United States
Environmental Protection
Agency
Office of
Emergency and
Remedial Response
EPA/ROD/R02-88/056
January 1988
oEPA
Superfund
Record of Decision
American Thermostat, NY
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50277-101 ,
REPORT DOCUMENTATION
PAGE
1. REPORT NO.
EPA/ROD/R02-88/056
3. Recipient's Accession No.
4. Title end Subtitle
. SUPERFUND RECORD OF DECISION
Thermostat, NY
Remedial Action
9. Report Oete
01/07/88
7. Authorts)
8. Performing Organization Rept. No;
9. Performing Organization Name and Address
10. Project/Task/Work Unit No.
11. Contract(C) or Grant(G) No.
(C)
(G)
12. Sponsoring Organization Name and Address
U.S. Environmental Protection Agency
401 M Street, S.W.
Washington, D.C. 20460
13. Type of Report & Period Covered
800/000
14.
IS. Supplementary Notes
16. Abstract (Limit: 200 words)
The American Thermostat Corporation (ATC) site, occupying approximately eight acres,
is located in South Cairo, New York. Private homes are near the site on its eastern and
western boundaries.- Former plant operations involving the assembly of thermostats for
small appliances were carried out in one existing large building. From the mid 1950s
through at least 1981, waste containing TCE and PCE sludges were poured down drains
which were connected to an abandoned septic system and dumped outside onto plant
The drains were connected to the abandoned septic system. .In March 1981, two
employees were observed dumping solvents on plant property. This triggered
investigations into the company's waste handling practices by the New York State
Department of Environmental Conservation (NYSDEC) and the New York State Attorney
General's office. Subsequently, water samples collected in five privately-owned wells
in the ATC vicinity revealed the presence of high levels of TCE and PCE. As a result,
ATC began supplying bottled water to local residents in April 1981. By late 1982, ATC
had installed carbon filters on its own well and the affected residential wells.
Pursuant to a 1983 Consent Order, ATC and AMRO Realty Coperation (AMRO), the owners of
the property, agreed to clean up the site and its surroundings; supply bottled water for
cooking and drinking purposes; and install, monitor, and maintain carbon filter systems
(See Attached Sheet)
17. Document Analysis a. Descriptors
Record of Decision
American Thermostat, NY
First Remedial Action
Contaminated Media: gw
PCE, TCE, VOCs
c. COSATI Field/Group
l^_Ayailab!lity Statement
19. Security Class (This Report)
None
20. Security Class (This Page)
None
21. No. of Pages
104
22. Price
(See ANSI-Z39.18)
See Instructions on Reverse
OPTIONAL FORM 272 (4-77)
(Formerly NTIS-35)
Department of Commerce
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report contains a significant bibliography or literature survey, mention it here.
17. Document Analysis, (a). Descriptors. Select from the Thesaurus of Engineering and Scientific Terms the proper authorized terms
that identify the major concept of the research and are sufficiently specific and precise to be used as index entries for cataloging.
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•••• Cr-O : 1983 0 - 381-526 (8393) OPTIONAL FORM 272 BACK (4-77)
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EPA/ROD/R02-88/056
American Thermostat, NY
First Remedial Action
16. ABSTRACT (continued)
for the five affected homes. ATC and AMRO did not fully comply with the Consent Order
and did not remedy the contamination at the site. In June 1983, a new onsite
4,500-gallon septic system was installed and, in September 1983, ATC provided carbon
filtration for septic system discharges to lower PCE levels. ATC ceased operations in
May 1985 and filed involuntary bankruptcy. EPA has been sampling area wells and
maintaining previously installed carbon filtration units. In addition, EPA installed
two new carbon filtration units on contaminated private wells; installed an air
stripping system on a highly contaminated well; and drilled a new well attempting to
locate a clean water supply. The primary contaminates of concern affecting the ground
water are VOCs including PCE and TCE.
The selected remedial action for this site includes: extension of the existing
Catskill Water District pipeline from Sandy Plains Road or from Rudolph Weir Road to the
affected and potentially affected area. The exact route of the pipeline will be
determined during design. The estimated capital cost for this remedial action ranges
from $2,270,000 to $2,380,000 with annual O&M of $100,000 to $110,000, pending the
pipeline route decision.
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
flfli* . „ REGION H
DATE: liiSC S i J8J7
SUBJECT: Record of Decision for the American Thermostat Site
^,, . ,.'~>
/Stephen D. Luftig, . ^^_ ^ .
•^/[Emergency and Remedial Response DJIvision
V
TO: Christopher J. Daggett "
Regional Administrator
Attached, pleased find the American Thermostat site Record of
Decision (ROD) prepared by my staff.
The American Thermostat Corporation site is located in the
Catskill Creek Valley in South Cairo, Greene County, New
York. Water in the area is supplied by private wells; there
is no nearby public water supply.
American Thermostat Corporation commenced operations at the
Site in 1954. The operations consisted of the manufacturing
of thermostats for small appliances. In 1981, the New York
State Department of Environmental Conservation (NYSDEC)
discovered employees of AT improperly disposing of chemicals
at the Site. Preliminary investigations by NYSDEC and the
New York State Department of Law in 1981 revealed that for a
number of years AT employees had been pouring waste organic
solvents down drains connected to the septic system and that
waste solvents and sludges were dumped on the parking lot.
Sample analysis of the discharge from two facility outfalls
by the New York State Department of Health ("NYSDOH"), detected
elevated levels of tetrachloroethylene ("PCE") and trichloroethylene
("TCE"). Subsequent potable water sampling of homes within a
quarter of a mile from the site, conducted in 1981 by NYSDOH,
indicated the presence of PCE and TCE in five residential
wells (Rath, Rivenburg, Lais, Nesensohn, and Briggs) and at
the AT facility. The concentrations of PCE ranged from 130
ppb to 47,000 ppb; TCE concentrations were much lower. The
highest concentration of PCE was detected at the Rath's well,
adjacent to the AT facility. The affected residents were
advised by NYSDOH not to utilize their well water for drinking
or cooking purposes.
On February 17, 1983, AT signed an Interim Consent Order with
the State of New York which stated that AT must provide for
the installation, monitoring, and maintenance of carbon
filtration systems, and must also supply bottled water for
cooking and drinking purposes to the five affected homes.
Other provisions called for the monitoring of two groups of
private wells in order to ensure prompt identification of
additional potable water contamination, and for a limited
remedial investigation to determine the nature and extent of
surface and subsurface contamination.
REQIOM II FORM 132O-1 »/M>
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-2-
AT provided bottled drinking water and installed carbon
filters at its facility and at three of the affected homes.
The Rath's residence was connected to AT's own treated water
supply because the high concentration of PCE and TCE in the
Rath's well would have required frequent recharge of the
carbon filter to prevent breakthrough. One affected resident
whose water was contaminated declined a carbon filter.
On May 7, 1985, AT ceased operations, and a bankruptcy petition
was subsequently filed against the company. As a result, AT
ceased providing maintenance of the carbon filtration systems
to ensure that breakthrough did not occur, and stopped supplying
bottled water to the five affected homes. In June 1985, EPA
sampled the water at homes in the vicinity of the Site to
determine potable water quality and to monitor carbon treatment
effectiveness for those homes with filters. PCE and TCE
were also detected at another residential well (Cornell).
In response to a request from NYSDEC, a removal action to
maintain the carbon filters installed by AT, to sample other
potable wells near the site and, where necessary, to provide
homes with bottled water and carbon filters, was authorized
by EPA in August 1985. EPA performed the sampling, recharged
the existing carbon filters at three residences, and installed
a filter at the Cornell residence.
In April 1986, NYSDEC requested that EPA extend the removal
action to provide a reliable source of safe drinking water
for the Raths and the Rivenburgs. Both wells had high concen-
trations of PCE. In September 1986, EPA authorized the
drilling of a new well for the Rivenburgs and the installation
of an airlift pump, organic adsorption unit, and carbon
filters for the Rath's well. The treatment system was installed
on the Rath's well; the new well that was drilled for the
Rivenburgs, however, was found to be contaminated with PCE
and TCE.
in February 1987, an additional contaminated well was discovered,
EPA authorized funding for the installation of a carbon
filter at the affected residence (Franks) and for continued
operation of the Rath's water treatment system.
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-3-
This ROD reflects the recommendations of the Emergency and
Remedial Response Division for an alternate water supply for
the residents affected or threatened by PCE- and TCE- contaminated
groundwater from the AT site. Upon completion of a source
control remedial investigation/feasibility study (RI/FS) to
further define the nature and extent of contamination at the
site, a separate ROD will be prepared.
Our recommendations were developed based upon the Administrative
Record for this site, which includes a focused feasibility
study (FFS) prepared by Ebasco Services, Inc.
The recommended remedy to provide an alternate water supply
involves the extension of the Catskill water supply pipeline
to the affected and potentially affected area. Under this
remedy, service connections will be provided to all residents
who currently have contaminated wells and those wells that
are threatened.
The capital and present worth costs for the recommended remedy
range from 2.27-2.38 million and 3.21-3.47 million, respectively.
The State of New York has been consulted, and agrees that the
recommended alternative is the most appropriate means of
providing an alternate water supply for the residents surrounding
the site.
The recommended actions, I believe, are consistent with the
goals and objectives of the Comprehensive Environmental
Response, Compensation, and Liability Act of 1980, as amended
by the Superfund Amendments and Reauthorization Act of 1986
(CERCLA), and the National Contingency Plan, to provide
adequate protection of human health and the environment.
This remedy satisfies all applicable or relevant and appropriate
requirements for this operable unit.
Notice to the potentially responsible parties, in accordance
with the special notice procedures outlined in $122(e) of
CERCLA, was sent on December 4, 1987 with the release of the
FFS.
The costs of construction of the recommended remedy will be
cost-shared as follows: 90% EPA and 10% NYSDEC.
Should you have any questions concerning the ROD, do not
hesitate to contact me.
Attachment
.-.v, -rv W-^v^^*#.^S!^^^^^
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Record of Decision
Remedial Alternative Selection
DECLARATION FOR THE RECORD OF DECISION
SITE NAME AND LOCATION
American Thermostat Corporation, South Cairo, Greene County,
New York.
STATEMENT OF PURPOSE AND BASIS
This decision document represents the selected remedial action
for providing an alternate water supply for the residents
affected or threatened by the tetrachloroethylene and trichloro-
ethylene-contaminated groundwater around the American Thermostat
Corporation site. The selected remedial alternative was
developed in accordance with the Comprehensive Environmental
Response, Compensation and Liability Act of 1980 (CERCLA), 42
USC $9601, et sea,., as amended by the Superfund Amendments
and ReauthorTzation Act of 1986 (SARA), and to the extent
practicable, the National Oil and Hazardous Substance Pollution
Contingency Plan (NCP), 40 CFR Part 300.
This decision is based on the administrative record for the
American Thermostat Corporation site. The attached index
identifies the items that comprise the administrative record,
upon which the selection of the remedial action is based. Among
the documents relied upon are:
-Focused Feasibility Study, Ebasco Services, Inc, September 1987,
-Attached Summary of Remedial Alternative Selection for the
American Thermostat Site.
-Attached Responsiveness Summary, December 1987.
A copy of the administrative record is located at the following
locations:
Greene County Court House
County Clerk's Office
446 Main Street
Catskill, New York 12414
U.S. Environmental Protection Agency
Emergency and Remedial Response Division
26 Federal Plaza
New York, New York 10278
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-2-
DESCRIPTION OF SELECTED REMEDY
The remedial alternative presented in this document is the
first operable unit of a permanent remedy for the American
Thermostat Corporation site. It will provide a permanent and
reliable solution for the prevention .of health risks to area
residents associated with exposure to contaminated groundwater.
The alternative selected involves extension of the Catskill
water supply pipeline to the affected and potentially affected
area. The specific waterline route will be determined during
the design phase. Service connections will be provided to
all residents currently utilizing contaminated or potentially
threatened wells.
The contaminant plume and source or sources of contamination
will be addressed in a subsequent remedial investigation/
feasibility study and Record of Decision.
DECLARATIONS
Consistent with CERCLA as amended, and the NCP, I have determined
that the selected remedy is protective of human health and
the environment, attains federal and state requirements that
are applicable or relevant and appropriate, and is cost-effective,
The selected remedy represents a permanent solution for a
portion of the problem posed by the site — namely, the threat
posed to area residents as a result of exposure to contaminated
groundwater. The selected remedy does not satisfy the statu-
tory preference for remedial actions in which treatment which
permanently and significantly reduces the volume, toxicity or
mobility of the hazardous substances is a principal element.
The reason for this is that such treatment options were not
found to be practicable or appropriate for this operable
unit. Such options, including possible methods of treating
the contaminated groundwater, will be considered in the next
operable unit.
The State of New York has been consulted and agrees with the
selected remedy, as is documented in the attached letter of
concurrence.
I have also determined that the selected remedial action for
the American Thermostat Corporation site is appropriate when
balanced against the availability of Superfund monies for use
at other sites.
7. iM8
Datei Chrfstophet J. Xfcggett
Regional Administrator
:;'ft«*V-»'«--;iI----'R.--'^>:'.~*-'J''--' :>^i*A";"---* •': '• •'^-•^X^ i^i^V^^
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SUMMARY OF REMEDIAL ALTERNATIVE SELECTION
AMERICAN THERMOSTAT SITE
NEW YORK
United States Environmental Protection Agency
Region 2
New York
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TABLE OF CONTENTS
Page
Site Location and Description 1
Site History 2
Current Site Status 3
Enforcement History 4
Community Relations 5
Preliminary Public Health Risk Assessment 6
Alternatives Evaluation 9
Selected Remedy 49
Schedule 54
ATTACHMENTS
A - Administrative Record Index
B - NYSDEC Letter of Concurrence
C - Responsiveness Summary
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American Thermostat Corporation Site
South Cairo, New- York
SITE LOCATION AND DESCRIPTION
The American Thermostat Corporation (AT) site is located in
South Cairo, Greene County, approximately thirty miles south
of Albany, New York. The site location is shown in Figure 1.
The property, about eight acres, is bounded on the northeast
and southwest by routes 23B and 23, respectively. Private
homes are near the site on its eastern and western boundaries.
The site is not fenced. The property itself is relatively
flat, but the surrounding land drops off steeply to Catskill
Creek and two small tributaries east and west of the site.
A site sketch is shown in Figure 2. The plant entrance is
located on Route 23B. The former plant operations were
carried out in one existing large building which is surrounded
by a large parking area, some of which is paved. A small
pump house which contains the company well is located at the
rear of the property near Route 23. A septic tank drainage
field on the western side of the building was disconnected in
1983 and replaced by a 4,500 gallon per day capacity septic
tank and drainage field east of the building. State Pol-
lutant Discharge Elimination System (SPDCS) permits were
issued by the New York State Department of Envirnmental
Conservation (NYSDEC) for the sewage discharge (discharge
point 003) and two non-contact cooling water discharges
(discharge points 001 and 002) as shown in Figure 2.
Regionally, the bedrock within Greene County consists of
interbedded shales and sandstones of Devonian age known as
the Catskill Formation (Amter, 1981). The Catskill Formation
is made up of four distinct bedrock groups. From oldest to
youngest, these groups are the Hamilton, Genessee, Sonyea and
West Falls. The AT facility lies within the Hamilton Group
which is further subdivided into the Plattekill Formation
which underlies the site.
The Plattekill Formation consists of sandstones, siltstones
and shales. These sediments have been uplifted and folded
resulting in a bedding plane dip to the west. This bedrock
structure controls the topography of the area which in turn
influences the surface and subsurface hydrology (Amter, 1981).
^^^
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MAP If A PORTION Of THE U.S.at. LEEDS. NT OUADAANOlE(7.t MINUTE ••Wti. ttl*.>HOT6nEVI8ED 1MO».~ CWTOUIl'INTERVAL'10V
8CM.E r «tOOO'
FMJUME 1
LOCATION MAP
AMERICAN THERMOSTAT SITE,
SOUTH CAIRO. NY
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to wmnt cftctx
THWUTAKt B
OIWHAIKM (Mil
noune z
AMNA
AMtmCAII TNIMMMTAT HI*.
tOUTN CAINO, NV
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-2-
Unconsolidated glacial deposits overlie bedrock throughout
most of the region. During the Pleistocene epoch a layer of
till was deposited over upland mountainous areas, and thick,
well-sorted, and stratified drift consisting of gravel, silt
and clay was deposited by meltwater in lower valley areas
(Berdan, 1954). The surficial till soils at the site exhibit
significant variations in permeability. Reportedly, the soil
is only about three feet thick overlying a significantly
permeable and fractured upper bedrock surface (Amter, 1981).
Alluvium is found in stream bed areas.
Groundwater is found almost exclusively in bedrock fracture
zones and joints throughout upland areas where the AT facility
is located. The Plattekill Formation is reported to have
very low primary permeability, but due to the presence of
numerous fractures and joints, its secondary permeability is
much higher. Yields of 20 gallons per minute (gpra) are
documented for wells completed in sandstone; and well yields
of 14-15 gpm are documented for the more tightly cemented
siltstones and shales (Berdan, 1954).
Regionally, depth to groundwater ranges from less than one
foot in swampy areas to almost 300 feet, with the average
depth about 30 to 40 feet (Berdan, 1954). Immediately west
of the facility is a small valley which includes Tributary
"B", a tributary to Catskill Creek. East of the facility is
Tributary "A" which also flows into Catskill Creek. Reportedly,
perched groundwater is found in this localized valley area ..'
(Amter, 1981). However, as mentioned, bedrock bedding planes
dip in a westerly direction. Accordingly, regional groundwater
appears to flow at depth towards the west.
SITE HISTORY
The original building was built in 1954 by AT for the assembly
of thermostats for small appliances. As operations expanded,
additions were made to the original building. From approximately
the mid-1950s through at least 1981, waste trichloroethylene
(TCE) and tetrachloroethylene (PCE) sludges were poured down
drains inside the building and were dumped outside on the
plant grounds. The drains were connected to the abandoned
septic system.
In March 1981, two AT employees were observed dumping solvents
on plant property. This triggered investigations into the
company's waste handling practices by NYSDEC and the New York
State Attorney General's office.
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-3-
During April and May 1981, water samples were collected from
several privately-owned wells in the vicinity of the AT site
by the New York State Department of Health (NYSDOH) and NYSDEC.
Figure 3 shows the locations of residential wells surrounding
the AT site. Analysis of water samples taken by NYSDEC and
NYSDOH indicated the presence of TCE and PCE. Five of the
sampled wells, those belonging to Rath, Lais, Rivenburg,
Briggs, and J. Schmidt (formerly Nesensohn), indicated concen-
tration levels of PCE in excess of the guideline of 0.05 ppm
(mg/1) for volatile organic chemicals established by the
Commissioner of NYSDOH. TCE was detected in four of the five
wells, with two samples indicating a concentration in excess
of the State guideline. The affected residents were advised
by NYSDOH not to utilize their well water for cooking or
drinking purposes. In November 1981, the State of New York
filed suit against AT and Amro Realty Corporation (Amro), the
owner of the property. Suits were also filed by several of
the plant's neighbors in late 1981.
As a result of the high level of PCE i'n several nearby wells,
AT began supplying bottled water to local residents in April
1982. By November 1982, AT had installed carbon filters on
its own well and the affected residential wells. The nearest
neighbor, the Raths, were connected to AT's well water supply
system. In December 1982, the site was added to the National
Priorities List, established pursuant to Section 105 of CERCLA
42 U.S.C. §9605.
In February 1983, New York State entered into an interim
Consent Order with AT and Amro in which the companies agreed
to investigate and clean up the site and its surroundings,
supply bottled water for cooking and drinking purposes, and
install, monitor, and maintain carbon filter systems for the
five affected homes listed above. The Order also stipulated
that two groups of bordering private wells had to be monitored
to determine whether any contamination had spread beyond the
originally affected area. AT and Amro did not fully comply
with the Consent Order and did not remedy the contamination at
the site, but only temporarily provided the affected residences
with safe drinking water.
In June 1983, a new 4,500-gallon septic system was installed
at the AT site, and the cooling water discharges were separated.
New SPDES permits were issued for three separate discharges,
the sewage system effluent and two non-contact cooling water
discharges. In September 1983, AT provided carbon filtration
for these discharges to lower the levels of PCE.
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Nlfi-
O OACUNIT
AIRLIFT STRIP?ING
SYSTEM
JtlYTORttlDEMTi:
MVUTIN
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•tllMM»
XlOHMIOT fRMWIIILV Nf SCMSOHN)
fAMTMAMI
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LOCATION 0^
SURFACE WATf
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•OURCC:NUt CORP. RIMEWAL ACTION
MASTER PLAN KCEMMR.1M*
SURROUNDtNQ HE8IDENT1AL WELL
LOCATIONS-SOUTH CAIRO, N.Y.
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-4-
In 1983, EPA's contractor prepared a Remedial Action Master
Plan for the site.
AT ceased operations in May 1985. In November 1985, several
of AT's creditors filed an involuntary bankruptcy petition
against the Corporation pursuant to Chapter 7 of the Bankruptcy
Code. The bankruptcy court subsequently entered an order for
relief against AT.
Since June 1985, EPA has been sampling wells in the area and
has been maintaining the previously installed carbon filtration
units. In addition, EPA installed two new carbon filtration
units on contaminated private wells, and installed an air
stripping system on a highly contaminated well, and drilled a
new well in an attempt to locate a clean water supply.
CURRENT SITE STATUS
Sampling was initially conducted at the AT site in May 1981
by NYSDOH and NYSDEC. As summarized in Table 1, the results
of groundwater analyses revealed the presence of certain
volatile halogenated organic compounds (VHO) (TCE and PCE) in
some samples from nearby residential wells. Concentrations
of PCC exceeded 1 part per million (ppm) in a number of
groundwater samples with a maximum value of 100 ppm observed
in one well water sample. Concentrations of TCE were signifi-
cantly lower.
Only one soil sample was collected from the dumping area (see
Figure 1) at the southern end of the AT site in March 1981.
This sample contained measureable levels of both PCE (3400
ppm) and TCE (0.5 ppm), and traces of 1,1,1-trichloroethane
(0.02 ppra).
VHOs were also detected in surface water samples collected
during 1981 and 1982 in tributaries near the site. The
principal VHO compounds detected were again PCE and TCE. In
summary, from the existing data it appears that the contami-
nation at the AT site is primarily due to VHOs, with PCE and
TCE being the principal contaminants. The source of these
compounds is spent degreasing solvents and sludges previously
disposed of on on-site soils, in the on-site septic system(s)
and/or released to surface water. The source, nature, and
extent of the contamination at and around the site will be
further investigated in the upcoming RI/FS.
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TABLE 1
AMERICAN THERMOSTAT STTE
Sample
Location
Berensheim
Briggs
Cornell
Goldstein
Lais
Nesensohn
Rath
Rivenburg
• (before
filter)
• (after
filter)
• (storage
tank)
• (spiked
storage
tank)
Ed Schmidt
Rath
Schmidt
Rivenburg
Sampling
Date
12/28/81
6/19/81
1/25/82
6/24/82
12/28/81
10/12/83
5/8/81
6/19/81
1/25/82
5/19/81
6/19/81
6/11/82
4/6/81
6/19/81
1/25/82
5/19/81
6/19/81
11/17/81
11/17/81
1/25/82
1/25/82
10/12/83
12/11/85
12/11/85
12/11/85
Trichloroethylene
(DDIlri
-
0.002
0.003
0.005
.
0.014
0.020
0.020
0.013
0.018
0.011
0.350
0.120
0.140
0.110
0.230
0.230
.-
<0.001
cO.OOl
0.001
Tetrachloroethylene
( opm)
0.002
0.220
0.430
0.220
0.003
0.001
1.6
1.5
!.•?
1.2
1.6
0.95
47.0
87.0
100.0
3.5
5.8
3.0
0.004
9.0
14.0
0.007
< 0.001
< 0.001
0.004
-------
TABLE 1 (Confd)
AMERICAN THERMOSTAT
Sample
Location
Cornell
Lais
Mallia
Chickocki
Greystone
Motel
Rath
Mariani
Frank
Goldstein
Wilczak
Sampling
Date
12/11/85
12/11/85
9/4/85
9/4/85
9/4/85
9/4/85
9/4/85
9/4/85
9/4/85
9/4/85
Rivenburg 9/10/85
(basement tap)
Schmidt
.(garage tap)
Cornell
(kitchen tap)
Lais
(kitchen tap)
Lais
• (before)
• (between)
• (after)
Hesensohn
• (before)
• (between)
• (after)
9/10/85
9/10/85
9/10/85
6/12/85
6/12/85
6/12/85
6/12/85
6/12/85
6/12/85
Trichloroethylene
( ppnO
<0.001
<0.001
<0.001
<0.001
<0.001
3.5
<0.001
<0.001
<0.001
<0.001
0.28
<0.001
<0.001
<0.001
0.028
ND
HD
0.033
HD
ND
SITE
*
Tetrachloroethylene
fopm)
< 0.001
< 0.001
0.002
< 0.001
< 0.001
98.0
0.005
< 0.001
< 0.001
0.005
14.6
0.011
0.003
< 0.001
2.1
ND
HD
3.2
0.001
HD
-------
TABLE 1 (Confd)
RESIDENTIAL WELLS - ANALYTICAL RESULTS
AMERICAN THERMOSTAT SITE
Sample
Location
Cornell
(no filter)
Briggs
(no filter)
Rivenburg
* (before)
• (between)
" (after)
Ed Schmidt
John Schmidt
Priputen
Sampling Trichloroethylene
Pate (ppm)
6/12/85 0.094
6/12/85 0.004
Tetrachloroethylene
6/12/85
6/12/85
6/12/85
6/12/85
6/12/85
6/12/85
0.19
0.28
0.016
ND
ND
ND
0.54
0.44
9.8
10.2
0.13
0.0071
ND
ND
American
Thermostat Plant
• (before) 6/12/85
• (between) 6/12/85
• (after) 6/12/85
• (Rath) 6/12/85
Berensheim
6/12/85
ND
ND
ND
ND
ND
0.320
0.003
0.014
ND
ND
Note: Dash (-) indicates not analyzed for
•ND" indicates not detected
Source: Remedial Action Master Plan, NUS Corp., December 1983,
and EPA, NYSDEC, NYSDOH analytical data from 1981-1987,
-------
-5-
ENFORCEMENT HISTORY
Four potentially responsible parties ("PRPs") have been
identified in connection with the AT site: Amro; AT; Mr.
Harry Moskowitz and Mr. David Moskowitz. Amro is the owner
of the property on which the AT facility is located. AT was
the company which operated the manufacturing facility at the
site. Harry Moskowitz was the president of the now defunct
AT; he is also the president of Amro. David Moskowitz is the
president of AT, and was formerly the vice president and
executive vice president of AT.
EPA filed a proof of claim on December 12, 1986 in the bank-
ruptcy proceeding of AT, seeking recovery of costs incurred
at the site. In addition, on October 30, 1987, the United
States commenced a civil action against Amro, Harry Moskowitz
and David Moskowitz pursuant to Section 107 of CERCLA for
recovery of EPA's costs at the site. EPA has also sent
several notice letters to the PRPs offering them the oppor-
tunity to agree to conduct or finance various response actions <
at the site. To date, none of the PRPs have offered to
undertake or finance such activities. The most recent notice
letter was sent to the PRPs on December 4, 1987. This letter
gave the PRPs sixty days to make a good faith offer to conduct
or finance the remedial action selected herein.
COMMUNITY RELATIONS
On December 3, 1987, EPA published a notice and brief analysis
of the Focused Feasibility Study (FFS) and Proposed Remedial
Action Plan (PRAP) prepared with respect to the AT site, and
made these documents available to the public. EPA informed
the public (including the Potentially Responsible Parties (PRPs))
of their opportunity to submit comments on the aforementioned
documents on or before December 24, 1987. In addition, on
December 8, 1987, EPA held a public meeting near the site to
discuss the PFS and PRAP. A responsiveness summary, containing
EPA's response to the significant comments received during
the public comment period, is attached hereto.
-------
-6-
PRELIMINARY PUBLIC HEALTH RISK ASSESSMENT
On the basis of existing site information and analytical re-
sults, a preliminary public health risk assessment was per-
formed for the site. The objective of this assessment was
to characterize health and environmental risks that would
prevail in the absence of further remedial action. The
methodology supporting this preliminary screening is described
below.
PCE and TCE were chosen for evaluation, as these chemicals
represent the principal contaminants detected in residential
wells. Results of the most recent (1986-1987) sampling
investigations indicate concentrations of PCE ranging from
0.001 ppm to 131 ppm. Concentrations of TCE ranged from
0.001 to 2.0 ppm. Both compounds are classified by EPA as
being probable human carcinogens. TCE has proven carcino-
genic in several strains of mice by the inhalation and oral
routes and is considered weakly mutagenic. PCE is carcino-
genic in mice by the inhalation route.
Because the purpose of this operable unit is to address the
need for provision of an alternative water supply to the
affected residents, this assessment addressed only those
pathways relating to the existing groundwater contamination.
These pathways include ingestion of groundwater, direct contact
with groundwater via washing and/or bathing, and inhalation of
contaminants volatilized during showers. Table 2 summarizes
the federal Applicable or Relevant and Appropriate Requirements
(ARARs).
As discussed above, the results of recent off-site groundwater
sampling programs indicate the continued presence of elevated
levels of PCE and TCE in residential well water samples. The
measured concentrations of these contaminants may be compared to
the ARARs listed in Table 3. As indicated in Table 3, EPA has
recently promulgated maximum contaminant levels (MCLs) for
safe drinking water for TCE (0.005 ppm) as well as several
other VHOs.
-------
Table 2
Federal Applicable or Relevant and Appropriate Requirements
1) Safe Drinking Water Act, National Primary Drinking Water
Regulations, Maximum Contaminant Levels (40 CFR 141.11-
141.16).
2) Other criteria/ advisories and guidance such as:
0 Maximum Contaminant Level Goals
0 USEPA Drinking Water Health Advisories
0 USEPA Health Effects Assessment
0 Cancer Assessment Group National Academy of Science
Guidance
3) Clean Water Act, Ambient Water Quality
Criteria (45 PR 798318-79379, November 28, 1980).
4) USEPA Groundwater Protection Strategy
-------
TABLE 3
CHEMICAL SPECIFIC - EPA ARARs
PARAMETER
TETRACHLOROETHYLENE
TRICHLOROETHYLENE
1,1-DICHLOROETHYLENE
1,1,1-TRICHLOROETHANE
SDWA MAXIMUM FRESHWATER
CONTAMINANT LEVEL QUALITY CRITERIA
-(2)
0.005
0.007
0.200
ACUTE CHRONIC
5.2 0.8
45 21
11
18 - . - .
(3)
SDHA /MCL
GOAL
0<
0
0.
0.
4)
007
200
requirements
NOTES: ••-_. " . -~
d) Federal applicable, relevant, and
(2) All concentrations in ppm. Dash indic&tes^no.t established or determined
(3) SDWA/MCL is the Safe Drinking Water Act Maximum Contaminant Level
..."~~~- '-• '• . -':"""' •*--"- • =•--• ''• -=~:~'--n j^^ff:!: '.' ..,. -,;:-/•.:'
(4> Proposed^as of October, 1986"' j^l >^ - -^\t-
-------
-7-
MCLs are enforceable standards established pursuant to the
Safe Drinking Water Act. MCLs are considered to be health
protective. For drinking water contaminants, the target
reference risk range associated with these standards is 10~4
to 10~6.
Using the measured ranges of TCE and PCE reported above, in
conjunction with carcinogenic potency factors developed for
these constituents (USEPA, 1986), one can derive carcinogenic
risk estimates for the receptors in question. Carcinogenic
potency factors represent the upper 95% confidence limit of
the probability of adverse response per unit intake of a
chemical over a lifetime. Using these values, and assuming
a daily water ingestion of two liters over a 70 year period,
the resultant risk estimates associated with TCE and PCE well
contamination are as follows:
Concentration Carcinogenic
Constituent Range Risk Estimate
Tetrachloroethylene 0.001 ppm (min.) 1.5 x 10"^
131 ppm (max.) 1.9 x 10'1
. t
Trichloroethylene 0.001 ppm (min.') 3.1 x 10"7
2.0 ppm (max.) 6.3 x 10~4
As illustrated above, the estimated risks associated with in-
gestion of groundwater, particularly PCE-contaminated groundwater,
at selected residential wells (e.g., Rath and Rivenburg, where
maximum PCE and TCE concentrations were measured) are signifi-
cantly greater than the target reference risk range referred
to previously.
Concentrations of TCE and PCE in drinking water which correspond
to a 10~5 risk are 0.026 ppm and 0.007 ppm, respectively. As
indicated in Table 1, the concentrations of these contaminants
detected in residential wells near the site far exceed
concentrations deemed health protective.
In addition. New York State has established water quality
standards and guidance values for Class GA (used for drinking
water) groundwaters. Relevant values are presented in Table
4. For TCE, a water quality standard of 0.01 ppm has been
established. For PCE and TCE guidance values for Class GA
waters have been established at 0.0007 ppm and 0.003 ppm,
respectively. Clearly, the difference between the concentrations
of these contaminants measured in residential wells near the
site and their associated health protective standards and
goals is significant.
-------
TABLE 4
NEW YORK STATE WATER QUALITY STANDARDS
AND GUIDANCE VALUES
FOR CLASS GA GROUNDWATERS
PARAMETERS
TETRACHLOROETHYLENE
TRICHLOROETHYLENE
TRANS-1,2-DICHLOROETHENE
STANDARD
(ppm)
0.01
GUIDANCE VALUE
(ppm)
0.0007
0.003
0.05
Source: Ambient Water Quality'Standards and Guidance Values,
New York State Department of Environmental Conservation,
Technical and Operational Guidance Report 85-W-38, July
1985.
-------
-8-
In addition to groundwater ingestion, the potential exists for
residents to be exposed to contaminants via washing or bathing.
The extent-of this exposure would depend on the period of time
spent washing and bathing, the fraction of contaminants absorbed
through the skin, and the surface area of the IndividuaK s)
exposed.
Qualitatively, evidence suggests that these two exposure path-
ways (inhalation and dermal absorption) present less health
risk of toxicity and/or carcinogenicity than ingestion.
As a result of the risk to public health from exposure to
contaminated groundwater from the AT site, remedial alterna-
tives were evaluated to address the problem.
-------
-9-
ALTERNATIVES EVALUATION
FPA's contractor conducted a Focused Feasibility Study (FFS)
aimed at identifying and evaluatinq various alternatives for
providing a safe alternate water supoly to the affected and
potentially affected residents near the AT site. During the
FFS, alternatives were identified screened and analyzed in
detail, as required by the NCP. The effectiveness, implementa-
bility and cost of each of the water supoly alternatives were
evaluated and summarized in the FFS and Proposed Remedial
Action Plan (PRAP) orepar^d by EPA.
The FFS was developed and preoared based on the limited existing
information (e.g., monitoring of 28 orivate wells) without the
RI which will identify the contamination sources and the extent
of the groundwater contamination migration plume(s). In addition,
the unique geohydrological configuration around the site (e.g.,
groundwater exists in the irregular channels and joints of the
fractured bedrock) contributed to the difficulties of predict-
ing the site-specific contamination conditions.
A preliminary review of. the existing data and information indi-
cate that approximately 100 oersons residing in the nearest 28
houses around the site are currently affected. This number
represents the population which is supplied by private wells
located within 1/2 mile downgradient and 1/4 mile upgradient
from the AT site as shown in Figure 3. Based on this informa-
tion, it appears that the groundwater contamination has migrated
at least this far during the last 20 years.
It is estimated that the groundwater remediation at this site
would take 20 years or more to complete. Because the extent of
contaminant migration has not been adequately determined at this
time, it is anticipated that the contamination would travel in
both directions and with the same migration soeed of the last
10 years. It is estimated that within the next 20 years the
contaminant plume(s) may reach one mile downgradient and 1/2
mile upgradient from the AT site.
The existing private well monitoring data indicate that no
contaminated well around the site was located outside the area
between Catskill Creek and Route 23. It is also assumed at
this point that the Catskill Creek and Route 23 act as bound-
ariesfor the migration of contamination on the north and south
sides of this site. Based on the above analysis,.the affected
and potentially affected areas are within the boundaries of
one mile downgradient, 1/2/ mile upgradient, Catskill Creed and
Route 23 (see Figure 4). Aporoximately 80 homes are located
within those boundaries.
-------
(80 HOUSES
260 PEOPLE)
FIGURE 4
PROPOSED WATER SUPPLY SERVH*
-------
-10-
Within the water suooly service area, it is estimated that
approximately 250 oersons residing in approximately 80 houses
would he ultimately affected and need to be orovided with an
alternate water suooly.
All but seven of the alternatives which underwent initial
screening during the FFS were eliminated. Table 2 lists the
water supply alternatives which were evaluated during the
initial screening phase, and summarizes the reasons why
certain alternate water suoply options were rejected.
The alternatives which were retained for a detailed evaluation
are as follows:
ALTERNATIVE 1
ALTERNATIVE 3Q
ALTERNATIVE 4A-1
ALTERNATIVE 4A-2
ALTERNATIVE 4A-3
ALTERNATIVE 4C
ALTERNATIVE 4D
NO ACTION
TANKER TRUCK AND ELEVATED
STORAGE TANK
PIPELINE FROM LEEDS
PIPELINE FROM SANDY PLAINS ROAD
PIPELINE FROM RUDOLPH WEIR ROAD
NEW WELL FIELD -
WATER SUPPLY FROM TRAILER PARK
WELLS
DESCRIPTION OF ALTERNATIVES
• - ' •
With the exception of Alternative 1 (No Action), each water
supoly alternative was evaluated on the assumption that it
would need to meet a typical domestic demand for a rural area
of 75 gallons oer capita oer day (gpcd) (aooroximately 15
gallons per minute (gpm) for 250 persons). The provision of
such an alternate water supoly system for the potentially
affected residents is consistent with Section 121 of the
CERCLA, which requires that remedial actions assure protection
of human health, attain ARARs, and be cost-effective. This
operable unit does, not satisfy the statutory preference for
treatment. This statutory preference will be addressed"in
the second operable-unit.
^.-,^_-..,-.,:.i.,r..,r:.,;,,^,^.;^^^
-------
TABLE 5
.SUMMARY OF ALTERNATE WATER SUPPLY
OPTIONS EVALUATED IN INITIAL SCREENING
Water Supply Alternative
Status
1. No Action
2. Point-of-Use Treatment
2A.Install Carbon Filters
on 72 Houses
O&M of systems
2B. Centralized Well Water
Treatment System
3. Point-of-use Water Supply
3A-1.Tanker Truck Delivery
3A-2.Bottled Water Delivery
3B.Tanker Truck and
Storage Tank
3C.Collection of Rainwater
4. Alternate Water Sources
4A.Catskill Water Supply
System
4A-1.Pipeline from Leeds
4A-2.Pipeline from Sandy
Plains Road
4A-3-Pipeline from
Rudolph Weir Road
4B.New Surface Water
Supply (Catskill Creek)
4C.New Well Field
4D.Water Supply from
Trailer Park Wells
Reason for Rejection
Retained
Rejected
Rejected
Rejected
Rejected
Retained
Rejected
Retained
Retained
Retained
Rejected
Retained
Retained
Fails to provide completel
safe water supply, complex
O&M
Fails to provide permanent
and long-term remedy, comp
construction
Fails to provide standard
domestic water supply,
considered temporary
solution only
Fails.to provide standard
domestic water supply,
considered temporary
solution only
Unproven, unreliable, compl
construction
Unproven, uncertain useful
life, complex O&M and
construction, major negativ<
environmental impact
-------
-12-
ALTERNATIVE 1 - NO ACTION
The no-action alternative includes long-term monitoring of the
28 potentially affected homes immediately surrounding the AT
site. Water samples taken from these homes every 3 months
would be analyzed for organic contaminants. The existing
treatment systems, including one airlift stripper and seven
carbon filter units, would be operated and maintained. This
alternative would not, however, provide for any additional
treatment units which might be required if contamination is
detected at any of the other potentially affected residences.
No construction of major facilities or installation of large
equipment would be required for this alternative. Only
monitoring and operation and maintenance (O&M) services would
be provided.
ALTENATIVE 3B - WATER DELIVERY BY TANKER TRUCK, ELEVATED
STORAGE TANK, WATER LIFT PUMP AND WATER DISTRIBUTION SYSTEM
Alternative 3B is a point-of-use water supply system utilizing
an alternative water source and a water distribution system.
This water supply system would provide a standard rural water
demand by trucking water from the nearby water district.
The proposed water supply system would consist of two tractor
trucks, two 5,000 gallon tanker trailers, an elevated storage
tank, a water lift pump and a water distribution system. The
nearest municipal water supply system is the Cats kill Mater
Supply system where the water loading station for trucking
could be located either at the Potuck Reservoir Water Treatment
Plant or at the existing transmission pipeline which crosses
Route 23B in Leeds. Purchase of treated water from this
water supply system would require a delivery by tanker truck
along public roadways. It is estimated that the total water
demand for the proposed service area would be approximately
0.02 million gallons per day (MGD) and that it would require four
deliveries per day at a distance of approximately twenty
miles each round trip.
An elevated hydrostorage tank with a 50,000 gallon capacity
would be required to provide adequate storage to compensate
for water demand fluctuations. The preliminary location
of the water tower would be at the AT site, where an approxi-
mately 55 feet (ft) of static hydraulic head will be available
(based on an elevation of 255 ft at the site and an elevation
of 200 ft at the furthest residence). The water tower would
have a 80 ft height to provide a normal working pressure
range of 35 to 60 pounds per square inch.
^
-------
-13-
A 6-inch diameter ductile iron pipe would be installed as the
primary transmission pipe for a total length of approximately
11,000 ft from the water tower to the proposed service area
and along Route 23B. As shown in Figure 5, a 4-inch diameter
branch pipe would be installed along the streets off Route
23B for the domestic water distribution system. The total
length of the branch pipes would be approximately 7,500 ft,
providing hookups for approximately 80 homes. The installation
of water supply pipeline would include rock excavation,
dewatering, loam excavation, restoration and repavement.
ALTERNATIVE 4A-1 - EXTENDED CATSKILL WATER SUPPLY PIPELINE
FROM LEEDS
Alternative 4A-1 consists of purchasing water from the Catskill
Water Supply system and extending the Catskill water supply
pipeline from Leeds along Route 23B. The current average
daily demand for Catskill is approximately 1.7 million gallons
per day (MGD). To supply the potentialy affected residences,
it is estimated that the additional load on the system would be
0.02 MGD. >
As shown in Figure 6, the proposed system would connect to
the existing pipeline by means of a water diversion station
in Leeds. A 6-inch diameter ductile iron pipeline would be
installed along Route 23B as the primary transmission pipe
for a total length of approximately 18,000 ft. The pipeline
would cross 400 ft pf Catskill Creek by submerged installation
near the historic bridge.
A booster pumping station would be required to provide adequate
flow and pressure for domestic conditions. Approximately
7,500 feet of 4-inch diameter ductile iron branch pipe would
be installed along the streets off Route 23B to supply each
potentially affected residence. Approximately 80 homes would be
connected to th«^ distribution system. ..
ALTERNATIVE 4A-2 - EXTENDED CATSKILL WATER SUPPLY PIPELINE
FROM SANDY PLAINS ROAD ' ;
Alternative 4A-2 is similar to alternative 4A-lr except that
the tie-in to the existing Catskill pipeline would" be at
Sandy Plains Road. As shown in Figure 7, the propos**'system
would utilize a water diversion station on Sandy Plains Road
and the pipeline would cross privately-owned t-arviF. - Trt"addition,
-------
s
LOCATION MAP
AMERICAN
THERMOSTAT
SERIES. l»5». •HOTOREVISEO 10SOI. CONTOUR* INTERVAL* 10*.,
SCALE 1* • 9AAA*
EBASCO SERVICES INCORPORATED
FIQURE 5
ALTERNATIVE SB -
WATER TANKER TRUCK.
-------
r -— •"'/••
•Ml. rNOIO*f*IMO •«•!
COHTOMI IHIf N«M. M*
ALTERNATIVE
CATM'IU WATEN
-------
^^^^^^T^5^
MIS. rnoTomnMD »ML
COMRXM IMTE***! ••
EBASCO KNVICf • IMCOXPOHATtO
FKUM 7
ALTtHNATIVC 4A-t tlTBHOtO
CATtKIU WATCH »WfLT MMtlNt
-------
-14-
both the 60 ft. Potic and 200 ft Catskill creeks would be
crossed by .submerged installation. A 6-inch diameter ductile
iron pipeline of approximately 13,000 ft in length, would
serve as the primary transmission pipe along Route 23B. A
booster pumping station would also be required to supply ade-
quate flow and pressure for domestic conditions. The same
amount of branch piping as Alternative 4A-1 would be installed
and the service area would include the same 80 homes.
ALTERNATIVE 4A-3 - EXTENDED CATSKILL WATER SUPPLY PIPELINE
FROM RUDOLPH WEIR ROAD
Alternative 4A-3 is similar to Alternatives 4A-1 and 4A-2,
except that in this option the tie-in to the existing Catskill
water supply pipeline would be near Rudolph Weir Road. As
shown in Figure 8, the proposed system would have a diversion
station on the east side of Potic Creek. A 6-inch diameter
ductile iron pipeline, approximately 23,000 ft long, would
serve as the primary distribution pipe. The extension would
cross 60 ft Potic Creek by submerged installation and would
be hung from an existing 200 ft steel truss bridge over
Catskill Creek at Route 67 in -Cairo. An identical booster
pumping station in this case would be located at the inter-
section of Route 67 and Sandy Plains Road.' The same amount
of branch piping would be installed and the service area
would include the same 80 homes.
ALTERNATIVE 4C - NEW WELL FIELD WATER SUPPLY SYSTEM
Alternative 4C consists of developing a new well field to
provide a water supply system for the affected and potentially
affected area. As indicated previously, the Plattekill
Formation, located throughout the upland area where the AT
site is located consists mainly of sandstones, siltstones and
shales. Groundwater is found almost exclusively in bedrock
fracture zones and joints in this area. Yields of 20 gpm are
documented for wells completed in sandstone (Berdan, 1954).
Some currently installed deep wells located near the stream
bed areas have operated in the range of 30 to 60 gpm. This
is due to two important factors: the area adjacent to the
creek consists of loamy soil formed in alluvium which has
favorable recharge characteristics, and the direction of
groundwater flow is expected to be towards the creek.
-------
room b
ALTtMNATIVI «A-| IITCNOCO
CAT win «rATin sumv
-------
-15-
Based on these factors, the preliminary location of the
proposed new well field would be approximately one mile
upgradient of the site between Catskill Creek and Route 23B
as shown in Figure 9. Use of the Sandstone aquifer would
require new wells approximately 400 ft deep, and wells in
this aquifer would have a safe yield of approximately
40 gpm each. The groundwater pumped from this aquifer is
expected to be good quality potable water after chlorination.
Based on the above geohydraulic information, two 400 ft deep
wells of 6-inch diameter and 400 ft deep would provide a
total of 75 gpm, sufficient for the nearby affected residents.
It is estimated that a reinforced concrete ground storage
tank with a 50,000 gallon capacity and a booster pumping
station would be required to provide the necessary pressure
and flow. A 6-inch ductile iron force main of approximately
13,000 ft would be required from the water storage tank to
the western end of the proposed service area- along Route 23B.
A total of approximately 7,500 ft of 4-inch diameter branch
pipeline along the side streets off Route 23B would be required
for the domestic water distribution system which will have
hook-ups for approximately 80 homes.
ALTERNATIVE 4D - EXTENDED TRAILER PARK WELL WATER SUPPLY
SYSTEM
Alternative 4D is similar to Alternative 4C in that it would
use uncontaminated groundwater from a well field which is
located approximately 3/4 mile upgradient from the AT
site. A trailer park, located off Route 23B, consists of
roughly 43 trailers and is currently expanding to accommodate
an additional 37 units. One older well and one which was
recently drilled could provide a combined flow of approximately
70 gpm. Since this is considerably more than the instantaneous
demand at the trailer park, it could be possible to extend this
system to supply the potentially affected area near the AT site.
An agreement would have to be negotiated with the owner of the
trailer park in order to implement this alternative.
The combined flow from the two trailer park wells would have to
be chlorinated and pumped to a reinforced concrete ground
storage tank with a 50,000 gallon capacity. As shown in
Figure 10, the proposed distribution system would include the
installation of a 12,000 ft, 6-inch diameter ductile iron pipe-
line along Route 23B as the primary transmission pipe. The
water storage tank and booster pumping station would provide
a buffer against fluctuations in demand while maintaining an
adequate supply of water to meet a typical rural demand of 75
gpcd.
-------
FIGURE 9
ALTERNATIVE 4C -
NEW WELL FIELD
WATFR SIIPPI V UVCTCM
-------
-16-
Approximately 7,500 feet of 4-inch diameter ductile iron
branch pipe would be installed along the streets off Route
23B to supply each potentially affected residence. A total
of 80 homes would be connected to the distribution system.
EVALUATION CRITERIA
The above seven alternatives were evaluated using evaluation
criteria derived from the NCP and CERCLA. These criteria
relate directly to factors mandated by CERCLA in Section 121
and to the maximum extent practicable, EPA's Interim Guidance
on Selection of Remedy (December 24, 1986 and July 24, 1987).
The primary objective of this operable unit is to provide safe
drinking water to the current and potentially affected
residents. This operable unit does not address a preference
for treatment. In addition, the reduction of toxicity,
mobility or volume of waste is not addressed, but will be
addressed in the subsequent operable unit. The criteria
which are applicable to the selection of an alternate water
supply system for the AT site are as follows:
0 EFFECTIVENESS
- Protection of public health and welfare
- Minimization of exposure pathways
- Adverse environmental impacts
- Operation and maintenance complexity
0 IMPLEMENTABILITY
- Technical feasibility and availability
- Constructability
- Timeliness
- Institutional requirements (public acceptance, permits)
- Safety
* COST
- Capital cost
- Operation and maintenance cost
- Present worth cost
- Sensitivity analysis
EVALUATION PROCESS
This section presents a detailed evaluation of each of the
alternatives which passed the initial screening. The de-
tailed evaluation process includes:
0 Refinement and confirmation of the appropriateness of each
water supply alternative with respect to site conditions;
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-17-
8 An assessment of the extent to which the alternative is
expected to effectively prevent exposure, minimize
threat's to and provide adequate protection of public
health and welfare and the environment (Evaluation of
Effectiveness);
0 Evaluation in terms of technical feasibility and
availability, constructability, timeliness, institutional
requirements and safety (Evaluation of Implementability);
and
0 Detailed cost estimation including capital cost, annual
operation and maintenance cost and distribution of cost
over time.
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-18-
Effectiveness
Effectiveness is evaluated in terms of performance, reliability,
public health protection, and environmental impacts.
Performance is the ability to effectively perform the intended
functions. Performance of a water supply alternative is
evaluated based on two factors: productiveness and useful
life. Productiveness refers to the quantity and quality of
the water supply which an action will provide for the potentially
affected residences. The useful life is the length of time
the level of productiveness can be maintained.
Reliability of a water supply alternative is evaluated in
terms of 0 & M requirements and demonstrated performance at
similar sites. Evaluation of 0 & M includes availability of
labor and materials and the frequency and complexity of the
necessary O&M. Technologies requiring frequent or complex
operation and maintenance activities are considered less
reliable. The evaluation of demonstrated performance includes
an estimate of the probability of failure for each water
supply alternative.
Public health protection of a water supply alternative is
evaluated based upon assessing how well the alternative
satisfies the health-based remedial objectives, i.e., prevents
ingestion of and direct contact with the contaminated groundwater,
The ARARs against which the protectiveness of the various
alternatives may be judged are summarized in Tables 2 and 3.
The qualitative evaluation and comparison of public health
impacts and protection is focused on the public health risk
reduction resulting from implementing each water supply
alternative.
Environmental impacts are compared based on the expected
environmental results for the seven water supply alternatives
and their relative beneficial and adverse effects on the
environment. Effects of substantial earthwork, construction
of submerged creek crossing support trenches, and the
associated adverse traffic impacts are also considered.
0 Performance
Alternative 1 - No Action
This alternative includes a long-term monitoring program for
twenty-eight houses near the site which have a high potential
of contamination in the near future and a long-term O&M
program for the existing eight individual point-of-use treatment
systems. The periodic monitoring program will not provide
any mitigative measures. The continuous O&M would only be a
partial and temporary solution for the present problem.
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-19-
This alternative requires separate 0 & M for each individual
house which, will have a lower effectiveness and efficiency
than for a centralized treatment system. The 0 & M consists
primarily of replacement of carbon filters and cleaning of
the airlift stripping unit. With proper operation and adequate
maintenance, these point-of-use treatment systems can supply
safe drinking water for each individual resident. It is
estimated that carbon filter replacement would be required
once every six months, and the inspection, adjustment and
repair would be required on a weekly basis for the airlift
stripping system.
Alternative 3B - Water Delivery By Tanker Truck, Elevated
Storage Tank, Water Lift Pump and Water Distribution System
Under this alternative, a permanent small municipal water
supply system would be installed to provide a domestic water
demand (75 gpcd). Except for the type of water delivery,
this community water supply system is a standard rural water
supply system. Since the daily water demand is approximately
0.02 MGD water transport by tanker trucks is highly feasible
and practical. The effectiveness and efficiency of this
alternative is slightly lower than the pipeline transport
system. _• - •-•-'•"L!-3
The useful life of a community water distribution system is
normally over 30 years, but requires long-term 0 & M. The
tanker truck would have a life of approximately 10 years
based on a 100 mile daily drive.
Alternative 4A-1 - Extended Catskill Water Supply Pipeline
From Leeds
Under this alternative, a water transfer and distribution
system would be installed to connect with an existing and
nearby municipal water supply system, thereby providing safe
drinking water to the designated service area. The Catskill
Water Supply District-has a water treatment design capacity
of 2.8 MGD at the Potuck Plant, which is capable of providing
more than 0.5 MGD out of the current district area. The
Potuck Water Plant supplies the district water demands in
compliance with established drinking water criteria. This
alternative would be an expansion project of the Catskill
Water Supply District.
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This alternative is very effective, since the use of an
alternative water source, which is a proven technology, would
terminate the use of contaminated groundwater and the associated
potential exposure pathways. A booster pumping station would
be installed to ensure adequate water flow and pressure to
the potentially affected area.
The useful life of a community water supply system is normally
over 30 years and this system would become a permanent public
facility under proper O&M.
Alternative 4A-2 - Extended Catskill Water Supply Pipeline
From Sandy Plains Road"
This alternative is similar to Alternative 4A-1 except for a
different water transfer pipeline route. The water diversion
pipeline along Sandy Plains Road has to cross both Catskill
Creek and Potic Creek, but will have shorter distance
(approximately 4,000 ft) than Alternative 4A-1. Accordingly,
the booster pumps will require lower pressure head and the
pipeline maintenance will be substantially reduced. The
effectiveness and efficiency of this alternative for providing
safe drinking water is equivalent to Alternative 4A-1.
This public water supply system would be very effective in
providing a standard rural water demand, and the use of an
alternate water source would eliminate the exposure pathways
of ingestion and direct contact with contaminated groundwater.
With 0 & M by the appropriate state or local entities, the
level of effectiveness would remain the same over a long-terra
period.
Similarily, the useful life of this alternative would be over
30 years since it would become a permanent public facility.
Alternative 4A-3 Extended Catskill Water Supply Pipeline From
Rudolph Weir Road
This alternative would have a longer water transfer pipeline
along Rudolph Weir Road, and the booster pumps would require
higher pressure head than Alternative 4A-1. The standard
water works criteria would govern construction of the water
supply extension. The alternative water supply source concept
has been proven to be effective at similar sites where alternate
supplies have been installed. Therefore, the effectiveness
and efficiency of this alternative is very good.
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The useful life of a public water supply system is normally
over 30 years but would require long-term operation and
maintenance. As a portion of the Catskill Water Supply
District, the useful life of this alternative would be
permanent.
Alternative 4C - New Well Field Water Supply System
The effectiveness of a new well field water supply is considered
to be good, but it is unproven for long-term operation. The
potential new well field would be located along the banks of
Catskill Creek based on the favorable recharge characteristics
of this location, and the assumption that groundwater is
flowing towards the creek. The expected yield of deep wells
in this area may vary seasonally. Based on current operational
results of two trailer park wells which were installed in
this area in the Summer of 1987, the effectiveness of this
alternative is good. _^_:?J". ..__..;: ... --_^_-..-'-. -^
^ - *•••-••- • •• ••-.«p ~"a ?V*cer :".-, 3" •_•-.•.', » - -~ " - .. "^
An old municipal landfill, however, is located approximately
1/2 mile upgradient of the new well field,'and could become a .
potential contamination source in the future.
Alternative 4D - Extended Trailer Park Well Water Supply
System
Two deep wells for trailer park use were installed approximately
one mile upgradient of the AT site. The" total combined yield
is approximately 70 gpm, which is sufficient to serve both
the trailer park and the potentially affected area. The well
water is not contaminated and meets the drinking water criteria.
The installation of an elevated storage tank and a water
distribution system will create an independent water supply
district and provides i. standardr"rural water supply.
- • —• -* - - -f^ • ~; » . _ -. - .
This alternative will accomplish the design'objectives (75
gpcd, 35 to 60 psi) for short-term operation, but its ability
to maintain the same level for long-term operation is uncertain
as in the case of Alternative 4C. The effectiveness of this
alternative is high based on the current operational results.
-w ,= •- • -^ : . • - , • ••••-•,-. -*,-, •--.-• .B^, . . ,* •-«..,.
The trailer park wells are facing a potential contamination
threat from both the AT site and the municipal landfill.
There is insufficient information to confirm and quantify this
contamination potential at this time. The useful life of
this alternative is, therefore, unknown and depends upon the
migration of the nearby contamination sources.
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0 Reliability
Alternative 1 - No Action
To maintain the effectiveness of this alternative requires
intensive operation and maintenance of an airlift stripping
system and seven carbon filter systems. Vendor O&M may be
required for the airlift stripping system.
Any potential scaling and bio-fouling will result in failure
of the air stripper to remove volatile organics. Weekly
inspection, adjustment, repair and cleaning would be required
for normal operation. The level of operator training required
would be intensive and specific.
Periodic monitoring and replacement of carbon filter s would
have difficulty maintaining the same effectiveness for safe
drinking water, because the groundwater contamination is
changing due to the continuous migration. The possibility
of replacing carbon filters after their exhaustion is high,
therefore, the possibility of failing to provide safe-drinking
water is also high. The replacement of exhausted filters and
well water sampling and analysis requires well-trained and
experienced technicians.
Alternative 3B - Water Delivery by Tanker Truck, Elevated
Storage Tank, Water Life Pump and Water Distribution SysTem
Labor and materials are readily and commercially available
for all components of this alternative. The operation and
maintenance requirements are not complex. This alternative
will create a new water supply district which would require
independent administrative, financial and technical resources.
This alternative would require daily water deliveries by
tanker trucks and periodic maintenance of the water tower and
water distribution system. The possibility of failure due to
truck maintanance problems, and adverse weather conditions is
low because the water tower would have sufficient storage for
approximately 10 days normal water demand, and a standby truck
would be provided. Other failure due to pipe leakage is
rarely possible within its useful life.
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Alternative 4A-1 - Extended Catskill Water Supply Pipeline
From Leeds_
This alternative would divert water from the Catskill Water
District's 16-inch transfer line to the proposed service area
by means of a 12-inch diameter pice along Route 23B from
Leeds. The extended water distribution facilities including
water diversion station, booster pumping station, force main
and domestic connections are made from readily available
material and technologies. The O&M of public water works
systems is straightforward and requires no special technologies.
This alternative would not create an independent water district,
but would instead be governed by the Catskill Water Supply
District.
The probability of a public water works failure is generally
low because an emergency water source is provided, and most
of the pipelines are underground to protect from freezing.
The Catskill Water Supply District has pumped emergency water
from Catskill Creek in an extreme drought season. The booster
pumping station in this alternative provides a standby pump
and diesel generator in case of power failure.
Alternative 4A-2 - Extended Catskill Water Supply Pipeline
from Sandy Plains Road
This alternative is similar to Alternative 4A-1, but has a
shorter transfer pipeline diverting the water from the Potuck
Water Plant to the potentially affected area. The extended
force main requires two submerged creek crossing support
trenches for both Catskill and Potic creeks. All of the
technologies to install the creek crossing trenches have been
proven under similar site conditions, and the availability of
labor and material is generally good.
The O&M of this extended water tranfer and distribution
system is not complex. The Catskill Water Supply District
has sucessfully operated and maintained the same type of
water works for more than 50 years. The probability of
failure for a water distribution system is relatively low
within its useful life.
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Alternative. 4A-3- Extended Catskill Water Supply Pipeline
From Rudolph Weir Road
This alternative is similar to Alternative 4A-1 , but has a
longer transfer pipeline along Rudolph Weir Road. The pipe
would be hung on the Route 67 bridge crossing Catskill Creek.
This bridge hangling technology has been proven and demonstrated.
Labor and materials for this technology are readily and
commercially available. The pipe will be insulated, and
requires a periodic and long-term maintenance which is technically
simple.
The possible mode of water supply failure in a water transfer
and distribution system is primarily from pipe leakage beyond
the useful life of the pipe joints. The technologies of
water pipe leakage prevention are available and proven.
Alternative 4C - New Well Field Water Supply System
This alternative consists of two new deep wells, an in-line
chlorinator, a water storage tank and a water distribution
system. Except for the deep wells, the reliability of other
water supply facilities is generally high, since labor and
materials are readily available and technologies are proven
and demonstrated. 06M of the water transfer and distribution
system are normally simple.
The long-term reliability of new deep wells with respect to
yield and water quality is uncertain based on the following
considerations:
0 The area groundwater is found almost exclusively in
bedrock fracture zones and joints, and typical yields
are approximately 20 gpm;
0 Within two miles upgradient of the AT site, only the
flood plain area near Catskill Creek (Leeds Flat area)
appears to be capable of providing a yield of more than
30 gpm. This is based upon favorable recharge character-
istics and the assumption that groundwater is flowing
towards the stream. Two trailer park wells are currently
installed in this area; and
0 The proposed new well field would be located between
Catskill Creek and Route 23B in the Leeds Flat area.
The long-term operation of the new well field would have
two uncertainties: the potential for interference from
of the trailer park wells, and the potential for contaminatio
from the old municipal landfill which is located approxi-
mately one half mile upgradient of the proposed well
field.
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-25-
At this time,, there is not enough information to resolve
these two uncertainties related to the future operation of
new wells.
Alternative 4D - Extended Trailer Park Well Water Supply
System
The utilization of the trailer park wells to serve the potentially
affected area is technically feasible based on the current
operation performance. The availability of a sufficient
yield and the maintenance of water quality of the trailer
park well field are not issues of concern, since the wells
are currently operating and can provide the required capacity
at this time. However, the future capacity and the potential
for contamination from the upgradient municipal landfill are
unknown.
"Public Health Protection
Alternative 1-No Action
This alternative includes a long-term groundwater monitoring
program and an operation and maintenance program for the
existing point-of-use treatment devices, seven carbon filters
and one airlift stripping system.
This alternative will provide limited protection of public
health in the present eight affected residences only. These
point-of-use treatment devices reduce the public health threat
to less than a 10"^ risk level. However, to maintain the
same level of effectiveness, regular replacement of the carbon
filters and proper cleaning to prevent the growth of microbes
is required for an airlift stripping system. Treatment system
malfunctions and operational errors could cause exposure to
accumulated contaminated residues on the equipment and facilities.
The long-term monitoirng program would exert no effect on
health concerns, but it would provide an early warning of any
additional contaminated wells.
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Alternative 1 would not include any implementation of treatment
facilities and, therefore, no construction hazards are expected.
However, the direct contact and inhalation risk of volatile
contaminants might threaten workers during the operation and
maintenance activities. Hence, a health and safety protection
procedure would be required for workers.
Post-remedial reductions in public health risks would be
moderate and not complete for Alternative 1. The continously
migrating groundwater contaminants may cause additional well
contamination, and additional installation of carbon filters
would be required in the future.
In summary, this alternative provides only partial public
health protection.
Alternative 3B - Water Delivery By Tanker Truck, Elevated
Storage Tank, Water Lift Pump and Water Distribution System
This alternative consists of a water tanker truck, an elevated
storage tank, water lift pumps and a water distribution
system. The. intent of this alternative is to provide a rural
community with an alternate water source so that the potentially
affected residences can discontinue the use of potentially
contaminated groundwater.
Utilizing trucked in water, this alternative will eliminate
the potential exposure of the public through ingestion and
direct contact of contaminated groundwater from the currently
unprotected wells, significantly reducing the associated
public health risk.
This alternative would be implemented in the potentially
affected area where the extent of contaminated soil is unknown,
particularly where the elevated storage tank will be located
at the AT site. Since the water distribution system would b«
installed in a shallow subsurface (4 to 5 ft), normal construction
hazards such a« dust, soil erosion and dewatering would be
encountered. The regular occupational safety and health
protection measures would be provided during the short-ten
construction.
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Health considerations associated with the construction of an
elevated water storage tank on-site could be significant,
since there is a potential to come in direct contact with
hazardous materials. Volatile emissions may be released and
cause a possible deterioration of air guality, hence a short-
term air monitoring program may be required.
After remedial action is completed, no further exposures
would be expected before the contaminated groundwater is
remediated. The probability of the alternate water distribution
system being contaminated by groundwater is very low.
Alternative 4A-1 - Extended Ca"tskill Water Supply Pipeline
From Leeds
This alternative would provide an alternative water source by
extending the Catskill water supply pipeline to the potentially
affected area. The expanded water distribution system consists
of a water diversion station, a booster pumping station, the
creek crossing support trench and a water distribution system.
This remedial alternative is designed for a risk level below
10~*> and focuses on providing a totally alternate water
source. The alternate water supply does not contain any hazardous
substances. Termination of the contaminated groundwater uses
would totally eliminate the existing exposure pathways of
ingestion, inhalation and direct contact of the contaminated
groundwater. The public health risk reduction of this alternative
is high and complete.
Normal construction hazards such as dust, noise and temporary
air quality deterioration due to traffic congestion are
expected during the implementation of this public water works
project. Basic public health and safety protection measures
would be applied as a short-term requirement. Aside from
normal construction hazards associated with the water transfer
pipeline installation, the construction of the water distribution
system in the potentialy affected area would have a low
probability of direct worker contact with the contaminated
soil and groundwater. There should be only minimal effects
on neighboring communities during construction of this alternative
if dust and traffic control measures are taken.
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This alternative is similar to Alternative 38 in that the
complete elimination of potential post-remediation public
health risk would be achieved. Considering the extent and
level of contaminants where the pipeline would be installed,
the exposure of subsurface contaminanted soil and groundwater
to the water supplies would be minimal.
Alternative 4A-2 - Extended Catskill Water Supply Pipeline From
Sandy Plains Road
This alternative would have a water transfer system and water
distribution system identical to Alternative 4A-1, except for
different water transfer pipe routing. A shorter water
transfer pipeline is not developed based on any public health
risk concerns.
The minimization of exposures to the contaminants, safety
concerns and post-remediation risk reduction would be equivalent
to those detailed in Alternative 4A-1.
Alternative 4A-3 - Extended Catskill Water Supply Pipeline From
Rudolph Weir Road
This alternative would have a water transfer system and water
distribution system identical to Alternative 4A-1, except for
different water transfer pipe routing. A longer water transfer
pipeline is not developed based on any public health risk
concerns.
The same exposure minimization to the volatile organic contaminants
that was outlined in Alternative 4A-1 can be applied to this
alternative.
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The same safety concerns with implementing Alternative 4A-1 can be
applied to this alternative. However, traffic congestion
could have greater consequences on Route 67 and the surrounding
residences because of the construction activities in hanging
the water transfer pipe on the bridge.
The complete elimination of potential post-remediation public
health risks would occur after implementation of this alternative.
Alternative 4C - New Well Field Water Supply System
This alternative involves the implementation of a new well
field, a water storage tank and a water distribution system.
This new system would provide an alternative water source by
utilizing uncontaminated groundwater upgradient from the AT
Site.
Technologies being considered for Alternative 4C would successfully
mitigate the existing and future exposures of the receptor
population to all contaminated on-site matrices. As long as
the new well field is not contaminated, the reduction in
public health risks contributed by this alternative is complete.
This alternative would have the normal hazards associated with
construction activities as outlined in Alternative 3B, except
the potential for workers to contact and inhale volatile
organics during the construction of an elevated storage tank
on-site. Alternative 4C would have the elevated storage tank
installed on the new well field site where no volatile air
emissions could expose the workers and the surrounding
population.
Improperly constructed new wells can provide an effective
conduit for contaminant* to move from a contaminated aquifer
to an uncontamlnated aquifer. As discussed previously, the
new well field would be located approximately one mile upgradient
of the AT site and 1/2 mile downgradient of the municipal landfill.
The precise, location of the contaminant plumes from the AT site
as well as the possibility of the presence of a plume from the
landfill cannot be determined at this time.
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In the future, this alternative might completely eliminate
the potential post-remediation public health risks. However,
if any contaminant migration reaches the new well field, this
would create significant post-remediation risk.
Alternative 4 D - Extended Trailer Park Well Water Supply System
This alternative would utilize the existing trailer park wells
as an alternative water source and create a new water supply
district covering both the potentially affected area and the
trailer park. This alternative consists of a water storage
tank and a water distribution system similar to Alternative
4C, except that a portion of the force main would be extended
to serve the trailer park.
The minimization of exposure to the contaminants would occur
in the same manner as those detailed in Alternative 4C.
The same safety concerns with implementing alternative 4C can
be applied to this alternative. However, since the wells are
currently existing., the hazards posed by remediation is less
than Alternative 4C.
Since Che trailer park well field is located- approximately 3/4 mile
upgradient of the AT site and 1/2 of a mile downgradient of the
municipal landfill, the post-remediation risk reduction of this
alternative would be the same as Alternative 4C.
0 Environmental Impacts
Alternative 1 - No Action
This alternative involves only groundwater monitoring and 0AM
of the existing treatment facilities. Essentially, no im-
plementation would be required, since the treated flow is
small compared to the contaminated groundwater, there would
be no change in the existing migration of groundwater con-
tamination. The possibility that this action would appreciably
affect groundwater quality is considered remote. Any beneficial
effects on groundwater restoration would depend upon the
long-term natural soil attenuation and groundwater flushing.
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The intermittent pumping and treatment of eight residential
wells would have essentially no effect on the existing environmental
conditions of the surface water, groundwater and ecosystem.
The groundwater pumping may slightly affect the migration
pattern of groundwater contaminants, but the positive impact
of removing contaminants and the negative impact of spreading
contaminant would be balanced. Since this alternative requires
no construction, there would be no improvement of human use
resources, and the existing migration of contaminants off-site
via groundwater would continue indefinitely. This alternative
would not increase the extent and/or level of contamination
in this study area.
Alternative 3B - Water Delivery By Tanker Truck, Elevated
Storage Tank, Water Lift Pump and Water
Distribution System
This alternative includes the implementation of an elevated
storage tank at the AT site and a water distribution system
in the potentially affected area. The construction activities
may result in a slight beneficial impact on removal of contamination
sources in the study area. During the excavation activities,
soils would be monitored and those with high contaminant
levels would either be removed for off-site disposal and
replaced with clean soils or handled as part of the source
control remedy. The possibility of disturbing and removing
contamination sources is much higher for the elevated storage
tank construction than for the installation of the water
distribution system, since it would be installed on the AT
property.
The implementation of Alternative 3B would temporarily increase
the potential for contaminated surface water runoff, particulate
(dust) dispersion, traffic congestion and high noise levels.
Since the pipeline excavation, restoration and repavement
would be completed in the same day, the amount of contaminated
surface runoff would be minimized. Portions of the pipeline
installation would require dewatering which would be monitored.
Adequate treatment should be provided for contaminated groundwater
prior to discharge. The potential of shallow groundwater
contamination within the affected area cannot be determined
at this time.
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Dust suppression measures would be provided for the earthwork
construction*- particularly an air monitoring program during
the excavation of a water tank foundation at the site. A
runoff drainage barrier system such as a silt fence would.be
installed to offset the possibility of erosion at the site.
A traffic control plan would be developed and executed to
minimize the potential increase of traffic congestion, air
pollution and noise. Since the rural area does not have a
heavy volume of traffic on Route 23B, the short-term traffic
impacts on the human environmental are considered insignificant.
The long-term traffic impacts due to the water deliveries at
four round-trips per day are also considered minimal.
Alternative 4A-1 Extended Catskill Water Supply Pipeline From
Leeds
This alternative includes the installation of a water transfer
pipeline, a booster pumping station and water distribution
system. Since these construction activities are not directly
related to environmental improvement/ no beneficial impact on
the contamination source removal and groundwater restoration
is expected. A long-term water supply would directly raise
the living standards and improve the community's environment.
The same adverse environmental impacts in terms of traffic
effects, dust dispersion and increased noise that was discussed
in Alternative 3B during the water distribution system construction
can be applied to this alternative. In addition, the water
transfer pipeline would cross Catskill Creek and would require
submerged pipe installation. Catskill Creek is classified as
a B(T) stream which denotes that it has a water quality
suitable for fishing, especially for trout. The construction
of submerged trenches would require a short-term diversion of
creek flow which would alter the existing flow pattern.
Marine biota and species would not be adversely affected
after construction is complete. The installation of pipe
submerged trenches in the creek would not raise the water
level, change flow patterns or increase the possibility of
flooding.
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Alternative 4A-2 - Extend Catskill Water Supply Pipeline From
Sandy Plains Road
This alternative would implement a water transfer and distri-
bution system utilizing an alternate water source similar to
Alternative 4A-1, except by means of a different water transfer
route. As discussed in Alternative 4A-1, the beneficial
impacts on the human environment, ecosystem and human use
resources for this alternative are insignificant. However,
this alternative provides a public water supply and terminates
the use of potentially contaminated groundwater, thereby
creating an unquestionable long-term benefit for the community.
The same adverse environmental impact concerns with implementing
Alternative 4A-1 can be applied to this alternative. However,
a portion of this water transfer pipeline would be trenched
subgrade through a strip of agricultural land before and after
crossing the Catskill Creek. The loss of approximately one
quarter acre of farm land is not considered a significant
adverse impact.
Alternative 4A-3 - Extended Catskill'water Supply Pipeline From
Rudolph Weir Road
This alternative is similar to Alternative 4A-1 and Alternative 4A-2,
since the beneficial environmental impact of this alternative
is considered minimal.
The same adverse environmental impact concerns related to
implementing alternative 4A-1 can be applied generally to
this alternative, except the adverse environmental impacts on
Catskill Creek. This alternative would involve the hanging
of the water transfer pipe on the Route 67 bridge instead of
the creek crossing support trenches. During the temporary
construction of pipe supports on the bridge, adverse environmental
impacts would be limited to traffic-related effects. An
increase in noise levels would accompany the construction
activities, but once completed, the negative impacts would be
completely eliminated.
Alternative 4C - New Well Field Water Supply System
This alternative would install a new well field in an uncontaminated
aquifer and a water distribution- system to serve the potentially
affected area. Any beneficial effects to the biological
environment and human environment are minimal. However, this
alternative creates a new public water supply district which
would improve the social-economic environment for the community.
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Short-term adverse effects such as traffic, dust and noise
during the installation of a water distribution are the same
as described in Alternative 3B. However, adverse impact on
the area ecosystem may occur as a result of this alternative.
A slight environmental risk would still remain after the
implementation of the new well field, since the well pumping
would create a radius of influence which may interfere with
the migration of contaminants from both the AT site and any
contaminants the could be migrating from the old municipal
landfill. During long-term pumping, the groundwater flow
pattern may be changed, and deleterious effects on other
wells in the area may result from intercepting contaminated
groundwater.
The chlorination of groundwater would not require intensive
material handling and would not increase the risk of exposure
or accident.
Alternative 4D - Extended Trailer Park Well Water Supply
System
This alternative would divert the trailer park well water to
a newly built water storage tank and then a water distribution
system within the potentially affected area. The positive
and negative environmental impacts described in Alternative
4C are similar for this alternative. However, this project
would not include the installation of new wells. Accordingly,
the groundwater pumping interference would be reduced and the
associated environmental risk would be minimized. In general,
this alternative has the same long-term benefit as Alternative
4C, but with less adverse side effects resulting from construction
and operation.
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ImplemenCability
Each alternative is evaluated with respect to technical
feasibility, constructability, institutional requirements,
and safety.
The evaluation of technical feasibility consists of determining
how technically practicable each water supply alternative
would be to implement at this specific site under these
particular conditions. Feasibility considers the availability
of required equipment and facilities for an alternative in
addition to the appropriateness of recommending that alternative.
Constructability relates to the ease of installation and the
estimated time required to design and construct each water
supply alternative. This evaluation reflects the estimated
difficulty of construction due to the need for rock excavation,
dewatering, crossing of steep terrain or bodies of water, and
access to private property. Timeliness (time to implement)
system) also considers how long it might take to secure all ,
of the required state, county, and local construction approvals
for each alternative.
The implementation of each water supply alternative will
involve certain site-specific and technology-specific insti-
tutional requirements. These include administrative and permit-
ting, requirements and compliance with all of the ARARs, including
more stringent state requirements. State and public acceptance
of the alternative is also considered.
The evaluation of safety includes the potential short-term
occupational health impacts to workers during implementation
of an alternative based on Occupational Safety and Health
Administration and National Institute of Occupational Safety
and Health guidelines for health and safety. In addition,
consideration is given to safety and potential impacts to nearby
residents.
0 Technical Feasibility
The technical feasibility evaluation is based on whether the
water supply alternative is technically practicable, available
and appropriate for implementation at this site under these
particular conditions.
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Alternative 1 - No Action
This alternative includes long-term O&M for the eight existing
point-of-use treatment systems along with a long-term monitor-
ing program of the other twenty homes in the potentially affected
area immediately surrounding the AT site. It is technically
practicable to continue to use these treatment systems since
they have functioned effectively to date and replacements are
readily available. This alternative is not appropriate for
this site, since it continues to pose a threat to the residents
not currently utilizing (point of use) treatment systems.
Since there is no way to predict when the carbon filters will
be exhausted ("break through"), it is possible that the
residents could be exposed to contaminated water at their
taps and not be aware of this until the laboratory analysis
is received from the next round of sampling. Also, this
alternative has no provisions for carbon treatment units in
the other homes should the contamination continue to migrate
beyond the current eight residences.
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Alternative 3B - Water Delivery by Tanker Truck, Elevated
""Storage Tank, Water Lift Pump, and Water
Distribution System
This alternative entails establishing a new independent water
supply district consisting of an elevated storage tank,
regular deliveries of purchased water by tanker truck, a lift
pump and a complete distribution system. Since each required
piece of equipment is both conventional and readily available,
implementing this alternative is technically practicable.
Although this type of system has not been previously used, it
would provide an appropriate solution for this small and rural
community. A 5000-gallon tanker truck would have to pick up
and deliver water to the 50,000-gallon water tower four times
per day, seven days per week. Water could be purchased from the
nearby Catskill Water District and each delivery would only
entail a 20-mile round trip. The water tower could be installed
on the AT site for easy access from Route 23B and to take
advantage of the available static head from this local point
of maximum elevation. An adequate supply of water would be .
provided.
. r " - -
Alternative 4A-1 - Extended Catskill Water Supply Pipeline
from Leeds'
This alternative consists of purchasing water from the nearest
available municipal water supply system by extending the
Catskill water supply pipeline from Leeds, across Catskill
Creek, and along Route 23B. Since the Catskill Water District
system has a capacity of 2.8 MGD and currently uses only 1.7
MGD during typical average demand periods, it is technically
feasible to extend this system to supply the 80 residences
(approximately 250 persons) in the potentially affected area.
The Catskill water District is well-established and has been
functioning successfully for over 50 years. Installing an
extension would entail standard and readily available equip-
ment such as a water diversion station and a booster pumping
station. In addition, this type of project has been implemented
at other similar sites. This alternative is appropriate for
this site and would provide an adequate supply of water to
meet a typical rural demand of 75 gpcd.
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Alternative 4A-2 - Extend Catskill Water Supply Pipeline from
Sandy Plains Road
This alternative is similar to alternative 4A-1, except that
the tie-in to the existing Catskill pipeline would be at
Sandy Plains Road, and the extension would have to cross both
Potic and Catskill Creeks by submerged installations. Less
piping is required than for either Alternative 4A-1 or 4A-3.
Implementing this alternative is technically practicable,
uses conventional and readily available equipment and
facilities, and is appropriate for use at this site.
Alternative 4A-3 - Extend Catskill Water Supply Pipline from
Rudolph Weir Road
This alternative is similar to Alternative 4A-1 and 4A-2,
except that in this option the tie-in to the existing Catskill
pipeline would be near Rudolph Weir Road, and the extension
would have to cross both Potic and Catskill creeks. More
piping is required than for either Alternative 4A-1 or 4A-2,
but this route does not require crossing private land and
uses the Route 67 bridge to hang the pipe over Catskill
Creek.
Implementing this alternative is technically practicable,
uses conventional and readily available equipment and
facilities and is appropriate for use at this site.
Alternative 4C - New Well Field Water Supply System
This alternative establishes a new independent water supply
district consisting of two new wells, a water storage tank,
chlorine treatment and a complete distribution system. The
proposed location of the new well field is approximately one
mile southeast of the AT site, in an area labeled as the
"Leeds Flat" on the USGS topographic map, between Catskill
Creek and Route 23B. Deep wells installed in this area have
yielded between 30-60 gpra. Sand and gravel deposits are
capable of yielding the most water. Each well should be
capable of providing at least 40 gpm based on the favorable
recharge characteristics of this location, and the assumption
that groundwater is flowing towards the creek.
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Pumping the groundwater to a 50,000-gallon water storage tank
provides a buffer against the continually fluctuating domestic
demand. Based on recent results at a trailer park located
less than 1,000 feet northwest of the proposed location, the
groundwater pumped from this aquifer is expected to be suitable
for potable use after chlorination. However, definitive
proof to confirm the adequacy of this water supply with
respect to quantity and quality can only be obtained when the
wells are actually drilled and tested. Several wells might
have to be drilled before meeting the requirements.
Implementing this alternative is technically practicable,
uses conventional and readily available equipment and facilities,
and appears to be appropriate for use at this site.
Alternative 4D- Extend Trailer Park Well Water Supply System
Alternative 4D is similar to Alternative 4C since it would
use uncontaminated groundwater from a well field which is
located approximately 3/4 mile upgradient of the AT site.
The trailer park has two existing wells which could provide a
combined flow of approximately 70 gpm. Since .this flow is
considerably more than the instantaneous demand at the trailer
park, it would be technically feasible to pump the groundwater
continuously to a 50,000-gallon water storage tank which
would enable servicing the potentially affected area (80
homes, 250 persons) and would provide a buffer against con-
tinual fluctuations in the domestic demand.
Combining and extending the trailer park system is practicable,
and uses conventional and readily available equipment and
facilities. This alternative should be appropriate for use
at this site, and it would benefit the residents of the trailer
park.
The existing wells currently provide groundwater of adequate
quantity and quality. This mitigates the uncertainty associated
with installing a new well field (Alternative 4C).
0 Constructibility and Timeliness
The constructibility evaluation is based on the ease of
installation and the timeliness of implementing the water
supply alternative at this site under these particular
conditions.
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Alternative 1 - No Action
Since this alternative only includes long-term O&M of the eight
existing point-of-use treatment systems and monitoring of the
other 20 homes immediately surrounding the AT site no con-
struction is required
Alternative 3B - Water Deliver by Tanker Truck,_ Elevated Storage
Tank, Water Lift Pump, and Water Distribution
System
This alternative requires the construction of a 50,000 gallon
elevated storage tank at the abandoned AT site to take advantage
of its central location, available static head due to elevation,
and paved access roads. The ease of installation of this
80-foot high water tower constructed of steel and supported
with a multi-column structure should be relatively straight-
forward since this site has had previous construction work.
Burial of 11,000 feet of transmission and 7,500 feet of
branch piping along Route 23B and its side streets will
entail moderate difficulty due to the need for rock excava-
tion over approximately one quarter of the total excavation
length. The pipe'.will be buried at least five feet to protect
against freezing.
The time required to implement would be approximately nine
months, including construction approvals from the Greene
County Highway Department and the Town of Cairo, and possible
precautionary procedures while excavating contaminated soil at
the AT site.
Alternative 4A-1 - Extended Catskill Water Supply Pipeline
from Leeds
This alternative entails construction of a water diversion
station in Leeds/ extension of the pipeline across Catskill
Creek by means of a 400 ft submerged installation, construction
of a booster pumping station and installation of 18,000 ft of
transmission and 7,500 ft of branch piping along Route 23B
and its side streets. Crossing Catskill Creek near the
historic bridge in Leeds will require submerged installation
of the pipe in a 3 ft wide by 5 ft deep trench.
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Road excavation along the proposed route will require roughly
45 percent rock excavation and 35 percent dewatering. The
majority of .the piping will be along a straight and relatively
flat segment of Route 23B. The excavation requirements within
the proposed service area (branch piping) are the same for each
water supply alternative.
The time required to implement would be approximately one
year, including construction approvals from the Greene County
Highway Department and the Town of Cairo.
Alternative 4A-2 - Extended Catskill Water Supply .Pipeline from
Sandy Plains Road
Alternative 4A-2 is similar to Alternative 4A-1 except that
it connects to the existing Catskill pipeline at Sandy Plains
Road in Athens and crosses both Potic and Catskill Creeks
along with various private properties, resulting less (13,000
ft) transmission pipeline than either Alternative 4A-1 or
4A-3. Crossing Potic Creek will require a pipe support
trench (3 ft. wide x 5 ft deep) approximately 60 feet long,
while crossing Catskili Creek will require a similar structure
roughly 200 feet long.
Only 20 percent of the total excavation will be rock excavation
in this case, although roughly 50 percent will require dewatering
due to the prevalence of low-lying floodplain areas. Some of
the terrain will be rolling but the installation of both the
water diversion and booster pumping stations should not pose
unusual difficulties.
The time required to implement this alternative is estimated
at 15 months, which is longer than for Alternative 4A-1 due to
the need to cross two creeks and privately-owned land. Access
agreements often take two to six months to negotiate. This
land consists of mostly plowed fields used for agricultural
purposes.
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Alternative 4A-3 - Extended Catskill Water Supply Pipeline from
Rudolph Weir Road
Alternative 4A-3 is similar to Alternatives 4A-1 and 4A-2
except that in this option the tie-in to the existing pipeline
would be near Rudolph Weir Road in Cairo. The pipeline
extension would then cross Potic Creek by means of a pipe
support trench aoproximately 60 feet long. The Route 67
steel truss bridge would be used to hang the pipe across
Catskill Creek, which is roughly 200 feet wide at that point.
This bridge has a weight limit on vehicles crossing over it
of 28 tons and should, therefore, have no problem supporting
the proposed pipeline.
Approximately 10 percent of the total proposed excavation
will be rock excavation and roughly 60 percent will require
dewatering. As in Alternative 4A-2, some of the terrain will
be rolling, but the installation of both the water diversion
and booster pumping station are not expected to pose unusual
difficulties.
Although this alternative requires the longest length of
piping (23,000 feet of transmission pipe), it takes advantage
of an available bridge crossing and does not require access
to privately-owned land as in Alternative 4A-2. The time
required to implement this alternative is expected to be
approximately ten months, which is shorter than for either
Alternative 4A-1 or 4A-2.
Alternative 4C - New Well Field Water Supply System
Alternative 4C requires the installation of a new well field
consisting of two new deep wells, each six inches in diameter,
approximately 400 feet deep, and with a combined capacity of
at least 60 gpra. The proposed location of this new well
field is roughly one mile southeast of the AT site off Route
23B and within 1,000 feet of two recently installed wells at
two existing trailer parks. This location has been picked
because this area is expected to yield the most groundwater,
and the quality of water from the new trailer park wells is
reported to be satisfactory. However, the exact location and
number of wells can not be determined until a detailed
groundwater study is completed.
Construction of a 50,000 gallon, reinforced concrete, water
storage tank could require special foundation work depending
on the soil composition, and an agreement would have to be
negotiated with the private land owner regarding the location
of this tower on his property.
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-43-
Burial of the 13,000 ft of transmission pipeline would re-
quire approximately 30 percent rock excavation and 30 percent
dewatering. The time required to implement this alternative
is estimated to be approximately seven months.
Alternative 4D - Extended Trailer Park Well Water Supply
System
Alternative 4D is similar to Alternative 4C in relation to
constructability except that it requires extending an existing
trailer park well field instead of developing a new well
field. The major requirement in this case is to construct a
50,000 gallon, reinforced concrete, water storage tank to
enable using the maximum combined capacity of the two existing
wells (roughly 70 gpm). An agreement would have to be negotia-
ted with the trailer park owner regarding the location of
this tower on his property. Special foundation work might be
required due to the soil composition.
Burial of the 12,000 ft of transmission pipeline will require
roughly 30 percent rock excavation and 30 percent dewatering.
The time required for implementation is estimated to be
approximately six months.
0 Institutional Requirements
The institutional requirements evaluation is based on whether
the water supply alternatives can: 1) meet the administrative
and permitting requirements; 2) attain ARARs for this operable
unit; and 3) be acceptable to the public and state.
Alternative 1 - No Action
This alternative only inlcudes long-term O&M of the eight
existing point-of-use treatment systems and monitoring of
the other 20 homes immediately surrounding the site. No
permits have to be acquired for this activity. This alterna-
tive will not attain all of the ARARs because breakthrough
could occur and not be detected until the next round of sampling.
The public and State are not likely to accept this alternative
as a long-term protective measure.
Alternative 3B - Water Delivery by Tanker Truck, Elevated Storage
Tank, Water Lift Pump, and Water Distribution
L£Y_
Til
System
This alternative will require the establishment of a new
independent water supply district which will own and be
responsible for the O&M of the entire water supply system.
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-44-
A NYSDEC "Application for Permit" and its supplement, "Appli-
cation for Public Water Supnly Permit," would have to be
filed for this project. Any such project must also be reviewed
by NYSDEC with respect to its potential environmental impact
under New York State's Environmental Quality Review Act
(SEQR). A "negative declaration" would have to be filed by
the lead agency stating that in its judgment, this alternative
would not produce an adverse impact.
In addition to obtaining the NYSDEC permit, NYSDOH would have
to approve the proposed water supply system in terms of
compliance with water guality standards and would have to
review the engineering plans and specifications for the
distribution system. The design should be consistent with
"Recommended Standards for Water Works - 1982" (Water Work
Standards, 1982) and "The Design of Small Water Systems"
(NYSDOH, 1985).
Construction approval will be required from the Greene County
Highway Department to enable burial of distribution pipe
along County Route 238. An "Application for Permit to Do
Work On and Within a. County Road Area" must be filed along
with additional information such as a description of the
project and proposed activities, and a plan for handling
traffic disturbances or other special conditions. The Highway
Engineer would also meet with the contractor to discuss the
proposed work. A similar approval would be required from the
Town of Cairo for all work performed on town roads off Route
238.
This alternative is expected to meet the ARARs since it will
utilize purchased potable water from the nearby Catskill
Water District.
The public and State are likely to accept this alternative
since it provides a clean water supply with adequate quality
and quantity.
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-45-
Alternative 4A-1 - Extended Catskill Water Supply Pipeline from
Leeds
This alternative is different from Alternative- 38 since it
extends the existing Catskill Water Supply District pipeline
from Leeds to the potentially affected area. The same NYSDOH
and NYSDEC permit applications would be required as with
respect to alternative 3B, however.
Construction approvals would have to be obtained from the
Greene County Highway Department, the Town of Catskill and
the Town of Cairo. Permission would be required from the
Village of Catskill to enable connection to the existing
pipeline by the construction of a water diversion station.
Construction activities related to submerged installation of
the pipe across Catskill Creek would require an application
for a NYSDEC Stream Disturbance Permit. Permission might
have to be obtained from either the National and/or the New
York State Historical Society to enable construction of this
structure near the historic bridge in Leeds. No private land
would have to be acquired.
This alternative is expected to meet the ARARs since it
extends a currently approved potable water supply system. The
public and State are likely to accept its implementation.
Alternative 4A-2 Extended Catskill Water Supply Pipeline form
Sandy Plains Road
This alternative is almost identical to Alternative 4A-1 with
respect to institutional requirements. The only major dif-
ference is that Catskill Creek would be crossed by submerged
installation at a different location and an additional NYSDEC
Stream Disturbance Permit would be required for crossing Potic
Creek near Sandy Plains Road. Construction approval would
have to be obtained from the Town of Athens to enable work on
Sandy Plains Road. Privately-owned agricultural land might
have to be obtained in order to enable burial of the pipeline.
This alternative should also meet the ARARs and the public and
State are likely to accept its implementation.
V"'>~:>T't''""^Wv^
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«.
-46-
Alternative 4A-3 - Extended Catskill Water Supply Pipeline
'~from Rudolph Weir Road
This alternative is almost identical to Alternatives 4A-1 and
4A-2 with respect to institutional requirements. The only
major difference is that Catskill Creek would be crossed by
hanging the pipe on the Route 67 bridge in South Cairo. Use
of this bridge would require approval of the Greene County
Highway Department. Mo privately-owned land would be crossed
in this alternative.
This alternative should also meet the ARARs; and the public and
State are likely to accept its implementation.
Alternative 4C - New Well Field Water Supply System
This alternative also requires the establishment of a new
independent water supply district. All of the same require-
ments would have to be satisfied including obtaining the
NYSDEC permit, complying with SEQR requirements, obtaining
NYSDOH approval,.a Greene County Highway Department permit,
and Town of Cairo approval.
Private land would also have to be acquired in order to
establish the new well field and install the storage tank.
It is unknown whether this alternative will meet ARARs, since
the radius of influence of the well pumping might draw
contaminants from the AT site, or from the municipal landfill
(if that landfill is a source of groundwater contamination).
The public and state are not likely to accept this alternative.
Alternative 4D - Extended Trailer Park Well Water Supply System
This alternative is almost identical to Alternative 4C with
respect to institutional requirements. The only major
difference is that an agreement would have to be negotiated
with the trailer park owner as to the connection to and
extension of the existing well water supply system.
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0 Safety
The safety evaluation is based on whether the water supply
alternative might cause potential short-term health impacts
to workers and the oublic during excavation, construction and
other implementation activities.
Alternative 1 - No Action
Since this alternative only includes long-term O&M of the eight
existing point-of-use treatment systems and monitoring of the
other twenty homes immediately surrounding the AT site, the
only implementation activities would be replacing exhausted
carbon filter cells with new ones and replacing parts on the
airlift stripping system. Since these are closed systems and
no excavation or construction would he required, these activi-
ties should pose no potential short-term health impacts to
the workers and the public.
Alternative 3B - Water Delivery by Tanker Truck, Elevated Storage
Tank, Water Lift Pump, and Water Distribution
System . '
This alternative requires construction of a 50,000 gallon
elevated storage tank at the abandoned AT site to take advantage
of its central location, available static head due to elevation,
and paved access roads. Since the extent of on-site soil
contamination has not yet been completely characterized, but
dumping of hazardous waste onto site soils has been reported,
it is assumed that any excavation work conducted on the
property might result in potential short-term health impacts
to workers.
This potential risk can be mitigated by following the health and
safety plan which would be developed for the construction of this
remedy.
Installation of the transmission and branch piping along Route
23B and its side streets, common to each of the remaining
water supply alternatives, is not expected to result in any
short-term health impacts to workers. No other complex or
dangerous work is involved in the implementation of this
alternative..
Alternative 4A-1 - Extended Catskill Water Supply Pipeline
from Leeds
The major construction activity in this alternative is the
submerged installation of the pipeline including the pipe
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-48-
support trench required for crossing Catskill Creek at a point
where it is roughly 400 ft wide. Installation of the trans-
mission and" branch piping alone Route 238 and its side streets,
which is required by each of the water supply alternatives, is '
not expected to result in any short-term health impacts to the
workers. Burial of the pipe along the boundaries of the
American Thermostat property may require the workers to wear
PPE for that portion of the project.
Construction of the pipe support trench under Catskill Creek
might involve some complex and potentially dangerous work,
but only from the standpoint of working in and around a body
of water, not in relation to exposure to hazardous waste.
Alternative 4A-2 - Extended Catskill Water Supply Pipeline
from Sandy Plains Road
Alternative 4A-2 is similar to Alternative 4A-1 with respect
to worker safety considerations during implementation activi-
ties. The major construction activity in this case is the
installation of the oipeline, including two submerged trenches
to cross both Potic and Catskill creeks.
No short-term health impacts to the workers are expected
during burial of the pipeline, except maybe during the portion
of the project which entails work along the boundaries of the
American Thermostat site. Adherence to site-specific health
and safety protocols should minimize this concern.
Alternative 4A-3 - Extended Catskill Water Supply Pipeline from
Rudolph Weir Road
Alternative 4A-3 has the same safety concerns as Alternatives
4A-1 and 4A-2, in addition to concerns associated with suspending
a pipeline from the bridge.
Alternative 4C - New Well Field water Supply System
The major construction activity in this alternative entails
drilling two new wells-and installing a water storage tank and
complete distribution system. Unlike Alternatives 4A-1, 4A-2,
and 4A-3, no complex or potentially dangerous work involving
crossing water bodies will be required. The only potential
short-term exposure to the workers might occur during excava-
tion for pipe-laying alone the boundaries of the AT site.
The remainder of the construction work should pose no safety
problems.
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TABDrc
AMERICAN THERMOSTAT
COMPARISON OP ALTERNATIVE HATER SUPPLY ALTERNATES
Tiro to
Capital Cost OtM Cost Present Worth Cost
Qograent
Remedial Alternative
Alt. 1 No Action
Point of Use Hater Supply
Alt. 3B Water Delivery by
Tanker Truck, Elevated
Storage Tank, Mater
Lift Punp and Water Dis-
tribution System
Alternate Mater Sou
Alt. 4A-1 Extended Cataklll Hater
Supply Pipeline from
Alt. 4A-2 Extended Catskill Water
Supply Pipeline from
Sandy Plains Road
Alt. 4A-3 Extended Catskill Hater
Supply Pipeline froa
Rudolph Weir Road
Alt. 4C New Nail Field Htter
Supply System
2.32
3.17
2.27
2.38
2.20
Alt. 4D attended Trailer Park Hall 2.06
Niter Supply System
costs ere in 9 million
0.18 1.70
0.20 4.38
0.12 4.23
0.10 3.21
0.11 3.47
0.13 3.38
0.12 3.22
N/A
Does not protect human health by providing
potable water to the comunity.
Would require 4 tanker truck deliveries
per day. Subject to service interuption
(e.g. truck breakdowns).
lyr.
Would provide adequate potable water fron
existing water district. Crosses Catskill
Creek near historic bridge in Leeds.
l-2yrs. Would provide adequate potable water fran
existing water district. Would require
easenents or acquisition of private land
for pipe routing.
1 yr. Would provide adequate potable water from
existing water district. Crossing of Cat-
skill Creek by suspending pipe fron Route
67 bridge.
1 yr. Would require creation of new water dis-
trict. Hall field location could be sub-
ject to leachate contamination from nearby
landfill.
1/2 yr. Sane as 4C.
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Alternative 4P - Extended Trailer Park Well Water Supply System
Alternative-4D is similar to Alternative 4C except that it
requires extending an existing trailer- park well field instead
of developing a new well field.
Cost
The cost evaluation of each alternative is based on the
capital cost (cost to construct), O&M cost (O&M), and present
worth cost.
Present worth analysis is used to allow the costs of the
various alternative to be compared on the basis of a single
total cost figure representing the amount of money, that, if
invested in the base year and expended as needed, would be
sufficient to cover all the costs associated with the remedial
action over its planned life.
The capital, O&M, and present worth costs for each alternative
are presented in Table 6.
SELECTED REMEDY .
The objective of this operable unit is to eliminate the threat
posed to area residents by exposure to contaminated groundwater,
and represents the first operable unit of a permanent remedy
for the AT site. Identification of the nature, extent and
sources of the contamination at and around the site, and the
possible remediation of the groundwater contamination will be
addressed in a subsequent ROD.
Based upon CERCLA as well as upon the review and evaluation
of the water supply alternatives, the viable alternatives were
narrowed down to two:
Alternative 4A-2 consists of extending the existing Catskill
Water District pipeline from Sandy Plains Road along Route 23B
to supply all of the potentially affected residences. This
option would require crossing both Potic Creek and Catskill
Creek along with crossing privately owned properties.
Alternative 4A-3 consists of extending the existing Catskill
Water District pipeline from Rudolph Weir Road along Routes
67 and 23B to supply all of the potentially affected residences.
This option would require crossing Potic Creek near an existing
wooden bridge, and Catskill Creek by hanging the pipeline from
the Route 67 bridge in South Cairo.
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EPA has rejected the various other alternatives that were
considered during the detailed evaluation phase of the FFS.
Alternative 1 was rejected because it would allow the existing
situation to continue, and therefore, would not protect human
health. Alternative 3B is not considered reliable on a long-
term basis. O&M problems are potentially high (e.g., road
closures due to inclement weather, tank truck breakdowns,
etc.) Alternative 4A-1 was rejected because of its relatively
high cost, compared with the expected costs of Alternatives
4A-2 and 4A-3 and because of the potential impacts of construc-
tion near the Leeds Bridge (a historical site) and the additional
rock excavation during construction. Alternative 4C was
rejected due to the uncertainties related to developing a new
well field in this area. While the area selected might
provide wells with a yield of 60 gpm, only a detailed and
lengthy hydrologic groundwater study would determine if this
was indeed a fact. In addition, the proximity of an existing
landfill nearby could create a new potable water quality
problem in the future.. Alternative 4D has similar problems
associated with it. If the existing wells were pumped at
their maximum capacity, water quality problems could arise
due to leachate from the nearby landfill. For this reason,
Alternative 4D was also rejected.
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The extension of the Catskill water supply system (in particular,
Alternatives 4A-2 and 4A-3) best meets all evaluation criteria
as previously described. Specifically, this remedy will best
meet the objectives of CERCLA in that it is protective of
human health, is implementable and cost effective, will
provide a permanent solution to the problem of potential
exposure of area residents to groundwater contaminants, and
attains the ARARs and criteria relevant to this operable
unit.
Although Alternative 4A-2 requires less pipeline and is less
costly than Alternative 4A-3, it would require easements or
acquisition of private land for the waterline routing.
Because of the concerns that significant delays in acquiring
the necessary easements might impact our ability to implement
Alternative 4A-2 in a timely manner, Alternative 4A-3 was
presented to the public as the preferred remedial alternative.
However/ as a result of local concerns regarding possible
vandalism associated with suspending the pipeline from the
Route 67 bridge as called for in Alternative 4A-3, and an
increase in O&M costs that would result from the booster pump
and a longer pipeline, EPA has decided that further evaluation
of the advantages and disadvantages of Alternatives 4A-2 and
4A-3 should be conducted during the design phase. After
performing this evaluation, which will include consultation
with state and local agencies, EPA will make a final decision
regarding the exact route of the pipeline.
Implementation of this remedy will effectively remove the
risk of exposure to contaminated groundwater. Further,
implementation of the selected alternative is consistent with
all ARARs, including the Maximum Contaminant Levels established
pursuant to the Safe Drinking Water Act.
Extension of the waterline (Alternative 4A-2 or 4A-3) represents
the most cost-effective of all remedies considered. The
estimated present worth cost of extending-the waterline
ranges from $3.21-3.47 million.
Selection of the waterline extension does not satisfy the
statutory preference for remedial actions including treatment
(which permanently and significantly reduces the volume,
toxicity or mobility of hazardous substances) as a principal
element, the reason being that such treatment options were
not found to be practicable or appropriate for this operable
unit. Such options, however, will be considered during the
next operable unit.
. _ „ „ .,.........,„.. -,~,,^v.^-v-*-«>^,j:W5:;;^^
''•'•••-'$ ••;,>t-V.,-.--,'-,V;f'i"-'l' "'•'V?* *"' •''*'"?* ' "•,~:"^V rJ'*-*--^t-~ • ' '-- - . -,r - - *--vt
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-52-
Among the alternatives considered during the FFS was one
which would have involved the provision of an alternate water
supply through the use of a centralized well water treatment
system. However, this alternative (Alternative 2B) would
not provide-a reliable permanent and long-term remedy for
the water supply problem. Due to the continuous migration
of groundwater contaminants in an unpredictable way in the
bedrock fractures and joints, the O&M that would be required
for Alternative 2B to produce safe drinking water in compliance
with the ARARs would be very difficult. Construction of
this alternative would entail high difficulty in relation to
burial of two sets of pipe (one for clean and one for contami-
nated water), installation of a centralized treatment facility,
and replacement of any existing well pumps which may be in-
adequate for these purposes.
Consistency with Other Environmental Laws
EPA conducted a preliminary evaluation of the project area
for its potential for discovery of cultural resources. The
evaluation indicates that known prehistoric occupations have
been identified on both the terraces and low-lying areas to
the north and south of the project area. In addition, Route
23B (i.e., the Mohican Trail), which is listed on the National
Register of Historic Places,- and Leeds bridge, which is an
Historic Landmark, are in the project area and may be impacted
by the proposed operable unit alternatives. Accordingly, it
has been determined that the project area is highly sensitive
for the discovery of cultural resources. Therefore, a survey
will be conducted during the design phase to determine the
presence or absence of unidentified cultural resources, as
well as to provide proper documentation of known resources
that could potentially be impacted by the proposed operable
unit. Further, if the survey determines that significant
resources will be impacted by the project, appropriate mitiga-
tion measures will be developed and implemented during the
remedial design phase of the project.
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-53-
The selected-alternative will be located within a 500 year
floodplain. Although the major portion of the project (i.e.,
the water main) will not result in long-term impacts to the
floodplain or flooding levels, construction of the diversion
chamber associated with the project may have long-term impacts
on flooding levels depending on its location. Although it is
not believed that the impacts will be significant, a floodplain
assessment will be prepared for the diversion chamber during
the remedial design phase of the project. This will include
development of appropriate control measures to protect the
diversion chamber from flooding effects.
Community Acceptance
The residents were notified of the preferred remedy with the
issuance of the PRAP, released on December 3, 1987, and at
the public meeting held on December 8, 1987. The reaction at
the public meeting was, in general, one of support for the
proposed remedy. The main area of questions concerned the
possibility of adding fire protection and/or expanding the
service area. In addition, the Village of Catskill raised
the question regarding the ability of its water system to
handle the additional capacity associated with adding 80
residences to the system. According to CPA's contractor, the .
water supply system appears to be capable of providing enough
additional capacity for both the proposed service area
surrounding the AT site and for limited growth in the present
water district. It is EPA's intention to work cooperatively
with the Village to resolve the capacity issue during the
design phase. However, if disagreement between EPA and the
Village still persists, EPA will seek an independent assess-
ment to evaluate the Village's capacity to handle the additional
load.
In order to comply with the request for fire protection, if
the local entities agree to pay for the incremental cost
associated with full fire protection, EPA is prepared to
provide an alternate water supply and distribution system
with partial fire protection capabilities, including hydrants,
valves, pumps, and the means for providing adequate pressure.
EPA would not, however, provide equipment specifically related
to the provision of extra water capacity, such as a larger
diameter pipeline or larger capacity water storage tank.
These additional costs for full fire protection would have
to be covered by the State or locality. The cost involved in
providing partial fire protection and full fire protection
are compared to the base costs, and are shown in Table 7.
With regard to an expanded service area, EPA can only provide
water to correct the problems within an existing system. If
the local communities wish to expand the service area, they
would be required to pay the incremental cost increase.
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TABLE 7
AMERICAN THERHOSTAT
COMPARISON OP ALTERNATIVE WATER SUPPLY ALTERNATIVES WITH FIRE PROTECTION
Capital Cost*
Remedial Alternative
Alt. 1 No Action
Point of Use Water Supply
Alt. 3B water Delivery by
Tanker Truck, Elevated
Storage Tank, Hater
Lift Pump and Water Dis-
tribution System
Alternate Water Sources
OtM Cost Present Worth Cost Time to
Inp lament
Without With With Without With With without With .With Prom ROD
FP2 Partial FP FP FP Partial FP FP FP Partial FP Signing
2.50
Alt. 4A-1 Extended Catski 11 Water 3.17
Supply Pipeline from
Leeds
Alt. 4A-2 Extended Catski 11 Water 2.27
Supply Pipeline from
Sandy Plains Road
Alt. 4A-3 Extended Catski 11 Water 2.38
Supply Pipeline from
Rudolph Weir Road
Alt. 4C New Well Field Water
Supply System
2.20
Alt. 4D Extended Trailer Park Well 2.06
Water Supply System
2.37
3.31
2.46
2.61
2.40
2.25
0 0.18 0.18 0.18 1.70 1.70 1.70 N/A
3.34 0.20 0.20 0.21 4.38 4.27 5.32 1 yr.
3.91 0.12 0.12 0.14 4.23 4.45 5.24 1 yr,
2.93 0.10 0.11 0.12 3.21 3.48 4.09 l-2yrs.
3.36 0.11 0.13 0.15 3.47 3.78 4.79 1 yr.
3.47 0.13 0.13 0.15 3.38 3.67
3.29 0.12 0.13 0.15 3.22 3.49
4. 89 1 yr>
4.68 1/2 yr,
Notes
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-54-
SCHEDULE *
f
AMERICAN THERMOSTAT REMEDIAL ACTION
Activity Date
0 Regional Administrator Siqns January 1988
Record of Decision
0 Complete 60 Day Enforcement February 1988
Moratorium**
If no PRP pick-up, then:
8 Contractor Procurement and February-September
Remedial Desiqn 1988
0 Contractor Procurement Process September to
for Construction . November 1988
0 Initiation of Implementation . November 1988
of Remedy
0 Construction Complete November 1989
* This is a projected schedule for this site and it is
therefore subject to future modification.
** If a "good faith" offer is made by the PRPs within the
60 days, the enforcement moratorium would be extended an
additional 60 days.
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ADMINISTRATIVE RECORD INDEX
(to be provided)
ATTACHMENT A
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Ltv. 31 '37 12 = 56 NYS.ENV. CONS. flLBflNY NY
Jew York State Department of Environment** Conaarvatian
0 Wolf Road, Albany, New Yorfc 12233. nniemai con««'v«tlon
TELEX
Mr. Stephen 0. Luftlg
Director
Office of Emergency and Remedial Response
Protect1on
26 Federal Plaza
New York. NY 10278
Dear Mr. Luftlg:
Re: American Thermostat Site
Operable Unit 1
Site I.D. No. 420006
sdF
(NYSOEC)
. f
n»1i>t«.nc. iftw tht flnt J.2 S wrlt'SI. ' h§ °Mr'tlM •»«
Sincerely,
cc: 8. Pavlou, ySEPJ, Region II
J. Slngermait. USEPA. Region II
••
D1v1i1on of Hazardous Haste Renedlatlon
ATTACHMENT B
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RESPONSIVENESS SUMMARY
ATTACHMENT C
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>A WORK ASSIGNMENT NO. 157-2L77
EPA CONTRACT NO. 68-01-7250
EBASCO SERVICES, INC.
RESPONSIVENESS SUMMARY
FOR THE
AMERICAN THERMOSTAT SITE
SOUTH CAIRO, NEW YORK
JANUARY 1988
NOTICE
The information in this document has been funded by the United
States Environmental Protection Agency (U.S. EPA) under REM III
Contract No. 68-01-7250 to Ebasco Services, Inc.
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AMERICAN THERMOSTAT SITE
SOUTH CAIRO, NEW YORK
RES PONS I VENESS . SUMMARY
The U.S. Environmental Protection Agency Region II (EPA) released
to the public on December 3, 1987 a Focused Feasibility Study
(FS) and Proposed Remedial Action Plan (PRAP) on the American
Thermostat site for public review and comment from December 3,
1987 until December 24, 1987. As part of the public comment
period, EPA held a public meeting on December 8, 1987 at the
Greene County Court House in Catskill, New York to describe the
remedial alternatives and to present EPA's preferred alternative
for the development of an alternate water supply at the American
Thermostat site. The implementation of an alternate water supply
at the American Thermostat site is considered the first step (or
first "operable unit") for remedial action at the site. A full-
scale Remedial Investigation and Feasibility Study (RI/FS) of the
American Thermostat site and the area groundwater will be
conducted by EPA at a later date.
The purpose of this responsiveness summary is to provide EPA and
the public with a summary of citizen comments and concerns about
the site, and EPA's response to those concerns. A summary of
comments received during the public comment period is provided in
Section III. All comments and concerns summarized in this
document have been factored into EPA's final decision regarding
the selection of an alternative to provide an alternate water
supply to areas affected and potentially affected by
contamination from the American Thermostat site.
This community relations responsiveness summary for the American
Thermostat site is divided into the following sections:
I. Responsiveness Summary Overview. This section, briefly
outlines the proposed remedial alternatives that were
evaluated as part of the Focused FS, including EPA's
selected alternative.
II. Background on Community Involvement and Concerns. This
section provides a brief history of community interest in
the American Thermostat site and a chronology of community
relations activities conducted by EPA during remedial
response activities conducted to date.
Ill . Summary of Major Questions and Comments Received During
-c Comment Period and EPA Resonses to
.
This section summarizes major questions and comments made
verbally and in writing to EPA during the December 8th
public meeting and public comment period (December 3 -
December 24) and provides EPA responses to these comments.
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IV. Remaining Concerns. This section discusses community
concerns about the American Thermostat site that were not
directly addressed during the Focused FS and that EPA
should consider during the next phase of remedial
activities, specifically the RI/FS for the second operable
unit at the American Thermostat site.
I. RESPONSIVENESS SUMMARY OVERVIEW
The American Thermostat site is located in the Catskill Creek
Valley in South Cairo, Greene County, New York. American
Thermostat Corporation operated from 1954 to May 1985 assembling
thermostats for small appliances. Tests of several residential
and commercial wells in the vicinity of the American Thermostat
plant indicated the presence of trichloroethylene (TCE) and
tetrachloroethylene (PCE) in five residential wells. In May 1981
the State issued an advisory to affected residents advising them
not to drink or cook with their well water. In 1983, under a
consent order from the State, American Thermostat Corporation
installed and periodically monitored carbon filters on
contaminated residential wells, provided bottled drinking water
to one resident whose well water was unfilterable, and conducted
regular sampling and analysis. The activities were halted in Ma
1985, when the American Thermostat Corporation ceased operation
at the site.
In August 1985, in response to a request for support from the New
York State Department of Environmental Conservation (NYSOEC), EPA
began a removal action to maintain the installed carbon filters,
sample other domestic potable wells near the site, and provide
additional affected homes with carbon filters and bottled water
if needed. In September 1986, EPA authorized the installation of
an airlift stripping system for the residential well closest to
the site and the most seriously contaminated. Another
contaminated residential well was discovered in February 1987 and
EPA authorized the installation of a carbon filter.
In November 1987,vEPA completed a Focused FS to identify an
alternate water supply for affected and potentially affected
residents. The Focused FS initially identified thirteen
potential remedial alternatives. EPA identified seven of the
most feasible for supplying an alternate water supply to affected
and potentially affected residents. These alternatives are
briefly summarized below.
Alternative It No Action
The no action alternative would involve the maintenance of the
existing granular-activated carbon filters and airlift stripping
-------
system and the continued monitoring of twenty-eight residential
wells within the vicinity of the American Thermostat site.
Alternative 3B; Water Delivery bv Tanker Truck. Elevated storage
Alternative 3B would involve the construction of an elevated
storage tank, a water lift pump, and a water distribution system.
EPA would deliver water four times per day by tanker truck to the
storage tank.
Alternatives 4A-1. 4A-2. and 4A-3: Extending the Existing
Catskill Water District Pipeline
Alternatives 4A-1, 4A-2, and 4A-3 all would involve purchasing
water from the nearest municipal water supply system and
extending the Catskill water supply pipeline to the affected and
potentially affected residences. Each alternative, however,
proposes to extend the existing pipeline from different
locations. Alternative 4A-1 would involve extending the Catskill
water supply pipeline from the Town of Leeds and run it across
Catskill Creek and along Route 23B. Alternative 4A-2 would
involve extending the Catskill water supply pipeline from Sandy
Plains Road then across both the Potic and Catskill Creeks and
along Route 23B. Alternative 4A-3 would involve extending the
pipeline from a point near Rudolph Weir Road, across both Potic
and Catskill Creeks, and along Routes 67 and 23B.
Alternative 4C; Mev Well Field Water Supply System
Under Alternative 4C, EPA would establish a new, independent
water supply district consisting of two new wells, a water
storage tank, chlorine treatment, and a booster pumping station.
In addition, EPA would extend a pipeline along Route 23B to serve
the affected and potentially affected homes. This alternative
would require EPA to select a suitable location for drilling new
wells outside the potential area of contamination.
Alternative ^ d rai.ler Park Well Water Su
Alternative 4O would involve extending the well water supply
system of an existing trailer park, located approximately three-
quarters of a mile upgradient of the site.
All of the alternatives discussed above, except for the no-action
alternative, would provide adequate potable water to the affected
and potentially affected residents.
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ALTERNATIVE
After careful evaluation of the remedial alternatives, EPA has
selected the extension of the Catskill water supply pipeline to
the affected and potentially affected residents. The specific
pipeline .route to be implemented will either be alternative 4A-2
or 4A-3, described above. The final decision will be made during
the design phase.
The selected remedial alternative is documented in the Record of
Decision (ROD) . A remedial investigation and feasibility study
will be conducted at a later date to determine the full extent of
contamination from the site and to develop alternatives to clean
up the site and restore the groundwater.
II. BACKGROUND ON COMMUNITY INVOLVEMENT AND CONCERNS
The residents that have shown the most interest and concern about
the site are mostly those residents with contaminated wells. In
early 1986, EPA researched the community concerns and developed a
Community Relations Plan to address those concerns. The concerns
identified in 1986 and EPA actions to address those concerns are
described briefly below.
Effectiveness of carbon filtered water. Residents who
have had carbon filters installed in their homes questi
the effectiveness of the filters in cleaning the water.
As a result, residents have been using bottled water
cooking and drinking. In response to this concern, EPA
made sampling results available- to the -residents and
assured residents through a meeting that the carbon filter
system does provide potable water meeting safe drinking
water standards.
Irregular schedule for carbon filter monitoring and
maintenance. The residents with carbon filters have
expressed concern with what they perceived as an irregular
schedule for monitoring their filters and requested that
EPA or the New York State Department of Health (NYSDOH)
provide regular and easily understandable monitoring
reports, concerning the status of their filters. In
response to this concern, EPA has taken quarterly samples
and has provided the monitoring reports. In addition,
when EPA officials visited residences to take samples they
answered .residents' questions.
Schedule for providing bottled water. In January 1986,
the residents using bottled water expressed concern about
depleting their bottled water supply before EPA or NYSDEC
would resupply them. EPA stopped providing bottled water
in 1986 once the carbon filters were installed. Since EPA
has satisfied concerns about the effectiveness of the
-------
carbon filters currently there is no requirement for EPA
to supply bottled water.
Concern about health effects from contamination.
Residents were concerned about an expeditive cleanup of
the American Thermostat site so that the plume of
contamination does not spread and exposure is reduced.
The remedy selected in the ROD will prevent exposure of
the residents to contaminated groundwater. The subsequent
RI/FS planned by EPA for the site will, among other
things, address possible methods of remediating the
contamination at and around the site.
Adverse economic impact from contamination. Residents
expressed concern about potential decrease in property
values as a result of well contamination and the effect on
employment because of the shut-down of the American
Thermostat operation.
In addition to community interviews in January 1986 and a
Community Relations Plan, EPA issued a Public Notice on December
3, 1987 that summarized the preferred remedial alternative,
announced the availability of the Focused FS and PRAP for public
review and comment, and provided notice of the upcoming public
meeting. The notice was published in the Catskill Daily Mail.
In addition, EPA developed a fact sheet that outlined the
remedial alternatives and described EPA's preferred remedial
alternative for the American Thermostat site. This fact sheet
was distributed at the public meeting.
EPA conducted a public meeting on December 8, 1987 at the Greene
County Court House in Catskill, New York, to provide information
on the Focused FS and EPA's preferred remedial alternative, and
to provide an opportunity for interested parties to present
verbal comments and questions to the EPA. Six local officials
and twelve residents attended this meeting, as well as three EPA
officials, members of EPA's contractor staff, and representatives
of NYSDOH and NYSDEC.
The comments and questions received* by EPA at the public meeting
are recorded in a full transcript of the meeting, which is
available for review at EPA's regional office in New York City,
NYSDEC'» office in Albany, New York, and the Greene County Court
House in Catskill, New York.
III. SUMMARY OF MAJOR QUESTIONS AND COMMENTS RECEIVED DURING
THE PUBLIC COMMENT PERIOD AND EPA'S RESPONSE TO COMMENTS
On December 3, 1987, EPA released the Focused FS and PRAP to
receive verbal and written comments from the public from December
3, 1987 until December 24, 1987. This responsiveness summary
summarizes the significant concerns and issues raised during the
-------
public comment period and EPA's responses to those concerns.
These concerns and issues have been considered by EPA in the
final decision on the remedial alternative.
Verbal Continents
During the public comment period approximately twenty verbal
comments were received at the public meeting; most dealt with
public health protection and the proposal to expand the pipeline
capacity. These comments are categorized by the following
topics.
A. Health and safety,
B. Nature and extent of contamination, and
C. Preferred remedial alternative.
A. Health and Safety
1. congn^n.^ * A local official asked if the public has been
informed of the nature and potential health effects of the
detected contaminants.
EPA Response! . in 1981 NYSDOH informed the affected
residents of the potential health effects of using contaminated
water and advised residents not to use the water for cooking or
drinking purposes. Furthermore, EPA has implemented a removal
action to maintain and install additional: carbon filters at seven
residences and an airlift stripping system at one residence to
mitigate the problem of drinking water contamination.
2. CQfflfflfnt * A resident inquired if EPA had conducted a
health evaluation of the affected residents.
EPA Response; A risk assessment will be conducted by
EPA's contractor during the RI/FS for the second operable unit.
The Agency for Toxic Substances and Disease Registry (ATSDR) will
prepare a health assessment based upon this document.
3. CPlTBflnt * A resident inquired if the quality of the
proposed alternative water source meets federal and state
drinking water standards.
EPA Response: Water supplied by the Catskill Water
District meets state and federal standards and NYSDOH will
routinely monitor to ensure that the proposed water supply
continues to meet safe drinking water standards.
4. CQBTIf nfe * A local official asked if the carbon filters
installed at the affected residences were proven to provide a
-------
safe level of public protection from the contaminated water.
EPA Response; The carbon filters that were installed at
seven of the affected residences have been proven to be effective
in removing contaminants.
5. Comment ; A local official inquired if future property
owners would be eligible to receive carbon filters if additional
wells were drilled and contamination was detected.
EPA Response; In accordance with EPA policy, until the
remedy selected in the ROD is implemented, future property owners
would be eligible to receive carbon filters to treat contaminated
well water. Once the waterline is installed, however, new
homeowners will have to hook up to the waterline at their own
expense .
B. Nature and Extent of Contamination
1. Comment ; A local official inquired about the extent of
the contamination and how EPA defined the proposed water supply
service area. .
EPA Response; Contamination was found to extend a half
mile northwest ami a quarter mile southeast of the American
Thermostat site and within the boundaries of Catskill Creek and
Route 23. To determine the proposed water supply service area,
EPA estimated the potential area of contamination by projecting
the extent of contaminant migration after twenty years of
groundwater restoration efforts. Based on these estimates, EPA
determined that the^ service area included all residents within
the boundaries of ' o'rie Trifle northwest and a half mile southeast of
the American Thermostat site and within Catskill Creek and Route
23. -••^,^c ;v ,-^,.,^ _,. ,:,v.^ .....-., ?i , ..... .,.,
2. Comment ; One resident asked if -groundwater contamination
will be removed.
EPA Response: A RI/FS will be conducted by EPA to examine
the source, nature, and extent of tlie contamination and to
develop *«asurea_to clean up the American Thermostat site and
groundwater contraf fiat ion. Based on the findings of this RI/FS a
remedial alternative may be selected to remove the contaminants
from
3. comment : X' local official asked if contaminants were
detected in the Catskill Creek and where water samples were taken
at the creek.
EPA Response; Based on one sample taken in 1982 near the
historical bridge at Leeds, contaminants have not been detected
in the Catskill Creek. Additional samples will be collected by
-------
EPA during the upcoming RI/FS for the second operable unit.
C. Preferred Remedial Alternative
1. Cg]flfl?nt ; One resident inquired about the number of
pipelines involved in implementing the preferred remedial
alternative.
EPA Response; The selected remedial alternative involves
the installation of one pipeline to provide a safe water supply
to the designated service areas. Installation of a single
pipeline is efficient and can be quickly implemented to provide
the public with a safe potable water supply as quickly as
possible.
2. Comment ; A local official asked whether the preferred
remedial alternative can accommodate all properties within the
proposed water supply service area.
EPA Response; The selected remedial alternative will
accommodate all properties within the proposed water supply
service area. A six inch diameter pipe has been determined by
EPA to provide a sufficient amount of water to the current
residents within the proposed water supply service area.
3. £gjBmej2£: A county official asked, who would operate and
maintain the proposed extended pipeline extension.
EPA Response; Pursuant to the Comprehensive Environmental
Response, Compensation and Liability Act. (CERCLA) the State of
New York is required "to provide for the operation and maintenance
of the system. The specific arrangements regarding the operation
and maintenance of the system will have to be coordinated between
the state and local municipalities.
4 . Comment - A. resident inquired about the costs that may be
incurred by homeowners to implement the preferred remedial
alternative.
EPA Response: EPA (or the potentially responsible
parties) will assume responsibility for all design and
construction cost* of the selected remedial alternative (the
state vill contribute 10 percent of the construction costs) . Once
the new pipeline is installed and homes are connected, EPA's
responsibilities do not extend to the additional usage and
maintenance expenses. Further expenses incurred by residents for
water usage would be determined by the water district.
5. C oimf n*^ ; Several local officials expressed support for
implementation of the preferred alternative. These local
officials wanted to know whether it was possible to increase the
size of the proposed pipeline to acconaodate future development
8
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in the Village of Catskill, and the Towns of Cairo, and Athens
and to provide fire protection.
EPA Response: EPA would support a proposal to increase
the capacity of the pipeline system 'to accommodate future
development and to provide fire protection. However, EPA's
primary concern and responsibility is to quickly provide public
health protection to affected or potentially affected residents.
Also, EPA cannot assume the additional cost of the pipeline
expansion. This additional cost would have to be borne by one or
more of the interested municipalities. The provision of fire
protection for the potentially affected area is not required by
law. However if the municipalities are willing to incurr the
incremental costs for fire protection, EPA would cover the costs
for partial fire protection such as the valves, hydrants, etc.
Furthermore, any commitment on their part to pay this incremental
cost would have to be made prior to the initiation of the
remedial design.
6. Comment; A local official asked if all the towns have
been informed of the request by the Village of Catskill to expand
the pipeline capacity.
EPA Response; Prior to the December 8th public meeting,
EPA representatives met with the Catskill Town Supervisor and
were informed of the request by the Town of Catskill to expand
the pipeline capacity beyond what is proposed in the Focused FS.
EPA is willing to arrange another meeting with interested parties
to discuss the request to increase the pipeline capacity.
7. Comment ; A resident inquired when EPA would need an
agreement among the towns to assume responsibility for the
additional costs of expanding the pipeline to accommodate future
development.
EPA Response; The detailed design of the remedial
alternative is scheduled to start in March 1988 and an agreement
from the towns must be reached before the design is started.
8. egpnji^n-fc • A local official inquired about the time period
involved in completing the design of the preferred remedial
alternative and when construction would begin.
BPA Response; The design of the selected remedial
alternative is scheduled to take three to four months to complete
and the construction is proposed to be funded in Fall 1988.
Written
Three letters with approximately thirty comments were received by
EPA during the public comment period; most involved technical
-------
questions and stressed the need to timely inform the appropriati^
agencies and municipalities and residents. The following letters
were received by EPA from the Greene County Planning Department,
the Village of Catski11 Board of Trustees, and a resident, and
are attached as Appendix One.
RESPONSES TO COMMENTS FROM THE GREENE COUNTY PLANNING DEPARTMENT
IN LETTER OF DECEMBER 16. 1987
1. Comment: Would greatly appreciate being supplied a
transcript of the December 8th meeting as soon as it becomes
available.
EPA Response; A copy of the transcript and a copy of the
Responsiveness Summary will be made available at the information
repositories established for this site. The information
repositories are located at the following addresses:
Greene County Court House
County Clerk's Office
P.O. Box 446
Main Street
Catskill, New York 12414
New York State Department of
Environmental Conservation
50 Wolf Road
Albany, New York 12233
U.S. Environmental Protection Agency
Emergency and Remedial Response Division
26 Federal Plaza
New York, New York 10278
2. Comment* There are several companies interested in
locating at the site, however, I am still not clear as to when
the site will be available for use. I would appreciate being
informed of other additional considerations which may be of
concern in regard to the future use of the site.
EPA Response; The reuse of the American Thermostat site
will depend on the requirements of the second operable unit,
cleanup of the site.
During the remedial investigation planned to commence in January
1988, EPA will determine the nature and the extent of the
contamination at and around the site. At the completion of this
study, EPA will be better able to discuss concerns about the
possible future use of this site. Measures need to be taken to
provide a safe water supply for future use at the American
Thermostat site. ""'" -.* •
10
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3. g9flffllfn^: Although I was very pleased to hear of a
solution close at hand, I was taken back by the inadequacy to
properly inform the appropriate municipalities of the
proposal(s).
I hope tl»t as you near a decision on a water supply alternative,
that better communication be had between your agency and those
having an interest here in Greene County.
In light of the fact that EPA's preferred alternative 4A-3 would
withdraw water from the Village of Catskill supply, I fail to
understand why the local authorities have not been fully informed
of your agency's proposal.
EPA Response: A public notice, which is required under
the Superfund Amendment and Reauthorization Act (SARA), was
published in the Catskill Daily frail announcing the date,
location, and time of the public meeting. EPA's preferred
remedial alternative and the 21-day public comment period to
review the Focused FS were also announced in the public notice.
In addition, the concerned municipalities were notified about the
public meeting. Futhermore, EPA and its contractor consulted the
Village consulting engineer during the months preceding the
issuance of the Focused FS.
EPA believed that all .of the"appropriate parties were contacted.
We regret any misunderstandings that may have resulted. At this
time, all of the appropriate agencies and municipalities have
been contacted by EPA and it is EPA's intent to work jointly with
these municipalities and agencies to expedite the implementation
of an alternate water supply.
During preparation of the Focused Feasibility Study Report, EPA's
contractor contacted the following interested agencies.
MYSDEC
NYSDOH -v. _,...<:o,.
a* Cairo Planning Board
• Greene County Highway Department
NYSGS, UGS
Potic Reservoir Water Treatment Plant
Village of Catskill Department of Public
Works
Village of Catskill Offices
11
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Greene County Tax Office
ISO Commercial RiaK Services, inc.
Consulting Engineer for Village of catsKill,
4. Confflint: According to a newspaper article, the village of
Cat skill water supply system does not have the capacity to
withstand additional vithdrawls proposed by several future
projects, including a 400 room hotel, expansion of a nursing home
and a townhouse development project.
EPA Raanon««! The provision of water for this project
requires about 3 percent of the total system capacity and
therefore has a very minor impact on the Village of Cat ski 11
water supply system.
EPA was informed of a proposal to construct a 400 unit hotel but
the project was defeated. EPA is not aware of any other proposed
projects. Based upon available data, the water supply system has
been calculated to provide enough water to accommodate both the
proposed service area and projected growth in the present water
district.
S. £gjDBftn£: According to EPA schedule of events, any
response to your proposal would be required almost immediately.
This sinply does not provide local and county governments enough
tine to accomplish the many tasks involved in preparing a
thorough response.
EPA Reaponse! in accordance with SARA, a public comment
period was established for 21 days after the release of the
Focused ta and EPA's preferred alternative for public review and
comment. An independent assessment may be conducted to
facilitate an agreement, if the Village and EPA deem necessary.
RESPONSES TO COMMgJfPS PROM THE VILLAQE OP
F TRUSTEES
IN LETTER Q EBER 16- 1987
1, comment i In reference to Figure 1-3 in the Focused FS the
septic tank absorption field is not an absorption field, it is a
sand filter with the treated effluent discharging to Tributary A o
gpi g««t*m«rtt The error is noted.
2 . eoamenti The present reservoir is inadequate to meet the
existing deaand in drought periods. How will the reservoir
capacity be increased? Present regulations are for a 100-year
safe yield; the Village supply has gone dry twice in the last 30
years.
12
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SPA Rf SPCnt* : The projected additional demand based on
population and maximum expected flow will only be approximately -
percent of the total capacity of the system. Any supplemental
water sources used during a drought by the existing water supply
district should be applicable to the proposed service area.
3. conaent t The present filters will be inadequate to meet
the increased demand; the two filters which were not rebuilt in
the recent rehabilitation will have to be rebuilt.
SPA Responses The two filters will not be needed to
supply the projected additional demand, which will only be about
3 percent of the total system capacity.
4. gomnanti There is a question by the U.S. Corps of
Engineers about the safety of the Potic Oam. This must be
addressed. The design is done, but there are no funds for the
rebuild. If the reservoir water level has to be dropped for
safety reasons, there will be no water for the project.
EPA Raaponsa! The potential impact of lowering the
reservoir water level for safety reasons' will be evaluated during
the design phase.
5. £ojua«nt: An increased demand of icr percent of present
usage has already been requested within the present water
district, part of which has been approved (part of the increased-
demand request 1* for an existing health related facility) .
There will be a meeting February 1, 1988, for all concerned
parties to submit comments on their future water usage requests
from- the Catsklll water supply. - -
EPA Raaponaa; The projected additional demand associated
with supplying water to the affected and potentially affected
residents is expected to be only y percent of the total capacity
of the system. Based upon available data, the water supply
system has been calculated to .provide enough water to accommodate
both the proposed service area and the projected growth in the
present water district. An independent assessment may be
conducted to facilitate an agreement, if the Village and EPA deem
necessary. " •••.<••
6. CpmtnV Tn* previous secondary pumping source used in
the two drought periods can no longer be used; a secondary source
must be developed prior to approval. ~Thl*r secondary source must
be acceptable to all concerned agencies and the water purveyor.
RMponaat Development of a new secondary source is
the responsibility of the Village of cat skill.
13
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7. cytmienti• Table 2-2 in the FS does not allow a proper to!
schedule foe- State Environmental Quality Review Act (SEQRA),
Water Supply Application (WSA) review, and possible approval by
the Catski11 Village Board. Since a WSA Permit is required/ the
SEQRA process is initiated.
EPA Response; EPA, NYSDEC, and NYSDOH are each working to
provide an alternate water supply to the affected and potentially
affected residents in a timely manner. To reach this goal, EPA
anticipates that all necessary permit reviews and approvals can
be performed and obtained expeditibusly.
8. Comment: The entire project must not produce a financial
burden upon the existing water purveyor, including costs of fire
protection, legal, technical, and administrative review of the
project on local and state levels; construction costs; inspection
costs; and operation and maintenance.
EPA Response; EPA does not anticipate this project
placing a significant financial burden on the local
municipalities. The construction costs will be paid for by EPA
and the New York State Department of Environmental Conservation
(or by the Potentially Responsible Parties). Pursuant to CERCLA,
the State is required to assure the payment of all operation and
maintenance costs before remedial construction can proceed. If
the local municipalities wish to have the water supply system
provide fire protection, a portion of the incremental costs-
involved will have to be borne by the municipalities, as
indicated in the ROD.
9. Comment; Comments by the New York State Department of
Health during the SEQRA, WSA process—which will not be available
by December 23, 1987—will be required for review by the Village
of Catskill prior to considering all concerns for the proposed
approval. The involved state agencies did not appear at the
public hearing because the public hearing was premature.
EPA Response; Both NYSDEC and NYSDOH officials were
consulted during the preparation of the Focused FS. Furthermore,
representatives of both state agencies attended a meeting with
the Town Supervisor on December 8, 1987 and participated in the
public meeting held that evening. EPA expects both state
agencies to remain actively involved during the implementation of
this remedial action.
10. Comment: The Village of Catskill requests a scoping
session for all concerned agencies to define under the SEQRA the
environmental issues to be addressed. The lead agency must be
acceptable to the Village of Catskill and under the SEQRA
regulations must be one of the permit-issuing agencies.
14
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EPA Response: The potential environmental concerns
associated with implementing each alternate water supply scenario
were evaluated in the Focused Feasibility Study, it is EPA's
intent to meet with all concerned agencies prior to the start of
the design of the selected alternative.
11. Comment ; Alternative 4A-3 has the longest pipe line,
almost twice that of the other alternatives, with resultant
greatest potential for failure. The length of pipe should be
reduced to a minimum.
EPA Response: Based on effectiveness, implementability,
and cost, alternative 4A-3 was selected by EPA as the preferred
alternative after a comprehensive evaluation was conducted. The
many concerns raised by residents and local and county officials
have been considered by EPA and have been incorporated into the
ROD. The selected alternate water supply remedy involves exten-
sion of the Catskill Water District pipeline to the affected
areas. Following discussions with the local agencies, the
specific route for this pipeline will be selected during the
design phase.
12. T9I^ffl?ntl ; In view of the deficiencies of the Potic
reservoir and filtration system, the alternatives eliminated from
detailed evaluation, specifically, items 2 and 11 in Table 2-10
of the Focused FS, should be re-evaluated.
EPA Response; The detailed evaluation of each alternative
is presented in the Focused Feasibility Study report. As
discussed in the report, Alternative 2A (Operations and
Maintenance of Existing and Additional Point-of-Use Treatment
Systems) was eliminated since it fails to provide a reliable and
permanent remedy. Alternative 4B (New Surface Water Source and
Treatment System) was eliminated since it was unreliable,
unproven, and would require complex construction and operation
and maintenance.
13. Comment ; A booster pumping station is an excessive
operating cost item for the cost of energy and an unnecessary
high-maintenance item. A larger pipe with gravity flow is
preferred, even if a water tower must be installed to provide a
fire surge reserve or peak demand. The highest affected
residence in the potential plume area appears to be at
approximately 300 feet; the clearwell head is about 400 feet,
allowing a gravity static pressure exceeding 40 psi. Every
effort should be made to eliminate pumps and a pumping station.
EPA Response; A pumping station was included to overcome
the frictional losses resulting from the 6-inch diameter
pipeline. If a 12-inch diameter pipeline were to be used, as
described in the fire protection scenario, it may be possible to
use an elevated water storage tank and thereby eliminate the need
15
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for a pumping station. However, the difference in cost
for using an. increased diameter will have to be paid by the
municipalities concerned.
14. C.QTmafl5 ; Assuming an annual operation and maintenance
cost of 100,000 (Table 4-8 in the Focused FS has a low of $99,600
to a high of $200,120), the operation and maintenance spread over
the 23 homes is $4,348/year per home; spread over 80 homes is
$l,250/year per home. This is excessive; who will pay this
amount to operate the water district? What will these costs be
to the user in 30, 40, and 50 years from now? What control will
the water purveyor have over the operation and maintenance?
EPA Response; A more accurate estimate of the operations
and maintenance costs will be developed during the detailed
design. As stated above, under CERCLA, the State must assure
payment of all operations and maintenance costs. Specific
arrangements regarding payment for and performance of the
necessary operations and maintenance will have to be worked out
by the State and the local municipalities concerned.
15. Comment: Alternative 4D - Extension of the mobile home
park water supply: This is a private supply. Have the owners of
the park been consulted on possible purchase of their water
supply? There does not appear to be a cost included in the
estimates for purchase of the private systems. What will the
effect of any pumping be on the pollution plume?
EPA Response: If this alternative was selected,
negotiations with the owners would be held during the detailed
design. Since it was not selected, the effect of pumping on the
contaminant plume was not determined.
16. Comment: The water district will include the entire
length of the pipe. What are the implications and possible
demands of future requests for water and possible developments
along the pipe line? This must be addressed.
EPA Response: The development of an alternate water
supply under CERCLA does not address future growth. If the local
community desires to increase the service area, the community
will have to bear the incremental cost.
17. C Q.TBBtn't ? The present water district outside of the
Village over which the transmission line traverses pays taxes to
the towns and school districts. What are these taxes for the new
district? They are not figured into the cost estimates. The
longer line in the recommended alternative will pay much higher
taxes than the shorter line.
EPA Response; The Village's concern regarding higher
taxes associated with Alternative 4 A- 3 will be taken into accoun
16
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by EPA when it makes a decision during the design phase regarding
the specific route of the water line.
18. C7mn?nt ; Since the Superfund will fund only the cost of
the original 23 affected hones, who will pay for subsequent homes
affected by the plume in future years?
EPA Response: EPA and the State will pay for the hookup
of all of the affected and potentially affected homes that are to
be hooked-up to the waterline. However, if new construction
should occur within the affected area after the new water
district is formed and the waterline is installed, the new
homeowners will be required to hook-up to the waterline at their
own expense.
19. Comment ; The eminent domain issue for obtaining right-of-
ways... has not been addressed. The Village of Catskill does not
have eminent domain rights outside of the Village. This must be
clarified.
EPA Response: The Greene County Highway Department has
been contacted regarding access to county roads and a sample of
the appropriate permit application has been included in Appendix
D of the report. Final approvals will be acquired during the
detailed design and construction.
20. Comjreurt ; The water rates •proposed and shown in the cost
estimate do not appear to be realistic; this must be addressed.
EPA Response; These water rates are preliminary and are
based on current data provided by the Village of Catskill in
October, 1987. The rates were converted from the District's
quarterly charge per thousand cubic feet of water to a price per
thousand gallons.
21. C?lPTO?n^ ; Looking at present and projected costs, would it
be cheaper to relocate the affected homes? This option should be
explored; it would reduce the risk of other environmental hazards
such as the cancer cases reported in the Catskill Daily Mail.
EPA Response: The objective of the Focused FS was to
develop an alternative water supply system for the affected and
potentially affected residents. It is EPA's intention to address
the contamination at and emanating from the American Thermostat
site during the RZ/FS of this project. Therefore, EPA presently
does not feel that it would be appropriate to simply relocate the
affected residents and not attempt to clean up the contaminated
area .
22. comment: The Village of Catskill is to directly receive
copies of all technical information, letters, comments, etc.,
associated with this project. The present repositories for
17
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records are not acceptable to the Village of Catskill; the
Village offices are to be a repository.
..-,•: N5
EPA Response; Technical report* concerning the site are
available at the established information repositories. EPA
selected the location of this information repository based on
suggestions made during community interviews. EPA will consider
relocating the local information repository to the Catskill
Village office, if it is deemed more convenient for the
community.
RESPONSES TO COMMENTS BY DOROTHY AND RICHARD LAIS
IN LETTER OF DECEMBER 22. 1987
1. Comment; Alternatives 4A-1, 2, and 3 are the safest and
most practical if an adequate water supply is available to
service the affected and potentially affected homes, and if the
Village of Catskill agrees to extend the water district.
EPA Response; The projected additional water demand
associated with extending the Catskill Water District waterline
based upon the population and maximum expected flow is expected
to be only 3 percent of the total capacity of the system. EPA
would like the Village of Catskill's support to extend the
pipeline and establish a water district, in order to quickly
provide an alternate water supply to the affected and potentially
affected residents.
2. £gjy&eji£: In September of 1987, Senator Moynihan released
$6.75 million of EPA funds to be used at the American Thermostat
site in 1988. We trust this means a sincere effort will be made
to remediate the site.
EPA Response; Funds under Superfund to initiate a
remedial investigation/ feasibility study at the American
Thermostat site were recently obligated. This RI/FS will, among
other things, evaluate possible methods of cleaning up the site.
3. £ojBBfin£: We feel that six days notice about the December
8, 1987 meeting, and the deadline of December 24, 1987 for
comments on the preferred alternative, combined with an
inaccurate, incomplete mailing list shows insensitivity to the
affected and potentially affected community.
EPA Response; According to CERCLA, notification of a
public meeting and a public comment period, including an
announcement of the availability of a feasibility study report,
must be given when the report is made available. Once the
Focused ?s for the American Thermostat site was finalized, a
meeting announcement was sent to all those interested residents,
18
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local officials, the media and state officials on our mailing
list. The names and addresses of all official group
representatives and residents who should receive regular
information about the site are included in our mailing list,
which is -revised periodically. A public notice, as required now
under SARA was also published in the legal section of The
Catskill Daily Mail, on December 3, 1987 which indicated the date,
time, and location of the meeting, provided notification of the
21 day public comment period and specified a preferred
alternative for providing an alternate water supply, in
addition, follow-up telephone calls were made to ensure that
interested residents were well informed of the scheduled meeting,
availability of the report and the 21 day public comment period.
IV. REMAINING CONCERN
The only remaining concern among residents is whether the
American Thermostat facility will be restored for future use and
development. "'
19
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APPENDIX
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GREENE COUNTY . Telephone (518)622 325
PLANNING DEPARTMENT RONALDM ROTH D!e
Greene County OHice Building
Rt. 3, Box 909
Cairo. New York 12413
December 16, 1987
Mr. Peter Acker, Remedial Project Manager
US Environmental Protection Agency, Region II
26 Federal Plaza
New York, NY 10278
Dear Mr. Acker:
Let me first take an opportunity to express my gratitude for the work
you have done in regard to the American .Thermostat Superfund Site in
Greene County, NY. I attended.the evening meeting on December 8th
and was pleased to be informed of EPA's progress in securing a safe
water supply for the affected residents. Your focused-attention is
especially reassuring in light of the seriousness of the problem.
"In addition 1 would also like to express several thoughts and comments
in response to the proceedings of the above mentioned meeting.
First, I iwould greatly appreciate being supplied with a transcript of
the December 8th meeting *s soon, as it becomes available, -in the mean-
time, 1 would like to request a- more immediate response to a few other
concerns I have in regard to the discussion at the public meeting.
One of my concerns relates to a specific question raised at the Beet-
ing regarding when the American Thermostat site could be reoccupied
by another company. At present, there are several companies inter-
ested in locating at the site, however, I am still not clear as to when
the site will be available for use. Such as it is, I would appreciate
you clarifying this matter. I would also appreciate being informed of
other additional considerations which may be of concern in regard to
the future use of the site.
Another concern relates directly to your proposal(s) to supply affected
residents with a clean, potable water source. Although I was very
pleased to hear of a solution close at hand, I was taken back by the
inadequacy to properly inform the appropriate agencies and municipali-
ties of the proposal(s). If appropriate contact had been made, I feel
better preparation to respond to the study could have been attained.
I would hope that as you near a decision on a water supply alternative
that better communication be had between your agency and those having
an interest here in Greene County. This lack of communication will only
lead to misinformation and possible delays in finding solutions to the
problem.
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-2-
•
As a case in point, I am aware of a potentially significant problem
which will likely have a bearing on several proposals that require
water withdrawal from the Village of Catskill supply. I have en-
closed a newspaper article which sites the Village's concern over
an already over-stressed water supply. According to the article,
the Village of Catskill water supply system does not have the capa-
city to withstand additional withdrawals proposed by several future
projects, including a 400 room hotel, expansion of a nursing home,
and a townhouse development project.
In light of the fact that EPA's preferred alternative (4A-3) would
withdraw water from the Village of Catskill supply, I fail to under-
stand why the local authorities have not been fully informed of your
agency's proposal. This is especially disturbing when a final de-
cision on an alternative water supply is scheduled to be made in a
few short months. • •.-£*". - •--'•"
Unfortunately, according to your schedule of events, any response to
your proposal would be required almost immediately. This simply
does not provide local and county governments with the time required
to accomplish the many tasks involved in preparing a thorough response
The Greene County Planning Department also has a deep interest in
American Thermostat situation. The Planning Department is prepared to
respond to the proposals discussed at the meeting; however, to do so
responsibly the Department must be kept up-to-date on any new develop-
ments and information. Therefore, it is imperative to keep the lines
of communication open in order to guarantee the quickest and most suit-
able solution to the problem.
In light of this, I am still encouraged by the proceedings of the pub-
lic meeting and look forward to working with you in the future. There-
fore, if I may be of further assistance, please feel free to contact me
Sincerely,
Albert Flick
Planner ,/ + •.
AF:mc
encl.
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ATTORNEY FOR VILLAGE
Robert Carpenter
""TE-^^. -*-45^ "
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Mr. Peter J. Acker, Project Manager - 2 - December 16,
(4) There is a question by the U. S. Corps of Engineers as to the safety
of the Potic Dam, which must be addressed. The design is done, but
there are no funds for the rebuild. If the reservoir water level
has to be dropped for safety reasons, there will be no water for the
project.
(5) An increased demand of 10% of present usage has already been requested
within the present water district, part of which has been approved
(part of the increased-demand request is for an existing health
related facility). There will be a meeting February 1, 1988, for all
concerned parties to submit comments on their future water usage re-
quests from the Catskill water supply.
(6) The previous secondary pumping source used in the two drought periods
can no longer be used; a secondary source must be developed prior to
approval. This secondary source must be acceptable to all concerned
agencies and the water purveyor.
(7) Table 2-2 does not allow a proper time schedule for SBQRA, Water
Supply Application review, and possible approval by the Catskill Village
Board. Since a NBA Permit is required, the SBQRA process is initiated.
(8) The entire project must not produce a financial burden upon the
existing water purveyor, including costs of fire protection; legal,
technical, and administrative review of the project on local and state
levels; construction costs; inspection costs; and operation and
maintenance.
(9) Comments by the New York State Department of Health during the SBQRA,
NBA process—which WILL NOT be available by December 23, 1987— will be
required for review by the Village of Catskill prior to considering
all concerns for the proposed approval. The involved state agencies
did not appear at the public hearing because the public hearing was
premature.
(10) The Village of Catskill requests a scoping session for all concerned
. agencies to define under the SBQRA the environmental issues to be
addressed. The lead.agency must be acceptable to the Village of
Catskill and under the SBQRA regulations must be one of the permit-
issuing agencies.
(11) Alternative 4A-3 has the longest pipe line, almost twice that of the
other alternatives, with resultant greatest potential for failure.
The length of pipe should be reduced to a minimum.
-------
Mr. Peter J. Acker, project Manager - 3 - December 16, 1967
(12) In view of the deficiencies of the Potic reservoir and filtration
system, the alternatives eliminated from detailed evaluation, Table
2-10—namely, items 2 and 11—should be re-evaluated.
(13) A booster pumping station is an excessive operating cost item
for the cost of energy and an unnecessary high-maintenance item.
A larger pipe with gravity flow is preferred, even if a water
tower oust be installed to provide a fire surge reserve or peak
demand. The highest affected residence in the potential plume area
appears to be at approximately 300 feet; the clearwell head is about
400 feet, allowing a gravity static pressure exceeding 40 psi.
Every effort should be made to eliminate pumps and a pumping station.
(14) Assuming an annual operation and maintenance cost of $100,000 (Table
4-8 has a low of $99,600 to a high of $200,120), the O 4 M spread
over the 23 homes is $4,348/year per home; spread over 80 homes is .;
$l,250/year per home. This is excessive; who will pay this amount
to operate the water district? What will these costs be to the user
in 30, 40, and 50 years from now? What control will the water pur-
veyor have over the operation and maintenance?
(15) Alternative 4D - Extension of the mobile home park water supply:
This is a private supply. Have the owners of the park been consulted
on possible purchase of their water supply? There does not appear
to be a cost included in the estimates for purchase of the private
systems. What will the effect of any pumping be on the pollution
plume?
(16) The water district will include the entire length of the pipe. What
are the implications and possible demands of future requests for water
and possible developments along the pipe line? This must be addressed.
(17) The present water district outside of the Village over which the trans-
mission line traverses pays taxes to the towns and school districts.
What are these taxes for the new district? They are not figured into
the cost estimates. The longer line in the recommended alternative will
pay much higher taxes than the shorter line.
(18) Since the Super fund will fund only the cost of the original 23 affected
homes, who will pay for subsequent homes affected by the plume in future
years?
(19) The eminent domain issue for obtaining right-of-ways—if the right-of-way
is not given—has not been addressed. The Village of Catskill does not
have eminent domain rights outside of the Village. This must be
clarified.
-------
Mr. Peter J. Acker, Project Manager - 4 - December 16, 196
(20) The water rates proposed and shown in the cost estimate do not appear
to be realistic; this must be addressed.
(21) Looking at present and projected costs, would it be cheaper to relocate
the affected homes? This option should be explored; it would reduce
the risk of other environmental hazards such as the cancer cases reported
in the Cat ski 11 DAILY MAIL.
(22) The Village of Cat ski 11 is to directly receive copies of all technical
information, letters, comments, etc., associated with this project.
The present depositories for records are not acceptable to the Village
of Cat skill; the Village offices are to be a depository.
The Village of Cat ski 11 Board of Trustees realize the health problems and water
supply problems within the polluted area. The Board is responsible to the
approximately 8,000 existing users of the Catskill water system and must
'COMPLETELY assured that any additional load on the system will not
costs of operation and maintenance and that there will be a continual
source of potable water. When all concerns by all the involved agencies and
the Board of Trustees have been addressed to the Board's satisfaction, the
Board will then consider approval of connection to the proposed water district.
Very truly yours,
VILLAGE OF CATSKILL
Michael Battagl
President
cc: Robert 2. Carpenter, Esq.
Mr. S. Lawrence Baldwin, P.E.
Mr. J. D. Rusack, P.E.
Mr. Gilbert Faustel, P.E.
Mr. Jeffrey Sama, P.E.
Mr. Neil Gaevers, EBASCO
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TEXAS WATER COMMISSION
- .
Paul Hopkins. Cheirman - - "^ •' /j J. D. Head. General Counsel
John O. Houchins. CGrr.missioner \:.'.-**•'.:/ Michael E. Field, Chief Examiner
B. J. Wynne. III. Ccrr.missiorier ^==^' Karen A. Phillips, Chief Clerk
Allen Beinke, Executive Director
March 18, 1988
Dr. Allyn M. Davis
Director, Hazardous Waste Management Division
U.S. Environmental Protection Agency
Region VI (6H)
1445 Ross Avenue
Dallas, TX 75202
Re: Industrial Transformers Superfund Site
Draft Record of Decision
Dear Dr. Davis:
We have reviewed the proposed Record of Decision (ROD) for
the contaminated soils (Operable Unit I) at the Industrial
Transformers Superfund Site. We have no objection to the
selected remedy as described in the draft ROD. The selected
remedy for the site includes treatment of soils contaminated
with polychlorinated biphenyls (PCBs) above the cleanup
criterion using chemical dechlorinization.
Sincerely,
Allen P. Beinke
Executive Director
GT/mem
C .... - , . . ;-," N .--.- :•-.-.< A-.t
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