA Hazardous Wastes
                                                               Any waste exhibiting one of the following
                                                          characteristics, as defined in 40 CFR 261:

                                                                •      IgnhabOity

                                                                •      Conosiviiy

                                                                •      Reactivity

                                                                •      Extraction Procedure (EP)
                                                                      Toxicity
                                                          • A solid wwte fc any material that it discarded or
                                                          disposed of (Un abandoned, recycled is certain way*, or
                                                          considered inherently rate-like). Tbe wicte may be
                                                          aolid, ceai-aolid, liquid, or a contained gaseous material.
                                                          Eiclusjons boa the definition ((4., domestic sewage
                                                          sludge) appear a 40 CPU 261.4(a). Exemptions
                                                          aouscboM wattes) art found m 40 CFR 261.4(b).
   Site managers are not required to presume that a
CERCLA hazardous  substance is a RCRA hazardous
waste unless there is affirmative evidence to support
such a finding.  Site  managers, therefore, should use
'reasonable efforts* to determine whether a substance
is  a  RCRA fisted or characteristic waste.  (Current
data collection efforts during CERCLA  removal and

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remedial site investigations should be sufficient for this
purpose.)  For listed hazardous wastes, if manifest* or
labels are  not available,  this evaluation  likely will
require fairly specific information about the waste (e^,
source,  prior use,  process type) that is  'reasonably
ascertainable'  within  the  scope  of  a  Superfund
investigation.  Such information may be obtained from
facility business records or from aa examination  of the
processes used at the facility.  For characteristic wastes,
site managers may rely  on  the  results of the tests
described  in  40 'CFR   26121 -  2C124 for   each
characteristic or on knowledge of the properties  of the
substance.  Site managers should work with Regional
RCRA staff. RegionaJ Counsel, State RCRA staff, and
Superfund enforcement personnel,  as  appropriate, in
Baking  these determinations.

   In addition to understanding the two categories of
'RCRA hazardous wastes,  site managers will also need
to understand the d:rived-from rule, the mixture rule,
and the  containcd-in interpretation to identify correctly
whether a CERCLA substance is a RCRA hazardous
waste.    These  three  principles,  as well as  an
introduction  to  the  RCRA  delisting process,  are
described below.

Derived-from Rule  (40 CFR 261J(c)(2))

   The derived-from rule states that any tolid  waste
derived  from the tr:atment,  storage, or disposal of a
listed RCRA hazardous waste  is   itself a  listed
hazardous wast: (r:gaxdless of the concentration of
hazardous  constituents).    For  example,  ash and
scrubber water from the incineration of a listed waste
are hazardous wastes on the basis of the derived-from
rule.    Solid  wastes  derived  from  a characteristic
hazardous waste are hazardous wastes only if they
exhibit a characteristic.

Mixture Rule (40 CFR 261-3(a) (2))

   Under the mixture rule, when any  tolid waste and
a listed  hazardous waste are mixed, the entire mixture
is a  listed  hazardous waste.   For  example, if a
generator  mixes  a  drum  of listed F006 electroplating
waste with a non-hazardous wastewater (wastewaters
are solid wastes - see Highlight 3), the entire mixture
of the F006 and wastewater is a listed hazardous waste.
Mixtures of aoBd- wastes  and tfaynflfristic hazardous
wastes are hazardous only if the mixture exhibits  a
characteristic.

Cootalned«iB Interpretation (OSWMemorandnm dated
Nomnber 13, 1986)

   He  eontamed-m interpretation  states that  any
mixture  of  a  aon-soSd  waste  and  a RCRA  fisjgd,
hazardous waste  must be  managed as a hazardous
waste as long as the material «™t^in« (Le, is  above
health-based levels) the listed hazardous waste.  For
example, if soil or ground  water (Le, both non-solid
wastes) contain an F001 spent solvent,  that soil or
ground water must be managed as a RCRA hazardous
waste, as long as it 'contains* the F001 spent solvent.

Delisting (40 CFR 260.20 and 21)

   To be exempted from the RCRA hazardous waste
'system," a listed hazardous  waste, a mixture of a listed
and  solid waste,  or a derived-from waste  must be
delisted  (according  to  40 CFR  26020  and  22).
Characteristic  hazardous wastes  never aeed   to be
delisted, but can  be treated to no longer exhibit the
characteristic. A contained-in waste also does not have
to be delisted; it  only has  to "no longer contain" the
hazardous waste.

   If  site managers determine that the  hazardous
substance(s) at the site is a  RCRA hazardous waste(s),
they should  also determine  whether that RCRA waste
is a  California list waste.  California list wastes are a
distinct category of RCRA  wastes restricted under the
LDRs (see Superfund LDR Guide #2).

(3)     IS  THE  RCRA   WASTE  RESTRICTED
        UNDER THE LDRs?

   If a site manager determines that a CERCLA waste
is a  RCRA hazardous waste, this waste also must be
restricted  for  the  LDRs  to  be  an  applicable
requirement.  A RCRA hazardous waste becomes a
restricted waste on  its HSWA statutory dfrfljlinf or
sooner if the Agency promulgates a standard before
the deadlinf. Because the LDRs are being phased in
over a period of time (see Highlight 4), she managers
may need to determine what type of restriction is in

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Highlight 4: LDR STATUTOEY DEADLINES
Spent SoKroT ud Dions-
Containing Wanes
Califoni* List Wastes
Fast Third Wastes
Spen: Solvent. Diono-
Containing, tnd California
LJS: SOL and Debru From
CERClA/RCRA Contenve
Actions
Second Third Wastes
Third Third Wastes
Ne»-i\  Identified
Wastes
         i, 1966



JidyS.19C7


 Aufusi & 1968


 November g, 1988
  June 8, 1989
 Kte> 8, 1990
Withia 6 Booths of
 idcatifiauos at •
hazardous wiste
effect at the time placement is to occur. For example,
if the RCRA hazardous wastes at  a site are currently
under a nauonaJ capacity extension  when the CERCLA
decision  document  is  signed,  site managers should
evaluate whether the response action will be completed
before the  extension  expires.   If these  wastes are
disposed  of is surface  impoundments or landfills prior
to the expiration  of the extension, the receiving unit
would have to meet minimum technology requirements,
but the wastes would  not have to  be treated to meet
the LDR treatment standards.

APPLICABILITY DETERMINATIONS

    If the site manager determines that the LDRs are
applicable  to  the  CERCLA response based on the
previous  three questions,  the site  manager must: (1)
                            comply with the LDR restriction m effect, (2) comply
                            with  the  LDRs  by  choosing one  of the  LDR
                            compliance options  (e.g-, Treatability Variance, No
                            Migration  Petition),  or (3)  invoke  an ARAR waiver
                            (available only for ae-tite actions).  If the LDRs are
                                               b* •BB&ClblC, tfcffPt  fOT  OO-SJIe
                                   only, the F1* manager should determine if the
                                                        LDRs are relevant and appropriate.  The process for
                                                        determining whether the LDRs ire applicable to a
                                                        CERCLA action is p**"*" "JT*^ in HW«Hct»t 5.
                                                        Highlight 5 • DETERMINING WHEN LDRS
                                                        ARE APPLICABLE REQUIREMENTS
                                                                                           LDR* ar* nen
                                                                                            •ppueaei*
                                                                                            e»t»nrun* If
                                                               CEACLA ••«• •
                                                              HCRA ruuaroeut or
                                                                 CcBfemialttt
                                                                  WMt*?
                                                               r«i«v«m and
                                                                •ppropnat*
                                                                 (en-tit*
                                                              rttooni* enr/)
                                                               RCAA
                                                               wart* r«tinet*d
                                                               widsrth* IDA*?
                                                              LO*U ar* net
                                                                •ppica&M

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                DOCUMENT  2


      i        UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

      *                   WASHINGTON, D.C. 204«0

'%! *#F
                                                         'I ANC
                                      OSWER Directive 19355.4-02
 SUBJECT:     Interim Guidance en Establishing £oi^  Lead Cleanup
             Levels at  Superfund Sites.

 FROM: .      Henry L. Longest II,  Director'*'
             Office of  Emergency and Remedi
           '  Bruce Diamond,  Director-
             Office ef  Waste Programs Enforcement

 TO:          Directors, Waste Management  Division,  Regions Z, ZI,
             iv,  v, vii and  vill             ,
             •Director,  Emergency and Reaedial Response Division,
             Region II
             Directors, Hazardous Waste Management  Division,
             Regions III  and VI
             Director,  Toxic Waste Xanageaent Division,
             Region IX
             Director,  Hazardous Waste Division,  Region X
      The purpose of this directive  is to  set  forth en interim soil
 cleanup level for total  lead,  at  SOO to 1000  ppa,  vhich the Office
 ef Fie^cncy and Reaedial Response  and the  Office  of Waste Programs
 Cnfcrceaent consider protective for direct  contact at residential
 settings.  This rangt is to be used at both Fund-lead and
 Enforceaentrlead CERCLA  sites.  Further guidance vill be developed
 after the Agtacy &*• developed a verified Cancer Potency Factor
 and/or a Reference Dose  for lead-
      L*.ad is cosaonly found* at hazardous vaste sites an  .s a
 contaainar.t of concern at approximately one-third ef tne sites on
 the National Priorities List (KPL) .  Applicable or relevant and
 appropriate requirements (ARARs)  are available to provide cleanup
 levels for lead in air and water  but not in soil*  The current

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National Aabient Air Quality Standard for lead ic 1.5 ug/e3.
While the existing Kaxiaua Contaainant Level (MCL) for lead is
50 ppb, the Agency has proposed levering the HCL for lead to 10 ppb
at the tap and to 5 ppb at the treataent plant I1'.  A Xaxiaua
Contaminant Level Goal (MCLC) for lead ef sere vas proposed in
1988 (<) .  At the present tiae, there are no Agency verified
toxicological values (Reference Dose and Cancer Potency Factor,
ic., slope factor), that can be used to perfora * risk assessaent
and to develop protective soil cleanup levels for lead.

     If forts are undervay by the Agency to develop a Cancer
Potency Factor (CFF) and Reference Dose (RfD) ,  (or siailar
approach) , for lead.  Recently, the Science Advisory Board
strongly suggested that the Human Health Aceessaent Group (HHAG)
of the Office of Research and Develepaent (ORD)  develop a CPF for
lead, which vas designated by the Agency as a 12 carcinogen in
1988.  The HHAG is in the process of selecting studies to derive
such a level.  The level and documentation package vill then be
sent to the Agency's Carcinogen Risk Assessaent Verification
Exercise (CRAVE)  workgroup for verification.  Zt is expected that
the documentation package vill be sent to CRAVE by the end of
1969. "The Office ef Eaergency and Reaedial Response, the Office
of Waste Prograas Enforceaent and ether Agency prograas are
working with ORD in conjunction vith the Office ef Air Quality
Planning and Standards (OAQPS) to develop an RfD, (or siailar
approach) , for lead.  The Office ef Research and Developaent and
OAQPS will develop a level to protect the aost sensitive '
populations, naaely young children and pregnant .yoaen, and subait
a documentation package to the Reference Dose vorkgroup for
verification.  Zt is anticipated that the documentation package
vill be available for reviev by the fall of 1989.
     The fol loving guidance is to be iapleaented for reaedial
actions until further guidance can be developed based on an Agency
verified Cancer Potency Factor and/or Reference Dose for lead.

     Guidance

     This guidance adopts the recoaaendation contained in the. 1985
Centers for Disease Control (CDC) stateaent en childhood lead
poisoning '3) and is to be followed vhen the current or predicted
land use is residential.  The CDC recoaaendation states that
•...lead in soil and dust appears. to be responsible for bleed
levels in children increasing aboye background levels vhen the
concentration ir the soil or dust. exceeds 500 to 1000 ppa". •
Site-specific conditions aay varrant the use ef soil cleanup
levels belov the 500 ppa level or. seaevhat above the • 1000. ppa
level.  The administrative record should include background
documents en the toxicology of lead and information related to
site-specific conditions.

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     The rang* of 500 to 1000 ppa refers to  levels for total lead,
as aeasured by protocols developed by the Superfund Contract
Laboratory Prograa.  Issues have  been raise* concerning th« role
that the bioa vail ability of lead  in various  cheaieal feras and
particle sizes should play in assessing the  health risks posed by
exposure to lead in soil.  At this tine, the Agency has not
developed a position regarding the bioavailability issue end
believes that additional information is needed to develop •
position.  This guidance say be revised as additional information
becoaes available regarding the bioavailability  of lead in soil* .

     Blood-lead testing should not be used as the sole criterion
for evaluating the need for long-tern reaedial action at sites that
do not already have an extensive,  long-tern  blood-lead data
based).
                                            ' •   »
          D&TE or THIS
     This interim guidance  shall take effect  iaaediately.   The
guidance dees not require that  cleanup levels already entered into
Records of Decisions,  prior to  this date, be  revised to confers
with this guidance.
1 In er.e case, a biokinetic uptake aodel developed by the Office
  of Air Quality Planning and  standards vas used for a site*
  specific risk assessaent. This approach vas  reviewed end
  approved by Headquarters for use at the cite,  based on the
  adequacy of data (due to continuing CDC studies conducted over
  sany years).  These data included all children's blood-lead
  levels collected over a period of several years,  as veil as
  fasily socio-econoaic status, dietary conditions/ conditions of
  hones and extensive environaental lead data,  also collected over
  several years.  This aaount  of data allowed the Agency to use the
  acdel vithout a need for extensive default values.  Use of^the
  aodel thus allowed a aore precise calculation of the level"of
  cleanup needed to reduce risk to children based en the aaount of
  contamination froa all ether sources, and the effect of
  contasination levels on blood-lead levels of  children.
                                i

E£fER£KCES           *
                                                    »
1.  53 FR 31516, August II, 19SI.
2.  53 rR 31521, August it, IMS.
3.  Preventing Lead Poisoning  in Young Children, January 1995,
    U.S. Departaent of Health  and Huaan Services, Centers, for
    Disease Control, 99-2230.

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                  DOCUMENT  3
DATE:

SUBJECT:

FROM:

TO:
7 June 1990
Risk Based
Soil Clean-up Levels for the Sinclair Site
Marina Stefanidis

Mike Negrelli
k/-u.
            Soil Cl«an-up Levels  for the Sinclair  Bit*
     The determination of soil clean-up levels was based on
recreational and industrial use scenarios.  Wherever possible,
the assumptions for those scenarios were taken from the
Endangerment Assessment (EA).  Both the ingestion and inhalation
routes of exposure were evaluated.  The following table lists the
scenarios considered in addition to the one based solely on the
EA  (*).  The other scenarios assumed parameters similar to those
found in the EA (x).
Recreational
     Child
     Adult
               Risk Based Soil Cl«an-up Levels

                                   Ingestion
                             *
                             x
                                             Inhalation
                              x
                              x
Industrial
     Adult

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                             Outline

Z.   Determination of Soil Clean-up Level•  Based on Xngestion of
     Site Soil

     A. Child Recreational Use Scenario
          1. General Exposure Equation
          2. Determination of Soil Clean-up Levels

     B. Adult Recreational Use Scenario
          1. General Exposure Equation
          2. Determination of Soil Clean-up Levels

     c. Adult Industrial Use Scenario
          1. General Exposure Equation
          2. Determination of Soil Clean-up Levels

II.  Determination of Soil Clean-up Levels  Based on Inhalation of
     Fugitive Dust from RI Data and Approach

III. Determination of Soil Clean-up Levels  Based on Inhalation of
     Fugitive Dust from RI Data and Suggested Approach

     A. Child Recreational Use Scenario
          l. General Exposure Equation
          2. Determination of Soil Clean-up Level

     B. Adult Recreational Use Scenario
          1. General Exposure Equation
          2. Determination of Soil Clean-up Level

     c. Adult Industrial Use Scenario
          1. General Exposure Equation
          2. Determination of Soil Clean-up Level


IV.  summary

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I.   Determination of Soil Clean-up Levels Based on Zngestion of
     Bite Soil

Project:       Determination of soil cleanup levels for arsenic
based on ingestion of site soils in recreational and industrial
site use scenarios.

Assumptions:   A residual cancer risk of 1E-6 under the ingestion
pathway of exposure will provide a protective level of exposure
to site contaminants.

Scenarios:     On p.3-35 of the Endangerment Assessment (£A)
report, the soil pathways evaluated included children playing
onsite and at the offsite tank farm.  The assumptions made are
listed below.  Construction workers encountering subsurface soil
during excavation activities were also evaluated.  This scenario
will, however, not be addressed because the workers were only
assumed to be exposed for 1 year.  Rather, adult recreational and
industrial ingestion scenarios will be evaluated.

A.   Child Recreational Use Scenario

     1. General Exposure Equations Scenario

1)   Intake dose = Cs x IR x CF x DF x EF. x ED
                         BW x AT
     Where:
          Cs = Contaminant concentration * mg/kg
          IR - Ingestion rate « 200 mg/day, children
          CF = Conversion factor « lkg/lE6mg
          DF = Desorption factor «= 1
          EF = Exposure frequency « 100 days/year
          ED - Exposure duration « 6 years/lifetime, child
          BW = Body weight   « 16 kg, child
          AT = Averaging time « 365 day/yr x 75 yr
2)   Risk = Intake Dose X CPF

     Where:

          CPF= Cancer potency factor (l/(mg/kg/d)
              - 1.5/(mg/kg/day) as of 4/90
              = 1.8/(mg/kg/day) used in RI

          2. Determination of Soil Cleanup Levels


1)   Risk = Intake Dose X CPF

2)   Intake Dose « Risk

-------
                   CPF

3)   Intake Dose «

      Cs x 200ma/day x IQOd/y x 6y x lka/lE6ma
             75 year x 365 d/year x 16 kg

4)   Intake Dose - Cs x 2.74E-7
5)   Risk ^ CS X 2.74E-7
     CPF

6)   Cs =     Risk
          CPF X 2.74E-7

7}   Residual Risk Goal « 1E-6

8)   Cs =    1E-6
         CPF X 2.74E-7
9)   Cs =  2.4 ppm  (CPF -1.5)
           2.0 ppm  (CPF -1.8)

B.   Adult Recreational Use Scenario

     1.General Exposure Equation

1)   Intake dose =  Cs x IR x CF x DF x ET x EF x ED
                         BW x AT
     Where:
          Cs = Contaminant concentration - og/kg
          IR = Ingestion rate « 100 ing/day, adult
          CF = Conversion factor « lkg/lE6ag
          DF = Desorption factor « 1
          EF = Exposure frequency « 100 days/year
          ED = Exposure duration - 30 years/lifetime
          BW = Body weight   - 70 kg, adult
          AT * Averaging time » 365 day/yr x.75 yr
2)   Risk B intake  Dose X CPF

     Where:

          CPF* Cancer potency factor  (l/(mg/kg/d)
              -  1.5/(mg/kg/day) as of 4/90
              «  1.8/(mg/kg/day) used in RI

-------
          2. Determination of Soil Cleanup Levels
1)   Risk = Intake Dose X CPF

2)   Intake Dose -= Risk
                   CPF

3)   Intake Dose «

      Cs x IQOmer/day x IQOd/v x 30v x Ika/lESina
             75 year x 365 d/year x 70 kg

4)   Intake Dose = Cs x 1.56E-7
5)   Risk = Cs x 1.56E-7
     CPF
6)   CS =
          CPF X 1.56E-7

7)   Residual Risk Goal = 1E-6

8)   Cs =    1E-6
         CPF x 1.56E-7
9}   Cs =  4.3 ppm  (CPF « 1.5)
           3.5 ppm  (CPF -1.8)

C.   Adult Industrial Use Scenario
     1. General Exposure Eolation

1)   Intake dose - Cs x IR x CF x DF x ET x EF x ED
                         BW x AT
     Where:
          Cs « Contaminant concentration » ng/kg
          IR = Ingest ion rate *• 100 ing/day, adult
          CF « Conversion factor - lkg/lE6mg
          DF * Desorption factor « 1
          EF = Exposure frequency « 250 days/year
          ED = Exposure duration - 20 years/lifetime
          BW - Body weight   « 70 kg, adult
          AT = Averaging time - 365 day/yr x 75 yr

-------
2)   Risk - Intake Dose X CPF

     Where:
          CPF« Cancer potency factor  (l/(ng/kg/d)
              « 1.5/(mg/kg/day) as of 4/90
              - 1.8/(ng/kg/day) used in RI
          2. Determination of Soil Cleanup Levels
1}   Risk = Intake Dose X CPF

2)   Intake Dose = Risk
                   CPF

3)   Intake Dose =

      Cs x lOOing/day x 250d/v x 20y x lka/lE6Tnq
             75 year x 365 d/year x 70 kg

4)   Intake Dose = Cs x 2.61E-7
5)   Risk = CS X 2.61E-7
     CPF

6)   Cs =     Risk
          CPF x 2.61E-7

7)   Residual Risk Goal = 1E-6

8)   Cs *    1E-6
         CPF X 2.61E-7
9)   Cs =  2.5 ppm  (CPF - 1.5)
           2.1 ppm  (CPF « 1.8)

-------
II.  Determination of Soil Clean-up Levels Based on Inhalation
of Fugitive Dust from RI Data and Approach

     In the RI, fugitive dust was assumed to be released into the
air through vehicular traffic.  Based on the geometric mean
arsenic concentration,  (8.8ppm, p.3-23), The emission rate was
calculated (2.07E-4 g/s, p.3-29) for vehicle induced emissions at
the site.  The mean ambient concentration at 10m (1.17E-4) was
calculated using a near-field box model.  Intake (p.3-30) and
subsequently risk (1.53E-4, p.4-18) were determined.

     Based on these calculations, the concentration of arsenic in
the soil needed to obtain a 1E-6 risk level would be 5.76E-2 ppm.

III. Determination of Boil Clean-up Levels Based on Inhalation of
     Fugitive Dust from RI Data and Suggested Approach


Project:       Determination of soil clean-up levels for arsenic
based on inhalation of fugitive dust emitted from the site.

Assumptions:   A residual cancer risk of 1E-6 under the
inhalation pathway of exposure will provide a protective level of
exposure to site contaminants.

Scenarios:     Child and adult recreational use scenarios and
adult industrial scenarios were evaluated.

A.   Child Recreational Use Scenario
     1. General Exposure Equation Scenario

1)   Intake dose = Cs x IR x PC x ET x EF x ED x CF
                                   BW x AT
     Where:
          Cs = Contaminant concentration
          IR » Inhalation rate « 1.25 m3/hr
          PC = Particulate concentration « 0.03 ug/m3
          ET - Exposure time « 4 hr/day
          EF « Exposure frequency « 100 days/year
          ED «= Exposure duration -  6 years/lifetime
          CF « Conversion factor « 1kg/IE9ug
          BW « Body weight -  16 kg, child
          AT « Averaging time « 365 days/year x 75 years
2)   Risk - Intake dose X CPF

     Where:
          CPF= Cancer potency factor  (l/(mg/kg/d)
              « 5.0El/(mg/kg/day)

-------
          2.  De'termination of Soil Cleanup
1)   Risk « Intake Dose X CPF

2)   Intake Dose « Risk
                   CPF

3)   Intake Dose «=

Csx 0.03uq/m3 x 1.25 B3/hr x4 hr/d x IQOd/v x 6 y xlko/lE9uq
             75 year x 365 d/year x 16 kg

4)   Intake Dose « Cs x 2.05E-13
5)   Risk = CS X 2.05E-13
     CPF

6)   Cs »     Risk
          CPF X 2.05E-13

7)   Residual Risk Goal - 1E-6

8)   Cs =    1E-6
         CPF x 2.05E-13
9)   Cs =  97,561 ppm

B.   Adult Recreational Use Scenario
     1. General Exposure Eolation

1)   Intake dose « Cs x IR x PC x ET x EF x ED x CF
                                   BW x AT

     Where:

          Cs « Contaminant concentration
          IR * Inhalation rate - 1.25 m3/hr
          PC - Particulate concentration « 0.03 ug/&3
          ET * Exposure tine * 4 hr/day
          EF - Exposure frequency - 100 days/year
          ED « Exposure duration »  30 years/lifetime
          CF « Conversion factor * lkg/lE9ug
          BW = Body weight «  70 kg, adult
          AT « Averaging time « 365 days/year x 75 years

2)   Risk = Intake dose X CPF

-------
     Where:
          CPF= Cancer potency factor (l/(mg/kg/d)
              = 5.0El/(mg/kg/day)
     2.  Determination of Soil Cleanup Level
1)   Risk « Intake Dose X CPF

2)   Intake Dose * Risk
                   CPF

3)   Intake Dose =

Csx 0.03 ua/m3 x 1.25 Tn3/hr x 4 hr/d x IQOd/v x 30v xlka/lE9ua
             75 year x 365 d/year x 70 kg

4)   Intake Dose = Cs x 2.35E-13


5)   Risk = Cs x 2.35E-13
     CPF

6)   Cs =     Risk
          CPF X 2.35E-13

7)   Residual Risk Goal = 1E-6

8)   Cs =    1E-6
         CPF x 2.35E-13
9)   Cs =  85,167 ppm

C. Adult Industrial Use Scenario
     1. General Exposure Ecfuation

1)   Intake dose « Cs x IR x PC x ET x EF x ED x CF
                                   BW x AT
     Where:
          Cs «= Contaminant concentration
          IR « Inhalation rate « 1.25 m3/hr
          PC = Particulate concentration «* 0.03 ug/m3
          ET « Exposure time - 8 hr/day
          EF = Exposure frequency = 250 days/year
          ED = Exposure duration «  20 years/lifetime

-------
          CF « Conversion factor « lkg/lE9ug
          BW « Body weight «  70 kg, adult
          AT « Averaging time - 365 days/year x 75 years

2)   Risk - Intake dose X CPF

     Where:

          CPF= Cancer potency factor (l/(ing/kg/d)
              - 5.0£l/(ng/kg/day)
     2. Determination of Soil Cleanup Level
1)   Risk = Intake Dose X CPF

2)   Intake Dose = Risk
                   CPF

3)   Intake Dose =

Csx 0.03 ua/m3 x 1.25 rc3/hr x 8 hr/d x 250d/v x 20v xlka/lE9ua
             75 year x 365 d/year x 70 kg

4)   Intake Dose = Cs x 7.83E-13


5)   Risk = Cs x 7.83E-13
     CPF

6)   Cs =     Risk
          CPF x 7.83E-13

7)   Residual Risk Goal - 1E-6

8)   Cs =    1E-6
         CPF X 7.83E-13
9)   Cs =  25,550 ppm

-------
IV. SUMMARY

                 Risk Bas«d Soil C'«an-up L«v«ls

                              Ingestion           Inhalation

Recreational
     Child                    2.4 ppm,  2.0 ppm     97,561  ppm
     Adult                    4.3 ppo,  3.5 ppm     85,167  ppm

Industrial
     Adult                    2.5 ppm,  2.1 ppm     25,550  ppm


EA Fugitive Dust Model                             5.8E-2  ppm

-------
DOCUMENT  4
         NEW YORK STATE AMBIENT WATER QUALITY STANTARDS
                       AND GUIDANCE VALUES
    FOR CHEMICALS  DETECTED  IN SITE GROUNDWA7ER i SURFACE  WATER
                   (Revised September 25, 1990)
Substance
Water Class
Standard
 fua/Ll
Guidance Value
    rua/L)
Aluminum, ionic


Arsenic


Barium


Benzene


Beryllium


Butyl benzyl phthalate


Cadmium


Chlorobenzene


Chromium


Cobalt


Copper


1,1-Dichloroethane


Diethylphthalate
     A
     GA

     A
     GA

     A
     GA

     A
     GA

     A
     GA

     A
     GA

     A
     GA

     A
     GA

     A
     GA

     A
     GA

     A
     GA

     A
     GA

     A
     GA
  100 (A)
   50
   25

 1000
 1000
  0.7*
   10
   10

   20
    5

   50
   50

    5 (A)
  200
  200
               0.7
                3
                3

               50
               50
               50
               50

-------
Substance Water Class
Ethylbenzene A
GA
2-Hexanone
Iron
Lead
Magnesium
Manganese
Mercury
Naphthalene
Nitrobenzene
Phenanthrene
Silver
Sodium
1,1,2,2-
Tetrachloroethane
Toluene
Trans- 1,2-
Dichloroethene
1,1,1-
Trichloroethane
A
GA
A
GA
A
GA
A
GA
A
GA
A
GA
A
GA
A
GA
A
GA
A
GA
A
GA
A
GA
A
GA
A
GA
A
GA
Standard
fua/U
5

.300
300
50
25
35,000
300
300
2
2
10
30
5

50
50
20,000
5
5
5
5
Guidance Value
fua/Ll
5
50
50


35,000


10

50
50


0.2
5
5
5

-------
                                   Standard  Guidance value
Substance           Water Class     fuo/L)   	fucr/Ll	
Trichloroethene          A
                         GA            5

Vanadium                 A            14 (A)
                         GA

Total Xylenes            A
                         GA            5

Zinc                     A           300
                         GA          300
Notes:
(A) signifies standard or guidance value designated for
     protection of aquatic life.  All other values for
     protection of human health.
* signifies a proposed standard.

Water class:
A signifies potable surface water;
GA signifies potable groundvater.

-------
    DOCUMENT  5

                 FEDERAL DRINKING WATER STANDARDS

                      40 CFR Parts  141  t 142

                      (as of January, 1991)


                             ORGANIC
             all  units are micro-grams per liter  (ppb)

Cheaieal	HCL •	PMCL •	MCLG *

Acrylanside Q     Treatment Technique     -               0
Benzene                    5             -               0
Carbon Tetrachloride       5             -               0
o-Dichlorobenzene Q      600             -             600
p-Dichlorobenzene         75             -              75
1,2-Dichloroethane         5             -               0
1,1-Dichloroethylene       7                             7

cis-l,2-Dichloro-
  ethylene 6              70                            70
trans-l,2-Dichloro-
  ethylene Q             100             -             100
1,2-Dichloropropane (55             -               0
Dichlorosethane
  (nethylene chloride)                    5               0  (P)
Di(ethylhexyl)adipate      -           500             500  (P)
Di(ethylhexyl)phthalate    -             4               0  (P)

Epichlorohydrin S   Treatment Technique  -               0
Zthylbenzene Q           700             -             700
Ethylene
  dibronide 6              0.05          -               0
Hexachlorobenzene          -          .1               0  (P)
Hexachlorocyclopentadiene  -            50              50  (P)

Kcnochlorobenzene 6      100             -             100
PAKs[Benzo(a)pyrene] +     -             0.2             0  (P)
PCBs G                     0.5           -               0
Pentachlorophenol          -             1               0  (P)
Styrene Q                100             -             100

Tetrachloroethylene Q      5             -               0
Toluene                 1000             -            :1000
1,2,4-Trichlorobenzene     -             9               9  (P)
1,1,1-Trichloroethane    200             -             200
1,1,2-Trichlorethane       -             5 .              3  (P)
Trichloroethylene          5             -               0

Trihalonethanes
  (total)                100             -
2,3,7,8-TCDD               -             SxlO*1          0  (P)

-------
                              -2-


Chenical 	MCL	PMCL	MCLC
Vinyl Chloride
Xylenes (total) 0
PESTICIDES /HERBICIDES
Alachlor Q
Aldicarb
Aldicarb Sulfoxide
Aldicarb Sulfone
Atrazine G
Carbofuran Q
Chlordane G
Dalapon
DibroF.ochloropropane G
Dinoseb
Diguat
2,4-D ** G
2,4,5-TP •*• 6
Endothall
Endrin
Glyphosate
Heptaehlor G
Heptaehlor epoxide G
Lindane G
Methoxyehlor G
Oxaryl (Vydate)
Piclorar,
Sir.azine
Toxaphene Q
2
10000

2
•
.
•
3
40
2
-
0.2
-
—
70
50
_
0.2
-
0.4
0.2
0.2
40
-
-
-
3
—
-

_
3
3
3
-
.
-
200
-
7
20
-
—
100
2
700
-
-
.
-
200
500
1
-
0
10000

0
1
1
2
3
40
0
200
0
7
20
70
50
100
2
700
0
0
0.
40
200
500
1
0




(P)
(P)
(P)



(P)

(P)
(P)


(P)
(P)
(P)


2

(P)
(P)
(P)

*     KCL: Maximum Contaminant L«vel
     PKCL: Proposed Maximum Contaminant  Level
     MCLG: Maximum Contaminant Level  Coal
      (P): Proposed MCLG

**    2,4-D:  2,4-Dichlorophenoxypropionic acid

***   2,4,5-TP:  2,4,5-Trichlorophenoxypropionic acid (Silvex)

Q    Phase II MCLs promulgated 1/30/91 in  56 FR 3526 and will
     take effect for PWS in 7/92.   These MCLs  Bust be adopted or
     made more stringent by the States by  7/92.

+ EPA is also considering the establishment of MCLGs and MCLs for
     six additional Polycyclic Aromatic  Hydrocarbons (PAHs).

-------
                               -3-
                            XNORGANIC
all units are milligrams per liter (ppm) , except
Chemical MCL PMCL
Arsenir
AJitimony
Asbestos2 Q
Barium
Beryllium
Cadmium Q
Chromium 6
Copper3
Cyanide
Fluoride
Lead
Mercury
Nickel
Nitrate (as N) 
-------
        DOCUMENT 5 (continued)


        COMPARISON O? FEDERAL TO HEW YORK STATE MCLS
                       (as of January 1991)

                             ORGANIC

             all  units  ar* aierograas per  liter (ppb)

Chenleal                   TEDMCL                      KYMCL+

Acrylanide Q              treataent
Benzene                        5                        5
Bronobenzene                   -                        5
Bronochloronethane             -                        5
Broaoraethane                   -                        5
n-Butyltenzene                 -                        5
sec-Butylbenzene               -                        5
tert-Butylbenzene              -           .             5
Carbon Tetrachloride           5                        5
Chlorobenzene                  -                        5
Chloroethane                   -                        5
Chlorowethane                  -                        5
2-Chlortoluene                 -                        5
4-Chlortoluene                 -   .                     5
Dibrononethane                 -   '                     5
o-Dichlorobenzene (1,2)0     600                        5
tt-Dichlorobe'nzene (1,3)        -                        5
p-Dichlorobenzene (1,4)       75                        5
Dichlorodifluoroaethane        -                        5
1,2-Dichloroethane             5                        5
1,1-Dichloroethane             -                        5
1,1-Dichloroethylene           7                        5
cis-l,2-Dichloroethylene8     70                        5
trans-l,2-Dichloroethylen«a  100                        5
1,2-Dichloropropane          .5                        5
1,3-Dichloropropane            -                        5
2,2-Dichloropropane            -                        5
1,1-Dichloropropane            -                        5
cis-l,3-Dichloropropene        -                        5
trans-l,3-Dachloropropene      -                        5
Epichlorohydrin 9          treatment
Ethylbenzene Q               700                        5
Ethylene dibroaide •           0.05                     -
Hexachlorobutadiene            -                        5
Isopropylbenzene               -                        5
p-Isopropyltoluene             -                        5
Methylene chloride             -                        5

-------
                               -2-
CheEieal	:	TEDMCL	KYMCL+

Monochlorobenzene 9          100                        -
PCB'S 0                        0.5
n-Propylbenzene                -                        S
Styrene Q                    100                        5
1,1,1,2-Tetrachloroethane      -                        5
1,1,2,2-Tetrachlororthane      -                        5
Tetrachloroethylene Q                                   5
Toluene                        -                        5
1,2,3-Trichlorobenzene         -                        5
1,2,4-Trichlorobenzene         -                        5
1,1,1-Trichloroethane        200                        5
1,1,2-Trichloroethane          -                        5
Trichloroethylene              5                        5
Trichlorofluoronethane         -                        5
1,2,3-Trichloropropane         -                        5
1,2,4-Trinethylbenzene         -                        5
1,3,5-Trinethylbenzene         -                        5
Vinyl Chloride                 2                        2
Xylenes (total)  6          10000                        5

Tribalonethanes
  (total)                   100                       100

Unspecified organic
 contarinant (UOC)          N/A                        50
Total Principal organic
 (POCs)+ and UOCs-M-         N/A                       100
PESTICIDES/HERBICIDES
Alachlor Q                    2
Atrazine 63                         -
2,4-D   * Q                  70                        50
2,4,5-TP  ** Q               50                        10
Carbofuran Q                 40                         -
Chlordane Q                   2                         -
Dibroaochloropropane Q        0.2                       -
Endrin                        0.2                       0.2
Keptachlor Q                  0.4
Keptachlor tpoxide •          0.2                       -
Lindane Q                     0.2                       4
Methoxychlor Q               40                        50
Toxaphene 6                   35

-------
                               -3-
*    2,4-D:  2,4-Dichlorophenoxypropionic acid

**   2,4,5-TP:   2,4,5-Trichlorophenoxypropionic acid (Silvex)

N/A « not applicable

4-    Principal  organic contaminant (POC) Beans any organic
     chemical compound belonging to the following classes, except
     for Total  Trihaleaethanes,  Vinyl Cbloride and regulated
     Pesticides/Herbicides:
          1)  Halogenated alkane
          2)  Halogenated ether
          3)  Halobenrenes and substituted halobenzenes
          4)  Benzene and alXyl-  or nitrogen-substituted benzenes
          5)  Substituted, unsaturated hydrocarbons
          6)  Halogenated nonaromatic cyclic hydrocarbons

     Further definition of the POCs is contained in Chapture I of
     the Nev York Sanitary Code  Part 5, Subpart S-l.l(ab).  A
     table listing the POCs  is found in Table 9A of the same
     document.

++   Unspecified organic contaminant (UOC)  means any organic
     cherical compound not otherwise specified in Chapture I of
     the Mew York Sanitary Code  Part 5, Subpart 5-1.

Q    Phase II MCLs promulgated 1/30/91 in 56 FR 3526 and will
     take effect for PWSS in 7/92.  These,MCLs must be adopted or
     made more  stringent by  the  States by 7/92.

-------
                               -4-
                              OTHER


The standards for Radiological, polifonn Bacteria and Turbidity
have been adopted from the federal  MCLs by the states (including
VI 4 PR).
                            INORGANIC

    all units are milligrams per liter (ppm),  except as noted
Chemical
Arsenic
Asbestos1 Q
Bariuis
Cad.-ixnE 6
Chromium 8
Fluoride (ppn)
Lead
Mercury
Nitrate (as N) Q
Nitrite (as N) 0
Nitrate4Nitrite(as N)Q
Selenium Q
Silver
FEDMCL
0.05
7
1.0
0.005
0.1
4
0.05
0.002
10
1.0
10
0.05
0.05
KYKCL
0.05
1.0
0.01
0.05
2.2
0.05
0.002
10
0.01
0.05
0    Phase II MCLs promulgated 1/30/91 in 56 FR 3526 and will
     take effect for PWSS in 7/92.  These MCLs must be adopted or
     made acre stringent by the States by 7/92.
     1 The MCL for asbestos apply to fibers longer than 10
micrometers, and are in units of Billion fibers per liter.

-------
APPENDIX D

-------
New York State Department of Environmental Conservation
50 Wolf Road, Albany, New YD* 12293
                                                                        Thorn** a Jortlng
                                                                        Comml*»»oner
    Ms.  Kathleen Callahan
    Director                                       CPP g
    Emergency Si Remedial Response Div,              "fc" 3 0 1991
    U.S. Environmental Protection Agency
    Region II
    2G Federal Plaza
    New York, New York  10278

    Dear Ms. Callahan:

    Re:   Sinclair Refinery Site, Wellsville, New York,
         Allegany County,  Site No.  9-02-003, Record of Decision

    The New York State Department of  Environmental  Conservation  (NYSDEC) accepts
    the remedy selected for this sit* as  outlined in  the Record  of Decision  (ROD).

    The proposed remedy is primarily  a groundwater  containment remedy which  will
    reduce the mass of contaminants in the  groundwater at the site and prevent
    migration of contaminants  to the  Genesee River  combined with select surface
    sc.il excavation at areas of high  lead and  arsenic contamination.  The State
    will be afforded the opportunity  to review, comment and concur on all
    contingency decisions  should modification, termination, reconsideration  or
    waiver of any part of  the  remedy  be considered.  Although we cannot concur with
    this remedy as being able  to achieve  ARARs, we  accept that a possibility exists
    that ARARs may be achieved by this remedy  and that the remedy will certainly
    provide containment of groundwater contaminants at this site.

    The acceptance of this letter is  conditioned by recent correspondence
    (see enclosure) which  resolved  pertinent issues.  This correspondence is as
    follows:

              Letter to Ms. Kathleen  C. Callahan, USEPA, from K.J. O'Toole,  NYSDEC,
              dated July 31, 1991.

              Letter to Michael Negrelli, USEPA, from A. Joseph White, NYSDEC,
              dated September  25,  1991.

-------
Ms. Kathleen Callahan-                                               Page 2.


          Letter to A. Joseph White,  NYSDEC,  from Michael Negrelli, USEPA,
          dated September 25, 1991.

          Letter to A. Joseph White,  NYSDEC,  from Michael Negrelli, USEPA,
          dated September 27, 1991.

If you have any comments or questions on this letter,  please call Mr. Edward R.
Bellcore. P.E., at 518/457-0414.

                                        Sincerely,
                                        Edward 0. Sullivan
                                        Deputy Commissioner
cc:  N. Kim, tfYSDOH

Enclosure
                                                                         TOTAL P.03

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APPENDIX F

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09/23/91                       •       Index Chronological  Order                                                Page: 1
                                     SINCLAIR REFINERY SITE Documents
Document Number:  SIN-002-0903 To 0905                                               Date:    /  /

Title:  Statement  of Work -  Community Relations Support;  Sinclair  Refinery, Wellsvi lie,  NY

     Type:  PLAN
   Author:  none:   US EPA
Recipient:  none:   none                       _


Document Number:  SIN- 002-0906 To 0906     .                                          Date:    /  /

Title:  (Public Notice inviting public comment  on the Proposed Plan for the Remediation  of the Sinclair
       Refinery site)

     Type:  CORRESPONDENCE
   Author:  none:   US EPA
Recipient:  none:   none


Document Number:  S1N-002-0966 To 0966                                               Date:    /  /

Title:  Draft Press Release:  EPA Extends Public Comment  Period for Sinclair  Refinery Superfund Site
       in Allegany County,  New York

     Type:  CORRESPONDENCE
Condition:  DRAFT
   Author:  none:   US EPA
Recipient:  none:   none


Document Number:  SIN-001-2099 To 2222                               .                Date:    /  /

Title:  Sinclair Refinery Operable Unit No. 2 Risk Assessment (Appendix J)

     Type:  PLAN
   Author:  none:   Ebasco Services
Recipient:  none:   Atlantic Richfield Company (ARCO)

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09/23/91
Index Chronological Order
SINCLAIR REFINERY SITE Documents
                                                                                                             Page: 2
Document Number: SIN-002-0617 To 0617                                               Date: 09/25/85

Title: (Memorandum forwarding the attached Draft Record of Decision  for  the Sinclair Refinery  site,
     .  Operable Unit No.  1)

     Type: CORRESPONDENCE
   Author: Librizzi, William J.:   US EPA
Recipient: Daggett,  Christipher  J.:   US EPA
 Attached: SIN-002-0618

Document Number: SIN-002-0618 To 0694                  Parent:  SIN-002-0617          Date: 09/30/85

Title: Record of Decision - Sinclair Refinery Site Landfill  (Operable Unit No.  1)

     Type: LEGAL DOCUMENT
   Author: Daggett,  Christopher  J.:   US EPA
Recipient: none:  none


Docunent Number: SIN-002-0699'To 0812      .                                        Date: 07/28/88

Title: Administrative Order on Consent (issued to the Atlantic  Richfield Company,  Inc.)

   •  Type: LEGAL DOCUMENT
   Author: Daggett,  Christopher  J.:   US EPA
Recipient: Leake, William D.: Atlantic Richfield Company (ARCO)
Document Number: S1N-001-OOC2 To 0185
                  Parent: SIN-001-0001
Date: 08/01/88
Title: Project Operations Plan for Completion of Phase II  Remedial  Investigation  and Work  Plan for
       Feasibility Study at the Sinclair Refinery Site,  Uellsville,  New York  - Volume  l" of II,  Work
       Plan
     Type: PLAN
   Author: none:  Ebasco Services
Recipient: none:  ARCO Petroleum Products Company

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09/23/91                         '    Index Chronological Order                                                 Page: 3
                                     SINCLAIR REFINERY  SITE Documents
Document Number; SIN-001-0186 To 0380                                               Date:  08/01/88

Title: Project Operations Plan for Completion  of  Phase  II Remedial Investigation and Uorlc Plan for
       Feasibility Study at the Sinclair Refinery Site, Wellsville, Mew York - Volume  II of II,  Field
       Operations Plan

     Type:  PLAN                             _
   Author:  none:  Ebasco Services
Recipient:  none:  ARCO Petroleum Products Company
Document Number: SIN-001-0382 To 0474                  Parent: S1N-001-0381          Date:  08/01/88

Title: Project Operations Plan for Completion  of  Phase  II Remedial  Investigation and Work Plan for
       Feasibility Study at the Sinclair Refinery Site,  Wellsville, New York  - Revised  Field Sampling
       and Analysis Plan

     Type: PLAN
   Author: none:  Ebasco Services
Recipient: none:  ARCO Petroleum Products Company
Document Number: S1N-001-2329 To 2351                                                Date:  08/08/88

Title: Appendix A.3 - Treatment Standards and Effective Dates  for  First Third Wastes  (Guidance)

     Type: DATA
   Author: none:  none
Recipient: none:  none


Document Number: SIN-002-0813 To 0892                                                Da'te:  08/22/88

Title: (Sinclair Refinery Operable Unit No.  1 Consent Decree - United States v.  Atlantic Richfield
       Company, Inc.)

     Type: LEGAL DOCUMENT.
   Author: Muszynski, William J.:  US EPA
Recipient: Leake, William D.:  Atlantic Richfield Company (ARCO)

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09/23/91                             Index Chronological Order                                               Page: 4
                                     SINCLAIR REFINERY SITE Documents
Document Number: SIN-001-0001 To 0001                                               Date: 08/30/88

Title: (Letter forwarding the' attached Remedial Investigation Project  Operations Plan for the  Sinclair
       Refinery site)

     Type: CORRESPONDENCE
   Author: Simmons, R. Walter:  ARCO Petroleum Products Company
Recipient: Olivo, Paul J-:  US EPA
 Attached: SIN-001-0002                          "

Document Number: SIN-001-2247 To 2255                                               Date: 09/30/88

Title: (Technical and Administrative Guidance Memorandum regarding alteration of groundwater samples
       collected for metals analysis)

     Type: CORRESPONDENCE
   Author: O'Toole, Michael J., Jr.:  NY Dept of Environmental Conservation
Recipient: various:  NY Dept of Environmental Conservation
Document Number: SIN-001-0381 To 0381                                               Date:  10/03/88

Title: (Letter forwarding the attached revised Field Sampling and Analysis Plan for  the  Sinclair
       Refinery site)

     Type: CORRESPONDENCE
   Author: Granger, Thomas:  Ebasco Services
Recipient: Olivo, Paul J.:  US EPA
 Attached: S1N-001-0382

Document Number: SIN-001-2246 To 2246           '                                    Date:  02/03/89

Title: (Memorandum containing comments relating to the filtering of groundwater at Bausch and Laumb)

     Type: CORRESPONDENCE
   Author: Concarmon, Patrick:  NY Dept of Environmental Conservation
Recipient: Nattanmai, Vivek:  NY Dept of Environmental Conservation

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09/23/91
Index Chronological  Order
SINCLAIR REFINERY SITE  Documents
                                                                                                              Page: 5
Document Number: SIN-001-0635 To 0934

Title:  (Remedial Investigation sampling data)

     Type: DATA
   Author: none:  Ebasco Services
Recipient: none:  ARCO Petroleum Products Company
                                                Date:  02/23/89
Document Number: SIN-002-0894 To 0902
                  Parent:  SIN-002-0893
Date: 06/30/89
Title: Preliminary Health  Assessment. Sinclair Refinery,  CERCLIS No. NYD980535125, Allegany County,
       Uellsville, NY

     Type: PLAN
   Author: none:  NY Dept  of Health
Recipient: none:  Agency for Toxic Substances & Disease Registry (ATSDR)
Document Number: SIN-001-2322 To 2325
                                                Date: 07/01/89
Title: Superfund LOR Guide #5,  Determining When  Land  Disposal  Restrictions  (LDRs)  are applicable
       to CERCLA Response Actions

     Type: PLAN
   Author: none:  US EPA
Recipient: none:  none
Document Number: SIN-002-0893 To 0893
                                                Date: 07/12/89
Title: (Letter forwarding attached Preliminary Health Assessment  for  the Sinclair  Refinery site)

     Type: CORRESPONDENCE
   Author: Nelson, Uilliam Q.:  Agency for Toxic Substances & Disease Registry (ATSDR)
Recipient: Olivo, Paul J.:  US EPA
 Attached: SIN-002-0894
Document Number: SIN-001-2272 To 2272
                                                Date: 03/06/90
Title: (Letter providing ARCO with guidance on preparing a Feasibility Study for the Sinclair Refinery
       .site)
     Type: CORRESPONDENCE
   Author: Petersen, Carole:  US EPA
Recipient: Turco, Michael A.:.  Atlantic Richfield Company (ARCO)

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09/23/91                             Index Chronological  Order                                               Page: 6
                                     SINCLAIR REFINERY SITE Documents
Document Number: SIN-002-0695 To 0697                                               Date: 04/13/90

Title: (Letter forwarding the attached table of potential  groundwater Applicable or Relevant and
       Appropriate Requirements (ARARs) for the Sinclair Refinery site)

     Type: CORRESPONDENCE
   Author: Negrelli. Michael J.:  US EPA     __
Recipient: White, A. Joseph:  NY Dept of Environmental  Conservation
 Attached: S1N-002-0698

Document Number: SIN-001-2232 To 2234                  Parent:  SIN-001-2229          Date: 04/24/90

Title: (Letter containing NYSDEC and NYSDOH comments on the "Final Endangerment Assessment Report")

     Type: CORRESPONDENCE
   Author: White, A. Joseph:  NY Dept of Environmental  Conservation
Recipient: Negrelli, Michael J.:  US EPA


Document Number: S1N-002-0698 To 0698                  Parent:  SIN-002-0695          Date: 04/30/90

Title: (Letter responding to EPA's April 16, 1990,  letter  regarding  the  proposed ARARs for the Sinclair
       Refinery site)

     Type: CORRESPONDENCE
Condition: MISSING ATTACHMENT
   Author: White, A. Joseph:  NY Dept of Environmental  Conservation
Recipient: Negrelli, Michael J.:  US EPA


Document Number: SIN-001-2267 To 2271                              '                 Date: 05/24/90

Title: (Letter forwarding the attached table of Applicable or Relevant and Appropriate Requirements
       for the Sinclair Refinery site)

     Type: CORRESPONDENCE
   Author: Petersen, Carole:  US EPA
Recipient: Turco, Michael A.:  Atlantic Richfield Company (ARCO)

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09/23/91                      .       Index Chronological  Order                                                 Page: 7
                                     SINCLAIR REFINERY  SITE Documents
Document Number: SIN- 001 -2256 To 2266     .                                          Date:  06/07/90

Title: (Memorandum discussing the soil clean-up levels for  the  Sinclair  Refinery  site)

     Type: CORRESPONDENCE
   Author: Stefanidis,  Marina:  US EPA
Recipient: Negrelli,  Michael J.~:  US EPA


Document Number: SIN-001-2242 To 2245                  Parent:  SIN-001-2241          Date:  08/28/90

Title: (Memorandum discussing the performance of risk  assessments  in  Remedial  Investigations/ Feasibility
       Studies (RI/FSs) conducted by Potentially Responsible  Parties)

     Type: CORRESPONDENCE
   Author: Clay, Don R.:   US EPA
Recipient: various:  US EPA


Document Number: SIN-001-2326 To 2328                                               Date:  09/01/90

Title: (Memorandum discussing the interim guidance on  establishing soil  lead clean-up  levels at Superfund
       sites)

     Type: .CORRESPONDENCE
   Author: Longest, Henry L., II:  US EPA
Recipient: various:  US EPA


Document Number: SIN-001-2230 To 2231                  Parent:  SIN-001-2229          Date:  09/10/90

Title: (Letter discussing major concerns about the Sinclair Refinery  site Remedial  Investigation
       which have not been addressed)

     Type: CORRESPONDENCE
   Author: White, A. Joseph:  NY Dept of Environmental Conservation
Recipient: Negrelli, Michael J.:  US EPA

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09/23/91                             Index Chronological Order                                               Page: 8
                                     SINCLAIR REFINERY SITE Documents
Document Number: S1N-001-2273 To 2321                                               Date: 09/25/90

Title: New York State Ambient Water Quality Standards and Guidance Values

     Type: DATA
   Author: none:  none
Recipient: none:  none                        .


Document Number: S1N-001-2241 To 2241                                               Date: 10/09/90

Title: (Letter forwarding the attached memorandum regarding the development  of  risk  assessments by
       EPA for all Superfund sites)

     Type: CORRESPONDENCE
 '  Author: Negrelli, Michael J.:  US EPA
Recipient: Zannos, John A. A.:  Atlantic Richfield Company (ARCO)
 Attached: SIN-001-2242

Document Number: SIN-001-0476'To 0634                  Parent:  SIN-001-0475          Date: 10/11/90

Title: Volatile Analysis - Analytical Data Package (for sampling performed at the  Sinclair Refinery
       site)

     Type: DATA
   Author: none:  Versar
Recipient: none:  Ebasco Services


Document Number: SIN-001-0475 To 0475                                               Date: 10/12/90

Title: (Letter forwarding the attached GC/MS volatile results for water samples from the Sinclair
       Refinery site)

     Type: CORRESPONDENCE
   Author: Cassidy, Sheila:  Versar
Recipient: Vanpelt, Bob:  Ebasco Services
 Attached: SIN-001-0476

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09/23/91                         -    Index Chronological Order                                                 Page: 9
                                     SINCLAIR REFINERY  SITE Documents
Document Number; SIN-001-2235 To 2235                  Parent: SIN-001-2229          Date: 10/26/90

Title: (Letter containing information on the presence  of  federally  listed or proposed endangered
       or threatened species in the vicinity of  the  Sinclair Refinery site)

     Type: CORRESPONDENCE
   Author: Corin, Leonard P.:  US Dept of the Interior
Recipient: Hargrove, Robert W.:  US EPA      ~~~"
Document Number: SIN-001-0941  To 1189                                               Date: 03/01/91

Title: Remedial Investigation Report for the Sinclair  Refinery Site, Uellsville, New York - Volume
       I of IV, Technical Report

     Type: REPORT
   Author: none:  Ebasco Services
Recipient: none:  Atlantic Richfield Company (ARCO)
Document Number: SIN-001-1190 To 1697                                               Date: 03/01/91

Title: Remedial Investigation Report for the Sinclair  Refinery Site, Wellsville, New York, Volume
       II of IV, Appendices A-E

     Type: REPORT
   Author: none:  Ebasco Services
Recipient: none:  Atlantic Richfield Company (ARCO)
Document Number: SIN-001-1698 To 1894                                               Date: 03/01/91

Title: Remedial Investigation Report for the Sinclair Refinery Site,  Uellsville,  New York, Volume
       III of IV, Appendices F-J

     Type: REPORT
   Author: none:  Ebasco Services
Recipient: none:  Atlantic Richfield Company (ARCO)

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09/23/91                        '    Index Chronological Order                                               Page: 10
                                     SINCLAIR REFINERY SITE Documents
Document Number: SIN-001-1895 To 2092                                               Date: 03/01/91

Title: Remedial Investigation Report for the Sinclair Refinery Site,  Uellsville, New York, Volume
       IV of IV, Appendix K

     Type: REPORT
   Author: none:  Ebasco Services            	
Recipient: none:  Atlantic Richfield Company (ARCO)
Document Number: SIN-002-0001 To 0379                                               Date: 03/01/91

Title: Feasibility Study Report for the Sinclair Refinery Site, Wellsville,  New York

     Type: REPORT
   Author: none:  Ebasco Services
Recipient: none:  Atlantic Richfield Company (ARCO


Document Number: SIN-001-2238 To 2240                                               Date: 03/01/91

Title: (Letter forwarding the revised Final Endangerment Assessment  and responding to the finalization
       of the Sinclair Refinery Remedial Investigation)

     Type: CORRESPONDENCE
Condition: MISSING ATTACHMENT
   Author: Petersen, Carole:  US EPA
Recipient: Zannos, John A. A.:  Atlantic Richfield Company (ARCO)


Document Number: SIN-002-0446 To 0469                                               Date: 03/01/91

Title: (Letter addressing Feasibility Study issues, requesting an  extension for the submittal of
       the Feasibility Study Report, and forwarding information about  the deep aquifer, calculation
       of arsenic clean-up  levels and barium)

     Type: CORRESPONDENCE
   Author: Zannos,' John A. A.:  Atlantic Richfield Company (ARCO)
Recipient: Negrelli, Michael J.:  US EPA

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09/23/91                              Index Chronological Order                                                 Page: 11
                                     SINCLAIR  REFINERY  SITE Documents

=======================================•==================== ======SS=SS=======================SSSMr===S=======S========

Docunent  Number:  SIN-002-0470 To 0471                                               Date: 03/01/91

Title:  (Letter forwarding a copy of an EPA document  entitled "Determining Soil Response Action Levels
       Based on Potential Contamination to Groundwater:  A Compendium of Examples" and discussing
       its relevance to the Sinclair Refinery  site)

     Type: CORRESPONDENCE                    ___
Condition: MISSING ATTACHMENT
   Author: Negrelli, Michael J.:  US EPA
Recipient: Zannos, John A. A.:   Atlantic Richfield Company (ARCO)


Document  Number:  SIN-001-2236 To 2237                                               Date: 03/06/91

Title:  (Letter discussing issues pertaining to the Remedial Investigation/Feasibility Study  (RI/FS)
       that require clarification)

     Type: CORRESPONDENCE
   Author: Negrelli, Michael J.:  US EPA
Recipient: White, A. Joseph:  NY Dept of Environmental  Conservation


Document  Number:  SIN-001-2229 To 2229                                               Date: 03/07/91

Title:  (Memorandum forwarding the attached packet of relevant documents for  a Biological  Technical
       Assistance Group review of the Sinclair Refinery site)

     Type: CORRESPONDENCE
   Author: Negrelli, Michael J.:  US EPA
Recipient: Stevens, Shari 1.:  US EPA
 Attached: SIN-001-2230   SIN-001-2232   SIN-001-2235

Document  Number:  SIN-001-2227 To 2228                                               Date: 05/16/91

Title:  (Letter commenting on the Sinclair Refinery  site Remedial  Investigation Report and the Feasibility
       Study Report)

     Type: CORRESPONDENCE
   Author: Petersen, Carole:  US EPA
Recipient: Zannos, John A. A.:  Atlantic Richfield  Company (ARCO)

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09/23/91                         .    Index Chronological  Order                                                Page: 12
                                     SINCLAIR REFINERY  SITE  Documents
Document Number: SIN-002-0438 To 0445                                               Date: 05/30/91

Title: (Letter forwarding the attached detailed analysis  of  Alternative  1E  identified in the Feasibility
       Study for the Sinclair Refinery site)

     Type: CORRESPONDENCE
   Author: Zannos, John A. A.:  Atlantic Riehf_Uld Company (ARCO)
Recipient: Negrelli, Michael J.:  US EPA
Document Number: SIN-001-2225 To 2226                                               Date: 06/06/91

Title: (Memorandum containing the Biological  Technical  Assistance Group's  review of the "Revised
       Final Endangerment Assessment" and "Final  Remedial  Investigation  Report" for the Sinclair Refinery
       site)

     Type: CORRESPONDENCE
   Author: Hemmett, Roland:  US EPA
Recipient: Negrelli ,  Michael J.:  US EPA
Document Number: S1N-002-0598 To 0616                                               Date: 06/19/91

Title: (Letter providing comments on the Draft Proposed Plan for  the  Sinclair Refinery site)

     Type: CORRESPONDENCE
   Author: Belmore, Edward R.:  NY Dept of Environmental Conservation
Recipient: Petersen, Carole:  US EPA


Document Number: SIN-001-2093 To 2098                                               Date: 07/01/91

Title: Remedial Investigation Report - Addendum (general and specific comments)

     Type: REPORT
   Author: none:  US EPA
Recipient: none:  none

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09/23/91                         "    Index Chronological  Order                                                Page: 13
                                     SINCLAIR REFINERY SITE Documents
Document Number: SIN-002-0380 To 0396                                                Date:  07/01/91

Title: Feasibility Study Report - Addendum (general  and specific comments)

     Type: REPORT
   Author: none:  US EPA
Recipient: none:  none


Document Number: S1N-002-0397 To 0419                         '                       Date:  07/01/91

Title: Superfund Proposed Plan - Sinclair Refinery Site,  Uellsville,  New York

     Type: PLAN
Condition: DRAFT
   Author: none:  US EPA
Recipient: none:  none


Document Number: SIN-001-0935 To 0940                                                Date:  07/01/91

Title: Remedial Investigation Report - Addendum

     Type: REPORT
   Author: none:  US EPA
Recipient: none:  none


Document Number: SIN-001-2352 To 2368                                                Date:  07/01/91

Title: Feasibility Study Report Addendum

     Type: REPORT
   Author: none:  US EPA
Recipient: none:  none


Document Number: SIN-002-0420 To 0437                                                Date:  07/01/91

Title: Superfund Proposed Plan - Sinclair Refinery Site, Wellsville,  New York

     Type: PLAN
   Author: none:  US EPA
Recipient: none:  none

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09/23/91                             Index Chronological Order                                               Page:
                                     SINCLAIR REFINERY SITE Documents
Document Number: SIN-002-059A To 0597                              .                 Date: 07/10/91

Title: (Letter responding to NYSDEC's comments on the Draft Proposed Plan for the  Sinclair Refinery
       site)

     Type: CORRESPONDENCE
   Author: Petersen. Carole:  US EPA         ___
Recipient: Belmore, Edward R.:  NY Dept of Environmental Conservation
Document Number: SIN-001-2223 To 2224                                               Date: 07/16/91

Title: (Memorandum discussing biological sampling performed at the Sinclair Refinery site)

     Type: CORRESPONDENCE
   Author: Stevens, Shan" I.:  US EPA
Recipient: Negrelli, Michael J-:  US EPA


Document Number: SIN-002-0590 To 0593                                               Date: 07/19/91

Title: (Letter discussing the resolution of issues raised by NYSOEC and NYSOOH  regarding  the  revised
       Proposed Plan for the Sinclair Refinery site)

     Type: CORRESPONDENCE
   Author: Belmore, Edward R.:  NY Dept of Environmental Conservation
Recipient: Petersen, Carole:  US EPA


Document Number: SIN -002- 0587 To 0589                                               Date: 07/23/91
                                                                                     _'
Title: (Letter responding to NYSDEC's comments on the Draft Proposed Plan for the  Sinclair Refinery
       site)

     Type: CORRESPONDENCE
   Author: Petersen, Carole:  US EPA
Recipient: Belmore, Edward R.:  NY Dept of Environmental Conservation

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09/23/91                         '    Index Chronological  Order                                                 Page: 15
                                     SINCLAIR REFINERY SITE Documents
Document Number: SIN-002-0967 To 0969                                               Date: 07/29/91

Title: (Press Release:)"  EPA proposes $15.5 Million Cleanup Remedy for Super-fund Site in Wellsville,
       New York

     Type: CORRESPONDENCE
   Author: none:  US EPA                     ___.
Recipient: none:  none
Document Number: SIN-002-058A To 0586                                               Date: 07/31/91

Title: (Letter concurring uith the selected remedy  for  the Sinclair Refinery site)

     Type: CORRESPONDENCE
   Author: O'Toole, Michael J., Jr.:  NY Dept of Environmental Conservation
Recipient: Caltahan, Kathleen C.:  US EPA


Document Number: SIN-002-0907 To 0965                                               Date: 08/01/91

Title: (Transcript for the public meeting discussing  the proposed plan to remediate  the  Sinclair
       Refinery site)

     Type: LEGAL DOCUMENT
   Author: Bennett, Joan:  Bennett Court Reporting
Recipient: none:  none


Document Number: SIN-002-0472 To 0472                                               Date: 08/12/91
                                                                                      ..'
Title: (Letter agreeing to extension of time for the  submittal of ARCO's comments  on the Sinclair
       Refinery site Proposed Plan)

     Type: CORRESPONDENCE
   Author: Negrelli, Michael J.:  US EPA
Recipient: Zannos, John A. A.:  Atlantic Richfield  Company (ARCO)
 Attached: SIN-002-0473

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09/23/91                         "    index Chronological Order                                               Page: 16
                                     SINCLAIR REFINERY SITE Documents
Document Number: SIN-002-0473 To 0473                  Parent:  SIN-002-0472          Date:  08/1S/91

Title: (Letter requesting an extension of time in which to submit  comments on  the Sinclair  Refinery
       site Proposed Plan)

     Type: CORRESPONDENCE
   Author: Zannos, John A. A.:  Atlantic Richfield Company (ARCO)
Recipient: Negrelli, Michael J.:  US EPA
Document Number: SIN-002-0477 To 0583                  Parent:  SIN-002-0475          Date:  08/30/91

Title: Response' to EPA's Proposed Plan - Operable Unit II,  Sinclair  Refinery  Site, Wellsville, New
       York

     Type: PLAN
   Author: various:  various
Recipient: none:  Atlantic Richfield Company (ARCO)
Document Number: SIN-002-0475 To 0476                                               Date:  09/03/91

Title: (Letter forwarding ARCO's response to EPA's Proposed Plan for Operable Unit  No.  2  for  the
       Uellsville (Sinclair Refinery) site)

     Type: CORRESPONDENCE
   Author: Zannos, John A. A.:  Atlantic Richfield Company (ARCO)
Recipient: Negrelli, Michael J.:  US EPA
 Attached: SIN-002-0477

Document Number: SIN-002-0474 To 0474                                               Date:  09/04/91

Title: (Letter providing comments on the Sinclair Refinery site Proposed Plan)

     Type: CORRESPONDENCE
   Author: Chaffee, Robert L.:  Village of Welllsville, NY, Department of Public Works
Recipient: Negrelli, Michael J.:  US EPA

-------