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.
ia ProiectnrnkWorfc Urit No.
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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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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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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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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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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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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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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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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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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24
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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26
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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27
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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28
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.
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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
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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
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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
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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
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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.
-------
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.
-------
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.
-------
APPENDIX C
-------
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-
-------
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
-------
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
-------
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
-------
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
-------
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.
-------
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.
-------
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
-------
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
-------
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
-------
APPENDIX F
-------
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)
-------
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
-------
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)
-------
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
-------
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)
-------
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)
-------
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
-------
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
-------
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)
-------
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
-------
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)
-------
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
-------
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
-------
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
-------
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
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