EPA Superfund
Record of Decision:
PB95-963809
EPA/ROD/R02-95/255
February 1996
Sealand Restoration Site,
Town of Lisbon, St. Lawrence County, NY
9/29/1995
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RECORD OF DECISION
Sealand Restoration Site
Town of Lisbon, St. Lawrence County, New York
United States Environmental Protection Agency
Region II
New York, New York
September 1995
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DECLARATION FOR THE RECORD OF DECISION
SITE NAME AND LOCATION
Sealand Restoration Site
Town of Lisbon, St. Lawrence County, New York
STATEMENT OF BASIS AND PURPOSE
This Record of Decision documents the U.S. Environmental Protection Agency's selection of a
remedial action to address groundwater contamination at the Sealand Restoration site in accordance
with the requirements of the Comprehensive Environmental Response, Compensation and Liability
Act of 1980, as amended (CERCLA), 42 U.S.C. §9601-9675, and to the extent practicable the
National Oil and Hazardous Substances Pollution Contingency Plan, 40 CFR Part 300. This decision
document explains the factual and legal basis for selecting the remedy for the Site. The attached
index (Appendix III) identifies the items that comprise the Administrative Record upon which the
selection of the remedial action is based.
The New York State Department of Environmental Conservation has been consulted on the planned
remedial action in accordance with CERCLA §121(f), 42 U.S.C. §9621(f), and it concurs with the
selected remedy (see Appendix IV).
ASSESSMENT OF THE SITE
Actual or threatened releases of hazardous substances from the Site, if not addressed by implementing
the response action selected in this Record of Decision, may present an imminent and substantial
endangerment to public health, welfare, or the environment.
DESCRIPTION OF THE SELECTED REMEDY
The selected remedy includes:
• Extraction of contaminated groundwater in the vicinity of the former cell disposal area,
specifically "hot spots" in the shallow aquifer and contaminated groundwater in the bedrock
aquifer, on an expedited basis;
• Ex-situ biological treatment of the extracted groundwater, followed by reinjection to the
groundwater or discharge to surface water;
• Long-term monitoring of groundwater and surface water;
• Taking steps to secure that institutional controls (the placement of restrictions on the
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installation and use of groundwater wells at the Site and limitations on the future use of the
Site) be implemented; and
• Implementation of a hydrologic and vegetation monitoring program to monitor impacts to
potentially affected wetlands.
Approximately concurrent with the action to remediate the groundwater hot-spots, a study will be
conducted to determine if natural attenuation can reduce the remaining contaminants in the
groundwater to maximum contaminant levels (MCLs) within an acceptable time frame. Obtaining
sequential rounds of groundwater quality data will allow a determination as to whether the plume has
reached equilibrium conditions or whether it continues to attenuate. The study will assess the intrinsic
capability of the aquifer to naturally reduce contaminants.
If, after implementing the hot-spot groundwater remediation, groundwater monitoring results indicate
that the contaminants in the groundwater continue to exceed MCLs, and if the results of the study
indicate that natural attenuation has little potential to reduce groundwater contamination to MCLs,
a long-term action will be implemented. The long-term action would include:
• Extraction of contaminated groundwater in the vicinity of the former cell disposal area;
• Ex-situ biological treatment of the extracted groundwater, followed by reinjection to the
groundwater or, if groundwater reinjection is not feasible, discharge to surface water;
• Chemical pretreatment, if needed, to remove inorganics prior to the biological treatment unit;
and
• Long-term monitoring of groundwater and surface water.
DECLARATION OF STATUTORY DETERMINATIONS
The selected remedy meets the requirements for remedial actions set forth in CERCLA §121, 42
U.S.C. §9621 in that it: (1) is protective of human health and the environment; (2) attains a level or
standard of control of the hazardous substances, pollutants and contaminants, which at least attains
the legally applicable or relevant and appropriate requirements (ARARs) under federal and state laws,
(3) is cost-effective; (4) utilizes permanent solutions and alternative treatment (or resource recovery)
technologies to the maximum extent practicable; and (5) satisfies the statutory preference for
remedies that employ treatment to reduce the toxicity, mobility, or volume of the hazardous
substances, pollutants or contaminants at a site.
V
it a site.
/ i Lik
Jeanne M. Fc&c '\ /)/ r / Date
Regional Ac/rninistrstor
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TABLE OF CONTENTS
SITE NAME, LOCATION AND DESCRIPTION 1
SITE HISTORY AND ENFORCEMENT ACTIVITIES 2
HIGHLIGHTS OF COMMUNITY PARTICIPATION 3
SCOPE AND ROLE OF OPERABLE UNIT 3
SUMMARY OF SITE CHARACTERISTICS '. 4
SUMMARY OF SITE RISKS 7
REMEDIAL ACTION OBJECTIVES 11
DESCRIPTION OF REMEDIAL ACTION ALTERNATIVES 11
SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES 17
SELECTED REMEDY 22
STATUTORY DETERMINATIONS 23
DOCUMENTATION OF SIGNIFICANT CHANGES 26
ATTACHMENTS
APPENDIX I. FIGURES
APPENDIX II. TABLES
APPENDIX in. ADMINISTRATIVE RECORD INDEX
APPENDIX IV. STATE LETTER OF CONCURRENCE
APPENDIX V. RESPONSIVENESS SUMMARY
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RECORD OF DECISION
DECISION SUMMARY
Sealand Restoration Site
Town of Lisbon, St. Lawrence County, New York
United States Environmental Protection Agency
Region II
New York, New York
September 1995
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SITE NAME, LOCATION AND DESCRIPTION
The Sealand Restoration site ("Site"), located in the Town of Lisbon, St. Lawrence County, New
York, is situated south of Pray Road, 2.5 miles southwest of the Village of Lisbon. (See Figure 1.)
The Site, formerly a dairy farm, was acquired by Sealand Restoration in 1977, and beginning in
November 1978, it was operated as a waste disposal facility. Petroleum wastes were landfilled in a
disposal cell near the southern boundary, were spread on the ground in the central and northern areas
of the Site, or were stored adjacent to a barn. The former facility is comprised of two parcels of land,
approximately 210 acres in total area.
The area surrounding the Site is predominantly farmland, with a significant amount of wetlands
drained by intermittent low-flow streams. The area is sparsely populated; however, residential homes
and farmhouses can be found as close as 100 feet from the facility's property line.
The areas of contamination at the Site included the landspreading area, the cell disposal area, and the
drum storage area. (See Figure 2.)
The landspreading area consisted of several distinct open fields where liquid, biodegradable wastes
considered "vegetable oil" were intended to be spread on the ground in a thin layer. This oil was to
be worked into the soil prior to cultivation and planting with corn. However, the wastes which were
landspread were characterized as a petroleum oil-based liquid, containing generally low levels of
metals and polychlorinated biphenyls (PCBs). Improper landspreading practices apparently resulted
in episodes where oily wastes drained into nearby streams and wetlands. After the facility was
abandoned, most of the fields were cultivated and crops were harvested. The northern fields were
subsequently plowed and planted with corn, and the southern fields were utilized as hayfields.
Currently, none of the fields are in use.
The cell disposal area, located in the southern part of the Site, was originally designed as a disposal
site for oil spill debris containing no readily drainable fluids. However, oily waste materials, such as
chemical solvents used in cleanup operations, were disposed of at this location for approximately one
year. (Response actions conducted in 1984 and 1989-90 identified and removed a total of 1,680
buried drums and 4,900 cubic yards of contaminated soils in this area.) The disposal cell was located
less than 100 yards from a 100-acre, New York State Department of Environmental Conservation
(NYSDEC)-designated wetland. This wetland area drains into an unnamed tributary to Sucker
Brook.
The drum storage area was an unapproved disposal area located in the northern part of the facility,
in the vicinity of a house and barn. Approximately 200 empty or nearly empty drums were stacked
in the barnyard. Residue from these drums accumulated as a tar-like sludge on the ground surface
and beneath and around the drums. Alongside the barn was a 2,000-gallon tanker-trailer partially
filled with waste oil. A 20,000-gallon waste storage tank, containing 5,000 gallons of waste oil, was
located southeast of the barn. The tank had been used for the temporary storage of waste oil, until
it could be landspread on the fields. A gravel pit is also located in this area. The gravel pit was not
used as a disposal area.
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Mainly used for domestic and agricultural purposes, approximately 25 private wells, situated on Pray,
McFadden, and Tuck Roads, are located within a one-mile radius of the Site.
SITE HISTORY AND ENFORCEMENT ACTIVITIES
In March 1979, Sealand Restoration, Inc. was issued a permit by the New York State Department
of Environmental Conservation ("NYSDEC") to accept waste products. Under the terms of this
permit, only uncontaminated waste, petroleum wastes, and mineral oils were designated as acceptable
for disposal; specific approval was required for stockpiling wastes and disposal of any contaminated
wastes.
>
In April 1980, NYSDEC determined that Sealand Restoration was out of compliance with the permit
and ordered the facility to cease operation. In November 1981, officials from Sealand Restoration
signed an Administrative Consent Order with NYSDEC, under which the company agreed to take
measures to address contamination at the Site. However, shortly after signing this Order, Sealand
Restoration, Inc. defaulted on the Order and filed for bankruptcy.
During 1983, NYSDEC completed a Phase I and II engineering investigation and site evaluation.
During 1984, St. Lawrence County received a $100,000 Local Assistance Grant from the New York
State Legislature to perform a limited cleanup at the Site. The cleanup included the removal of 133
surface drums, 60 full or partially full buried drums, 42 empty, buried drums, and 150 cubic yards of
contaminated soil from the cell disposal area.
From 1986 through 1987, Dames and Moore, under contract with NYSDEC, conducted an
investigation of the Site, which concluded that the contaminated wastes and soils from the cell
disposal area and drum storage area should be removed.
From 1987 through 1988, utilizing funds from the State of New York totaling $90,000, the County
of St. Lawrence implemented the recommended cleanup plan for the drum storage area, including:
(1) removal and off-site disposal of 200 drums and the tar-like sludge from the drum storage area
located near the barn including approximately 20 cubic yards of contaminated soils; (2) off-site
disposal of the 5,000 gallons of waste oil in the waste-oil tank; (3) dismantling and off-site disposal
of the waste-oil tank; (4) removal and off-site disposal of the tanker-trailer; and (5) removal of small
quantities of acids and miscellaneous contaminated debris (hoses, buckets, etc.).
During March 1989 through March 1990, Sevenson Environmental Services, under contract with
NYSDEC, implemented the remaining elements of the recommended cleanup plan, removing 1,445
drums, 4,762 cubic yards of contaminated soil, and 375,000 gallons of liquid from the cell disposal
area, at a cost of approximately $15 million. The disposal cell was backfilled with clean soil and
covered with a multi-layered cap to significantly reduce infiltration of rain and snowmelt and to
control the generation of leachate (contaminated water) which could seep into the underlying
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groundwater. A leachate monitoring/collection system was installed to monitor the leachate
periodically and facilitate its collection, if necessary.
On August 27,1990, the Site was listed on the National Priorities List: EPA became the lead agency
at the Site.
On September 28,1990, a Record of Decision ("1990 ROD") for the Sealand Restoration site was
signed by the Environmental Protection Agency ("EPA") Regional Administrator. The 1990 ROD
explained the basis for selecting the interim cleanup actions for the Site and EPA's finding that
NYSDEC's selection of response actions was appropriate. The 1990 ROD also called for a
Supplemental Remedial Investigation and Feasibility Study ("RI/FS") to determine if there was a need
for further cleanup work at the Site.
EPA notified a group of parties which it identified as potentially responsible and provided them with
the opportunity to conduct the RI/FS. Negotiations were unsuccessful and EPA conducted the RI/FS
which is the basis of this ROD.
HIGHLIGHTS OF COMMUNITY PARTICIPATION
The RI report, FS report, and the Proposed Plan for the Site were released to the public for comment
on July 19, 1995. These documents were made available to the public in the administrative record
file at the EPA Docket Room in Region II, New York and the information repository at the Lisbon
Town Hall, 3108 Main Street, Lisbon, New York. The notice of availability for the above-referenced
documents was published in the Ogdensburg Journal on July 19, 1995. The public comment period
which related to these documents was to be held from July 19, 1995 to August 18, 1995. However,
in response to a few requests from the public to extend the public comment period, the conclusion
of the public comment period was revised from August 18, 1995 to September 22, 1995. A notice
of extension of the public comment period was published in the Ogdensburg Journal on August 28,
1995.
On August 8, 1995, EPA and NYSDEC conducted a public meeting at the Hepburn Library in
Lisbon, New York to inform local officials and interested citizens about the Superfund process, to
review current and planned remedial activities at the Site, to discuss the Proposed Plan, to receive
comments on the Proposed Plan, and to respond to questions from area residents and other interested
parties.
Responses to the comments received at the public meeting and in writing during the public comment
period are included in the Responsiveness Summary (see Appendix V).
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SCOPE AND ROLE OF OPERABLE UNIT
The first action taken at this Site, an interim source control measure, encompassed the removal and
disposal of drums, sludges, waste oils, tanks, trailers, and debris, and the excavation and disposal of
contaminated soils and liquids.
This is the second and final action for the Site. The primary objectives of this action are to reduce
and minimize the downgradient migration of contaminants in groundwater and to minimize any
potential impacts to human health and the environment.
SUMMARY OF SITE CHARACTERISTICS
The field investigation was conducted in 2 phases. The first phase, conducted from August to
December of 1992, included monitoring well installation and development, surface and subsurface
soil sampling, on-site monitoring well and residential well sampling, surface water and sediment
sampling, a geophysical survey, and an ecological investigation. The second phase of the field
investigation, conducted from August to November of 1993, included an expanded investigation of
groundwater contamination in the cell disposal area in order to characterize further and delineate the
extent of the contamination and groundwater flow. This effort consisted of the installation and
sampling often additional on-site monitoring wells in the cell disposal area and resampling of all other
monitoring and residential wells. Six additional residential wells were also sampled during this second
phase. In addition, the New York State Department of Health (NYSDOH) collected and analyzed
water samples from approximately 14 residences during the period between August 1993 to April
1995.
Surface and Subsurface Stiil
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The most frequently detected volatile organic found in the surface soil was acetone, which was
detected in 8 out of 42 samples. Acetone concentrations in surface soils ranged from 5.5 micrograms
per kilogram (ug/kg) to 82 ug/kg, which is less than the 200 ug/kg NYSDEC soil cleanup standard.
(See Figure 3.) Acetone was also found below the water table near the cell disposal area at
concentrations up to 80,000 fig/kg. The most frequently detected semi-volatile organic compound
(SVOC) in surface soils was bis(2-ethylhexyl)phthalate, which was detected in 22 of the 42 samples
collected. These detected concentrations ranged from 34 ug/kg to 6,500 ug/kg, which is significantly
below the NYSDEC soil cleanup level of 46,000 ug/kg. The only constituent found in surface soils
above NYSDEC's cleanup levels is benzo[a]pyrene. Only two samples contained this compound, and
the highest detected level was found in the gravel pit at a concentration of 73 ug/kg. This is only
slightly above 60 ug/kg, which is the NYSDEC soil cleanup level for benzo[a]pyrene. Arsenic was
detected in almost all of the surface soil samples; however, values ranged from just below to just
above 1 ug/kg, which is below background levels for New York State.
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Groundwater and Residential Well Water
Most of the contamination found in the shallow groundwater is east of the former cell disposal area.
(See Figure 4). Acetone was detected in this area in 8 samples, with the highest detected concentra-
tion at 2,100,000 ug/1 at MW-5I. Other volatile organic compounds (VOCs) found in this area at
elevated concentrations include 1,1-dichloroethane at 1,300 ug/1, 2-butanone at 4,700 ug/1, cis-1,2-
dichloroethylene at 440 pg/1, trichloroethene at 430 ug/1, chloroethane at 390 ug/1, vinyl chloride at
250 ug/1, and 1,1,1-trichloroethane at 240 ug/1. The federal drinking water standard for vinyl
chloride is 2 ug/1. New York State MCLs for acetone and 2-butanone are 50 ug/1 and for the other
VOCs are 5 ug/1. VOCs were detected in 4 bedrock wells, but only in one of these wells did the
levels exceed 1 ug/1. The exception was one well where acetone was detected near the former cell
disposal area at 280 ug/1. Also in this well, 2-butanone and 1,1-dichloroethane were detected at 10
ug/1 and 0.4 ug/1, respectively.
Five SVOCs were detected in the shallow groundwater samples. Bis(2-ethylhexyl)phthalate was
detected in 3 monitoring wells near the former cell disposal area at concentrations ranging from 0.7
ug/1 to 10 ug/1. The federal drinking water standard for bis(2-ethylhexyl)phthalate is 6 ug/1.
Naphthalene was detected in 2 wells at concentrations ranging from 0.8 ug/1 to 2 ug/1. The New
York State MCL for naphthalene is 10 pg/1. Di-n-octyl phthalate was detected at 10 ug/1 in one well
near the gravel pit. Near the former cell area, 4-methylphenol and 2,4-dimethylphenol were detected
in one well at 18 ug/1 and 2 ug/1, respectively. No SVOCs were detected in cm-site bedrock
monitoring wells. Three pesticides, beta-BHC, endrin ketone, and heptachlor epoxide, were detected
at low levels (less than 0.1 jig/l) in shallow groundwater samples. One pesticide, aldrin, was found
at 0.011 ng/1 in a bedrock groundwater sample. No PCBs were detected in on-site groundwater.
Eight inorganic analytes were detected at concentrations above or near MCLs in shallow wells,
including manganese (in 8 wells at levels ranging from 321 pg/1 to 2,066 ug/1), arsenic (in 4 wells
at levels ranging from 17 ug/1 to 95 ug/1), lead (in one well, B-8W, at 25 pg/1), and chromium (in one
well, DM-01, at 235 ug/1). (See Figure 5 and Table 1.) Cadmium was found at a level above "the
federal drinking water standard of 5 ug/1 in one bedrock well (7 ug/1 at MW-1D). It should be noted
that many of these high levels were 1) not found in source areas, 2) were not detected in both
sampling rounds, 3) may be due at least in part to the presence of excessive turbidity in older
monitoring wells, and 4) may be naturally occurring.
In the first round of groundwater samples collected from residential wells located near the Site, lead,
arsenic, bis(2-ethylhexyl)phthalate, and one PCB compound were detected in a few samples at or
above federal or state drinking water standards. Lead was also detected at elevated levels in 2 other
subsequent samples collected and analyzed by NYSDOH. Because lead, arsenic, bis(2-
ethylhexyl)phthalate, and PCBs were previously also found on-site in the soil, and lead was detected
in on-site groundwater, EPA issued a Unilateral Administrative Order in August of 1993 to the
potentially responsible parties, requiring that they supply an alternate water supply to potentially
affected residents on a regular basis for drinking and cooking. This action was taken as a
precautionary measure to ensure that nearby residents were not exposed to site-related contaminants.
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Deliveries of bottled water began in September 1993. However, based upon the results of the
remedial investigation, EPA determined that lead, arsenic, bis(2-ethylhexyl)phthalate, and PCBs were
either not found in on-site groundwater, or were found at levels too low and in areas too remote from
any of the affected residences to be a source of contamination to those private water supplies.
Moreover, with the exception of lead, which was detected in one background monitoring well on-site,
these contaminants were not detected in the bedrock aquifer, which is the aquifer from which most
residential wells in the area draw water. Subsequent samples collected by NYSDOH and EPA have
not detected arsenic, bis(2-ethylhexyl)phthalate, and PCBs in residential wells. Lead was found at
much lower levels in 2 residential wells in NYSDOH samples collected in August 1994 and March
1995. Through the St. Lawrence Co. Sanitarian, NYSDOH plans to continue to provide information
and assistance as needed to these homes. Since site-related contaminants were not found to be
impacting private homeowner wells, EPA notified the potentially responsible parties in May of 1995,
that they were no longer required to continue providing an alternate water supply. Deliveries of
bottled water ceased in July 1995. No other VOC, SVOCs, PCBs, or pesticides were detected above
state or federal MCLs in the private wells. Magnesium, manganese, copper, zinc, and iron were
detected above MCLs. However, the source of these substances in residential wells is not considered
to be related to contamination at the site.
Leachate
Six VOCs, vinyl chloride, 1,1-dichloroethane, 1,1,1-trichloroethane, trichloroethane, tetrachloro-
ethane, and cis,l,2-dichloroethane were detected in water quality samples collected from the leachate
monitoring system at levels ranging from 4 ug/1 to 1,200 ug/1. Endrin aldehyde, a pesticide, was
detected at 0.003 ug/1. Magnesium was detected at elevated levels, with the highest detection at
68,851 ug/1. No SVOCs or PCBs were detected in leachate samples.
Surface Water and Sediments
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In the surface water, 7 VOCs were detected at low concentrations in 6 of 18 samples. (See Figure
6.) Acetone was detected in 2 locations in the northwestern wetlands at 12 ug/1 and 6 ug/1. The
remaining VOCs were detected at levels ranging from 0.2 ug/1 to 0.8 ug/1. Five SVOCs were
detected in surface water samples. One sample collected in the northwestern wetlands contained 4-
methylphenol at 2 ug/1 and di-n-butyl phthalate at 1 ug/1. Samples collected east of the former cell
disposal area showed 4-chloro-3-methylphenol and pentachlorophenol, both at 2 ug/1. N-
nitrosodiphenylamine was detected in 3 samples at 1 ug/1. Three pesticides, endrin, endosulfan
sulfate, and gamma-BHC, were detected at levels below 0.01 ug/1 in surface water. No PCBs were
detected in surface water samples. Iron was detected in surface water samples at concentrations as
high as 37,176 ug/1. The NYSDEC surface water standard for iron is 300 ug/I. Copper and cadmium
were found in surface water samples at 45.2 ug/1 and 12.2 ug/1, respectively. The EPA surface water
quality standards for copper and cadmium are 18 ug/1 and 3.9 ug/1, respectively.
Three VOCs, chloroform, 2-butanone, and toluene, were detected in 4 of 18 sediment samples. (See
, Figure 7.) Toluene and 2-butanone were detected in one sample east of the former cell disposal area
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at 6 pg/kg and 17 pg/kg, respectively. One sample collected in the northwestern wetlands exhibited
a detection of 2-butanone at 12 pg/kg. Chloroform was detected in 2 samples at 2 pg/kg and 1
pg/kg. Five SVOCs, di-n-butyl phthalate, phenol, 4-methylphenol, 4-chloro-3-methylphenol, and 2,4-
dimethylphenol were detected at concentrations as high as 210 pg/kg. One sample collected in the
eastern wetlands downgradient from one of the landspreading areas contained phenol, 4-
methylphenol, and 4-chloro-3-methylphenol at 75 pg/kg, 43 pg/kg, and 210 pg/kg, respectively. In
a sample collected east of the former cell disposal area, 2,4-dimethylphenol was detected at 110
pg/kg. Di-n-butylphthalate was found in 3 other samples at levels ranging from 43 pg/kg to 58
pg/kg. Five pesticides, heptachlor epoxide, methoxychlor, endrin aldehyde, aldrin, and 4,4'-DDE,
were detected in 12 of 18 sediment samples. Methoxychlor was detected in 3 samples at
concentrations ranging from 2.3 pg/kg to 6.3 pg/kg. Arsenic, cadmium, chromium, manganese, and
mercury were detected in sediments at concentrations above NYSDEC sediment criteria.
SUMMARY OF SITE RISKS
Based upon the results of the RI, a baseline risk assessment was conducted to estimate the risks
associated with current and future site conditions. The baseline risk assessment estimates the human
health and ecological risk which could result from the contamination at the Site, if no remedial action
were taken.
Human Health Risk Assessment
A reasonable maximum exposure scenario, which is the highest exposure that is reasonably expected
to occur at a site, was evaluated using a four-step process to assess site-related human health risks:
Hazard Identification ?—identifies the contaminants of concern at the site based on several factors such
as toxicity, frequency of occurrence, and concentration. Exposure Assessment—estimates the
magnitude of actual and/or potential human exposures, the frequency and duration of these
exposures, and the pathways (e.g., ingesting contaminated well-water) by which humans are
potentially exposed. Toxicity Assessment—determines the types of adverse health effects associated
with chemical exposures, and the relationship between magnitude of exposure (dose) and severity of
adverse effects (response). Risk Characterization—summarizes and combines outputs of the exposure
and toxicity assessments to provide a quantitative (e.g., one-in-a-million excess cancer risk)
assessment of site-related risks.
EPA conducted a baseline risk assessment to evaluate the potential risks to human health and the
environment associated with the Site in its current state. The Risk Assessment focused on
contaminants in the surface soil, onsite and offsite groundwater, surface water, and sediments which
are likely to pose significant risks to human health and the environment. A summary of the
contaminants of concern in sampled matrices is provided in Table 2 for human health receptors.
EPA's baseline risk assessment evaluated the health effects which could result from exposure to Site
contamination as a result of several basic exposure pathways. These pathways, evaluated under both
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current and future land-use conditions, include: incidental ingestion of site soil; dermal absorption of
constituents from site soil; incidental ingestion of on-site surface water; dermal absorption of
constituents from surface water; incidental ingestion of on-site sediments; and dermal absorption of
constituents from sediments. Three additional exposure pathways evaluated under potential future
land-use conditions include: ingestion of groundwater (potable well water); dermal contact with
groundwater (bathing, household uses of tap water); and inhalation of groundwater-derived volatile
constituents (through showering and bathing). Three potential receptors were identified: young
children (ages 1-6); older children (ages 6-12); and adult residents living downgradient from the
former facility. Exposure intakes (doses) were calculated for each receptor for all exposure pathways
considered. The exposure pathways considered under current and future uses are listed in Tables 3
and 4, respectively. The reasonable maximum exposure was evaluated.
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Under current EPA guidelines, the likelihood of carcinogenic (cancer-causing) and noncarcinogenic
effects as a result of 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 noncarcinogenic
risks associated with exposures to individual compounds of concern were summed to indicate the
potential risks associated with mixtures of potential carcinogens and noncarcinogens, respectively.
Potential carcinogenic risks were evaluated using the cancer slope factors developed by EPA for the
contaminants of concern. Cancer slope factors (SFs) have been developed by EPA's Carcinogenic
Risk Assessment Verification Endeavor for estimating excess lifetime cancer risks associated with
exposure to potentially carcinogenic chemicals. The SFs for the compounds of concern are presented
in Table 5. 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.
i
For known or suspected carcinogens, EPA considers excess upper-bound individual lifetime cancer
risks of between 10"4 to 10"6 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.
Noncarcinogenic risks were assessed using a hazard index (HI) approach, based on a comparison of
expected contaminant intakes and safe levels of intake (Reference Doses). Reference doses (RfDs)
have been developed by EPA for indicating the potential for adverse health effects. RfDs, which are
expressed in units of milligrams/kilogram-day (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 to the RfD to derive the hazard quotient for the
contaminant in the particular medium. The RfDs for the compounds of concern at the Site are
presented in Table 5. The HI is obtained by adding the hazard quotients for all compounds across all
media that impaci a particular receptor population. An HI greater than 1.0 indicates that the potential
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exists for noncarcinogenic 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 results of the baseline risk assessment under the current land use conditions are shown in Table
6. The total cancer risks to an adult and older child on-site trespasser from exposure to site-related
constituents of concern is 1.4 X 10"5 and 1.2 X 10'5, respectively. Dermal contact with surface water
contributed 63% of these risks. These risks are within EPA's acceptable cancer risk range of 10"4 to
10"6. The HI, which reflects the likelihood of noncarcinogenic effects occurring in a population, was
not significant (i.e., less than 1.0) for both the adult and child receptor under current land use. It was
estimated to be 0.05 for adults and 0.2 for older children.
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g
The results of the baseline risk assessment under the future land use conditions are shown in Table
7. Under this scenario, cancer risks of 2.3 X 10"4 and 1.5 X 10"4 were estimated for the adult and
young child receptor, respectively. These risks, which are at the upper boundary of the acceptable
cancer range, are mostly attributable to the ingestion of groundwater, with arsenic acting as the major
contributor. The HI for adults and young children ingesting groundwater was estimated to be 578
and 1,350, respectively. A total of 99.9% of the noncarcinogenic hazard is attributed to the use of
groundwater. Acetone accounts for 99% of the noncarcinogenic hazard of this groundwater.
Ecological Risk Assessment
A four-step process is also utilized for assessing site-related ecological risks for a reasonable
maximum exposure scenario: Problem Formulation - a qualitative evaluation of contaminant release,
migration, and fate; identification of contaminants of concern, receptors, exposure pathways, and
known ecological effects of the contaminants; and selection of endpoints for further study. Exposure
Assessment—a quantitative evaluation of contaminant release, migration, and fate; characterization
of exposure pathways and receptors; and measurement or estimation of exposure point
concentrations. Ecological Effects Assessment-literature reviews, field studies, and toxicity tests,
linking contaminant concentrations to effects on ecological receptors. Risk Characterization-
measurement or estimation of both current and future adverse effects.
The site and the surrounding area were investigated to determine existing ecological conditions. All
of the environs within the study area were characterized and grouped into 3 habitat types: aquatic,
wetlands, and terrestrial. Observations during the September 1992 field investigations were reviewed
and species lists for avians, mammals, and vegetation were compiled.
Twenty-nine constituents of ecological concern were identified and evaluated for potential impacts
to the selected target species and aquatic biota in general. (See Table 8). A comparison of the total
daily intake of these constituents for target species with the range of available toxicological data
found in the literature was the basis for the risk characterization. Total daily intakes for each of the
target species were calculated as a result of the ingestion of soil, sediment, surface water, vegetation,
and food.
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Only two of the calculated exposure values for the target species exceeded appropriate levels for any
of the constituents of ecological concern for the site. These are lead and di-n-butylphthalate.
However, the data used to calculate the exposure values for di-n-butylphthalate were based on high
detection limits in samples where di-n-butylphthalate was not detected. Detected concentrations of
di-n-butylphthalate do not predict unacceptable exposure values. Although lead exposure in surface
soil in some areas of the Site exceed ranges and typical values detected in soil samples, background
levels of lead also produce unacceptable exposure levels. Concentrations of other constituents of
ecological concern are at levels which do not pose an unacceptable environmental hazard.
The results of the human health and ecological risk assessment indicate that no unacceptable risks are
present in surface soil or surface water at the Site. However, actual or threatened releases of
hazardous substances via groundwater from the Site, if not addressed by the preferred alternative or
one of the other active measures considered, may present a current or potential threat to public
health, welfare, or the environment.
'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
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 concern, the period of time over which such exposure
would occur, and in the models used to estimate the concentrations of the chemicals of 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 baseline risk assessment
provides upper bound estimates of the risks to populations near the Site, and it is highly unlikely to
underestimate those actual risks related to the Site.
10
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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.
REMEDIAL ACTION OBJECTIVES
Remedial action objectives are specific goals to protect human health and the environment. These
objectives are based on available information and standards such as applicable or relevant and
appropriate requirements and risk-based levels established in the risk assessment.
The following remedial action objectives have been established for the Site:
• minimize migration of contaminated groundwater, and
• restore the on-site groundwater quality.
DESCRIPTION OF REMEDIAL ACTION ALTERNATIVES
CERCLA §121(b)(l), 42 U.S.C. §9621(b)(l), mandates that a remedial action must be protective
of human health and the environment, cost-effective, arid utilize permanent solutions and alternative
treatment technologies or resource recovery technologies to the maximum extent practicable. Section
121(b)(l) also establishes a preference for remedial actions which employ, as a principal element,
treatment which permanently and significantly reduces the volume, toxicity, or mobility of the
hazardous substances, pollutants and contaminants at a site. CERCLA §121(d), 42 U.S.C. §962l(d),
further specifies that a remedial action must attain a level or standard of control of the hazardous
substances, pollutants, and contaminants, which at least attains ARARs under federal and state laws,
unless a waiver can be justified pursuant to CERCLA §121(d)(4), 42 U.S.C. §9621(d)(4).
This Record of Decision ("ROD") evaluates, in detail, five remedial alternatives for addressing the
contamination associated with the Site. Various processes are considered and are assembled into
remedial alternatives which can accomplish the remedial action objectives. Cost and construction
time, among other criteria, were evaluated for each remedial alternative. The time to implement a
remediaraltemative reflects only the time required to construct or implement the remedy and does
not include the time required to design the remedy, efforts to negotiate with the responsible parties,
procurement of contracts for design and construction, or operation and maintenance activities at the
Site.
The remedial alternatives are:
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Alternative 1 — No Further Action
Capital Cost: $0
Annual Operation and Maintenance Cost: $80,000
Present Worth Cost (30 years): $1,300,000
Construction Time: 3 months
The Superfund regulations requires that the "no-action" alternative be considered as a baseline for
comparison with the other alternatives. The no-further-action remedial alternative does not include
any physical remedial measures that address the problem of contamination at the Site. However, this
response action would include the implementation of a long-term monitoring program, the
development and implementation of a public awareness and education program to enhance the
community's knowledge of the conditions existing at the Site, and would include steps to secure
institutional controls (the placement of restrictions on the installation and use of groundwater wells
at the site and limitations on the future use of the Site).
Alternative 2A — Hot-Spot Groundwater Extraction, Ex-Situ Bioremediation, and Reinjection
or Surface Water Discharge
Capital Cost: 5711,000
Annual Operation and Maintenance Cost: $162,000
Present Worth Cost (3 years): $ 1,152,000
Construction Time: 6 months
The major features of this alternative include contaminated groundwater extraction to immediately
address groundwater "hot spots" in the shallow aquifer and contaminated groundwater in the bedrock
aquifer in the vicinity of the former cell disposal area, ex-situ biological treatment of the extracted
groundwater, and reinjection of the treated water to the groundwater or surface water discharge. It
is anticipated that this alternative would, within 1 to 3 years, treat the groundwater hot spots in the
shallow aquifer and contaminated groundwater in the bedrock aquifer in the vicinity of the former cell
disposal area sufficiently to meet federal and state MCLs. (The estimated cleanup time, which is based
upon analytical modelling using published values of soil-to-groundwater partitioning coefficients, is
approximate and may underestimate the actual cleanup time frame.) Because this alternative focuses
on only the highest areas of contamination, cleanup levels may not be met in all areas of the localized
plume within this time frame.
Under this alternative, groundwater extraction wells would be installed in the vicinity of the hot spots.
Other components of the extraction system would include submersible pumps for groundwater
extraction and a system of interconnecting pipes from the wells to the treatment system. Assuming
continuous pumping, the estimated extraction rate of groundwater would be approximately-10 gallons
12
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per minute ("gpm").
Extracted groundwater would be pumped into an equalization tank and then to the biological
treatment unit. In the biotreatment unit, microorganisms would metabolize the biodegradable
organics. The extent of biodegradation would be dependent upon the types of contaminants present.
This technology would include conventional aerobic biological treatment, such as activated sludge.
Biological treatment results in the production of biomass or sludge, which must be disposed of.
Sludge would be dewatered and staged in a roll-off for off-site disposal. The treated groundwater
would be injected back into the ground or discharged to surface water. Effluent samples from the
groundwater treatment system would be collected and analyzed periodically. Groundwater and/or
surface water monitoring would be conducted quarterly. This alternative would also include
implementation of a hydrologic and vegetation monitoring program to monitor impacts to potentially
affected wetlands, and mitigative actions so as to minimize any destruction, loss, or degradation of
wetlands resulting from construction activities, groundwater drawdown, or contaminant migration
to the maximum extent practicable. This alternative would also include steps to secure institutional
controls (the placement of restrictions on the installation and use of groundwater wells at the site and
limitations on the future use of the Site).
Alternative 2B — Hot-Spot Groundwater Extraction and Transport to a Publicly-Owned
Treatment Works (POTW)
Capital Cost: $384,000
Annual Operation and Maintenance Cost: $675,000'
Present Worth Cost (3 years): $2,220,000
Construction Time: 6 months
The major features of this alternative include the construction of a groundwater extraction system to
immediately address groundwater hot spots in the shallow aquifer and contaminated groundwater in
the bedrock aquifer in the vicinity of the former cell disposal area, with its subsequent transport to
the Ogdensburg POTW for treatment. It is anticipated that this alternative would, within 1 to 3 years,
treat the hot spots in the shallow aquifer and contaminated groundwater in the bedrock aquifer in the
vicinity of the former cell disposal area to levels required by federal and state MCLs. (The estimated
cleanup time, which is based upon analytical modeling using published values of soil-to-groundwater
partitioning coefficients, is approximate and may underestimate the actual cleanup timeframe.)
Because this alternative focuses on only the highest areas of contamination, cleanup levels may not
be met in all areas of the localized plume within this timeframe.
1Annual O & M costs for Alternative 2B are based on estimates obtained from consultations
with the City of Ogdensburg.
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Alternative 2B would use the same groundwater extraction system as Alternative 2A. Additional
components required would be on-site storage tanks (with a storage capacity of 20,000 gallons),
which would be utilized to store the extracted groundwater temporarily. The stored, extracted
groundwater would be transferred to 5,000-gallon tank trucks and hauled to the Ogdensburg POTW.
Four trips to the POTW per day would be required to empty the tanks.
The POTW has a primary and secondary wastewater treatment system and discharges its effluent to
the St. Lawrence River. The primary system consists of a grit chamber, comminutor, primary settling
tanks, and chlorination. The secondary treatment system consists of activated sludge aeration tanks
and final settling. The average design flow during dry weather is 6.5 million gallons per day (mgd),
with a maximum design capacity of 13 mgd. The wet weather maximum capacity is 20 mgd. Any
flows greater than 13 mgd, but. less than 20 mgd, receive only primary treatfnent, bypassing the
secondary treatment before discharge. Any flows in excess of 20 mgd bypass both treatment systems
and are discharged directly into the St. Lawrence River. Because the sewer system is a combined
(sanitary and stormwater) sewer system, flows in excess of 20 mgd only occur during heavy rainfall
events or large snow melts. At such times, the groundwater extraction system would be shut down
temporarily and reactivated when the POTW resumed operation at average flow conditions. This
would ensure that the contaminated groundwater would receive primary and secondary treatment.
It is believed that the contaminated groundwater would be amenable to biological waste treatment.
However, a pilot study would need to be performed to ensure that the discharge would not adversely
impact the biomass, effluent discharge limits, or the sludge generation of the Ogdensburg POTW.
Monitoring of the groundwater would be performed semi-annually to determine any changes as a
result of this alternative. This alternative would also include implementation of a hydrologic and
vegetation monitoring program to monitor impacts to potentially affected wetlands, and mitigative
actions to minimize any destruction, loss, or degradation of wetlands resulting from construction
activities, groundwater drawdown, or contaminant migration to the maximum extent practicable. This
alternative would also include steps to secure institutional controls (the placement of restrictions on
the installation and use of groundwater wells at the site and limitations on the future use of the Site).
Alternative 3A — Hot-Spot Groundwater Extraction, Ex-Situ Bioremediation, and Reinjection
or Surface Water Discharge, Followed by Groundwater Extraction, Ex-Situ Bioremediation,
and Reinjection or Surface Water Discharge
Hot Spots Long- Term Total
Capital Cost: $1,191,000
Annual Operation and Maintenance Cost: $162,000 $189,000
Present Worth Cost (10 years): $2,029,000
Construction Time: 6 months 1 year
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This alternative includes hot-spot groundwater remediation and on-site reinjection or discharge to
surface water of treated groundwater as described in Alternative 2A. Approximately concurrent with
this action, additional groundwater monitoring and a study would be conducted to determine if
natural attenuation could reduce the remaining contaminants to MCLs within an acceptable time
frame. Obtaining sequential rounds of groundwater quality data would aid in the assessment of
whether the plume has reached equilibrium conditions or would continue to attenuate within an
acceptable time frame. Approximately 5 to 10 additional monitoring wells would probably be
necessary to conduct this study. Other requirements would be determined in the natural attenuation
work plan. If, after implementing hot-spot groundwater remediation, groundwater monitoring results
continue to exceed MCLs, and if the study indicates natural attenuation has little potential to reduce
groundwater contamination to MCLs, a long-term action to extract contaminated groundwater would
be implemented.
The long-term action would be designed to extract, collect, treat, and reinject or discharge all
contaminated groundwater in the vicinity of the former cell disposal area, and it would be
implemented upon completion of the design of the groundwater capture and treatment systems.
Assuming continuous pumping, the estimated extraction rate of the groundwater would be 30 gpm.
The long-term action would employ structures, facilities, equipment, and supplies, where feasible,
used in the expedited action. Additional groundwater extraction wells, tanks, biotreatment units, and
reinjection wells or trenches would be constructed or procured as needed in order to extract, collect,
treat, and discharge all contaminated groundwater in the vicinity of the former cell disposal area. The
treatment system for the long-term action would be implemented as described in Alternative 2A.
It is anticipated that this alternative would treat the contaminated groundwater to levels required by
federal and state MCLs within 10 years. (The estimated cleanup time, which is based upon analytical
modeling using published values of soil-to-groundwater partitioning coefficients, is approximate and
may underestimate the actual cleanup timeframe. Also, if the remedy is implemented using hot spot
remediation followed by natural attenuation, the estimated cleanup time would be longer than 10
years.) Groundwater and surface water monitoring would be conducted quarterly. This alternative
would also include implementation of a hydrologic and vegetation monitoring program to monitor
impacts to potentially affected wetlands, and mitigative actions to minimize any destruction, loss, or
degradation of wetlands resulting from construction activities, groundwater drawdown, or
contaminant migration to the maximum extent practicable. This alternative would also include steps
to secure institutional controls (the placement of restrictions on the installation and use of
groundwater wells at the site and limitations on the future use of the Site).
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Alternative 3B - Hot-Spot Groundwater Extraction and Transport to a POTW, Followed by
Groundwater Extraction and Discharge to POTW
Hot Spots Long-Term Total
Capital Cost: $2,682,000
Annual Operation and Maintenance Cost: $675,000 $566,000
Present Worth Cost (10 years): $7,059,000
Construction Time: 6 months 1 year
This alternative includes hot-spot groundwater remediation as described in Alternative 2B.
Approximately concurrent with this action, additional groundwater monitoring and a study would be
conducted to determine if natural attenuation could reduce the remaining contaminants to MCLs
within an acceptable time frame. 'Obtaining sequential rounds of groundwater quality data would aid
in the assessment of whether the plume has reached equilibrium conditions or would continue to
attenuate within an acceptable time frame. Approximately 5 to 10 additional monitoring wells would
probably be necessary to conduct this study. Other requirements would be determined in the natural
attenuation work plan. If, after implementing hot-spot groundwater remediation, groundwater
monitoring results continue to exceed MCLs, and if the study results indicate that natural attenuation
has little potential in reducing groundwater contamination to MCLs, a long-term action to extract
contaminated groundwater and discharge the effluent to the Ogdensburg POTW would be
implemented.
The extracted groundwater would be discharged through a 6-inch force main to an existing sewer line
located 24,000 feet northwest of the Site for transport to the City of Ogdensburg's POTW. A pilot
study would be performed to ensure that the discharge would not adversely impact the biomass,
effluent quality, or the sludge generation of the Ogdensburg POTW. The extracted groundwater
would fall within the Domestic Sewage Exclusion, 40 CFR 261.4, and would not require a RCRA
permit for purposes of discharge to the wastewater treatment plant.
It is anticipated that this alternative would treat the contaminated groundwater to levels required by
federal and state MCLs within 10 years. (The estimated cleanup time, which is based upon analytical
modeling using published values of soil-to-ground water partitioning coefficients, is approximate and
may underestimate the actual cleanup time frame. Also, if the remedy is implemented using hot spot
remediation followed by natural attenuation, the estimated cleanup time would be longer than 10
years.) Monitoring of the groundwater would be performed quarterly to determine any changes as
a result of this alternative. This alternative would also include implementation of a hydrologic and
vegetation monitoring program to monitor impacts to potentially affected wetlands, and mitigative
actions to minimize any destruction, loss, or degradation of wetlands resulting from construction
activities, groundwater drawdown, or contaminant migration to the maximum extent practicable.
This alternative would also include steps to secure institutional controls (the placement of restrictions
on the installation and use of groundwater wells at the site and limitations on the future use of the
site).
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SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES
In selecting a remedy, EPA considered the factors set out in CERCLA §121, 42 U.S.C. §9621, by
conducting a detailed analysis of the viable remedial alternatives pursuant to the NCP, 40 CFR
§300.430(e)(9) and OSWER Directive 9355.3-01. The detailed analysis consisted of an assessment
of the individual alternatives against each of nine evaluation criteria and a comparative analysis
focusing upon the relative performance of each alternative against those criteria.
The following "threshold" criteria are the most important and must be satisfied by any alternative in
order to be eligible for selection:
>
1. Overall protection of human health and ihe environment addresses whether or not a remedy
provides adequate protection and describes how risks posed through each exposure pathway
(based on a reasonable maximum exposure scenario) are eliminated, reduced, or controlled
through treatment, engineering controls, or institutional controls.
2. Compliance with ARARs addresses whether or not a remedy would meet all of the applicable
(legally enforceable), or relevant and appropriate (pertaining to situations sufficiently similar
to those encountered at a Superfund site such that their use is well suited to the site)
requirements of federal and state environmental statutes and requirements or provide grounds
for invoking a waiver.
The following "primary balancing" criteria are used to make comparisons and to identify the major
trade-offs between alternatives:
3. Long-term effectiveness and permanence refers to the ability of a remedy to maintain reliable
protection of human health and the environment over time, once cleanup goals have been met.
It also addresses the magnitude and effectiveness of the measures that may be required to
manage the risk posed by treatment residuals and/or untreated wastes.
4. Reduction oftoxicity, mobility, or volume via treatment refers to a remedial technology's
expected ability to reduce the toxicity, mobility, or volume of hazardous substances,
pollutants or contaminants at the site.
5. Short-term effectiveness addresses 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 periods until cleanup goals are achieved.
6. Implementability refers to the technical and administrative feasibility of a remedy, including
the availability of materials and services needed.
7. Cost includes estimated capital and operation and maintenance costs, and the present-worth
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costs.
The following "modifying" criteria are considered fully after the formal public comment period on the
Proposed Plan is complete:
8. State acceptance indicates whether, based on its review of the RI/FS reports and the
Proposed Plan, the State supports, opposes, and/or has identified any reservations with the
selected alternative.
9. Community acceptance refers to the public's general response to the alternatives described
in the Proposed Plan and the RI/FS reports. Factors of community acceptance to be
discussed include support, reservation, and opposition by the community.
A comparative analysis of the remedial alternatives based upon the evaluation criteria noted above
follows.
• Overall Protection of Human Health and the Environment
Alternative 1, no further action, would be the least protective of human health and the environment,
because contaminated groundwater would continue to migrate unabated and, consequently, would
not address the remedial action objectives established for the Site. Alternatives 2A and 2B, which
include an expedited action to extract and treat contaminated groundwater from the known areas of
high groundwater contamination, would prevent significant migration of contaminated groundwater.
Thus, less potential exists for higher levels of contamination to reach both the wetland areas or
residential areas, if the early actions were to be implemented.
Alternatives 3 A and 3B would be more protective of human health and the environment than either
of the expedited response action alternatives, Alternatives 2A and 2B, because under Alternatives 3 A
and 3B, the long-term component of these remedies addresses the entire plume of groundwater
contamination. Alternatives 2A and 2B may achieve the remediation goals for the known hot spots,
but they would not actively address areas of the groundwater plume outside the zone of influence of
the existing monitoring wells or groundwater extraction wells.
Alternative 3A, utilizing reinjection of treated groundwater, may be more protective of the
environment than Alternative 3B, because reinjecting treated groundwater to the aquifer would not
result in lowering the water table as much as the alternatives with off-site groundwater treatment and
disposal, as is the case with Alternative 3B.
• Compliance with ARARs
No further action would not reduce groundwater contamination levels to MCLs and would, therefore,
rely on long-term natural attenuation to achieve these ARARs in the aquifer. Alternatives 3A and 3B
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would be the most effective in reducing groundwater contaminant concentrations below MCLs
because only these alternatives combine both expedited and long-term collection and treatment of
groundwater. Both expedited response action alternatives would not meet MCLs in areas where
groundwater is not extracted and treated until these areas attenuate naturally.
The discharge to POTW alternatives, Alternatives 2B and 3B, would have to comply with federal,
state, and local pretreatment requirements and the local sewer ordinances. In addition, the selected
POTW must be in compliance with all federal and state permit requirements.
All of the alternatives, except for the no-further-action alternative, include groundwater extraction
in or adjacent to a wetland area. Consequently, in order to comply with Executive Order 11990 on
the protection of wetlands, adverse impacts to wetlands and aquatic resources would need to be
avoided.
In Alternatives 2A and 3A, the options to reinject the treated groundwater, would comply with state
groundwater standards. The surface water discharge options would comply with the state surface
water standards and discharge requirements.
• Long-Term Effectiveness and Permanence
All alternatives, except Alternative 1, no further action, would actively collect and treat groundwater
until concentrations of contaminants were reduced to cleanup standards. Alternatives 2A and 2B
would operate for approximately 3 years, whereas Alternatives 3A and 3B would operate for
approximately 10 years. Biological treatment technologies are expected to be effective in remediating
contaminated groundwater. Major equipment replacement is not expected as a result of the relatively
short duration of the remediation. Alternatives 2B and 3B would not require major equipment other
than the extraction system, because treatment of the groundwater would be performed off-site at the
POTW. The long-term effectiveness of Alternative 3 A is contingent on proper operation of the
groundwater extraction and treatment systems. Alternatives 3 A and 3B, combining expedited hot
spot extraction and treatment with long-term groundwater extraction and treatment, would contribute
greatly to the long-term effectiveness of the remedial system.
• Reduction in Toxicitv. Mobility, or Volume via Treatment via Treatment
Alternative 1, no further action, does not use treatment to reduce toxicity, mobility, or volume of the
groundwater contaminants. Contaminant migration would continue because the groundwater would
not be contained.
Alternatives 2A and 2B would both use treatment to provide a reduction of toxicity, mobility, and
volume of the contaminated groundwater present at the Site. Because both expedited response action
alternatives would extract groundwater at the same rate, the reduction of toxicity, mobility, and
volume of contaminants in the groundwater hot-spot areas would be similar.
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Alternatives 3A and 3B employ long-term extraction and treatment systems to further reduce the
toxicity, mobility, and volume of contaminated groundwater. Sludge from precipitation and filtration
processes for Alternative 3A would all have to be disposed of off-sUe. In Alternatives 2B and 3B,-
groundwater treatment would be conducted off-site.
• Short-Term Effectiveness
Alternative 1, no further action, does not include any active remediation, therefore, it does not present
an additional risk to the community or workers resulting from activities at the Site.
All of the action alternatives, Alternatives 2A, 2B, 3 A, and 3B, would require the installation of
extraction wells. Alternatives 2A and 3 A would treat the groundwater on-site, while Alternatives 2B
and 3B would transport untreated groundwater to a POTW for treatment. All of the action
alternatives present some risk to on-site workers through dermal contact and inhalation from
construction and groundwater sampling activities, which can be minimized by utilizing proper
protective equipment.
• Implementabilitv
Alternative 1, no further action, would be the easiest alternative to implement, and it would only
require a public awareness program and monitoring. The remaining alternatives would require the
construction of treatment systems, extraction systems, and pipelines. Most services and materials
required for the implementation of any of these remedial alternatives are readily available. All
potential adverse impacts to wetlands from remedial activities would be minimized to the maximum
extent practicable.
Alternatives 2A and 3A would require constructing or procuring a biological treatment system.
Equipment used in these alternatives is readily available from vendors. Initial start-up of the system
would require close monitoring to ensure that the system is operating efficiently and that effluent
standards are being met. Transportation and disposal of the dewatered process sludge would be
easily implementable using commercially-available equipment. Sampling for treatment effectiveness
and groundwater monitoring would be necessary, but can be easily implemented.
In addition to monitoring the quality of the treated groundwater prior to surface water discharge, for
Alternatives 2A and 3 A, these alternatives would require monitoring of surface water and sediments
to evaluate the impact on the wetlands. Meeting permit requirements for a surface water discharge
would also be more difficult than for groundwater reinjection because water quality standards for
surface water, in general, would be more stringent than MCLs. For groundwater reinjection options,
discharge trenches would need to be constructed. This would require testing of the soil to determine
a suitable location that would allow for adequate drainage of treated groundwater back into the
aquifer. Because many till lenses exist on-site and a homogeneous sand layer downgradient of the
source and upgradient of the wetlands may be difficult to locate, additional studies would need to be
.performed in the pre-design phase to identify suitable locations for the discharge system. Provided
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a location can be determined in the pre-design stage, groundwater reinjection would be easier to
implement than surface water discharge, based upon the considerations noted above.
Alternatives 2B and 3B, although treating groundwater off-site, would require a pilot study to ensure
that the discharge would not adversely impact the biomass, effluent quality, or the sludge generation
of the Ogdensburg POTW. If the pilot study indicates that the POTW system is incapable of handling
the contaminated groundwater from the Site, on-site treatment would be the only viable expedited
response action alternative. Approval would also be needed from the City Council of Ogdensburg
to accept contaminated groundwater from the Site. (Initial consultations between EPA and the City
of Ogdensburg has indicated that approval would be likely.) In addition, the contaminated
groundwater collected at the Site would have to comply with the POTW's pretreatment requirements.
%
In Alternative 3B, the construction of a 24,000-foot force main to connect to the existing sewer line
would require an additional survey and design, as well as access agreements with impacted property
owners. Approval would also be needed from St. Lawrence County and the Bridge and Port
Authority for construction of the force main along roadways and in areas near a railroad easement.
Cost
Cost estimates were developed for each of the remedial alternatives and treatment and disposal
options. The present-worth costs are calculated using a discount rate of 5 percent. Present-worth
costs for the no-action alternative, Alternative 1, are based on a 30-year time interval. Present-worth
costs for Alternatives 2A and 2B are based on a 3-year time interval, while present-worth costs for
Alternatives 3 A and 3B are based on a 10-year time interval. The estimated capital, annual operation
and maintenance (O&M), and present-worth costs for each of the alternatives are presented below.
Alternative
1
2A
2B
3A
3B
Capital Cost
$0
$711,000
$384,000
$1,191,000
$2,682,000
Annual Cost
$80,000
$162,000
$675,000
$162,000
to $189, 000
$566,000
to $675,000
; Present Worth: -...:
$1,300,000
$1,152,000
$2,220,000
$2,029,000
$7,059,000
The capital costs for all action alternatives include costs for a groundwater extraction system, piping,
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and building. The capital costs for Alternatives 2A and 3 A also include costs for the groundwater
treatment system and groundwater reinjection system. The capital costs for Alternatives 2B and 3B
include the costs for conducting a 100-day pilot test, storage tanks, and leak detection. The capital
costs for Alternative 3B also include the costs for a 24,000 feet of 6 inch diameter underground
piping. Annual 0 & M costs for Alternatives 2B and 3B are based on estimates obtained in
consultations with the City of Ogdensburg.
All annual costs for all alternatives include groundwater and surface water monitoring. Annual costs
for all action alternatives include electrical costs for groundwater pumping and maintenance of the
groundwater extraction system. Annual costs for Alternatives 2A and 3 A include costs to maintain
the bioreactor and for sludge disposal. Annual costs for Alternatives 2B and 3B include costs for
trucking of collected groundwater and disposal fees to the POTW.
• State Acceptance
NYSDEC concurs with the selected remedy.
• Community Acceptance
Comments received during the public comment period indicate that the public generally supports the
selected remedy. Comments received during the public comment period are summarized and
addressed in the Responsiveness Summary, which is attached as Appendix V to this document.
SELECTED REMEDY
Based upon consideration of the requirements of CERCLA, the detailed analysis of the alternatives,
and public comments, EPA and NYSDEC have determined that Alternative 3 A is the appropriate
remedy for the Site, because it best satisfies the requirements of CERCLA §121, 42 U.S.C. §9621,
and theNCP's nine evaluation criteria for remedial alternatives, 40 CFR §300.430(e)(9).
The major components of the selected remedy include extracting contaminated groundwater in the
vicinity of the former cell disposal area, specifically "hot spots" in the shallow aquifer and
contaminated groundwater in the bedrock aquifer, on an expedited basis, ex-situ biological treatment
of the extracted groundwater, and reinjection of the treated groundwater into the aquifer provided
that a suitable location for reinjection can be identified during preliminary design. If groundwater
reinjection is not feasible, treated groundwater will be discharged to a surface water body. Other
components of the selected remedy include long-term monitoring of groundwater and surface water;
and taking steps to secure institutional controls (the placement of restrictions on the installation and
use of groundwater wells at the Site and limitations on the future use of the Site). In addition, water
level and monitoring data will be evaluated in and around the leachate monitoring/collection system
to determine if additional leachate collection is necessary. Any collected leachate associated with the
leachate monitoring/collection system will be addressed as part of the groundwater remediation
activities.
22
-------
Also, a hydrologic and vegetation monitoring program will be undertaken to monitor impacts to
potentially affected wetlands, and mitigative actions will be implemented to minimize any destruction,
loss, or degradation of wetlands resulting from construction activities, groundwater drawdown, or
contaminant migration to the maximum extent practicable.
Alternative 3A was selected over Alternative 3B principally because it was believed to be more
protective of the wetlands and more cost-effective. However, if the results from the hydrologic and
vegetation monitoring program indicate that failing to reinject the treated groundwater will not
adversely impact the wetlands, and since the costs for disposal of collected leachate and contaminated
groundwater at the Site are based on estimates obtained from the City of Ogdensburg, EPA will
reevaluate these costs to determine if off-site treatment and disposal is more cost-effective than on-
site treatment and disposal. If off-site treatment and disposal is found not to adversely impact
wetlands and is more cost-effective than on-site treatment and disposal, then Alternative 3B may be
implemented in lieu of Alternative 3 A.
Approximately concurrent with the action to remediate groundwater hot-spots, a study will be
conducted to determine if natural attenuation can reduce the remaining contaminants to MCLs within
an acceptable time frame. Obtaining sequential rounds of groundwater quality data will allow a
determination as to whether the plume has reached equilibrium conditions or continues to attenuate.
The study will assess the intrinsic capability of the aquifer to naturally reduce contaminants.
If, after implementing hot-spot groundwater remediation, groundwater monitoring results continue
to exceed MCLs, and if the results of the study indicate that natural attenuation has little potential in
reducing groundwater contamination to MCLs, a long-term action would be implemented. The long-
term action would address contaminated groundwater above MCLs in the vicinity of the former cell
disposal area. In addition to biological treatment, the long-term action in the selected alternative may
include groundwater pretreatment to reduce the concentration of inorganics in extracted
groundwater.
The selected remedy is believed to be able to achieve the ARARs more quickly, or as quickly, and
at less cost than the other alternatives. Therefore, the selected remedy will provide the best balance
of trade-offs among alternatives with respect to the evaluating criteria. EPA and the NYSDEC
believe that the selected remedy will be protective of human health and the environment, comply with
ARARs, be cost-effective, and utilize permanent solutions and alternative treatment technologies or
resource recovery technologies to the maximum extent practicable. The selected remedy also will
meet the statutory preference for the use of treatment as a principal element.
STATUTORY DETERMINATIONS
As was previously noted, CERCLA §121(b)(l), 42 U.S.C. §9621(b)(l), mandates that a remedial
action must be protective of human health and the environment, cost-effective, and utilize permanent
solutions and alteinative treatment technologies or resource recovery technologies to the maximum
23
-------
extent practicable. Section 121(b)(l) also establishes a preference for remedial actions which employ
treatment to permanently and significantly reduce the volume, toxicity, or mobility of the hazardous
substances, pollutants, or contaminants at a site. CERCLA §121(d), 42 U.S.C. §962l(d), further
specifies that a remedial action must attain a degree of cleanup that satisfies ARARs under federal
and state laws, unless a waiver can be justified pursuant to CERCLA §121(d)(4), 42 U.S.C.
§9621(d)(4).
For the reasons discussed below, EPA has determined that the selected remedy meets the
requirements of CERCLA §121,42 U.S.C. §9621.
Protection of Human Health and the Environment ,
The selected remedy, Alternative 3 A, would be more protective of human health and the environment
than any of the other alternatives because it addresses the entire plume of groundwater contamination,
and treated groundwater would be reinjected to groundwater or discharged to surface water, which
would maintain water table levels in the affected wetland areas.
Compliance with ARARs
The selected remedy would be the most effective in achieving ARARs, since it best ensures that
groundwater contaminant concentrations would be reduced to levels below MCLs and it provides the
most protection for wetlands.
A summary of chemical-specific ARARS for specific contaminants is presented in Table 1. The
following Action-, chemical-, and location-specific ARARs will be complied with during
implementation.
i
Action-specific ARARs:
• National Emissions Standards for Hazardous Air Pollutants
• 6 NYCRR Part 212, Air Emission Standards
• 6 NYCRR Part 373, Fugitive Dusts
• State Permit Discharge Elimination System
• Resource Conservation and Recovery Act
Chemical-specific ARARs:
• .. Safe Drinking Water Act Maximum Contaminant Levels and Maximum Contaminant Level
24
-------
Goals (MCLs and MCLGs, respectively, 40 CFR Part 141)'
• 40 CFR 50, Air Quality Standards
• 6 NYCRR Part 257, Air Quality Standards
• 6 NYCRR Parts 700-705 Groundwater and Surface Water Quality Regulations
• 10 NYCRR Part 5 State Sanitary Code
Location-specific ARARs:
s
• Clean Water Act Section 404, 33 U.S.C. 1344
• Fish and Wildlife Coordination Act, 16 U.S.C. 661
• National Historic Preservation Act, 16 U.S.C. 470
• New York State Freshwater Wetlands Law ECL, Article 24, 71 in Title 23
• New York State Freshwater Wetlands Permit Requirements and Classification, 6 NYCRR
663 and 664
• New York State Endangered and Threatened Species of Fish and Wildlife Requirements, 6
NYCRR 182
Other Criteria, Advisories, or Guidance To Be Considered:
i
• Executive Order 11990 (Protection of Wetlands)
• Executive Order 11988 (Floodplain Management)
• EPA Statement of Policy on Floodplains and Wetlands Assessments for CERCLA Actions
• New York Guidelines for Soil Erosion and Sediment Control
• New York State Sediment Criteria, December 1989
• New York State Air Cleanup Criteria, January 1990
• SDWA Proposed MCLs and MCL Goals
• NYSDEC Technical and Operational Guidance Series 1.1.1, November 1991
25
-------
Cost-Effectiveness
The selected remedy provides effectiveness proportional to its cost. The total capita! and present-
worth costs for the selected remedy are estimated to be $1,191,000 and $2,029,000, respectively.
Utilization of Permanent Solutions and Alternative Treatment Technologies to the Maximum Extent
Practicable
The selected remedy utilizes permanent solutions and alternative treatment technologies to the
maximum extent practicable. The extraction and subsequent treatment of groundwater will
permanently and significantly reduce the toxicity, mobility, and volume of contaminants in the
groundwater. The selected remedy provides the best balance of trade-offs among the alternatives
with respect to the evaluation criteria.
Preference for Treatment as a Principal Element
The statutory preference for remedies that employ treatment as a principal element is satisfied by
treating the contaminated groundwater in the vicinity of the former cell disposal area. *
DOCUMENTATION OF SIGNIFICANT CHANGES
There are no significant changes from the selected alternative presented in the Proposed Plan.
26
-------
APPENDIX I"
FIGURES
Regional Site Location Hap
Site Location Hap
Site Plan
-------
i \ 'o
v 1 i I
-A r -^ttfszj i .-\xlz.-r---~i'~i . "•
s£
'6/r"
/i :•;-: V-^
/{ --.- ^' t^
ih --::^i/ -\- •
SOURCE:
USGS 7.5 Minuts Series Topographic Map.
Quadrangle Lisbon. New York
2000
SCALE OF FEET
4000
REV. Ht. ' Otfl lOCSCOTnONOF REVUIONl REV. IT EMU) ICHOm WWOI
u, w«g | DRAWN BY: T. mkRTOSp*7^ OB • S •
TECHNOLOGY
I CORPORATION
FIGURE 1
SITE LOCATION MAP
Remedial Investigation Report
Sealand Restoration Site
U. S. ENVIRONMENTAL PROTECTION AGENCY
NEW YORK. NY
DECEMBER 1994
529504
HEN.
OOAWIMC NUUBCR
SEAl-003 P-4
-------
Known Landspread Areas
Propeny Boundary
Woodiands/Wetlands Boundary
-------
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SURPACC SOIL CONCCHTfUTIOHS
DETECTED VOUTILC AMD SCUI VOUTILC
ORGANIC COUPOUMOS
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-------
TABLE 2
SUMMARY OF CONSTITUENTS OF CONCERN
IN ENVIRONMENTAL MEDIA .
Remedial Investigation Report
Sealand Restoration Site
\ \.V '• '' vC;-f ^'* - WEIGHT:
CONSTITUENT:'-' '»!- * OF;;:*
- , OF CONCERN '$£'$1 EVIDENCE
luamnla
Arsenic A
Barium
Beryllium B2
Cadmium Bl
Chromium A
Lead B2
Manganese D
Mercury • D
Nickel
Selenium D
Vanadium
Pesticide* & PCB't
alpha-Chlordane B2
Ramma-Chlordane B2
Volatile Organic*
Acetone D
Benzene A
Bromochloromethane D
Cbloroeihane
1.1.1-Trichloroetbane D
Trichloroeihene C-B2
Vinyl Chloride ' A
5*fn|Yo|atlI* Organic^
Benzo(a)anthracene B2
Benzo(b)l1uoranthene B2
Benzo(a)pyrene B2
4-chloro-3-methylphenol . ' -
4-Methylphenol C
Phenaothrene D
Penlachloropbeaol B2
^.CURRENT tANDlJSE-^r
SURFICIAL
X
X
X
X
X"
X
X
X
X
X
X
X
X
X"
SURFACE
:• WATER,
X
X
X
X
X"
X
X
X
X
X"
X"
X"
X
SEDIMENT
X
X
X
X
X
X"
X
X
X
X
X"
X"
SlS^K'f'-FutURE 'LAND'-'USE'-^
SURFIC1AL;
X
X
X
X
X"
X
X
X
X
X
-
X
X
X
X"
3ROUNOWATE
(COMBJNEO)
X
X
• ;
X*
X"'
X
x- •
X"
X"
X
X*
SURFACE
X
x •
X
X
x~
X
X
X
X
• X"
X"
X"
X
r-'-''\'v/-. •' •'•'.'•.
SEDIMENT
X
X
X
X
X
X"
X
X .
X
X
X"
X"
X * - By default, all class A human carcinogens are considered to be COC In the risk assessment.
X " = These COCs do not have toxicity values but were detected >S% frequency in a medium of concern.
-------
TABLE 3
SUMMARY OF CURRENT ON-SITE TRESPASSER EXPOSURE PATHWAYS
Remedial Investigation Report
Sealand Restoration Site
;:;^j^«mfg
Groundwater
Soil
Sediment
Surface Water
f^;^o|^^^j
Ingestion/Dermal Contact
Ingestion
Dennal Contact
Inhalation of Dusts/VOCs
Ingestion
Dermal Contact
Ingestion
Dermal Contact
Ingestion of Pish
•" ' vf '-,•••. '-^-l ^fjM|y$w>! Y£ yj'|' ,,-
None
Adult/Older Child
Adult/Older Child
Adult/Older Child
Adult/Older Child
Adult/Older Child
Adult/Older Child
Adult/Older Child
Adult/Older Child
*$^*$*j&$i%.
No
Yes
Yes
No
Yes
Yes
Yes
Yes
No
VliaSgf^^^^^f
All on-site wells are abandoned. There are
no on-site personnel.
There are no on-site personnel but
trespassers may incidentally ingest surface
soils.
There are no on-site personnel but
trespassers may have dermal contact with
surface soils.
Site is heavily vegetated.
Trespassers may incidentally ingest
sediments.
Trespassers may have dermal contact with
sediments.
Trespassers may incidentally or deliberately
ingest surface water.
Trespassers may have dermal contact with
surface waters.
There are no permanent bodies of surface
water on site. Wetlands are seasonal, low
flow, intermittent streams.
-------
TABLE 4
SUMMARY OF FUTURE ON-SITE/OFF-SFTE RESIDENTIAL EXPOSURE PATHWAYS
Remedial Investigation Report
Sealant) Restoration Site
g^iMed&m (^
Groundwaur
Soil
Sediment
Surface Water
Ingcstion
Dermal Contact
Inhalation
Ingcslion
Dermal Contact.
Inhalation of Dusls/VOCs
*
Ingestion
Dermal Contact
Ingestion
Dermal Contact
Adult/Young Child
Adult/Young Child
Aduli/Young Child
Adult/Young Child
Adult/Young Child
Adult/Young Child
'
Adult/Young Child
Adult/Young Child
Adult/Young Child
Adult/Young Cliild
Yes
Yes
Yes
Yes
Yes
No
Yes
Yes
Yes
Yes
Potential future use of grouodwater as a •
drinking water source.
Potential future use of groundwater for
domestic uses, i.e., bathing, cleaning,
laundiy.
Potential future use of groundwater for
bathing/showering.
Potential future use of property as
residential area.
Potential future use of property as
residential area.
Low concentration of non-volatile and semi-
volatile COCs in surficlal soils indicate on-
site Inhalation to be a minor route of
exposure at this site.
Incidental ingestion of sediment during
. play/hiking activities.
Dermal contact with sediment during
play/liiking activities.
Incidental ingestion of surface water during
'play/liiking recreational/activities.
Dermal contact will) surface water during
play/liiking recreational activities.
-------
TAOLE 5
CARCINOGENIC AND NONCARC1NOCEMC EFFECTS
or CONSTITUENTS OF CONCERN
Remedial Iiwtillplloa Raparl
Seahtnd Reiteration Sll«
.:•-• . -;--^-.<^"^yg
Jrtoffaatet
Arsenic
Qirium
Beryllium ,
'tdmtum
hfomium
Copper
Mang.n<«
Mercury
Nickel
Selenium
medium
,UK
Pniiddti & fCO'S
alpha -Chief da ne
S.mma.Ch.ordaoe
-
Acetone
erttcnc
romocfaloromeUune
CtUoroclhine
t.l.l-Triehtoroethine
richJoroethenc
Vmyl Chloride
S^LVMto
Rcnzo(*>nthrtecne
)eittoCb)nuonnihcne
Ben^pv™
3 ii(l -ethyl hexyOphlh* l*ie
4l
Phcr-nU^K
Pentachlo.oi.hmol
fil|
^MS**
7440-38-2
7440-39-3
7440-41-7
7440-43-9
18540-29-9
7440-504
7439-96-5
7439-97-6
7440-02-0
,7782-49-2
7440-42-2
7440-6&--6
57-74-9
57-74-9
67-64-1
71-43-2
74-97-5
75-00-3
71-55-6
75-01-6
75-OM
56-55-)
205-99-2
50-11-1
117-81-7
59-50-7
106-14.1
85-014
17-86-3
H
W'™$
A
NA
B2
Bl
A
D
D
D
budco^le
0
NA
D
B2
B2
D
A
D
NA
0
C-B2
A
B2
B2
B2
B2
NA
C
o
B2
IIP
5rP:??-'.r^
I.7SE«00 i
NA
4.10E+00 j
NA
NA
NA
NA
NA
NA
NA
NA
NA
UOE+00 i
i.ioe+oo i
NA
2.90E-02 i
NA
NA
NA
I.IOE-02 c
I.90E-K» h
7JOE-OI f
7JOE-OI f
7.30E400 i
l.4ȣ4)2
NA
NA
NA
UflE-01
Jta'.\'^h
InhiUtknV
NA
MOE+00 i
6JOE400 i
4JOE+OI i
NA
NA
NA
8.40E-OI h
NA
NA
NA
I.29E400 i
I.29E+00 i
NA
2.90E-OZ i
NA
NA
NA
6JOQE43 e
3.00EOI h
NA
NA
NA
NA
NA
NA
NA
NA
^l^unwr^f--^'
liwi^T^^^p
^S{fe^fe^''A
uing cancer
unglumon,
yautumon.
nd iU sites combined.
upinlotytnci
dptnlory system tumor
epatocellular carcinom*
cptioecUuUr cateinooM
t*1*mu
.ung, liver tumors
'oreslMnoch.
tquLimous cell papiltonui.
tnd ctrcinenui
•deiwnui. or ctrcinonu
Hq-toocllulir
ftdenoRu. or ekreinonu
Wi&
*;°n*f.y^
3.00E44 i
7.00C-02 i
I.OOE-03 i
5.00E-04 i
5.00E-03 i
3.7IE-02 h
I.40E-OI i
3.00E44 h
2.00E-02 1
5.00C-03 i
7.00E-03 h
3.00E-OI i
6.00E-05 i
6.0QE-05 i
I.OOE-0 1 i
3.00E-04 e
NA
NA
Wilhilnvm' i
6.00E-0] e
NA
NA
NA
NA
J.OOE-01 i
NA
5.00E-03 h
NA
3.00C-02
5.2?.^^ S
sS*!W!?"3
3.ME-04 1
I.43C-04 h
NA
Pending i
Pending i
NA
I.43E-05 i
8.57E-05 h
Pending i
NA
NA •
NA
NA
NA
NA
NA
NA
2.ME400 1
2.KE41 c
Pending i
NA
NA
NA
NA
NA
NA -
Inadequate
NA
Pending
li
.3
1
100
10
500
looo
300
3
100
1000
1000
1000
1000
300
3000
1000
100
[cnloris,
nd possible vMcuUr
Acixuttl blood pressure
otdvenedcfTecU
puOetiM zvotcuiuna,
Defeated blood tmsure
""""^
ulniniailnit iniuiton
mptirmentof
OTVDUJ fyiiem.
dnevcflecb
Domed tody
indoninxctihl
bfllCSI leJCQBIII
Deereued cryihrecyte
niperadde alumna se cone.
eginuil liver nypertrapuy
ejMfial tiver hypertrajniy
Incnaaod liver
wd kidney writhu
andnnhromicnv
DdayaJfcUlonlCaUoo
ivcrloodetr/
Liver toneity
iMrcuodrcUlrn
tvervmsht
Liver indkkhey
Miholocv
luacquile -EPA R1D/IUC WorkCioupcyenniotdlobciMdojiuiefcrdcrivilioiiihil infonnalion
NA - Nol .vnkbloMtfib lime • • -
Polling •UAdernviewbj EPA wafkiroan
WiiMnwn-Wnhdnvmby EPA R1DAUC Work Cmip
Sourca: «» EPA cVlviramenld Crilim «d Auaiovml Office. July 29.1994
f- EPA ECAO. EPAMOO"X-«3At9. July 1993.
h » Hallh EOoai AumaeM Sumnuy Table* (HEAST). OERR 9200.«-30)(93-l). •
-------
TABLE 6
SUMMARY OF CARCINOGENIC RISKS AND NON-CARCINOGENIC HAZARDS
- CURRENT LAND USE REASONABLE MAXIMUM EXPOSURE -
Remedial Investigation Report
Sealand Restoration Site
-,:>:. ••••:•. ^^'t^^iM^Ms^P^&^ff^i
'. ; ?-:& ii?^i^B@sS«S«sf
:'i>?«:*S>S:...S:> ,-MS*-
:H<*?. ^,!~Vf ->? • „"*-" !--?v >.' r
CARCINOGENIC RISK \&£Z
„ Adult"
^» * " * r"^VV''"X
^v v. Older Child ^x',>^';| X •*
•"/•-.^ ^v.,-' - '* -',
> - > •*.;.,-*,* >,
NON-CARCINOCENIC HAZARD \ .'.
i^'i-I'Ajilllt-', V i~''v- Oldtr Child *\';-!':y'^
ON-SITE TRESPASSER
SOIL
Ingesdon
Eternal Contaa
TOTAL
SURFACE WATER
Ingesdon
Dermal Contaa
TOTAL
Ingesdon
Dermal Contaa
TOTAL
TOTAL
RISK /HAZARD
2J1E-06
NA
2.51E-06
5.26E-07
8.55E-06
9.08E-06
2.78E-06
NA
2.78E-06
1.44E-05
2J1E-06
NA
2.51E-06
4.21E-07
6.45E-06
6.87E-06
2.78E-06
'NA
' 2'78E^6
1.22E-05
1.21E-02
NA
1.21E-02
6.71E-03
6.28E-03
' 1.30E-02
1.60E-04
2.25E-02
4.76E-02
4.85E-02
NA
4.85E-02
2.6SE-02
2J7E-02
5.05E-02
8.92E-02
6.02E-04
8.98E-02
1.89E-01
-------
TABLE 7
SUMMARY OF CARCINOGENIC RISKS AND NON-CARCINOGENIC HAZARDS
- FUTURE LAND USE REASONABLE MAXIMUM EXPOSURE -
Remedial Investigation Report
Sealand Restoration Site
SOIL
Ingestion
Dermal Contact
TOTAL.
1.22E-05
NA
1.22E-05
2.28E-05
NA
2.28E-05
4.7IE-02
NA
4.71E-02
4.40E-01
NA
4.40E-01
GRQUNDWATER
Ingestion
Dermal Contact
Inhalation
TOTAL
2.07E-04
1.02E-06
1.88E-06
2.10E-04
9.6SE-05
3.46E-07
1.75E-06
9.86E-05
5.76E+02
2J3E+00
NA
5:78E+02
U4E-KJ3
3.97E+00
NA
1.35E+03
SURFACE WATER
Ingestion
Dermal Contact
TOTAL
S.26E-07
8_SiE-06
9.08E-06
9.82E-07
9.47E-06
1.05E-05
«.71E-03
6^8E-03
1.30E-02
6.26E-02
3.4SE-02
9.74E-02
SEDIMENT
Ingestion
Dermal Contact
3.48E-06
NA
1JOE-05
NA
2.23E-02
1.60E-04
4.16E-01
8.83E-04
TOTAL
3.48E-06
1.30E-05
2.25E-02
4.17E-01
-------
TABLE 8
CONSTITUENTS OF ECOLOGICAL CONCERN
Remedial Investigation Report
Sealand Restoration Site
Surficial Soils
Surface Water
Sediment
Inorganics
Arsenic
Lead
Manganese
Pesticides
Heptachlor
4,4'-DDE
Endrin
Endosulfan n
4,4'-DDD
Endosulfan Sulfate
4,4'-DDT~
Methoxychlor
Endrin Ketone
PCBs
Aroclor -1254
Semi-Volariles
Fluorene
Phenanthrene
Anthracene
Fluoranthene
Pyrene
Benzo(a)anthracene
Benzo(a)pyrene
Chiysene
Di-n-butyiphthalate
Inorganics
Aluminum
Pesticides
Endrin
Inorganics
Arsenic
Cadmium
Manganese
Mercury
Pesticides
Heptachlor Epoxide
-------
APPENDIX III
ADMINISTRATIVE
RECORD INDEX
-------
10/13/95
Index Chronological Order
SEALAND RESTORATION INC. SITE, OPERABLE UNIT #2 Documents
Page: 1
- Docunent Nunber: SLR-001-19U To 1914
Title: Pages 1-4 of non-site specific guidance document
Type: OTHER
Author: None: none
Recipient: Hone: none
Parent: SLR-001-1909
Date: 01/01/01
Docunent Hurfcer: SLR-001-2372 To 2386
Title: Administrative Order. Index Kucber II CERCLA-93-0213
Type: LEGAL DOCUMENT
Author: None: none
Recipient: Hone: none
Date: 10/10/10 Confidential
Document Wurber: SLR-001-0003 To 0092
Date: 01/01/92
Title: Final Work Plan, Remedial Investigation/Feasibility Study, Sea I and Restoration Inc. Site,
Town of Lisbon, Mew York, Volume I, Sections 1.0 through 8.0
Type: PLAH
Author: Watt, Maria D.: IT Corporation
Recipient: Kuo, Ming: Ebasco Services
none: US EPA
Sachdev, Dev: Ebasco Services
Document Number: SLR-001-0093 To 0193
Date: 01/01/92
Title: Final Work Plan, Remedial Investigation/Feasibility Study, Sealand Restoration Inc. Site,
Town of Lisbon, Mew York, Volume II, Tables and Figures
Type: PLAH
Author: none: IT Corporation
Recipient: none: Ebasco Services
none: US EPA
-------
10/13/95 Index Chronological Order Page: 2
SEALAND RESTORATION INC. SITE, OPERABLE UNIT #2 Documents
Document Number: SLR-001-0001 To 0002 . Date: 01/07/92
Title: (Letter forwarding the attached Final Work plan for the Sealand Restoration Inc. site)
Type: CORRESPONDENCE
Author: Sachdev Dev: Ebasco Services
Recipient: Hacker, Jill: US EPA
Nines, Robert: US EPA
Docunent Nurber: SLR-001-1905 To 1908 ' Date: 02/16/95
Title: (Letter expressing objections to the conclusions presented in the revised Remedial Investigation
Report submitted in January, 199S, and providing comments of the NYSDEC and HYSOOH concerning .
the report)
Type: CORRESPONDENCE
Author: Eastman, ICathryn: NY Dept of Environmental Conservation
Recipient: Munes, Robert: US EPA
Docunent Number: SLR-001-0194 To W03 " - . . Date: OA/01/95
Title: Final Supplemental Remedial Investigation Report, Sealand Restoration Inc. Site, Town of Lisbon,
New York, Volume I
Type: REPORT
Author: none: Ebasco Services
Recipient: none: US EPA
Docunent Nunber: SLR-001-0404 To 0797 Date: 04/01/95
Title: Final Supplemental Remedial Investigation Report, Sealand Restoration Inc.-Site, Town of Lisbon,
New York, Volume II
Type: REPORT
Author: Ebasco Services
Recipient: none: US EPA
-------
10/13/95 Index Chronological Order . Page: 3
SEALAND RESTORATION INC. SITE, OPERABLE UNIT #2 Documents
Document (lumber: SLR-001-0798 To 1576 Date: 04/01/95
Title: Final Supplemental Remedial Investigation Report, Sealard Restoration Inc. Site, Town of Lisbon,
Neu York, Volume III
Type: REPORT
Author: none: Ebasco Services
Recipient: none: US EPA
Docunent Umber: SLR-001-1577 To 1904 Date: 04/01/95
Title: Final Supplement Remedial Investigation Report, Sealand Restoration Inc. Site, Town of Lisbon,
Neu York, Volume IV
Type: REPORT
Author: none: Ebasco Services
Recipient: none: US EPA
Docunent Hurtber: SLR-001-1909 To 1913 Date: 05/22/95
Title: (Letter providing NTS Comments on Draft Supplemental FS, Sealand Restoration)
Type: CORRESPONDENCE
Author: Eastman, Kathryn: NY Dept of Environmental Conservation
Recipient: Nunes, Robert: US EPA
Attached: SLR-001-19U
Document Mutber: SLR-001-1915 To 1915 Date: 06/20/95
Title: (letter providing the notice that the "Sealand Croup" has completed all removal actions required
under the Adninistrative Order)
Type: CORRESPONDENCE
Author: Witkouski. John: US EPA
Recipient: Rothenberg, Eric: Morgan, Lewis I Bockius
-------
10/13/95 Index Chronological Order Page:
SEALAND RESTORATION INC. SITE, OPERABLE UNIT #2 Docunents
Docunent Number: SLR-001-1916 To 1927 Date: 07/01/95
Title: Superfund Proposed Plan. Sea.land Restoration Site, Town of Lisbon, St. Laurence County, New
York
Type: PLAN
Author: None: US EPA
Docunent Nuifcer: SLR-001-1928 To 2221 Date: 07/01/95
Title: Final Supplemental Feasibility Study Report, Sealand Restoration Inc. Site, Town of Lisbon,
New York
Type: REPORT
Author: Sachdev, Dev: Ebasco Services
Watt, Maria: IT Corporation
Document Nurfcer: SLR-001-2222 To 2224 Date: 07/05/95
Title: (Letter providing comments on Sealand Restoration Site No 6-45-014 Superfund Proposed Remedial
Plan)
Type: CORRESPONDENCE
Author: Smith, David, P.: NY Dept of Environmental Conservation
Recipient: Nunes, Robert: US EPA
Docunent Number: SLR-001-2225 To 2225 . Date: 07/10/95
Title: (Letter regarding the Leachate Removal free Collection System)
Type: CORRESPONDENCE
Author: O'Toole, Michael, J., Jr.: NY Dept of Environmental Conservation
Recipient: Callahan, Kathleen: US EPA
Docunent Number: SLR-001-2226 To 2226 Date: 07/14/95
Title: (Letter regarding the Sealand Restoration Proposed Plan)
Type: CORRESPONDENCE
Author: Singennan, Joel: US EPA
Recipient: Smith, David, P.: NY Dept of Environmental Conservation
-------
10/13/95 Index Chronological Order Page: 5
SEALAND RESTORATION INC. SITE, OPERABLE UNIT *2 Documents
• Document Number: SLR-001-2227 To 2227 Date: 07/19/95
Title: (Letter of understanding regarding the approval of Proposed Remedial Action Plan)
Type: CORRESPONDENCE
Author: O'Toote, Michael, J., Jr.: NY Dept of Environmental Conservation
Recipient: Callahan, Kathleen, C.: US EPA
Document Nutber: StR-001-2228 To 2228 Date: 07/19/95
Title: (Letter regarding the disposition of the contaminated water that is present in the leachate
room" tor ins system at the Sea I end Restoration Site)
Type: CORRESPONDENCE
. Author: Singerman, Joel: US EPA
Recipient: Rider, Gerald, Jr.,P.E: NY Dept of Environmental Conservation
Document Nuiber: SLR-001-2229 To 2229 Date: 08/08/95
Title: (Letter regarding the discontinuation of bottled water delivery)
Type: CORRESPONDENCE
Author: Uatkoff, Judith, A.: Morgan, Lewis I Bockius
Document Nu*er: SLR-001-2230 To 2231 Date: 08/28/95
Title: (Letter providing State Coraments on Draft ROD)
Type: CORRESPONDENCE
Author: Eastman, Kathryn: NY Dept of Environmental Conservation
Recipient: Nines, Robert: US EPA
Document Nuifcer: SLR-001-2232 To 2371 Date: 09/29/95
Title: Record of Decision, Sealand Restoration Site, Town of Lisbon, St. Lawrence County, Hew York
Type: REPORT
Author: None: US EPA
Recipient: None: none
-------
APPENDIX IV
STATE LETTER OF
CONCURRENCE
-------
DIRECTOR'S OFFICE
Fax:518-485-84CM
Sep "
Post-it* Fax Note 7671
To
New York State Department of Environments
50 Wolf Road, Albany, New York 12233-7010
SEP 28 1995
Michael D. Zagata
Commissioner
Ms. Kathleen Callahan
Director
Emergency & Remedial Response Division
U.S. Environmental Protection Agency
Region TT - 290 Broadway
New York, NY 10007-1866
Dear Ms. Callahan:
RE: Sealant! Restoration (Site No.: 6-45-014)
Record of Decision
The New York State Department of Environmental Conservation has reviewed the record of
decision for. the Sealand Restoration Site. The Department concurs with the selected remedy of
Alternative 3A, as it is detailed in the above-referenced document
If you have any questions, please contact Ms. Kalhryn Eastman, of my stall, at
(518)457-5677.
Sincerely,
fl
^<_>tichael J. OToole, Jr.
/ Director
Division of Hazardous Waste Remediation
-------
APPENDIX Y
RESPONSIVENESS
SUMMARY
-------
APPENDIX V
RESPONSIVENESS SUMMARY
Sealand Restoration Superfund Site
INTRODUCTION
A responsiveness summary is required by Superfund regulation. It provides a summary of citizens'
comments and concerns received during the public comment period and the United States
Environmental Protection Agency's (EPA's) and the New York State Department of Environmental
Conservation's (NYSDEC's) responses to those comments and concerns. All comments summarized
in this document have been considered in EPA's and NYSDEC's final decision for selection of a
remedial alternative to address the groundwater contamination at the Sealand Restoration site (the
"Site").
OVERVIEW
The public generally supports the preferred remedy, which includes extracting contaminant "hot
spots" in the shallow aquifer and contaminated groundwater in the bedrock aquifer in the vicinity of
the former cell disposal area on an expedited basis, ex-situ biological treatment of the extracted
groundwater, and reinjection of the treated water or discharge to surface water. Concurrent with the
action to remediate groundwater hot spots, a study will be conducted to determine if natural
attenuation could reduce the remaining contaminants to maximum contaminant levels (MCLs) within
an acceptable time frame. If, after implementing hot-spot groundwater remediation, groundwater
monitoring results continue to exceed MCLs in the vicinity of the former cell disposal area, and if
the results of the study indicate that natural attenuation has little potential in reducing groundwater
contamination to MCLs, a long-term groundwater remedial action would be implemented.
The primary concerns that were expressed were related to the water quality at private wells located
in the vicinity of the Site. Specifically, questions were raised about the degree of contamination found
in residential wells and EPA's decision to cease distribution of bottled water to potentially affected
residences1.
Because contaminants found in residential well samples collected early in the remedial investigation (RI)
were also known to be present in on-Site soil or on-Site groundwater, EPA issued a Unilateral
Administrative Order in August 1993 to the potentially responsible parties, requiring that they supply
bottled water for drinking and cooking on a regular basis. This action was taken as a precautionary
measure to ensure that nearby residents would not be exposed to site-related contaminants. Delivery of
bottled water began in September 1993. Subsequent analytical results of residential well samples
collected by EPA and the New York Stale Department of Health (NYSDOH), however, indicated that
contaminated groundwater at the Site has not migrated to and is not impacting residential wells.
Consequently, EPA notified the PRPs that continued distribution of bottled water was no longer required.
Delivery of bottled water was terminated in July 1995.
-------
SUMMARY OF COMMUNITY RELATIONS ACTIVITIES
The remedial investigation (RI) report, feasibility study (FS) report, and Proposed Plan for the Site
were released to the public for comment on July 19, 1995. These documents were made available
to the public in the administrative record file at the EPA Docket Room in Region II, New York and
the information repository at the Lisbon Town Hall. A notice of availability for the above-referenced
documents was published in the Ogdensburg Journal on July 18, 1995. The public comment period
related to these documents was originally from July 19, 1995 to August 18, 1995. However, in
response to several requests from the public to extend the public comment period, it was extended
to September 22,1995. A notice of the extension of the public comment period was published in the
Ogdensburg Journal on August 28,1995.
>
On August 2, 1995, EPA conducted a public meeting at the Hepburn Library in Lisbon, New York
to inform local officials and interested citizens about the Superfund process, to review current and
planned remedial activities at the Site, to discuss and receive comments on the Proposed Plan, and
to respond to questions from area residents and other interested parties.
SUMMARY OF COMMENTS AND RESPONSES
The following correspondence (see Appendix V-a) was received during the public comment period:
• Letter to Joel Singerman, dated August 9, 1995, from Mary Burns Velraque, Director, St.
Lawrence County Environmental Management Council.
• Letter to Robert Nunes, dated September 13, 1995, from James W. Armstrong, Supervisor,
Town of Lisbon.
• Letter to Robert Nunes, dated September 15, 1995, from John Pentilchuk, P. Eng.,
Conestoga-Rovers & Associates Limited.
• Letter to Robert Nunes, dated September 15, 1995, from Jon R.Montan, Jr., Planner III, St.
Lawrence County Environmental Management Council.
A summary of the comments contained in the above letters and the comments provided by the public
at the August 8, 1995 public meeting, as well as EPA's response to those comments, follows.
Letters
Letter to Joel Singerman, doled August 9,1995, from Mary Burns Velraque, Director, St. Lawrence
County Environmental Management Council
Comment #1: Under the preferred alternative, would it be feasible to air strip the acetone
Y-2
-------
Response #1:
out of the groundwater instead of using bioremediation as is proposed?
Would it be more cost-effective?
While air stripping is very effective in removing most volatile organics from
water, air stripping alone would not be effective in removing acetone from the
extracted groundwater because of acetone's high solubility in water and low
Henry's Law Constant, which relates equilibrium concentration of the
chemical in the vapor phase to its concentration in the dissolved phase and
plays an important role in surface water constituent transport and volatiliza-
tion. To address the acetone that is present in the groundwater, the air
stripping unit would need to be significantly oversized and would need to be
combined with other treatment technologies. For this j-eason, air stripping
was not included in any of the alternatives developed in the Proposed Plan.
Comment #2:
Response #2:
Are the operation and maintenance costs annual or spread out over time?
For each of the alternatives that were evaluated, the operation and mainte-
nance cost reflects the estimated annual cost to operate, monitor, and maintain
the respective remedies. The present-worth cost for each of the alternatives
includes the capital cost plus the estimated annual operation and maintenance
cost over the life of the project.
Comment #3:
Response #3:
What will be involved in the study of contaminant natural attenuation?
While the scope of the proposed natural attenuation study will not be
determined until the selected remedy's design phase, EPA envisions that the
investigation would not only include groundwater monitoring, but would
employ methods to evaluate the potential for in-situ biodegradation of the
volatile organics. Since biodegradation requires an electron acceptor, such
as oxygen for aerobic degradation, or nitrate, sulfate, or- methane for
anaerobic degradation, measuring the depletion of these parameters within the
plume via groundwater sampling could indicate that biodegradation is
occurring. One might also evaluate the rate of biodegradation by comparing
the losses of degradable organics to losses of a nonbiodegradable substance
in the plume. Another method to evaluate biodegradation would be the use
of microcosm studies. In these studies, samples of aquifer material and
groundwater would be obtained and maintained at conditions approximating
those found within the aquifer. One or more microcosms would then be
"killed" so that it would serve as an abiotic control. Then, contaminant levels
would be measured overtime to determine biodegradation potential and decay
rates.
V-3
-------
Letter to Robert Nimes, dated September 13, 1995, from James W. Armstrong, Supervisor, Town
of Lisbon and Letter to Robert Nimes, dated September 15, 1995, from Jon R.Montan,Jr.Planner.
Ill, St. Lawrence County Environmental Management Council
Comment: We support the selection of Alternative 3A and urge EPA to proceed with the
design and implementation of the remedy as soon as possible.
Response: Recently, the House of Representatives and a Senate subcommittee passed
appropriation bills for EPA's Fiscal Year 1996 funding. Contained in the
House bill is language restricting EPA's ability to start new remedial designs
or remedial actions after September 30, 1995. In addition, the proposed
Fiscal Year 1996 appropriation represents a substantial cut in EPA's budget.
Any differences between the House and Senate bills will have to be reconciled
in conference between the House and the Senate before submittal to the
President. If the bill is approved in its current form, all Superfund remedial
actions, including those planned for the Sealand Restoration site, would be
prioritized for funding, nationally, in order of current risk to human health or
the environment. Based on current projections of funding needs, many sites
may not receive full funding in Fiscal Year 1996.
Letter to Robert Nimes, dated September 15, 1995, from John Pentilchiik, P. Eng., Conestoga-
Rovers & Associates Limited.
Comment #1: The supplemental Remedial Investigation and Feasibility Study (RI/FS)
process has taken approximately five years to complete. The RI itself has
taken approximately three years to complete since approval of the work plan
and approximately one and a half years since completion of field work. These
time frames were unreasonably long and indicate inefficient time expenditures
which have led to unnecessary project costs:
Response #1: The need for a supplemental RI/FS was identified in September 1990.
Following the development of the supplemental RI/FS work plan in January
1991, EPA deferred the initiation of the study until the first phase of a
potentially responsible party (PRP) search could be completed. In July 1991,
twenty-two PRPs were identified by EPA and were given notice of EPA's
intent to conduct the supplemental RI/FS. At that time, EPA invited the PRPs
to undertake the study voluntarily. After several months of negotiating the
terms of a consent order to perform the subject work, in September 1991, the
PRPs declined to undertake the study. EPA then developed a sampling and
analysis plan, health and safety plan, and site management plan which were
necessary to conduct .the study; these plans were finalized in August 1992.
Y-4
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The first phase of field work, which was conducted from August 1992 to
December 1992, included monitoring well installation and development,
surface and subsurface soil sampling, on-Site monitoring well and residential
well sampling, surface water and sediment sampling, a geophysical survey,
and an ecological investigation. A second phase of the field investigation,
conducted from August 1993 to November 1993, was necessary to investigate
groundwater contamination in the cell disposal area in order to characterize
further the extent of the contamination and groundwater flow. This effort
consisted of the installation and sampling often additional on-Site monitoring
wells in the cell disposal area and resampling of all other on-Site and off-Site
wells. From November 1993 to August 1994, second round environmental
samples were analyzed, data was generated, validated, and evaluated, and a
baseline human health and ecological risk assessment was generated. Draft
RI and FS reports were developed in August 1994 and January 1995,
respectively. The RI report was finalized in April 1995. The draft FS report
was revised and a Proposed Plan was developed in July 1995.
Comment #2:
Response #2:
NYSDECs 1986 RI/FS and EPA's 1995 supplemental RI/FS provide
sufficient information to characterize the Site. Additional information to
further delineate the groundwater plume is not required.
Since the selected remedy for this site includes the installation of a groundwa-
ter extraction system, additional data is necessary to characterize fully the
overburden and groundwater flow regime and contaminant plume boundaries,
and to conduct the natural attenuation study. Approximately 5 to 10
additional monitoring wells will be needed to obtain the additional data.
Also, because volatile organic compound (VOC) hot spots in the groundwater
have been identified,' these additional monitoring wells are necessary to
determine if the hot spots have migrated.
Comment #3:
Response #3:
With respect to groundwater contamination, the conclusions of EPA's
supplemental RI/FS are essentially the same as NYSDECs 1986 RI/FS—
both indicate no health or ecological risk at the Site under current land use
conditions.
While EPA's baseline human health risk assessment did not indicate a
significant risk to human health in the current land-use scenario, both the
carcinogenic and noncarcinogenic risks in the future land-use scenarios were
significant.
V-5
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Comment #4:
Response #4:
Sampling of the leachate collection system has-indicated that groundwater
within the former cell disposal area has been recontaminated. The selected
remedy in the New York State Department of Environmental Conservation
(NYSDEC) RI/FS stated that the disposal cell should remain in a dewatered
condition to assist in natural attenuation of the contaminant plume down-
gradient of the disposal cell. Because groundwater within the disposal cell has
been recontaminated, it is evident that NYSDEC failed to properly implement
a component of the selected remedy and allowed groundwater contamination
to persist. Had NYSDEC reassessed groundwater conditions and imple-
mented a groundwater remedy at that time, a large portion, if not all of the
groundwater contamination in the cell disposal area would have been
remediated by now. Furthermore, because NYSDEC did not implement a
groundwater remedy, it may now take longer to remediate the groundwater
under current site conditions.
Following NYSDEC's excavation of wastes from the cell disposal area,, a
leachate monitoring/collection system was installed to monitor the leachate
and facilitate its collection. NYSDEC delayed implementing its groundwater
monitoring program because it was aware that EPA would be collecting
samples from the leachate monitoring system, as well as from existing
groundwater monitoring wells, during the supplemental RI sampling activities.
As the water quality samples collected by EPA in the fall of 1992 from the
leachate monitoring system did not indicate significant contamination, there
was no need to pump out leachate from the leachate monitoring system.
However, the second round leachate monitoring system samples collected in
the fall of 1993 revealed significant levels of VOC contamination. Conse-
quently, NYSDEC intends to have leachate pumped out of the former disposal
cell and transported to an off-Site disposal facility in late in 1995.
. (
Because one of the objectives of the supplemental RI/FS was to determine if
additional remedial actions were necessary, it would have been premature for
NYSDEC to implement a groundwater cleanup, prior to completion of the
study. The inference that groundwater within the leachate monitoring system
has been "recontaminated" is incorrect. What is actually occurring is
contaminated groundwater from adjacent areas is being drawn into the
leachate monitoring system, which it was designed to do.
Comment #5:
Response #5:
Given the extensive previous analysis and work performed at the Site by
NYSDEC, a large portion of the supplemental RI/FS is redundant evaluation.
In 1990, EPA assumed the lead role for the Site and issued a Record of
Decision (ROD), which determined that the actions implemented by NYSDEC
V-6
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were appropriate and reasonable interim actions. The ROD also stated that
further actions may be necessary to protect human health and the environ-
ment. EPA determined that a second operable unit RI/FS was necessary to:
(a) ascertain whether past remedial actions taken at the Site were effective in
removing all contaminant source materials; (b) supplement existing informa-
tion as to the nature and extent of site-related surface/subsurface soil
contamination; (c) supplement existing information as to the nature and extent
of site-related groundwater, surface water, and wetland contamination; and
(d) evaluate the need for possible additional remedial actions.
Comment #6:
Response
The risk assessment presented in the RJ report for the current land-use
scenario (no one living at the Site) indicated that risks to human health and the
area ecology are within acceptable levels. Therefore, a no-action remedial
scenario with institutional controls to prevent groundwater usage would be
the most appropriate remedy (the majority of risks for the future land-use
scenario involving groundwater usage are associated with groundwater
ingestion). Furthermore, because the source of groundwater contamination
has been removed (cell disposal area excavation), groundwater contamination
will decline with time and the risks associated with the Site will also decline
at the same time.
While human health risks are not significant in the current land-use scenario,
they were found to be significant in the future use scenario. Moreover,
groundwater contaminant levels currently exceed MCLs in the area of the cell
disposal area. Acetone was detected in this area in 8 samples, with the highest
detected concentration at 2,100,000 micrograms per liter (ug/1) in one
monitoring well. Other VOCs found in this area at elevated concentrations
include 1,1-dichloroethane at 1,300 ug/1, 2-butanone at 4,700 ug/1, cis-1,2-
dichloroethylene at 440 ug/1, trichloroethene at 430 pg/1, chloroethane at 390
ug/1, vinyl chloride at 250 ug/1, and 1,1,1-trichloroethane at 240 ug/1. The
federal drinking water standard for vinyl chloride is 2 ug/1. New York State
MCLs for acetone and 2-butanone are 50 ug/1 and for the other VOCs are 5
ug/1. The selection of no further action with institution controls would not
reduce groundwater contamination levels to MCLs and would, therefore, not
be protective of human health and the environment, because contaminated
groundwater would continue to migrate unabated.
The selected remedy does include the implementation of a natural attenuation
study to determine if contaminant levels outside of hot-spot areas can be
reduced to MCLs through natural attenuation. If, after implementing hot-spot
groundwater remediation, groundwater monitoring results in the hot-spot
areas are below MCLs, and if the study indicates natural attenuation outside
V-7
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of hot-spot areas has potential to reduce groundwater contamination to
MCLs, a long-term action to extract contaminated groundwater would not be
necessary.
Comment #7:
Response #7:
The supplemental RI/FS report states that "most of the scenarios probably
overstate the level of exposure in the interest of standardization and
conservatism. As examples, the average person probably does not ingest 2
liters of water every day of his or her life, ingest 100 to 200 mg of soil daily
or remain in a residence 24 hours a day for 30 years." It also notes that
absorption estimates used in the risk analysis are as high as ten times what
studies indicate they would be. The analysis should, at least, use assumptions
that have some basis in scientific and/or observable fact. ^By using unrealistic
assumptions in the risk assessment analysis, the RI/FS creates the impression
that costly remediation out of proportion to the risk is required at the Site.
The standardized exposure assumptions of the risk assessment analysis of the
RI/FS are used in the absence of site-specific exposure parameters that are too
difficult and expensive to gather for each hazardous waste site. Standardized
exposure assumptions are based on national censuses and surveys published
in the scientific literature that have been reviewed by USEPA scientists for
their relevance that gather information regarding personal lifestyle, behavior
patterns and activities. The values used in the risk assessments represent the
reasonable maximum exposure (RME) or the highest exposure that is
reasonably expected to occur at a site. The intent of the RME is to estimate
a conservative exposure case (i.e., well above the average case) that is still
within the range of possible exposures. The assumptions are meant to be
protective of that portion of a population that is expected to be exposed to
site contaminants on a greater than the average basis. The assumptions are
meant to represent exposures that would occur greater than the average
exposure (general population) but less than the highest exposure or worst
case.
The risk assessment also calculated central tendency (average case) exposures
(CTE) for all the potential pathways that exceeded EPA's acceptable
carcinogenic risk range or a noncarcinogenic hazard index of 1. These
calculations utilized the average exposure frequencies and duration values
instead of the RME values. The results were unchanged from the risks
calculated using RME values, (the HI in the future land use scenario for adults
and young children was estimated to be 578 and 1,350, respectively) and were
still above the acceptable risk range and/or a hazard index of 1. The
remediation is not considered "out of proportion to the risk" because risk was
shown for exposure pathways using average assumptions as well as RME
V-8
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assumptions.
Site-specific information regarding sensitive subpopulations (children, local
fishermen, etc.) was reviewed to determine if there are people who may
potentially be at a higher risk from exposure to the Site-related contaminants.
For the Sealand Restoration site, children were considered a sensitive
subpopulation and were evaluated for their exposure to soils, groundwater,
surface water, and sediments.
Comment #8:
Response #8:
The risk assessment assumes that groundwater contamination exists across the
entire site. It is physically impossible for groundwater contamination to
migrate from the cell disposal area to the western portion of the Site (over
half the Site) because of the identified groundwater divide.
The risk assessment as a conservative estimate assumes that exposure occurs
at the highest contaminated areas. The purpose of the risk assessment is to
evaluate the highest exposure that is reasonably expected to occur at the Site
and quantify potential risks and hazards. The "nature and extent" section of
the RI report discusses the hydraulic divide and acknowledges that no
contamination exists west of this divide.
Comment #9:
Response #9:
Under the no-action alterative, it would be useful for EPA to determine how
long it would take for the groundwater contamination to naturally attenuate.
This would assist in determining if the no-action alternative were feasible and
would act as a baseline to determine how much faster the proposed remedies
would clean up groundwater contamination. .
i
Approximately concurrent with the action to remediate the groundwater hot
spots, a study will be conducted to determine if natural attenuation can reduce
the remaining contaminants in the groundwater to MCLs within an acceptable
time frame. If, after implementing the hot-spot groundwater remediation,
groundwater monitoring results indicate that the contaminants in the
groundwater continue to exceed MCLs, and if the results of the study indicate
that natural attenuation has little potential to reduce groundwater contamina-
tion to MCLs, a long-term action will be implemented.
Comment #10:
Response #10:
The alternatives discussed in the FS report are slightly different than those
discussed in the Proposed Plan.
The alternatives and the associated analysis and costs that were presented in
V-9
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the FS report were used as the basis for developing the alternatives presented
in the Proposed Plan.
Comment #11:
Response #11:
The criteria to terminate pumping should not only be based on attaining
federal and state MCLs, but also on risk-based standards and areal limitations
of plume extent (i.e., further remediation should not be required if the plume
is contained by flow system characteristics and/or natural attenuation). At the
completion of the hot-spot remediation, an option to perform a risk assess-
ment should be available. If risks under the future-use scenario are at
acceptable levels, then pumping should be terminated and natural attenuation
should be left to address any residual contamination.
The criteria to terminate pumping will be based not only upon attaining federal
and state MCLs, but will also be based upon natural attenuation and
contamination flow patterns. It is noted, however, that the remedy must at
least attain the applicable or relevant and appropriate requirements (ARARs)
as described in Section 121 of the Comprehensive Environmental Response,
Compensation, and Liability Act, as amended. In this case, the applicable
standards are MCLs. Therefore, obtaining acceptable risks under the future-
use scenario alone would not be sufficient cause to justify terminating the
pumping and treating of the ground water.
Comment #12:
Response #12:
Alternatives 3A and 3B should stress that the need for a long-term groundwa-
ter pumping and treatment system will be based upon data collected during
pre-design activities and operation of the hot-spot groundwater remediation
system.
The need for undertaking long-term groundwater remedial measures will be
based upon the pre-design investigation results, which will be conducted to
determine if natural attenuation can reduce the remaining contaminants in the
groundwater to MCLs within an acceptable time frame. If, after implementing
the hot-spot groundwater remediation, groundwater monitoring results
indicate that the contaminants in the groundwater continues to exceed MCLs,
and if the results of the study indicate that natural attenuation has little
potential to reduce groundwater contamination to MCLs, a long-term action
will be implemented.
Comment #13:
The description of Alternative 3 A states that the hot-spot remediation will
occur, followed by installation and operation of a full-scale system, if required.
The full-scale system is proposed to consist of three wells immediately
Y-IO
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Response #13:
downgradient of the disposal cell and seven wells at the downgradient edge
of the plume. Groundwater extraction during the hot-spot remediation will
occur in the immediate vicinity of the proposed three full-scale system wells.
Because hot-spot remediation should remove the bulk of contamination in this
area (near the disposal cell), it is unlikely that the three proposed wells will be
required. Also, based on data collected during the hot-spot remediation,
seven wells may not be required at the downgradient edge of the plume. The
possible location of the seven wells is near or within the wetlands which may
pose construction difficulties as a result of the presence of water and the need
for wetland encroachment permits.
The specific components of Alternative 3 A were developed conceptually, to
estimate the cost of this alternative. The actual number and location of
proposed extraction wells will be determined based upon the results of the
pre-design investigation. The need for a long-term remediation will also be
evaluated during the pre-design investigation. Wetland impacts will be
analyzed via monitoring activities during the design phase. On-site activities
at Superfund sites do not require permits; however, the substantive require-
ments of all permits will be met.
Comment #14:
Response #14:
The remedial alternatives should consider using the existing leachate
collection system as a reinjection system. This is only mentioned briefly in the
FS report. The advantages of using the existing leachate collection system to
reinject groundwater are that:
i) it would serve to accelerate movement of recontaminated groundwater in
the disposal cell toward the extraction wells;
ii) it would serve to flush the one small slug of soil contamination found at
the downgradient edge of the disposal cell; and
iii) it would negate the need for a new system thereby accelerating the
implementation schedule for the hot-spot remedy and lowering capital costs.
Reinjecting treated groundwater into the existing leachate monitoring system
was considered; however, this approach would tend to disperse and dilute
near-source contaminants and would result in the need to pump more
groundwater. Also, flushing soil contaminants to groundwater may allow for
some contaminants to escape collection during the expedited action, since all
contaminated groundwater would not be captured. The leachate monitoring
system would be better utilized as an extraction point, as is evident from the
RI groundwater data which show that it is effectively collecting VOC
V-ll
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contamination1.
During the remedial design, water level and monitoring data will be evaluated
in and around the leachate monitoring system to determine if additional
leachate collection is necessary. Any collected leachate associated with the
leachate monitoring system will be addressed as part of the groundwater
remediation activities.
Comment #15:
Response #15:
During the hot-spot remediation proposed in Alternative 3 A, it is suggested
that existing monitoring wells be used to extract contaminated groundwater.
Pump and control equipment for 2-inch diameter wells are^available. This will
have minimal impact on construction and operation costs, but will significantly
improve the chances of the hot-spot remediation cleaning up most of the
groundwater plume.
While existing groundwater monitoring wells could be utilized as extraction
wells, these wells are between 8 and 13 years old and some are not in suitable
condition to be used as extraction wells for any significant length of time.
Moreover, converted extraction wells could no longer serve as monitoring
wells, which would be needed to monitor and assess the effectiveness of the
pump-and-treat system. Use of the existing 2-inch diameter extraction wells
instead of new 6-inch diameter wells would also limit the volume of
groundwater to be collected.
Comment #16:
Response #16:
EPA is concerned about potential impacts to the wetlands from groundwater
extraction. It is likely that the estimated 10 to 30 gallons per minute
extraction rate is only a small fraction of the groundwater and surface water
that discharges to the wetland. The wetlands themselves cover approximately
70 acres. Therefore, it is unlikely that any significant impacts would occur.
In addition, treated water would either be reinjected or discharged directly to
the wetlands. There may be some loss of water to the wetlands when
groundwater extraction begins, however, an equilibrium condition will
develop over a relatively short period allowing water recharge to the wetland
to return to pre-pumping conditions.
The impact to wetlands from groundwater extraction may be insignificant;
however, further evaluation must be performed to support this hypothesis.
V-12
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Comment #1:
Response #1:
Comments from the Public Meeting
Several commentors requested that the public comment period be extended.
In response to these requests, the comment period was extended from August
18,1995 to September 22, 1995.
Comment #2:
Response #2:
How do acetone concentrations at the Sealand Restoration site compare with
other acetone-contaminated sites? Has bioremediation been utilized to
address acetone contamination in groundwater at other sites?
%
While the highest acetone concentrations (maximum value of 2,100,000 ug/1)
detected in groundwater samples collected at the Sealand Restoration site
(highest concentration was 2,100,000 micrograms per liter [ug/1]) are of
concern, acetone contamination at these levelslis not uncommon for
hazardous waste sites. Bioremediation to remove acetone in groundwater has
been successfully demonstrated at many industrial and municipal hazardous
waste sites including the Bostik, Inc. facility in Middleton, Massachusetts, the
Safety Kleen site in Hebron, Ohio, and BP Oil site in Paulsboro, New Jersey.
Comment #3:
Response #3:
What adverse health effects are attributable to exposure to acetone or to other
principal hazardous substances found at the Sealand Restoration site?
Exposure to acetone can produce noncarcinogenic, adverse health effects.
Symptoms of acetone exposure include restlessness, vomiting leading to
hematemesis and dermatitis from prolonged skin contact. Critical effects
include increased liver and kidney weights and nephrotoxicity. The baseline
human health risk assessment performed as part of the RI for the Site
indicated that 99% of the potential future noncarcinogenic risk is attributable
to ingestion of acetone in on-site groundwater, and that this risk is significant.
Almost all of the remaining 1% of the potential future noncarcinogenic risk
is attributable to arsenic in groundwater. Arsenic is widely distributed in the
environment and all humans are exposed to low levels via air, water, and food.
The skin is the critical organ of toxicity and a variety of skin lesions (e.g.
hyperpigmentation, keratosis, skin cancer) have been associated with arsenic
intoxication, particularly from chronic exposure in drinking water and from
certain occupational exposures. The risk assessment also indicated that a
potential, future carcinogenic risk is also significant, and that the ingestion of
arsenic in on-site groundwater is the principal contributor to this risk. No
other compounds were found at levels that would present a significant
carcii!o^enic or nonccrcinogenic risk.
V-13
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Comment #4:
Response #4:
How did the analytical results of the second round of residential well samples
collected by EPA affect EPA's earlier decision to provide bottled water to
certain residents located in the vicinity of the Site?
In the first round of groundwater samples collected from residential wells
located near the Site in the fall of 1992, lead, arsenic, bis(2-ethyl-
hexyl)phthalate, and one PCS compound were detected in a few samples at
or above federal or state drinking water standards. Lead was also detected
at elevated levels in 2 other subsequent samples collected and analyzed by
NYSDOH. Because lead, arsenic, bis(2-ethylhexyl)phtha]ate, and PCBs were
previously also found on-site in the soil, and lead was detected in on-site
groundwater, EPA deduced that the Site was a potential source of this
contamination. As a precautionary measure to ensure that nearby residents
would not be exposed to these contaminants which were believed to be
emanating from the Site, EPA issued a Unilateral Administrative Order in
August 1993 to the potentially responsible parties, requiring that they supply
bottled water for drinking and cooking on a regular basis; deliveries of bottled
water began in September 1993.
However, based on the results of the RI, EPA determined that lead, arsenic,
bis(2-ethylhexyl)phthalate, and PCBs were either not found in on-site
groundwater or were found at levels too low and in areas too remote from
any of the affected residences to be a source of contamination to the private
water supplies. Moreover, with the exception of lead, which was detected in
one background monitoring well (a monitoring well not affected by site
contaminants), these contaminants were not detected in the bedrock aquifer,
which is the aquifer from which most residential wells draw water.
Subsequent samples collected by NYSDOH and EPA have not detected the
above contaminants of concern in residential wells, with the exception of lead,
which was found in 2 homes in NYSDOH samples collected in August 1994
and March 1995. NYSDOH plans to continue to provide information and
assistance, as needed, to those homes. In May 1995, based on the new
information regarding the relationship between the Site contaminants and the
private wells, EPA notified the potentially responsible parties that they were
no longer required to deliver bottled water. Deliveries of bottled water ceased
in July 1995.
Comment #5:
If the Site is not the source of the lead found in the tap water, what was the
source?
Y-U
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Response #5:
The presence of lead in tap water samples may be the result of corrosion from
chrome-plated fixtures, lead pipes, or lead solder. A corrosivity test
performed by theNYSDOH did not, however, indicate corrosive conditions.
Another possibility is that lead is present in the rock formation, or was present
in suspended sediments in the well water, and was drawn into the sample
when water was collected from the tap. Although lead was detected at 170
ug/1 in one residence, which is considerably above the action level of 15 ug/1,
lead was not present in two other tap water samples collected from this same
residence, and it was present at only 17 ug/I in a third sample. Because of the
variable lead results in previous samples, NYSDOH may collect and analyze
additional samples from this home.
Comment #6:
Response #6:
The first action taken at this site, an interim source control measure,
encompassed the removal and disposal of drums, sludge, waste oils, tanks,
trailers, and debris, and the excavation and disposal of contaminated soils and
liquids. Other than addressing the contaminated groundwater, is any additional
cleanup needed at the Site?
Soil borings from one monitoring well located near the former cell disposal
area indicated that acetone was present below the water table at
concentrations well above cleanup levels. The extraction and treatment
remedy that has been selected to address the contaminated groundwater in this
area will also remove contaminants adsorbed onto subsurface soil, which
should significantly reduce subsurface soil contaminant levels. No other areas
at the Site require additional cleanup measures.
Comment #7:
Response #7:
Who owns the Site? Who is financially responsible for the cleanup expenses?
What payments have been made by these parties?
Although Sealand Restoration, Inc. abandoned the Site in 1981, a title search
conducted by EPA indicated that the current owner is Sealand Restoration,
Inc. Key Bank of Northern New York, NA, holder of a mortgage against the
property, began foreclosure proceedings in 1983, but it has not assumed title
to the Site. EPA has currently identified and notified 22 PRPs that are
potentially liable and appear to be financially viable to pay the costs for EPA's
and NYSDEC's past and future expenses at the Site.2 Following the selection
A substantial portion of the past costs related to the Site were incurred by NYSDEC in 1989 and 1990
when Sevenson Environmental Services, under contract with NYSDEC, removed drums, contaminated
soil, and liquid from the cell disposal area, and transported them to various off-site disposal facilities. The
coit for this action was approximately $15 million.
V-15
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of the groundwater remedy, EPA will contact the PRPs in an attempt to
determine whether they are willing to conduct, contribute to, or finance the
cleanup. If they are unwilling, EPA currently has various enforcement
options, such as it may order the PRPs to conduct the cleanup, or
alternatively, if funding is available, EPA could conduct the cleanup itself and
seek to recover its costs. To date, the PRPs have not financed any site
investigatory or cleanup activities, although a group of PRPs provided for the
distribution of bottled water to residents located in the vicinity of the Site.
V-16
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APPENDIX V-a
RESPONSIVENESS SUMMARY
LETTERS SUBMITTED DURING THE PUBLIC COMMENT PERIOD
-------
ftUG-t -1995 15:36 FROM ST.LAURENCE COUNTY TO 81212G374284 P.02
>
ST. LAWRENCE COUNTY
ENVIRONMENTAL MANAGEMENT COUNCIL
48 COURT STREET, COUNTY COURTHOUSE
CANTON, NEW YORK 13617-1194
TELEPHONE: 315-379-2281 * FAX: 315-379-2333
August 9, 1995
Mr. Joel•Singerman
Superfund Section Chief
U. S. EPA, Region 2
290 Broadway, 20th Floor
New York, NY 10007-1866
Dear Mr. Singerman,
As I indicated to you in Lisbon on Tuesday evening, I had some
questions concerning the Sealand Restoration project that had been
prepared by my staff person assigned to this project, Jon Montan.
I had inadvertently left the questions on my desk. It would be
helpful to have the answers to these -before September 1st so'that
we can include them in the discussions by the Environmental
Management Council on the recommended alternative.
1. Under the preferred alternative, would it be feasible to
air-strip the acetone out of the groundwater instead of using
bioremediation? Would it be more cost-effective?
2. Are the O & M costs annual or spread out over time?
3. What will be involved in the study of natural contaminant
• attenuation? Does this simply mean continued monitoring of
water samples to see if levels are dropping? Is this study
merely measuring the rate of dilution?
Finally, as was stated by several speakers at the meeting, it is
important for the EPA to extend the public comment period so that
the citizen groups interested and involved with this project over
the past 15 years can be afforded the time needed to review the
research materials and submit their comments to you. The executive
summary and meeting announcement did not arrive in the offices of
the County Planning Board and the EMC until July 27, well after the
start of the 30 day comment period. We have not yet received a copy
of the full report which will be necessary as a reference for the
EMC's review, it is not possible for us to use the Lisbon Library
copy as we are not located in Lisbon and our Council meets in the
evenings when the Library is closed. I understand that our copy
should be forthcoming in a matter of days.
I
The next meeting of the EMC is Wednesday, September 20. We can
arrange for committee review of the proposed plan prior to"
September 20, but the committee cannot act on behalf of the full
Council without prior authorization. Such authorization was not
given at the last meeting as we had no knowledge of the proposed
plan and its review at that time.
-------
fiUu-03-1995 15:37 FROM ST.LAURENCE COUNTY TO
Joel Singerman
August 9,- 1995
page 2
I understand the tight time line that your agency is working with
and your keen desire to see this project moving ahead in this
fiscal year. We share your concern, but must also undertake our
responsibilities to St. Lawrence County and the residents of the
area who depend on us to review the proposal professionally and
responsibly. This obviously cannot be done in the comment period
provided. While several weeks would normally be required for such
a review we wish to cooperate in speeding this process along if at
all- possible. We will be able to FAX our comments to you by the
close of business on Friday, September 22. This is lesss than 60
days from the time that your announcement arrived at our offices.
Please extend your comment period to September 22 in order to
accommodate the EMC, the Lisbon Planning Board and the other
citizens' groups that have indicated both the interest and the
intent to comment.
i
Thank you for your attention to our questions and our reguest for
an extention of the comment period. We will be looking forward to
hearing from you and to receiving the full report.
Sincerely yours/
Mary Burns Velraque
Director
. ep«
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FROM : TDUN OF LISBON
LISBON TOWN HNJ-
September 13, 1995
Mr. Robert Nunes
Remedial Project Manager
U.S. Environmental Protection Agency
290 Broadway, 20th Floor
New York, New York 10007-1866
Dear Mr. Nunes,
Please be advised that the Lisbon Town Board is in complete
agreement with the reconnendation of the Lisbon Planning Board
regarding the implementation of preferred alternative 3A and also
urges the EPA to proceed with the project as soon as possible.
Thanking you for your consideration in this matter, I re-
main,
Very^ruly yours,
:s W. Armstrong, S
Town of Lisbon
isor
JWA/rs
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CONESTOGA-ROVERS & ASSOCIATES LIMITED
651 Colby Drive
Consulting Engineers Waterloo, Ontario, Canada N2V 1C2
(519) 884-0510 Colby Office Fax: (519) 884-0525
(519) 725-3313 Bathurst Office (519) 725-1394
September 15,1995 Reference No. 4286
Mr. Robert Nunes
Remedial Project Manager
United States Environmental Protection Agency
290 Broadway, 20th Floor
New York, New York 10007-1866
Dear Mr. Nunes:
Re: Sealand Restoration Site
Lisbon. New York
On behalf of the Sealand PRP Group (Group), Conestoga-Rovers & Associates (CRA)
has reviewed the Supplemental Remedial Investigation/Feasibility Study (RI/FS)
reports and the Proposed Plan prepared by the United States Environmental
Protection Agency (USEPA) for the Sealand Restoration Site. Presented below are
CRA's comments on the above documents.
General Comments
;'l. The Supplemental RI/FS process has taken approximately five years to
""" complete. The RI itself has taken approximately three years to complete since
approval of the Work Plan and approximately one and a half years since
completion of field work. These time frames were unreasonably long and
indicate inefficient time expenditures which have led to unnecessary project
costs.
: 2. The New York State Department of Environmental Conservation's
(NYSDECs) 1986 RI/FS and the USEPA's 1995 Supplemental RI/FS provide
sufficient information to characterize the Site. Additional information to
further delineate the groundwater plume is not required. USEPA has
correctly concluded that significant risks to human health and ecology do not
exist at the Site and contaminants from the Site are not present in off-Site
residential wells.
..3. With respect to groundwater contamination, the conclusions of the USEPA's
Supplemental RI/FS are essentially the same as the NYSDECs 1986 RI/FS;
both indicate no health or ecological risk at the Site under current land use
conditions.
4? The preferred remedial alternative presented in the NYSDEC 1986 RI/FS was
to excavate wastes from the cell disposal area and then reassess the need for
groundwater remedial techniques. The NYSDEC spent $14,000,000 on
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September 15,1995 Reference No. 4286
-2-
excavation of the cell disposal area but did not reassess the groundwater
conditions as required in the selected remedy. Had the NYSDEC reassessed
groundwater conditions and implemented a groundwater remedy at that
time, a large portion, if not all of the groundwater contamination in the cell
disposal area would have been remediated by now. Furthermore, since the
NYSDEC did not implement a groundwater remedy, it may now take longer
to remediate the groundwater under current Site conditions.
5. • The cost of the USEPA Supplemental RI/FS was approximately $1,000,000.
Given the extensive previous analysis and work performed at the Site by the
NYSDEC, a large portion of the cost attributed to the USEPA Supplemental
RI/FS is for redundant evaluation. '
6. Groundwater within the former cell disposal area has been recontaminated as
indicated by sampling of the leachate collection system. The selected remedy
in the NYSDEC RI/FS stated that the disposal cell should remain in a
dewatered condition to assist in natural attenuation of the contaminant
plume downgradient of the disposal cell. Since groundwater within the
disposal cell has been recontaminated, it is evident that the NYSDEC failed to
properly implement a component of the selected remedy and allowed
groundwater contamination to persist.
Specific Comments
1. The risk assessment (RA) presented in the RI for the current land use
scenario (no one living at the Site) indicated that risks to human health and
the area ecology are within acceptable levels. Therefore, a no action remedial
scenario with institutional controls to prevent groundwater usage would be
the most appropriate remedy (the majority of risks for the future land use
scenario involving groundwater usage are associated with groundwater
ingestion). Furthermore, since the source of groundwater contamination has
been removed (cell disposal area excavation), groundwater contamination
will decline with time and the risks associated with the Site will also decline
at the same time.
2. The Supplemental RI/FS states "most of the scenarios probably overstate the
level of exposure in the interest of standardization and conservatism. As
examples, the average person probably does not ingest 2 liters of water every
day of his or her life, ingest 100 to 200 mg of soil daily or remain in a residence
24 hours a day for 30 years". It also notes that absorption estimates used in the
risk analysis are as high as ten times what studies indicate they would be. The
analysis should, at least, use assumptions that have some basis in scientific
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September 15,1995 Reference No. 4286
-3-
and/or observable fact. By using unreal assumptions in the RA analysis, the
RI/FS creates the impression that costly remediation completely out of
proportion to the risk is required at the Site.
3. The RA assumes that groundwater contamination exists across the entire
Site. It is physically impossible for groundwater contamination to migrate
from the cell disposal area to the western portion of the Site (over half the
Site) due to the identified groundwater divide.
4. Under the no action alternative in the FS and Proposed Plan, it would be
useful for the USEPA to determine how long it would take for the
groundwater contamination to remediate or be contained (Le., no further
migration) under natural attenuation. This would serve the following
purposes:
i) would assist in determining if the no action alternative is feasible; and
ii) would act as a baseline to determine how much faster the proposed
remedies would clean up groundwater contamination.
5. Alternatives 6B and 8B in the FS appear to be equivalent to Alternatives 3A
and 3B in the Proposed Plan. However, Alternatives 6B and 8B do not discuss
the natural attenuation evaluation to determine if the full-scale extraction
and treatment system is required after hot spot treatment. The Proposed Plan
also states that remediation will not be required after hot spot treatment if
concentrations are below MCLs or attenuation has the potential to reduce
concentrations to MCLs in the future. This language from the Proposed Plan
should be added to the FS.
6. At the completion of the hot spot remediation in Alternative 3A (Proposed
Plan), an option to perform a risk assessment should be available. If risks
under the future use scenario in the RI are at acceptable levels, then pumping
should be terminated and natural attenuation should be left to address any
residual contamination.
7. The criteria to terminate pumping should not only be based on attaining
federal and state MCLs but also on risk-based standards and areal limitations
of plume extent (i.e., further remediation should not be required if the plume
is contained by flow system characteristics and/or natural attenuation).
8. Alternatives 6B and 8B in the FS and Alternatives 3A and 3B in the Proposed
Plan should stress that the need for and design of a long-term system will be
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September 15,1995 Reference No. 4286
-4-
based upon data collected during pre-design activities and operation of the
hot spot system.
9. The selected alternative 6B (FS) and 3A (Proposed Plan) states that hot spot
remediation will occur followed by installation and operation of a full-scale
system if required. The full-scale system is proposed to consist of three wells
immediately downgradient of the disposal cell and seven wells ^ at the
downgradient edge of the plume. Groundwater extraction during the hot
spot remediation (MW-5I) will occur in the immediate vicinity of the
proposed three full-scale system wells. Since hot spot remediation should
remove the bulk of contamination in this area (near the disposal cell), it is
unlikely that the three proposed wells will be required. Also, based on data
collected during the hot spot remediation, seven wells may not be required at
the downgradient edge of the plume. The possible location of the seven wells
are near or within the wetlands which may pose construction difficulties due
to the presence of water and the need for wetland encroachment permits.
10. The remedial alternatives in both the FS and Proposed Plan should consider
using the existing leachate collection system as a reinjection system. This is
only mentioned briefly in the FS. The advantages of using the existing
leachate collection system to reinject groundwater are:
i) would serve to accelerate movement of recontaminated groundwater
in the disposal cell toward the extraction wells);
ii) would serve to flush the one small slug of soil contamination found at
the downgradient edge of the disposal cell; and
iii) would negate the need for a new system thereby increasing the
implementation schedule for the hot spot remedy and lowering capital
costs.
11. During the hot spot remediation proposed in Alternative 3A (Proposed Plan),
it is suggested that existing wells B-3W, DM-8S, and DM-8D also be used to
extract groundwater. Pump and control equipment for 2-inch diameter wells
are available. This will have minimal impact on construction and operation
costs but will significantly improve the chances of the hot spot remediation
cleaning up most of the groundwater plume.
12. Alternatives 2A, 2B, 3A, and 3B in the Proposed Plan state that new wells will
be installed for hot spot remediation. This is incorrect. As stated in the FS,
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CONESTOGA-ROVERS & ASSOCIATES LIMITED
Consulting Engineers
September 15,1995 Reference No. 4286
-5-
three existing wells will be used (MW-5I, MW-7D and MW-8S). The
Proposed Plan should be revised to reflect this.
13. USEPA is concerned about potential impacts to the wetlands from
groundwater extraction. It is likely that the estimated 10 to 30 gpm extraction
rate is only a small fraction of the groundwater and surface water that
discharges to the wetland. The wetlands themselves cover approximately
70 acres. Therefore, it is unlikely that any significant impacts would occur. In
addition, treated water would either be reinjected or discharged directly to the
wetlands. There may be some loss of water to the wetlands when
groundwater extraction begins, however, an equilibrium condition will
develop over a relatively short period of time allowing water recharge to the
wetland to return to pre-pumping conditions.
Should you have any questions regarding the above comments, please do not
hesitate to contact me at (519) 884-0510.
Yours truly,
CONESTOGA-ROVERS & ASSOCIATES
V
John Pentilchuk, P. Eng.
JP/csm/5
Encl.
cc: Eric Rothenberg
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ST. LAWRENCE COUNTY
ENVIRONMENTAL MANAGEMENT COUNCIL
48 COURT STREET. COUNTY COURTHOUSE
CANTON. NEW YORK 13617-1194
TELEPHONE: 315-379-2231 * FAX: 315-379-2333
September 21, 1995
Robert Nunes
Remedial Project Manager
U.S. Environmental Protection Agency
290 Broadway, 20th Floor
New York, New York 10007-1866
By FAX (212) 637-3966
RE: Sealand Restoration Site
Remediation
Dear Mr. Nunes:
The St. Lawrence County Environmental Management Council, a quorum
being present, passed the following motion with no opposing votes
at their regular monthly meeting on 9/20/95:
"The St. Lawrence County Environmental Management Council
(EMC) has reviewed the Superfund Proposed Plan for the
Sealand Restoration Site in the Town of Lisbon, New York,
issued by the U.S. Environmental Protection Agency in
July, 1995. The EMC has no objections to the agency
implementing Alternative 3A in order to remediate the
residual groundwater contamination at the site."
I want to thank you for giving the EMC additional time during which
to evaluate the alternatives and comment. I realize that you are
under pressure to proceed with timely implementation of a remedial
effort. It was necessary for the EMC members to satisfy
themselves that among the alternatives, 3A emerged as the most
optimal .
Best wishes with your continuing management of the Sealand site.
Sincerely,
Jon R. Montan, Jr.
Planner III
CC: A. Hamaill, R. Scott, S. Teele
4/TCV3I3UUUCD.V3
TOTflL P.02
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1
2 PUBLIC MEETING
3 for the
4 SEALAND RESTORATION SUPERFUND SITE
5 LISBON, NEW YORK
6 Tuesday, August 8, 1995
7 8:00 p.m.
8
9 APPEARANCES:
10 STEVEN KATZ
11 Community Relations Coordinator
12 U.S. EPA, Region 2
13
14 JOEL SINGERMAN
15 Superfund Section Chief
16 U.S. EPA, Region 2
17
18 ROBERT NUNES
19 Remedial Project Manager
20 U.S. EPA, Region 2
21
22 MARIA WATT
23 IT Corporation
24
25
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1 2
2 MR. KATZ: Okay, now I guess we can get started.
3 First let me introduce myself, I'm Steven Katz,
4 Community Relations Coordinator for Region 2, EPA.
5 Thank you very much for taking time out of
6 your schedule to talk about the Restoration Site with
>
7 me, to talk about the groundwater cleanup that EPA is
8 proposing.
9 Next to me is Bob Nunes, he's the engineer
10 in charge of the site for EPA; to his right as Maria
11 Watt, she is with the IT Corporation. That is the
12 contractor that actually carried out the study, she can
13 tell you a lot more about the details that occurred; to
14 her right is Joel Singennan, he's the Supervisor in the
15 Superfund Program.
16 What we can do tonight is take a look at
17 the agenda. We have a presentation to go through, what
18 we found, what we're proposing, which will take about
19 half-an-hour, thirty-five minutes. I'll ask you to hold
20 all your questions or comments until after we're done
21 with the presentation. We will try to take all your
22 questions, as many as we can, and.respond.
23 All your questions are also part of this
24 public comment period that we're having in response to
25 what we're proposing here tonight.
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1 3
2 As you see, there a stenographer, and when
3 you have a question or comment, if I could ask you to
4 stand, she might ask you to repeat what you just said.
5 State your name, it's a public meeting. You want to
6 let it sort of soak in, the information you're getting
7 here tonight.
8 You can still write to Bob, his address is
9 on this proposal and that's also there, and you can
10 send it in. The comment period closes August 18th so
11 you have another ten days to still think it over if you
12 have additional things that you wanted to say or
13 questions that you have. You can still write in.
14 There is additional information, we keep
15 all decisions and background information locally so
16 everyone can look it up and see how we came to the
17 decision on the site. That's being maintained right
18 down the street at the Town Hall so we can all go there
19 and look up whatever documentation you want about the
20 site.
21 Those are the only ground rules I have,
22 we'll keep it informal. All that I ask you to do is
23 just speak one at a time and state your name for the
24 stenographer. I think at this point we're just going
25 to try to get things moving along.
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1 4
2 . I'm going to turn it over to Bob to talk a
3 little bit about the site history which you're probably
4 familiar with. Bold your questions for about
5 half-an-hour, we'll get to it.
6 That's Joel will talk a little bit. I was
>
7 really trying to move things along, wasn't I?
8 . MR. SINGERMAN: Can everyone see that? Can
9 everyone see this?
10 THE AUDIENCE: Yes.
11 MAN IN AUDIENCE: I can't see.
12 MR. SINGERMAN: Several well-publicized
13 toxic waste disposal disasters in the late 1970's,
14 among them Love Canal, shocked the nation and
15 highlighted the fact that past waste disposal practices
16 were not safe.
17 In 1980, Congress responded with the
18 creation of the comprehensive Environmental Response,
19 Compensation, and Liability Act, more commonly known as
20 Superfund.
21 The original Super fund Law provided a
22 one-point-six-billion dollar Federal Fund to be used in
23 the cleanup of uncontrolled and abandoned hazardous
24 waste sites, and for responding to emergencies
25 involving'hazardous substances.
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1 5
2 In addition, EPA was empowered to compel
3 those who were responsible for these sites to pay for
4 or to conduct the necessary response actions.
5 Superfund was re-authorized by Congress in
6 1986, increasing the size of the fund to
s
7 eight-point-six-billion dollars.
8 The work to remediate a Superfund site is
9 usually very complex and takes place in many stages.
10 Once a hazardous waste site is discovered,
11 an inspection further identifies the hazards and
12 contaminants that are present.
13 A determination is then made whether to
14 place the site on the Superfund National Priorities
15 List, a list of the nation's worst hazardous waste
16 sites.
17 Sites are placed on the National Priorities
18 List primarily on the basis of the relative risks posed
19 by the site.
20 Only sites on the National Priorities List
21 are eligible for remedial work financed by Superfund.
22 This selection of a remedy for a site is
23 based upon two studies: A remedial investigation and a
24 feasibility study.
25 The purpose of the remedial investigation
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1 6
2 is to determine the nature and extent of the
3 contamination at and emanating from the site and the
4 associated risk to public health and the environment.
5 The purpose of the feasibility study is
6 identify and to evaluate remedial alternatives to
>
7 address the site's contamination problems.
8 Public participation is a key feature of
9 the Superfund process.
10 The public is invited to participate in all
11 of the decisions that will about made at a site through
12 the Community Relations Program.
13 Town meetings, such as this one, are held,
14 as necessary, to keep the public informed about what
15 has happened and what is planned for a site.
16 The public is also given the opportunity to
17 comment on the results of the investigations and
18 studies conducted at the site and the proposed remedy.
19 After considering public comments on the
20 proposed remedy, a Record of Decision is signed.
21 The Record of Decision documents the
22 selection of the remedy and the basis for that
23 selection.
24 The site then enters the remedial design
25 phase, where planning specifications associated with
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1 7
2 the selected remedy are developed.
3 The remedial action begins when the design
4 is completed. This is the actual hands-on-work
5 associated with cleaning up the site.
6 Following completion of the remedial
>
7 action, operation and maintenance associated with the
8 remedy, and monitoring, are performed, as necessary.
9 MR. KATZ: Now, Bob.
10 MR. NUNES: Okay, I'm going to speak
11 briefly about the site background and the site
12 history. After I go through that, Maria will follow up
13 with her presentation on the remedial investigation
14 phase of our study, and I will follow her again with a
15 discussion or presentation about the feasibility
16 studies on the proposed plan that we developed.
17 The Sealand Restoration Site is a
18 two-hundred-and-ten-acre site. It's located south of
19 Pray Road, about three miles southwest of here, the
20 Village of Lisbon.
21 The site was operated from the period
22 between 1977 through 1982 by Sealand Restoration,
23 Incorporated. The site was operated as a Hazardous
24 Waste Disposal Facility and the site was abandoned -
25 I'm sorry, the site was abandoned in 1982 by Sealand
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1 8
2 Restoration, Inc.
3 Following that period, the DEC through
4 their contractor. Dames and Moore, conducted
5 investigation of the site in 1983, 1984, and subsequent
6 investigation in 1986 and 1987.
>
7 Their investigation of the site identified
8 three principal areas of contamination.
9 MEMBER OF THE AUDIENCE: Could you stand to
10 the side so that we can see it?
11 MR. NUNES: I'm sorry. Too, the overhead
12 doesn't completely show on this, I have to keep moving
13 it around but, anyway on the site there are several
14 areas that are indicated as shaded areas here
15 (indicating), where landspreading took place.
16 Landspreading was an approved of practice
17 where with petroleum oil-based liquid was spread onto
18 the fields. The DEC contractor collected samples from
19 these areas and the sample results indicated that there
20 were low levels of inorganic metal pesticides and PCB
21 compounds.
22 The study that Dames and Moore conducted
23 concluded that although these contaminants were
24 present, they were present at low levels and that no
25 remedial action was needed for this area and no action
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1 9
2 was taken.
3 A second area of contamination that was
4 identified in the study is a drum-storage area shown
5 here as Insert A, (indicating). This area was an
6 unpermitted area where about two hundred drums were
7 found. These drums were filled — were empty or
8 partially filled with a tar-like sludge material.
9 The Dames and Moore study in 1986 and 1987
10 concluded that this area needed to be remediated and it
11 was by the County in 1987 and that area was cleaned up.
12 Also in this area is a storage tank, this
13 is a tank that was used to collect the waste oil before
14 it was landspread onto the landspreading field and that
15 was also cleaned up or removed in the site.
16 The third area of contamination identified
17 in studies was - is shown here as Inset B, that is
18 known as the cell disposal area and that is an area
19 where essentially a pit of the length of about a
20 hundred feet, and width about fifty feet, where drums
21 were buried.
22 The study also indicated that this was an
23 area that needed to be remediated and it was by
24 Sevenson Environmental Services under contract with the
25 DEC that action was undertaken in 1989 and 1990.
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1 10
2 That action included excavation of the pit,
3 removal of the drums. There were about fifteen-hundred
4 drums, about five-thousand-cubic yards and about
5 three-hundred-and-fifty gallons of waste water. All
6 that waste was taken off site to a permitted disposal
\
7 facility for incineration.
8 Following this the EPA reviewed the work
9 that DEC conducted and EPA issued a Record of Decision
10 in 1990 and the Record of Decision stated that the
11 actions that the State undertook to address these areas
12 of contamination were correct actions and that they -
13 but that further work was needed just to identify if
14 any other areas of the site needed to be remediated.
15 The other areas of the site included the
16 wetlands to the east of the cell disposal area and also
17 to investigate the groundwater aquifer east of the
18 disposal area. Also additional samples would be
19 collected in other areas of the site to determine if
20 any remaining - if there was any residual soil
21 contamination.
22 Okay, this study was begun in August of
23 1992 by having co-services of IT Corporation under
24 contract with EPA, and I'll turn the presentation at
25 this point to Maria, she'll discuss that phase of the
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1 11
2 study.
3 MS. WATT: Thanks, Bob. My name is Maria
4 Watt, I'm Site Manager for IT Corporation and I managed
5 the investigation and feasibility study that was
6 conducted over this two-hundred-acre site. In the work
\
7 plan we proposed to put over twenty-one borings that
8 covered the whole area. Eighteen surface water and
9 sediment samples. In the western wetland area -
10 eastern wetland area and in the western wetland area.
11 We also took sixteen hand borings and over
12 forty-two groundwater samples including residential as
13 well as on site wells and the additional wells that we
14 had put in.
15 After the meeting you can come up and look
16 at the site with the samples or where we took the
17 samples and also the location of the residential wells
18 in the perimeter of the site.
19 We conducted a - the first phase of the
20 investigation was conducted in 1992 and we basically,
21 in all these samples we really only found once area
22 that came up with contamination. This was down in the
23 area of the disposal cell, specifically this well right
24 here. That well (indicating).
25 Since that was the only area we came up
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1 . 12
2 with significant contamination we decided to go back to
3 a Phase 2 investigation, a second round to implement
4 additional wells and investigate this area a little bit
5 better since we only had once well in that area.
6 So we went to a Phase 2 investigation and
\
7 put in four more locations to investigate, upgrading
8 it, downgrading it and sidegrading the disposal cell.
9 The unique feature of this site is that
10 there is a groundwater divide extending from the south
11 southwest to the northeast, and this divide causes
12 overburdened groundwater to flow to the east, east of
13 the divide and west, to the west of the divide.
14 Since the disposal cell, this area right
15 here (indicating), is to'the east of the divide, only
16 groundwater flowing in this direction comes in contact
17 with any residual soil left downgrade into the disposal
18 cell. So groundwater flowing in this direction
19 (indicating), is the only groundwater that comes in
20 contact with this area downgrading it.
21 On this poster board we also showed the
22 localized other area of contamination and we found the
23 reason it really hadn't migrated at all is because of
24 the geology, in the area of the Sealand Site there are
25 dense till layers which tend to prevent migration.
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1 13
2 Cobbly, very dense material that prevents any
3 groundwater movement.
4 And looking at aquifer, this is a localized
5 area that we found some elevated levels of volatile
6 organics. These are our surface-water samples going up
•»
7 here and we found very little contamination in the
8 surface water and sediments samples; however, in some
9 of these overburdened-groundwater locations we did find
10 elevated levels but it was pretty much confined to this
11 localized area really downgrading the cell.
12 This is a aerial view (indicating). Here's
13 a cross-sectional view showing the till layers, a till
14 lens that extends right down here which prevents
15 downward migrating immediately downgrading of the
16 disposal cell.
17 And this was the once well that we did -
18 out of all the groundwater samples that we did find
19 contamination in that, which spurred on additional
20 wells in the area. So we sunk - this is in with seven
21 immediately farther downgrading from our first well
22 that we put in, to try and define the area.
23 The depth to water is about twenty feet
24 here and then the depth - this saturated thickness is
25 maybe thirty feet so it's under - it's like between
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1 14
2 thirty and fifty feet. It gets deeper as you start
3 going up into wetlands area.
4 I'd like to turn it back to Bob to talk
5 about some of the feasibility studies and alternatives
6 we evaluated to come up with cleanup for this localized
N
7 area.
8 MR. NUNES: This table shows the principal,
9 organic principal contaminants that were found in the
10 aquifer just east of the cell disposal area which is
11 the most contaminated area in the site.
12 By the way, if you can't see any of this,
13 there were handouts that were available as you came in
14 that have the slides on them, so if there something you
15 can't see or if you would like to look at it from that
16 vantage point, you can do that.
17 I just wanted to show this table so that
18 you could see most of the contaminants that were found
19 in the aquifer are VOC, Volatile Organic Compounds,
20 lack of contaminants.
21 The ones that we found with the highest
22 concentration was acetone. That was very important
23 because acetone, it's presence in this - at this site
24 meant that many standards methods of remediating
25 groundwater that we use at Superfund Sites, Hazardous
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1 15
2 Waste Sites, wouldn't about affected at this site.
3 These methods that I'm referring to, there
4 are several that come to mind, are air stripping and
5 carbon absorption, but because of the presence of
6 acetone these methods wouldn't about effective, and for
N
7 that reason we focused when we did our feasibility
8 study and our proposed plan, we focused on
9 bioremediation is a means of addressing the
10 contamination in the aquifer.
11 Bioremediation is the use of
12 microorganisms, namely bacteria, to degrade and
13 detoxify organic hazardous waste by consuming them by
14 remediation. It is becoming more and more commonplace
15 as a remediation tool at Hazardous Waste Sites and is
16 very effective in removing VOCs from groundwater.
17 Once of the forms of bioremediation that we
18 looked at when we did our screening is In-situ, In-situ
19 Biological Treatment refers to the enhancing of
20 bacteria in native south and groundwater to remove VOCs
21 from the groundwater.
22 The process though, is dependent upon many
23 factors, some of these factors include the volume of
24 groundwater that you're treating, the type of
25 contaminants that you're treating and the hydrology of
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1 16
2 the area of interest.
3 In the case of the area east of the
4 disposal cell the hydrologic conductivity is relatively
5 low and for that reason we think that the necessary
6 transport of oxygen and nutrients that would be used to
7 enhance by remediation would not be very rapid and for
8 that reason we didn't evaluate In-situ Biological
9 Treatment in our feasibility study or in our plan.
10 Ex-situ Biological Treatment refers to
11 extracting the water from the aquifer and then running
12 it through a biological treatment unit.
13 This is the more common biological
14 treatment that once sees at Hazardous Waste Sites today
15 and this process we retain when we evaluate - when we
16 develop alternatives for FS, the Feasibility Study and
17 for the proposed plan.
18 We also retain off-site treatment at the
19 Ogdensburg Sewage Treatment Plant. At that sewage
20 treatment plant waste are dealt with or addressed also
21 by bioremediation and because the Ogdensburg disposal
22 was so close to Sealand we retained this as an
23 alternative.
24 Okay, we developed an alternative for
25 evaluation. Once of the alternatives is Alternative 1,
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1 17
2 No Further Action. No-action alternative is something
3 we need to include whenever we do this type of study,
4 we need to evaluate the No-Action Alternative 1 basis
5 with any action alternative that we come up with.
6 Although there is no action in addressing
>
7 contaminated groundwater/ this alternative does include
8 a long-term program to monitor groundwater and it does
9 include the implementation of the institutional
10 controls which are essentially deed restrictions to
11 prevent someone coming in and installing a groundwater
12 well and using groundwater on site, okay. The first
13 Action Alternative.
14 Alternative 2A, On-site Hot-Spot
15 Groundwater Remediation. What this is, we wanted an
16 alternative that would expeditiously remediate those -
17 those areas of the plume that Maria showed you in a
18 slide earlier, where we had the highest VOC
19 concentration like the once well where we had acetone
20 at two-million-parts per billion.
21 Also any contamination in the bedrock
22 aquifer, in the drinking-water aquifer in the region,
23 we would probably also include in the expedited action.
24 This expedited action would be installing
25 extraction wells that is aquifer extracting, extracting
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1 18
2 groundwater, storing it in a storage tank, then running
3 it through a biological treatment unit. The type of
4 biological treatment unit would be determined, if we
5 select this alternative, following the Record of
6 Decision.
N
7 • After the groundwater has been treated in
8 the biological treatment unit, it will then about
9 either reinjected into the groundwater or discharged to
10 tributaries.
11 Okay. Alternative 2B, Off-Site Hot-Spot
12 Groundwater Remediation. This alternative would employ
13 the same - would have the same intent. It would about
14 to address those VOC Hot-Spots in the area, this
15 former cell disposal area and we again install
16 extraction wells to extract groundwater from these hot
17 spots but instead of treating it on site we would truck
18 it to the Ogdensburg Sewage Treatment Plant for
19 biological treatment at the plant.
20 And primary, secondary treatment is the
21 process essentially settling an aeration to promote
22 bacterial populations to degrade the waste that would
23 about undertaken at the treatment plant.
24 In addition, or I should say before this
25 happens though, we would have to conduct a
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1 19
2 one-hundred-day pilot study at the plant to ensure that
3 there was no problem as far as the operation of the
4 plant because of this wastewater being fed into it, and
.5 also that the plant meets effluent discharge limits and
6 sludge generation.
*
7 Okay, Alternative 3A, On-Site Hot-Spot
8 Groundwater Remediation followed by On-Site Expanded
9 Groundwater Remediation.
10 What this would entail would be
11 implementing exactly what we said we would implement
12 for Alternative 2A, address the hot spot, treat it
13 site. In addition, this would be concurrent with this
14 action.
15 We would do a study to determine whether
16 natural attenuation would take place within the plume
17 in those areas outside of the hot spots but still where
18 standards are not being met.
19 Wells would do a study to determine if the
20 - if by natural processes the aquifer, the
21 contamination, would be reduced so that the standards
22 would be met and that they would about met within a
23 comparable time frame to what would happen if you did
24 take a action.
25 So wells would do that study and if that
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1 20
2 study indicated that - if that study indicated that
3 MCLs would not be achieved within a reasonable time
4 frame, then what wells would do is put in more
5 extraction wells and capture the entire plume, not just
6 those areas of hot spots but the entire plume, run this
*
7 through the entire treatment unit and then either
8 inject into the groundwater or discharge to a
9 surface-water body as an alternative to 2A.
10 Alternative 3B is Off-Site Hot-Spot Ground
11 Remediation followed by Groundwater Extraction. This
12 essentially would be the same thing as doing
13 Alternative 2B, which is extracting the hot spot and
14 trucking it to the Ogdensburg Sewage Treatment Plant
15 and, concurrent with this, as an Alternative 3A, we
16 would do the same study.
17 Determine if the area outside of the hot
18 spot but still within the plume needs to be addressed
19 or not. If natural processes would reduce the
20 contamination to MCLs. If that would not take place
21 then we would put in - extract the entire plume,
22 instead of trucking all that which would likely be a
23 large volume of groundwater, we would do - we would
24 construct a pipeline, a sewer line, to the nearest
25 tie-in to a force main for Ogdensburg Sewage Treatment
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1 21
2 Plant.
3 That would entail constructing a pipeline
4 of approximately twenty-four-thousand feet in length
5 and the nearest tie-in I can show you on another figure
6 which Steve doesn't have - the nearest tie-in is right
\
7 here (indicating).
8 The site is off the map, actually down over
9 here somewhere (indicating). I'll show you. This is
10 Tuck Road, the site is actually over here so the - the
11 pipeline would run more or less along within - I think
12 it would run parallel to Wood Road, along the abandoned
13 railroad, Ogdensburg railroad, up to the point where
14 37-A meets the railroad, which I think is somewhere
15 over there anyway, it's twenty-four-thousand feet of
16 pipeline.
17 Okay next slide. Okay, when we evaluate
18 the alternatives we use nine criteria, standardized
19 criteria to do the evaluation.
20 Alternative 3A and 3B, these are the
21 combined hot spots and the entire plume remediation
22 alternative we think are the most protective or more
23 protective of the human health and the environment than
24 the other.
25 Alternatives 2A and 2B address the hot
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1 22
2 spots. We also think, however, that Alternative 3A,
3 the On-Site Treatment and Alternative 3B, VOC hot spots
4 and the entire plume would be more protective of the
5 environment than Alternative 3B, which is the
6 alternative that takes the waste off-site to the
>
7 Ogdensburg Sewage Treatment Plant.
8 The reason for that is by not reinjecting
9 the treated water into the groundwater or into surface
10 water body we would expect more lowering of the
11 wetlands which are just east of the cell disposal area
12 and that might damage them or reduce their efficiency.
13 So for that reason we think 3A is more
14 protective of the environment as far as compliance with
15 ARARs. ARARs is the standard for Applicable Relevant
16 and Appropriate standards, in essence, State and
17 Federal regulations and standards that must be met.
18 Alternative 3A and 3B, the combined
19 alternatives, we feel, are the most effective because
20 they ensure that standards will be met where the other
21 alternatives do not do that.
22 Alternatives 3A and 3B, we feel, will also
23 provide more long-term effectiveness and permanence and
24 they are also are more effective in reducing toxicity,
25 mobility and volume again because they address the
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1 23
2 entire plume of contamination.
3 ' Is for short-term effectiveness, all
4 actions are compliant in that respect because we think
5 that they all have the expedited action which will
6 about implemented, we think, within six months
%
7 following the Record of Decision.
8 As far as implementability, the equipment
9 that would about used to run the on-site treatment is
10 readily available. There are vendors who have the
11 technology who can provide it to us if we select it.
12 As for off-site treatment again, as I
13 mentioned before, for off-site treatment we would have
14 to do a one-hundred-day pilot study to determine if
15 there would be any upset at the plant. Also we would
16 need approval from the City Council of Ogdensburg
17 before we sent any wastewater there.
18 In addition, if we select Alternative 3B
19 which is the alternative pipeline, we would have to
20 obtain easement for the property that we run the
21 pipeline through.
22 Okay, the DEC and DOH concur with EPA's
23 selection of preferred remedy and community acceptance
24 would be gauged following the public-comment period
25 when all public comments are received and we evaluate
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1 24
2 them.
3 The last criterion is cost, okay. This
4 summarizes the cost of all the Alternatives. Capital
5 Cost refers to the construction cost for each of the
6 Alternatives.
%
7 Annual Cost refers to the operation and
8 maintenance costs that are incurred every year, and
9 Present Worth refers to the total cost of the project
10 over its lifetime in today's dollars.
11 As you can see from this table, Alternative
12 2A, the capital cost is higher than Alternative 2B's
13 capital cost because you have to put a unit on site and
14 you have to - you have to purchase nutrients and other
15 supplies for that unit.
16 However, its annual cost for 2A is much
17 lower than the annual cost for 2B and that's because of
18 the discharge fee for the sewage treatment plant which
19 is relatively high, and the result is that the total
20 cost for the expedited alternative is much lower than
21 it is for the off-site treatment alternative.
22 As for combined alternatives, again you can
23 see for annual costs there is much higher yearly costs
24 for off-site treatment than the on-site treatment and
25 that is, again due to the discharge fees that the
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1 25
2 sewage treatment plant would require.
3 Also the pipeline itself raises the
4 construction costs so that the total cost of
5 Alternative 3B is much greater than the total cost of
6 Alternative 3A, okay.
\
7 So this boils down to our preferred remedy
8 which we have selected or indicated as preferred, is
9 3A, On-Site Hot-Spot Groundwater Remediation followed
10 by On-Site Expanded Groundwater Remediation.
11 .We selected this because we thought it was
12 the most effective in achieving MCLs and is most cost
13 effective and it's also most protective of human health
14 and the environment.
15 Okay, I think that if you wanted to say
16 anything - yes, I think we can open up for questions.
17 I neglected to - I just wanted to introduce also for
18 the question-and-answer period - neglected to
19 introduce, we have a representative from the DEC, Kathy
20 Eastman, and John Sheehan up front, and also from the
21 New York State Department of Health, Claudine Jones
22 Rafferty.
23 There also a sign-in sheet, if at some
24 point you haven't signed in there, I think Joel —
25 MR. SINGERMAN: Just one thing, this
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1 26
2 preferred remedy is just that, a preferred remedy, and
3 we won't make a final selection until after we consider
4 all the public comments after the comment period.
5 That's why we're here tonight.
6 Sir.
>
7 MR. HARRIS: My name is Glenn Harris and I
8 guess my comment really has to do with the length of
9 your comment period because it's too short and I assume
10 that EPA is sincere about it's desire to have public
11 input, and I recognize the community acceptance is once
12 of your criterion but your comment date that the
13 comment period goes from July 19 to August 18th, I
14 didn't receive a notice about this meeting until July
15 26th.
16 I'm a member of the Lisbon Planning Board,
17 we meet the fourth Monday of every month. Our last
18 meeting then was on July 24th, this was within a couple
19 of days before I received the notice for this meeting.
20 We won't meet again now until the fourth Monday of
21 August.
22 If we are to sort of provide any comments
23 to you as a group, we would have to basically get
24 together in the next two or three days given the number
25 of days it might take us to develop a written response,
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1 27
2 and then two or three days to mail it down to you by
3 August the 18th.
4 This is a sincere request that you extend
5 the period for comments at least for thirty days, if
6 not sixty, to someone who's been studying the site for
>
7 fifteen years, according to my calculations that
8 amounts to five-thousand four-hundred and seventy-five
9 days.
10 To put down exactly, you know, what it's
11 necessary for us to respond to you within the next ten,
12 certainly maybe forty or fifty more days ought to be
13 possible.
14 You're talking about spending once million
15 two-hundred thousand as a capital cost on this site,
16 seems likes an awful lot of money to be spending
17 without a sort of adequate period of time for us to
18 digest this document.
19 May I borrow this for a second? Now some
20 of you in the audience, I'm sure haven't had a chance
21 to look at the formal document, I haven't had a chance
22 to see the document that the Environmental Protection
23 Agency has issued.
24 But to sort of digest a document of that
25 size, let alone your presentation or even the summary
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1 28
2 that I first learned about this evening, would require
3 a considerable amount of time. Much more time than I
4 think a couple of days warrants.
5 So I guess then my comment is, that your
6 period for public comments is too short and I would
s
7 request then that you extend the length of time for us
8 to have a chance to look at the document carefully, and
9 provide a response that would allow us to inspect these
10 alternatives as you would like us to.
11 I would note that at the GM Superfund Site
12 in Massena, the Environmental Protection Agency did
13 extend the public comment period, so there is precedent
14 this.
15 MR. SINGERMAN: You said your Planning
16 Board meeting was when, August? What was the date?
17 MR. HARRIS: We meet on the fourth Monday
18 of every month.
19 MR. SINGERMAN: So that would about August
20 28th.
21 MR. HARRIS: That would about the next time
22 that we would have a chance to bring this up and
23 discuss it.
24 MR. SINGERMAN: Assuming that we were to
25 extend it, how much more time beyond that? You said
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1 29
2 thirty, sixty, forty-five days, whatever. Would two
3 weeks beyond that meeting about enough time, because
4 presumably you're going to discuss the proposed remedy
5 at the meeting, right, and develop comments at that
6 time?
\
7 MR. HARRIS: Correct, look over these
8 documents and, well, you know how things work in small
9 towns at rural planning boards.
10 So I think the longer we have the more
11 considered response we would get. But I would think
12 that we would at least need a couple of weeks after
13 that.
14 MR. SINGERMAN: So basically we're talking
15 about maybe a couple of weeks then from the time that
16
17 MR. HARRIS: Yes, maybe mid-September.
18 MR. SINGERMAN: Okay, we can. The reason
19 we're here is to get public input. If your feeling is
20 there is a need for additional time, we have no
21 objection to extending it.
22 I guess we'll have to at some point have a
23 public announcement about the extension. We will
24 consider extending it but we have to come up a with
25 another date.
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1 30
2 At this point I'm noL at liberty to say to
3 what date we're going to extend it but we would
4 consider extending it.
5 MR. KATZ: We're willing to work with the
6 Town if you can get a better idea. We try - that's why
>
7 we try to write something like this because we don't
8 expect everyone to sit down and read a thousand-page
9 technical document. We try to boil it down to section
10 sieve summary to what we found, what the different
11 alternatives are.
12 MR. HARRIS: Were they conducted before
13 this date?
14 MR. KATZ: Yes, the comment period started
15 when these arrived in Town, that's what officially
16 started the comment period. We took out a legal ad in
17 the Journal announcing that they were in the Town.
18 Also there was a press release went out a
19 little bit before this meeting announcing this
20 meeting, and there was mailings to people we thought to
21 be Town officials. We sent the proposed plan to
22 everyone we thought interested, we sent notice of this
23 meeting and that this document was available.
24 It was done right before the big comment
25 period so they would have gotten it on the 27th, that's
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1 31
2 possible, probably sent down on the 15th or 20th before
3 the comment period started.
4 MR. HARRIS: If you could extend the
5 deadline, it would about appreciated.
6 MR. KATZ: Why don't you come up and
\
7 discuss it with Joel after the meeting.
8 MR. SINGERMAN: Once possible scenario, you
9 said you need about two weeks, that would about
10 approximately September 8th or thereabouts which will
11 through — with the extension which would give you two
12 weeks from the time of the Planning Board.
13 Do you think that would about a reasonable
14 time frame?
15 MR. HARRIS: It would help.
16 MR. SINGERMAN: Okay.
17 MS. CONNETT: I'm Ellen Connett,
18 C-o-n-n-e-t-t. I'm from Canton, I concur with the
19 length of the comment period. I would like to see at
20 least sixty days for a response to what you are putting
21 forward tonight Vasco Services, they performed the
22 study in 1980?
23 MS. WATT: Uh-huh.
24 MS. CONNETT: Is anybody from their
25 organization here tonight?
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1 32
2 MS. WATT: We are under contract with
3 Vasco, so basically we are key, meaning partners. IT
4 takes a certain side, Vasco takes — I'm the manager.
5 Basically I deal directly with Bob on managing the
6 site.
7 MS. CONNETT: So you're a representative for
8 Vasco and IT?
9 MS. WATT: Right.
10 MS. CONNETT: But who do you generally work
11 for?
12 MS. WATT: IT.
13 MS. CONNETT: IT. I just have a few
14 questions about your presentation. What was the depth
15 of the well that you showed before when you had found
16 those high concentrations?
17 MS. WATT: The depth of this, about
18 fifteen, twenty feet was the screen interval; at twenty
19 feet was where we found a lot of contamination.
20 MS. CONNETT: Okay, that was the well —
21 MS. WATT: Immediately downgradient.
22 MS. CONNETT: Where has bioremediation with
23 such high levels of acetone been performed before?
24 What other sites in the United States?
25 MS. WATT: You know Bog Creek Farm in New
-------
1 , 33
2 Jersey, they have used that and they have implemented
3 it.
4 I'm not sure the stage that site's at.
5 MR. KATZ: Well past construction.
6 MS. WATT: In construction?
\
7 MS. CONNETT: Where is that?
8 MR. KATZ: Burlington County.
9 MS. CONNETT: What is the name of the town?
10 MR. KATZ: I can't give you more
11 information, I'm —
12 MS. CONNETT: Is this the only place that
13 you're aware of where bioremediation has been used for
14 acetone?
15 MR. KATZ: It's difficult, we're only here
16 covering New York and New Jersey, I would have to do
17 some research. Off the top of my head — I could look
18 into it as far as what other EPA regions—
19 MS. CONNETT: I would really appreciate
20 that. I think it would about good for people to know,
21 to see what the effectiveness was, what levels you were
22 able to bring it down to, et cetera.
23 I think that would about valuable
24 information.
25 MR. NUNES: In general, bioremediation for
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1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
34
contaminated groundwater can be affected up to
ninety-nine percent.
MS. CONNETT: It would about nice to see
examples, where similar indications of these high
levels, of what the end result was and the problems
\
that they had, so —
MS. WATT: It's a conventional, widely used
type of remedial solution.
MS. CONNETT: Has IT performed this in
other places?
MS. WATT: Sure, we have put in a lot of
bioremediation all over New Jersey, New York, actually
nationwide.
MS. CONNETT: For similar situations of
levels of acetone of these concentrations?
MS. WATT: Yes. I could do that, also give
you some information about IT in particular but I will
get more about all companies in general.
MS. CONNETT: That would about great,
especially IT remediation efforts, what you have been
involved with your companies.
MS. WATT: Sure.
MS. CONNETT: Okay, I'll really about
interested in that.
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1 35
2 How does the concentrations of acetone at
3 the Sealand Site compare to other contaminated sites in
4 the U.S.? Are these very high, some of the highest,
5 below the highest?
6 MR. NUNES: In comparison with some sites
\
7 we felt that the levels that we found align, it is
8 relatively high and high enough to warrant doing an
9 expedited action to go in and address those hot spots
10 as soon as we can.
11 So I can't really speak about other sites
12 because I only have three sites myself and I only have
13 limited contact with what goes on in other sites, but
14 from what I have read, it seems like that this type of
15 level that we're seeing here have been found in other
16 sites where bioremediation has been employed and has
17 been effective in addressing acetone.
18 * MS. CONNETT: What type of illnesses or
19 developmental neurological impacts or cancers are
20 attributable to exposure to acetone or the other
21 contaminants that you have identified?
22 MS. WATT: Acetone itself is not a
23 carcinogen, it's a hazard. Basically nail polish, nail
24 polish —•
25 MS. CONNETT: I'm saying what illnesses or
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1 36
2 reproductive or neurological impacts or cancers,
3 anything, ill health, attributable to exposure to the
4 contaminants that you want to remediate?
5 MS. WATT: Every risk is mentioned. The
6 risk numbers are almost acceptable, they are within the
N
7 acceptable range of EPA limits, so far as cancers is
8 concerned acetone does not produce cancer or is not
9 carcinogenic.
10 It's a hazard, or the hazard index is
11 • above 1, which is the acceptable level. But acetone is
12 a commonly used substance. Acetone is found in nail
13 polish remover and it's found in everyone's house.
14 In terms of specific target organs that it
15 targets, there are several target organs that it
16 affects. However, I don't have my toxicologist here so
17 we'll have to get back to you on the specific effects
18 that acetone actually incurs so we would have to get
19 back to you.
20 MS. CONNETT: Well, for contaminants then
21 what do you want to remediate?
22 MS. JONES RAFFERTY: Claudine Jones
23 Rafferty, New York State Department of Health.
24 Once of the things I'd like to say to
25 answer your question is that the type of health effects
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1 37
2 that would occur from exposure of any kind of chemical
3 is going to depend on the type of exposure, if exposure
4 is actual occurring.
5 EPA specifically has not found toxicity and
6 exposure to acetone is not occurring right now and we
>
7 don't expect it to occur based on the proposed
8 remediation that EPA presented tonight.
9 What they are planning to do is capture the
10 acetone in groundwater at the site before it moves off
11 site and could get into residential wells.
12 Acetone is something that everyone produces
13 naturally in their body in small amounts. It's part of
14 metabolism process and so acetone is always in your
15 body.
16 Acetone is also very common is Maria
17 mentioned, often found in common household products
18 such as nail polish remover which many people probably
19 keep in their home.
20 So again, the type exposure, the type of
21 effect you would expect is this is not something that
22 will be occurring right now.
23 MS. CONNETT: Is this addressed in your
24 larger document for all —
25 ' MS. WATT: Yes, the entire Risk Assessment.
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1 38
2 MS. CONNETT: So each contaminant of
3 concern here is addressed in that document?
4 MR. SINGERMAN: Also the small document is
5 summarized risks.
6 MS. CONNETT: Can I get a copy of this
\
7 document?
8 MR. KATZ: The larger one? There is once
9 that we keep locally right in the Town Hall that' s on
10 reserve for anyone to look at or copy.
11 MS. CONNETT: Can I get a copy?
12 MR. KATZ: I don't know.
13 MR. NUNES: Do you want a copy of the full
14 report?
15 MR. SINGERMAN: Just the Risk Assessment.
16 MR. KATZ: The Risk Assessment is part of
17 the larger report.
18 MS. CONNETT: Is that possible for people
19 to get a copy?
20 MR. SINGERMAN: How about if we put a
21 second document in the repository?
22 MS. CONNETT: And allow people to take it
23 home for an evening or two?
24 MR. KATZ: As long as there is once there
25 for everyone.
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1 39
2 MS. CONNETT: So if you give the Town Hall
3 two copies then they can let people take once home and
4 • keep once there?
5 MR. KATZ: If it's okay with the Town,
6 sure.
%
7 MS. CONNETT: I would request that.
8 The bioremediation that you are
9 considering, is this a licensed technology? Is this
10 technology once you've - do you have to apply to
11 someone for a license? Does —
12 MS. WATT: Is there a patent?
13 MS. CONNETT: Yes.
14 MS. WATT: Various companies have different
15 patents on different versions of bioremediation.
16 MS. CONNETT: Which once are you
17 considering?
18 MS. WATT: We haven't got to the predesign
19 stage, we don't know which type we're going to use
20 right now.
21 MS. CONNETT: Is the different technology
22 placed in this document?
23 MS. WATT: Yes.
24 MS. CONNETT: That's if the moment, thanks.
25 Once other thing, Claudine Eastman from the DEC?
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1 40
2 MS. EASTMAN: Kathy Eastman.
3 MS. CONNETT: Kathy Eastman.
4 MR. SHEEHAN: John Sheehan, and I'm from
5 DOH, also.
6 MR. KATZ: S-h-e-e-h-a-n. Other questions?
>
7 MR. HASSIG: Yes, sir. My name is Don
8 Hassig, H-a-s-s-i-g. Does tonight's presentation
9 contain all the information provided on the most recent
10 ground-testing data?
11 Will there be any, say, like presentation
12 that will cover say, residential-well testing that was
13 done because that wasn't really discussed.
14 MS. JONES RAFFERTY: I think we have met
15 before. The Department of Health has sampled a number
16 of residential wells around the site as well as EPA.
17 EPA has provided the residents with copies
18 of their results and the Department of Health has also
19 provided the residents with copies of their results.
20 The Department of Health also held a public
21 meeting some time last summer, I think. I can't
22 remember the —
23 MR. HASSIG: Last August specifically to
24 address the residential-well issue and concerns about
25 the drinking water quality.
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1 41
2 MS. JONES RAFFERTY: Then we did send out a
3 meeting announcement with that and we developed a fact
4 sheet, also, to distribute to the residents.
5 MR. HASSIG: About that didn't cover this
6 most recent round of testing.
^
7 MS. JONES RAFFERTY: Didn't include the
8 most recent testing by EPA but we have presented the
9 document to the residents and they have gotten the
10 information that they need.
11 I think that RA Report included
12 second-round-sampling data, if I'm not mistaken, and
13 there will be copies of that.
14 MR. HASSIG: So there - there won't be any
15 public presentation on the last round of data as far as
16 residential wells go?
17 This whole presentation here on that last
18 round of data is - I'm just wondering if there would
19 about any kind of public presentation of information
20 that was gathered on residential wells?
21 MR. KATZ: The letters went out to people,
22 notification on the results went out a couple of months
23
24 MR. NUNES: We sent letters to the
25 residents informing them of the results of the samples
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1 42
2 that we did collect in the second round.
3 In summary, the results did not indicate
4 anything of concern, we didn't see any exigencies like
5 we did in a few isolated wells in the first round, and
6 for that reason that's pretty much why we didn't
>
7 discuss that area at this point because there wasn't
8 really anything there.
9 MR. HASSIG: Well, how would it affect the
10 earlier decision to provide bottled water to the
11 residents that had wells?
12 MR. NUNES: Okay, the second round of
13 samples that EPA collected and had results from, from
14 DOH, DOH test results were used in evaluating whether
15 or not to .continue bottled water, to expand it or
16 whatever was necessary.
17 And what we're saying is that the results
18 of - DOH test results and EPA test results did not
19 indicate that there was a problem with respect to
20 residential wells being in any way impacted by
21 contamination migrated from the site.
22 When we - we issued our orders to the EPA
23 to potentially to distribute bottled water, we did that
24 as a protective measure to ensure that there would
25 about no impact to residential wells because we did not
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1 43
2 have all of the information at the time, not because we
3 thought there was something going on. It was only a
4 protective measure, that was why it was done at that
5 time.
6 When we had all our data in and we saw
t
7 there was no connection between residential well
8 results and on-site monitoring we'll results, we said
9 we could see at that point that there was no reason to
10 have the EPA continue the bottled water and we told
11 them so, and they have discontinued it.
12 MR. KATZ: Yes, sir.
13 MR. MATTHEWS: Patrick Matthews. So what
14 you're saying that residential-well water is safe to
15 drink, basically the only cleaning up we have done on
16 the site of the water?
17 MS. JONES RAFFERTY: Let me address that.
18 MR. MATTHEWS: I understand my well had a
19 high lead level, I don't know where the hell it came
20 from.
21 MS. JONES RAFFERTY: We sampled a number of
22 residential wells, the Department of Health sampled
23 the wells in conjunction with EPA during the course of
24 remedial investigation that was completed.
25 EPA collected the first round of data, I
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1 44
2 can't remember the exact date, Bob, but the Department
3 of Health has also sampled the residential wells in
4 August '93, and we sampled them again in okay.
5 August'94, and some residential wells in March'95.
6 Some of the wells that were sampled by -
\
7 Bob has already explained that initially some
8 contaminants were found in the first round that EPA did
9 and they distributed bottled water as a protective
10 measure based on those early findings and then the
11 Department of Health also did some samplings.
12 We found some high lead in some of the
13 residential wells and bottled water was also
14 distributed through EPA. So then DOH continued to
15 sample the residential wells where we had found some
16 high levels of lead and we focused on those homes
17 because we saw some fluctuating levels over time.
18 Some of the wells that we sampled in the
19 area we also found didn't have any contamination like
20 volatile organic or metal, but they had some problems
21 with just bacteriological contamination.
22 But there are some homes where we have
23 found or visited the homes where we tested the wells to
24 find out how corrosive the water is because time the
25 corrosive water can leach lead out of the pipe in the
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2 solder that is used to weld the pipes together.
3 We didn't find any corrosive water in any
4 of the homes that we tested. Then we sampled or
5 collected some samples again from those homes, samples
6 . — filtered and unfiltered samples.
s
7 Basically that means we collected the
8 samples directly from — that people would turn on from
9 the tap, then we checked the sample, poured it through
10 a special filtering device. What that does is filter
11 out any sediment or particulate that might be
12 floating. We wanted to find out if there were any
13 sediment or particulate in the water that we sampled
14 before where we found the high lead.
15 We didn't find any difference between the
16 filtered or unfiltered samples in those homes where we
17 found the lead before. So today we have the most
18 recent sampling that we did in March 1995, that did not
19 show any level of lead.
20 MR. MATTHEWS: Mine had dropped right off
21 for some reason.
22 MS. JONES RAFFERTY: It's safe, bathe in
23 it, drink it, do whatever you wanted with it based on
24 what we found.
25 MR. MATTHEWS: Okay.
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MS. JONES RAFFERTY: We even sampled your
home for bacteriological, that was found to be fine, as
well.
MR. MATTHEWS: Okay.
MS. JONES RAFFERTY: Other homes1
^
bacteriological was fine. Still individuals having
concerns about their water quality can request that it
be tested regularly through the Massena District Office
or St. Lawrence County representative.
MR. MATTHEWS: You're going to continue to
test the water on a yearly basis?
MS. JONES RAFFERTY: We're not going to
continue to test the water based on what we have seen
and the data that we have.
MR. SHEEHAN: John Sheehan, also from DOH.
Because of some of the unusual things that we found,
especially with the fluctuating levels of lead we could
do samplings of your well. It would about totally
separate from the Sealand investigation, but our
Massena District Office can provide that service to you
just as a separate issue.
MR. MATTHEWS: Right, thank you.
MR. KATZ: Ma'am.
MS. HAMMILL: My name is Stacey Hammill and
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1 47
2 I'm with the St. Lawrence County Environmental
3 Management companies. I wish to agree with Mr. Harris
4 that we do need additional time, I would think thirty
5 days would be the least we could do because we would
6 have to study this document and make comments on it.
%
7 Also as this remedial action goes on, I
8 think some of these home owners should have their water
9 tested without having to request it from Massena.
10 Should be a matter of course as a remedial action takes
11 place to make sure that the water stays clear and
12 useable.
13 MS. JONES RAFFERTY: Bob, again like - what
14 I'd like to offer is that EPA - we have got base —
15 based on data we collected to date, we know where the
16 groundwater contamination is right now. We have
17 already determined that it isn't residential wells.
18 EPA has been monitoring wells. Set up as
19 part of the remedy for the site, EPA is going to be
20 monitoring those groundwater wells to make sure that
21 the contamination isn't moving further off-site or
22 isn't migrating off-site.
23 MR. SINGERMAN: Controlling the
24 groundwater, too, that would also help reduce the
25 levels that are migrating.
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2 MR. NUNES: Also part of our alternatives,
3 all of them include long-term groundwater monitoring.
4 What we need to do is delineate as best we can the
5 range extent of the plume, both laterally and
6 vertically and we'll do that with additional on-site
\
7 monitoring as well.
8 So once we have that information, we'll
9 have a better idea as to whether there is going to be a
10 - or whether there could be any impact, any off-site
11 receptors, although they are very far removed from the
12 area of contamination that we do see on site.
13 But through on-site monitoring wells, we
14 can monitor whether there is a potential for impact for
15 residential wells, so that might reduce the need to be
16 monitoring residential wells for that purpose.
17 MR. MATTHEWS: Any more cleanup necessary
18 on site content around the site? Has that all been
19 done and taken care of?
20 MR. NUNES: No, the only thing I guess we
21 didn't include in our presentation was that there is
22 some subsurface contamination in the vicinity of the
23 former cell disposal area below the water table.
24 There is some acetone in those - in that
25 soil and - but we think that the best way to address
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2 that is through groundwater, natural flushing.
3 As through groundwater flushing, exactly
4 what that would do, in cleaning up the groundwater,
5 whatever contamination is remaining on the soil will be
6 released into the groundwater and then about removed at
%
7 the time when we pump it out.
8 MR. MATTHEWS: No harm there to anybody,
9 really.
10 MR. NUNES: There is nobody there right now
11 so - but, yes, there is that once era that we did see
12 some subsurface contamination that we think will be
13 addressed by any groundwater remedy that we employ.
14 MS. CONNETT: Ellen Connett. You mentioned
15 in once of your alternatives that once of the things
16 would be deed restrictions, in the future deed
17 restrictions on use of land.
18 You mentioned it in conjunction with once
19 of the alternatives, I have it somewhere here but I
20 don't remember - from a few years ago when you had
21 discussed that this clean up so far has cost around
22 twenty million dollars.
23 MR. NUNES: Which cleanup?
24 MS. CONNETT: Seaway.
25 MR. NUNES: The State cleanup.
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2 MS. CONNETT: At the disposal cell.
3 MR. NUNES: Estimated cost for the
4 preferred alternative.
5 MS. EASTMAN: Kathy Eastman, I'm with the
6 Department of Environmental Conservation.
>
7 MS. CONNETT: A few years ago we were
8 discussing it was twenty-million dollars or
9 nineteen-something-million dollars and preparing to
10 spend that you did not know who the owner of that
11 property was. I had asked that question.
12 My question today is, do you know who owner
13 this site having spent twenty million dollars on it and
14 if you do, can you share that with us, and if you
15 don't, how can you enact deeds restrictions if you
16 don't no who the owner is?
17 MR. NUNES: I don't know the owner - the
18 owner of the site was doing restoration, they have
19 abandoned the site. There is no owner that I know of.
20 MS. CONNETT: So who owns the land?
21 MR. NUNES: I don't think know who owns the
22 land.
23 MS. CONNETT: At this point twenty million
24 dollars has happened on a piece of land that no one
25 knows who owns it.
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2 MR. KATZ: That's was with the consent of
3 Superfund.
4 MR. SINGERMAN: The way the law
5 says: "severally liable", so meaning that if we have
6 once party responsible we have a hundred parties
\
7 responsible.
8 Basically we look for all the parties
9 responsible. If we can't identify the owner or the
10 even is unwilling or unable to do any work —
11 MS. CONNETT: It just seems to me that if
12 you can't identify the owner of this property, he might
13 be a billionaire.
14 MR. SINGERMAN: As far as we know the
15 companies is a bankrupt company.
16 MS. CONNETT: So nobody knows who owns this
17 particular site? I just want to know that, you do not
18 know who owns this land? Does anybody know who owns
19 this land? Nobody knows.
20 MR. SINGERMAN: It doesn't really matter
21 regardless of who owns the property, all parties that
22 generated the waste of which the owners are
23 responsible, so if we can't identify the owner, the
24 owner is bankrupt, does not relieve of the
25 responsibility of the other parties.
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2 MS. CONNETT: If the owner was bankrupt you
3 would still about able to identify the person.
4 MS. WATT: Potentially, the parties have
5 been identified.
6 MS. CONNETT: Those are the people whose
>
7 waste has been dumped?
8 MS. WATT: Those are the people held liable
9 for the site.
10 MS. CONNETT: Will the people of Lisbon
11 ever be told, ever find out who owns this property?
12 MR. KATZ: I'm not a lawyer, we don't have
13 a lawyer here. It's plausible, plausible, you know I
14 find it really hard to do. Super fund is called that,
15 because the Federal government came in and said, what
16 happens with these abandoned toxic-waste sites?
17 If you find someone trying to use some
18 enforcement measures to clean it up, that's terrific.
19 When you don't have that capacity on these sites, they
20 set up this program to deal with it and eliminate the
21 threat.
22 When I first started with EPA it sounded
23 very hard to believe sometimes. You go back to the
24 fifties and sixties and there is a paper trail of
25 companies divesting, selling, companies changing names,
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2 and the trail just ended.
3 MS. CONNETT: So in New York State, would
4 the State own the land then if it's abandoned?
5 MR. KATZ: I don't think know the legal
6 ramifications of that.
%
7 Then you go into statutes, are there
8 further other generations? Was there a landlord? I
9 know when we talk about deed restrictions.
10 From my limited knowledge, a
11 deed-restriction covenant placed on property doesn't go
12 with the owner, it's supposed to outlive the owner.
13 Goes with the land, goes with the land, the actual
14 land.
15 So that is the whole purpose, so if it
16 changes ownership or, well, we're going to build condos
17 here, that's the whole point, goes with the land.
18 MR. SINGERMAN: Also for your information,
19 once we select a remedy for the site, after the comment
20 period we decide upon a final remedy, we will approach
21 the parties that are responsible and ask them whether
22 they intend to either to contribute or pay for it and
23 if not, we'll take the action and at some time in the
24 future, seek recovery of our costs.
25 ' MS. CONNETT: What percentage has been
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2 repaid by the parties responsible whose waste ended up
3 at this site? Have they paid any money towards any
4 remediation so far?
5 MR. SINGERMAN: At this point no, but they
6 did pay for the distribution of the water.
•s
7 MR. KATZ: The biggest hurdle is
8 identifying the parties and notifying them.
9 MS. CONNETT: Are these parties responsible
10 in this document here?
11 MR. KATZ: I don't think they are listed,
12 if they are —
13 MS. WATT: But they did provide bottled
14 water.
15 MR. KATZ: EPA, as far as Superfund Law,
16 doesn't have - what's the word I'm for - a deadline on
17 when you can use enforcement measures. We don't have a
18 statute of limitations.
19 MS. CONNETT: There are documents from
20 depositories that do list —
21 MR. KATZ: Some of the potentially
22 responsible parties are listed in the documents.
23 MS. CONNETT: And there is, I think, legal
24 action to try to recoup some money from this for
25 the remediation?
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2 MR. SINGERMAN: We intend to, again as I
3 said, we hope to negotiate with them after we select
4 the remedy to recover the cost.
5 We spent quite a bit of money on the study,
6 the State spent quite a bit of money on the cleanup
7 ' itself. What we would attempt to do is negotiate not
8 only the performance of different work that's
9 necessary, but recovery of all costs that have been
10 already incurred.
11 But again, if we can't convince them to
12 settle, then we may have to do the work ourselves using
13 Superfund, then at some point in the future then
14 recover our costs.
15 MR. HARRIS: Glenn Harris. As a point of
16 information, the potentially responsible parties have
17 formed a consortium, hired a private investigator who
18 is already collecting information to use in a lawsuit
19 if EPA tries to sue them.
20 I know that for a fact because the private
21 investigator has interviewed me.
22 MR. KATZ: Other questions or comments?
23 MS. CONNETT: Will you let us know how long
24 the comment period will be?
25 MR. SINGERMAN: Since I think as suggested
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2 - it was suggested that the fourth Monday in August
3 would be the Board meeting and then we' 11 give two
4 weeks beyond that, that basically will be September
5 8th, basically thirty days from today would be the
6 comment period.
\
7 So you have thirty days from today to
8 comment, which I think will cover both concerns.
9 MR. HARRIS: Maybe we should have a chance
10 for the Planning Board to forward it to the Town Board
11 which means another confusion, that most of us are sort
12 of volunteers, unpaid people up here.
13 Maybe we need a couple of weeks after the
14 Town Board meeting.
15 MR. KATZ: If it would help I can
16 disseminate so people have a chance to look it over.
17 We do have a time line that we are
18 concerned about, sir. I will disseminate to whatever
19 members' list you give me so you can discuss it, rather
20 than lose two weeks waiting to discuss it.
21 MR. SINGERMAN: We also have a stack of
22 quite a few of them over there.
23 MS. BURNS VERLAQUE: Mary Burns Verlaque,
24 Director of Planning and for the Environmental Council
25 for St. Lawrence County.
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2 I have spoken with you before the meeting
3 ' to indicate that we did have comments that we would
4 want to be making and Miss Hammill is the chairman of
5 the Environmental Management Council.
6 We routinely meet on the third Wednesday of
7 each month and our next regularly scheduled meeting is
8 the third Wednesday of September.
9 We are cognizant of your need to keep a
10 timetable, but I think the comments here tonight are
11 telling you that we would like to comment and it's
12 going to take a small amount, but still an appreciable
13 amount of time, for us to gather together comments and
14 review them with the citizens that are both on Mr.
15 Harris1 Planning Board and on the Environmental
16 Management Council.
17 These are the groups that have been
18 involved with this project for over fifteen years. We
19 understand your time frame but we need more than one
i
20 thirty-day period and I suggest you just, you know,
-21 work in a sixty-day period and that will give everyone
22 enough time to do the comments and be done with it.
23 What is the constraint that will not allow
24 sixty days from today?
25 MR. KATZ: Well, it's not - we can. It's -
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2 the consideration is the Federal fiscal year whatever I
3 can do to get that, maybe a letter in to us requesting
4 a extension of the comment period. Whatever you say.
5 MS. BURNS VERLAQUE: We'll do that.
6 MR. KATZ: Whatever parties, whether it's
s
7 the County or Town Board or whatnot, and get that in by
8 the comment period and then we'll come up with whatever
9 your needs are and we'll deal with that and we will
10 respond to you.
11 MR. SINGERMAN: Also the term, too. The
12 longer we take selecting a remedy, the longer it takes
13 to get started.
14 Also be aware that getting started, the
15 longer we delay, you're working with winter. We may
16 not be able to get anything started until next spring
17 or next summer.
18 Also the thing is, we have to negotiate
19 with the responsible parties, the sooner we select a
20 remedy, the sooner the whole process starts.
21 MS. BURNS VERLAQUE: Well, in a
22 fifteen-year process we're not thirty days tight, I
23 don't think.
24 MR. MATTHEWS: Agreed.
25 MR. KATZ: Any other additional questions
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2 or comments?
3 MS. BURNS VERLAQUE: Mary Verlague. Who
4 produced the larger document that's here tonight?
5 MR. KATZ: I don't think know what you are
6 pointing at.
\
7 MS. BURNS VERLAQUE: That was done, the
8 complete report?
.9 MR. NUNES: That was done by Vasco
10 Services, IT Corporation.
11 MS. BURNS VERLAQUE: Is it possible for the
12 County to have a copy of this, I know the Township has
13 once here. The County Planning Board and Environmental
14 Management Council were involved initially with this
15 effort, as you know.
16 MR. NUNES: I think we can.
17 MS. BURNS VERLAQUE: We sponsored the
18 initial cleanup of the site, thank you.
19 I'll give you my card.
20 MR. NUNES: Thank you.
21 MR. KATZ: I don't think know if anyone
22 else has any additional questions or comments, if not
23 we'll stay a few minutes, if anyone thinks of anything,
24 about anything else, okay.
25 I thank you all for coming. We'll respond
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2 to a number of questions that were left open, we'll try
3 to respond to them as quickly as we can.
4 Thank you very much. Take a moment to use
5 the sign-in sheet.
6 (Conclusion of proceedings).
s
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10 ST. LAWRENCE COUNTY) SS
11 TOWN OF LISBON )
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CERTIFICATION
I, Avril Warner, do hereby certify that the foregoing
transcript is a complete, true and accurate transcript taken
from my original shorthand notes at the time and place
hereinbefore set forth to the best of my ability.
Dated: August 12, 1995.
\x._/^ —i_i
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RECORD OF DECISION FACT SHEET
EPA REGION II
Site;
Site name: Sealand Restoration
Site location: Town of Lisbon, St. Lawrence County, New York
HRS score: 29.36 (8/90)
Listed on the NPL: August 27, 1990
Record of Decision;
Date signed: September 29, 1995
Selected remedy: Alternative 3A — Hot-spot Groundwater
Extraction, Ex-Situ Bioremediation, and Reinjection or Surface
Water Discharge, Followed by Groundwater Extraction, Ex-Situ
Bioremediation, and Reinjection or Surface Water Discharge
Capital cost: $1,191,000
Construction Completion: 6 months (hot spots), 1 year (long term)
O & M cost: $162,000 to $189,000
Present-worth cost: (5% discount rate for 10 years): $2,029,000
Lead;
Site is enforcement lead - EPA is the lead agency
Primary Contact: Robert Nunes (212) 637-4254
Secondary Contact: Joel Singerman, Chief, Western New York
Superfund Section I (212) 637-4258
Main PRPs:
Waste;
Waste type: Volatile organics, Semi-volatile organics, Inorganics
Waste origin: Hazardous waste
Contaminated medium: Groundwater
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