United State*
Environmental Protection
Agency
Office of
Emergency and
Remedial Response
EPA/ROO/R02-88/063
September 1988
«EPA
Superfund
Record of Decision:
Brewster Well Field, NY
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30273-101
REPORT DOCUMENTATION
PAGE
1. REPORT NO.
EPA/ROD/R02-88/063
3. Recipient's Accession No.
4. Title and Subtitle
SUPERFUND RECORD OF DECISION
Brewster Well Field, NY
cond Remedial Action - Final
5. Report Date
09/29/88
8. Performing Organization R«pt. No.
9. Performing Organization Name »nd Address
10. ProJect/T«»k/Worli Unit No.
11. Contnet(C) or Grent(Q) 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 Brewster Well Field consists of two municipal well fields, No. 1 and No. 2,
located on the northern bank of the East Branch Croton River, 3/4 of a mile east of the
Village of Brewster, Town of Southeast in Putnam, New York. The 18 shallow wells in the
field are a source of water for the municipal water system that serves over 2,100
residents in the Village of Brewster and the Town of Southeast, as well as a number of
businesses and a railyard. Additional receptors of the ground water from this aquifer
;lude downstream users of the East Branch Croton River, which contributes to the
ton Falls Reservoir approximately 3.5 miles downstream. Also, two reservoirs exist
tream-to the east and northeast within 3000 feet of the site, which are part of New
York City's Croton watershed reservoir system. Land use to the north and west is
predominantly residential, and to the south commercial and light industrial. VOC
contamination was detected in the Brewster Well Field in 1978 and alternate water
sources were subsequently added. Investigations identified the source of contamination
as a drywell adjacent to the Alben Cleaners south of the site, where dry cleaning wastes
wre disposed of via a floor drain until 1983. Approximately 100 yd^ of material
including drywell sludges, sediments, and soil have been contaminated with VOCs at
concentrations up to 620,000 ppm. In addition, a plume of ground water contaminated
(See Attached Sheet)
17. Document Analysis a. Descriptors
Record of Decision
Brewster Well Field, NY
Second Remedial Action - Final
Contaminated Media: gw, sediments, sludge, soil
(PCE' TCE >
c. COSATI Held/Group
Availability Statement
19. Security Class (This Report)
None
20. Security Class (This Page)
None
21. No. of Pages
41
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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EPA/ROD/R02-88/063
rewster Well Field, NY
cond Remedial Action - Final
16. ABSTRACT (continued)
with VOCs at concentrations up to 6,000 ppb extends from the vicinity of the cleaners
north to the Brewster Well Field. Consequently, the Village of Brewster and EPA have
operated a full scale packed column spray aeration system for treatment of the entire
village supply since 1984. The first Record of Decision (ROD) for the site was signed
in September 1986 and was aimed at controlling migration of contamination through the
ground water. The ROD called for the design and construction of a ground water
management system to extract, treat (by air stripping via a packed tower), and reinject
ground water to expedite the removal of VOCs. This second ROD is designed to remediate
the source of contamination, namely the drywell. The primary contaminants of concern
affecting the soil, sediments, sludge and ground water are VOCs including PCE and TCE.
The selected remedial action for this site includes: excavation and offsite
incineration of approximately 100 yd3 of drywell sediments, sludge, and soil with
greater than 4 ppm PCE followed by offsite disposal; and removal, decontamination, and
offsite disposal of the concrete drywell structure and debris. The estimated capital
cost for this remedial action is $241,940.
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DECLARATION FOR THE RECORD OF DECISION
SITE NAME AND LOCATION
Brewster Well Field, Village of Brewster, Putnam County, New York
STATEMENT OF PURPOSE ...
This decision document represents the selected remedial action
for the treatment and disposal of a drywell, sediments and soils
that are contaminated with volatile halogenated organic compounds
(VHO's) and that are the source of contamination of the Brewster
Well Field. The selected remedial action was developed in accord-
ance with the Comprehensive Environmental Response, Compensation
and Liability Act of 1980, 42 USC §9601, et seq., as amended
by the Superfund Amendments and Reauthorization Act of 1986,
and to the extent practicable, the National Oil and Hazard'ous
Substance Pollution Contingency Plan, 40 CFR Part 300.
STATEMENT OF BASIS
This decision is based on the administrative record for the
Brewster Well Field site. The attached index identifies the
items that comprise the administrative record, upon which the
selection of a remedial action is based.
DESCRIPTION OF SELECTED REMEDY
This Record of Decision for the Brewster Well Field site addresses
the treatment/disposal of a drywell, sediments, sludge, and soils
contaminated with VHO's. This portion of the site has been
identified as the source of groundwater contamination that is
being addressed under a separate operable unit.
0 The drywell sediments, sludge, and soils will be excavated,
containerized and transported to a permitted hazardous waste
facility where the waste will be incinerated and treated
residuals will be disposed of.
0 The concrete drywell structure and debris will similarly be
removed, decontaminated, transported to a permitted hazardous
waste facility and disposed of.
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DECLARATIONS
Consistent with the Comprehensive Environmental Response,
Compensation, and Liability Act of 1980 as amended by the
Superfund Amendments and Reauthorization Act of 1986, and the
National Oil and Hazardous Substances Pollution Contingency Plan,
40 CFR Part 300, I have determined that the selected remedy
is protective of human health and the environment, will
attain Federal and State requirements that are applicable, or
relevant and appropriate for this remedial action, and is
cost-effective. Furthermore, this remedy satisfies the statutory
preference for treatment that reduces the toxicity, mobility
or volume of hazardous substances as a principal element.
Finally, this remedy utilizes permanent solutions and alternative
treatment technologies to the maximum extent practicable.
Because this remedy will not result in hazardous substances
remaining on site above health based levels, the five year
review will not apply to this action.
The State of New York has been consulted and agrees with the
approved remedy.
f-M-tt
Date William >Ofr Mus^j^Ski , P.E.
Acting Regional Administrator
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Table of Contents
I. Site Location and Description 1
II. Site History and Enforcement Activities 1
III. Community Relations 4
IV. Scope and Role of Operable Unit
Within Site Strategy 4
V. Site Characteristics 4
VI. Summary of Site Risks 5
VII. Alternatives Evaluation 6
VIII. Summary of Comparative Analysis
of Alternatives 9
IX. Selected Remedy 13
X. Statutory Determinations 13
Figures
Figure Page
1. Regional Location Map 17
2. Area Map 18
3. Site Map . 19
4. Contaminant Plume Map 20
5. Schematic - Operable Unit One (GW) Remedy . 21
6. Unsaturated Soil Contamination Map 22
Tables
Table
1. Unsaturated Soil Data 24
2. Cost Estimates For Alternatives 25
Appendices
A. NYSDEC Letter of Concurrence
B. Responsiveness Summary
C. Administrative Record Index
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SUMMARY OF
REMEDIAL ALTERNATIVE SELECTION
BREWSTER WELL FIELD
SITE LOCATION AND DESCRIPTION
The Brewster Well Field is located on the northern bank of the
East Branch Croton River, 3/4 of a mile east of the Village of
Brewster, Town of Southeast in Putnam County, New York. The
site is approximately 3 miles west of the Connecticut/New
York border and approximately 47 miles north of New York
City. Interstate 84 passes just to the west of the site (see
Figure 1).
The land to the north of the study area, containing the
community of Brewster Hill, is largely residential with some
agricultural use. Most of the land south of the study area
is occupied by commercial or light industrial facilities. To
the west is the residential community of the Village of
Brewster.
The 1980 Census records the population of Putnam County as
77,193. Estimated population for the Town of Southeast and
the Village of Brewster are 15,500 and 1,700 respectively.
The municipal water system serves the Village and several
areas in the Town of Southeast, a number of business establish-
ments and the Consolidated Rail Corporation's Putnam Junction
Rail Yard. Residential users alone account for an estimated
2,100 people. ' . . .
Additional potential receptors are downstream users of the
East Branch Croton River which contributes to the Croton
Falls Reservoir approximately 3.5 miles downstream. The East
Branch Croton River flows adjacent to and south of the Well
Field. Three thousand feet to the east of the site (upstream)
the River is impounded to form the East Branch Reservoir,
part of New York City's Croton watershed reservoir system.
Three thousand feet from the site to the northeast, Bog Brook,
a tributary to the East Branch Croton River, is impounded to
form Bog Brook Reservoir, also owned by New York City as
shown on Figure 2.
SITE HISTORY AND ENFORCEMENT ACTIVITIES
Beginning in 1954, when Well Field No. 1 was developed, the
Village of Brewster has used the aquifers beneath the Village-
owned land, in the Town of Southeast, as a source of water for
its water supply system. In 1967 Well Field No. 2 was brought on
line. The two well fields consist of a total of 18 shallow wells.
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Evidence of volatile halogenated organic compound (VHO) contamina-
tion first appeared in 1978, and alternative water sources were
subsequently added to the water supply system, including a deep
bedrock well (DW-2) and two separate shallow wells (SG-1 and
SG-2) located as shown on Figure 3. As a result of low yield
DW-1 was not connected to the supply system. Two new wells SG-3
and SG-4 were added to the system in 1984. Prior to drought
conditions arising in 1981, East Branch Croton River surface
water was also used at times to supplement the water supply
system.
Since 1979, the Village has had several studies conducted to
identify potential alternative groundwater sources and to test
spray aeration as a potential treatment method for VHO removal.
It has since been concluded that treatment of existing sources is
the most promising of the alternatives for solving existing
contamination problems in the Well Field. Under a cooperative
agreement with the Environmental Protection Agency (EPA), Office
of Research and Development, the Village has constructed, tested
and in 1984, placed on line, a full scale packed column spray
aeration system for treatment of the entire Village supply.
The Brewster Well Field was placed on the National Priorities List
(NPL) in December 1982. Superfund work at the Brewster Well
Field has been divided into two phases or units, referred to as
operable units (OU's).The two operable units at Brewster. are:
0 OU One: Management of the migration of contamination through
the groundwater.
8 OU Two: Control of the contamination source.
Under OU One, in 1985, a study (Focused Feasibility Study) was
conducted by the New York State Department of Environmental
Conservation (NYSDEC), to investigate the feasibility of on-site
treatment alternatives for removal of volatile halogenated organic
compounds from the Village's water supply. Considering cost,
reliability, off-site releases and flexibility, the packed column
was adjudged superior to other alternatives.
Concurrent with the Focused Feasibility Study a Remedial Investi-
gation (RI) was initiated by NYSDEC, under OU One, to determine
the nature and extent of contamination at and in the vicinity of
the site. Volatile halogenated organic compounds have been the
primary contaminants detected in the groundwater from the Well
Field and in the vicinity of the site. The OU One RI defined a
plume of groundwater contaminated with tetrachloroethylene (PCE),
trichloroethylene (TCE) and 1,2 dichloroethylene (DCE) (see
Figure 4).
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PCE, TCE and DCE are suspected carcinogens and known causes of
liver and kidney damage and central nervous system depression
in humans.
The OU One Feasibility Study (FS), which was completed by NYSDEC
in 1986, evaluated alternatives for remediating the contaminated
groundwater .plume and provided the basis for approval of the
first Record of Decision (ROD) for the site/ which was signed by
EPA on September 30, 1986.
The first ROD called for the design and construction of a ground-
water management system (CMS) to extract, treat (by air stripping
via a packed tower) and reinject groundwater to expedite the
removal of VHO contaminants from the groundwater (see Figure 5).
It also cited the need for a supplemental study (OU Two) to
identify and recommend remediation measures for the source of the
groundwater contamination. It is estimated that the groundwater
management system will reduce groundwater cleanup time from 30
years (if left to naturally attenuate) to 10 years (if treated).
Groundwater will be treated to meet Federal drinking water
standards (Maximum Contaminant Levels or MCL's).
Design of the QMS proceeded under EPA lead and was completed in
September 1987. Construction will commence shortly.
OU One essentially addresses contamination in the saturated soil
zone. OU Two has therefore been designed to address the unsaturated
zone. OU Two is intended to identify and remediate any continuing
source for groundwater contamination and eliminate any direct
contact health threats.
The OU Two Remedial Investigation (conducted under EPA lead) was
completed in March 1988 and has identified a drywell adjacent
to Alben Cleaners as the source of the groundwater contamination.
It is estimated that 100 cubic yards of material (drywell liquids,
sediment, and soil) is contaminated with VHO's to the extent that
requires remediation. Based on interviews with the cleaning
operator, dry cleaning wastes were disposed of in the drywell,
via a floor drain, up until 1983. The principal VHO's, PCE and
TCE, are No. F002 listed wastes under 40 CFR 261.31, regulations
promulgated under the Resource Conservation and Recovery Act (RCRA).
The OU Two Feasibility Study (also under EPA lead) was completed
in July 1988. The FS looked at alternatives for dealing with the
source of contamination. The evaluation of those alternatives
is discussed in subsequent sections of this ROD.
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The supplemental RI/FS has identified the Alben Cleaners drywell
as the source of contamination. Information request letters and
subsequent general notice letters have been sent to the property
owners and cleaning operator. Remedial design and remedial
action will proceed under Superfund. Enforcement activities are
continuing in an attempt to identify and locate additional
potentially responsible parties (PRP's).
COMMUNITY RELATIONS
An extensive community relations plan was developed under OU One
and updated under OU Two. Community relations activities have
included fact sheets, interviews with local citizens and officials,
and public meetings. A public meeting was held on August 21,1986
to discuss the findings and alternatives for remediating the
groundwater contamination studied under OU One. Subsequent fact "
sheets have announced progress on design and construction under
OU One as well the RI/FS under OU Two. Additional interviews
with local citizens and officials were conducted and a public
meeting was held on August 31, 1988 to discuss the findings and
alternatives for remediating the source identified under OU Two.
A copy of the responsiveness summary is attached.
SCOPE AND ROLE OF OPERABLE UNIT TWO WITHIN SITE STRATEGY
The objective of OU Two is to identify and, as necessary, remediate
the source of the well field contamination. The identification
of the source will aid enforcement and cost recovery activities.
Remediation of the source will remove any health risks due to
direct contact and will ensure the viability of the groundwater
clean-up efforts under OU One by eliminating any continuing
contribution of contaminants to the aquifer. OU Two is the final
operable unit of the overall remediation strategy for this site.
SITE CHARACTERISTICS
The results of the OU One RI can be broken down into six areas:
1) groundwater, 2) water in drainlines in the vicinity of the Site,
3) surface water, 4) private water wells, 5) soil and, 6) air.
The results of the investigation are discussed in detail in the
OU One RI/FS which includes a discussion of the nature and extent
of contamination and potential risks from contaminated media.
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The prinicipal findings of the OU One study are that:
-There is a plume of groundwater contaminated with VHO's
(maximum concentrations of up to 6000 parts per billion
(ppb) ) extending from the vicinity of the Alben Cleaners
parking lot to the Brewster Well Field.
-The Alben Cleaners dryweil is the source of
site contamination.
The primary contaminants of concern are PCE and TCE which are
No. F002 RCRA listed wastes under 40 CFR 261.31.
The -analytical results from the OU Two RI, the objectives of
which were to confirm the source of site contamination and investi-
gate soil contamination in the unsaturated zone, can be found in
the OU Two RI report dated March 1988, and Risk Assessment (RA)
report dated July 1988. The OU Two site investigation included
over 100 soil gas probes in the vicinity of Alben Cleaners and
other possible source areas; 16 soil borings at suspected source
locations, soil gas "hot spots" and the Alben Cleaners dry well;
and an additional round of groundwater samples. The RI and RA
reports indicate elevated levels of organics in the Alben Cleaners
dryweil sediments and sludges (at up to 620,000 parts per
million (ppm) PCE). Additionally, mildly elevated concentrations
(up to 4ppm PCE) of organics were found in soil samples from two
.other isolated locations in the Alben Cleaners parking lot (see
Figure 6 and Table 1). A risk baseline assessment has determined
that the incremental cancer risk posed by soils at 4ppm is less
than lxlO~6. These areas were therefore not considered in the
alternatives evaluation phase.
SUMMARY OF SITE RISKS
The primary contaminant used in the baseline risk assessment is
PCE as the principal contaminant found at the site. The primary
health threat posed by contaminated site soils is from direct
contact by ingestion of soils or inhalation of dust. Although the
site is currently used for light commerce, anticipating that the
site might be rezoned for residential use in the future, a baseline
risk assessment conservatively calculated that soils containing up
to 4ppm of PCE would present excess carcinogenic risks of no more
than lxlO~6 (or one person in a million) for a 17 kg child
consuming 50 mg of soil per day over 70 years.
Contaminated soils present a secondary threat as contaminants
leach into the groundwater. A groundwater management system
which is being constructed under OU One will address this secondary
threat by treating the groundwater to safe drinking water standards
(MCL's) under the Safe Drinking Water Act.
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ALTERNATIVES EVALUATION
The major objective of the OU Two FS was to evaluate alternatives1
for addressing the source of groundwater contamination at the
site. Alternatives were formulated to achieve the following
goals:
- Ensure the viability of the groundwater management system to be
constructed under OU One by removing any continuing source of
contamination.
- Minimize any potential risks associated with direct contact
with contaminated residual site soils by removing any soils
posing unacceptable health risks.
A comprehensive list of appropriate remedial technologies was
identified for source control. These technologies were screened
based on the characteristics of the site and the characteristics
of the contaminants. The technologies which survived the initial
screening were further screened based on effectiveness, implement-
ability and cost. Cost was only used to differentiate between
alternative technologies providing similar degrees of overall
protecviveness.
Technologies which satisfied the screening requirements were
combined to form remedial action alternatives.. Containment
alternatives were dropped from consideration at this point of
the evaluation process. Given the relatively minor volume of
readily treatable, highly concentrated waste, the treatment
alternatives are clearly more practicable than the non-
treatment alternatives. The remaining alternatives included no
action and treatment. The alternatives developed are detailed
below and are numbered to correspond with the FS report.
Alternative 1 - No Action
The no-action alternative is required by the National Contingency
Plan (NCP) to be considered through the detailed analysis. It
provides a baseline for comparison of other alternatives. Under
the no-action alternative, no source control remedial measures
would be undertaken at the Brewster site at the present time.
Although no action would entail no operation or maintenance (O&M)
and require no time to implement, unremediated soils would
continue to release contaminants into this Class IIA aquifer,
thereby extending the period of time over which the drinking and
groundwater treatment systems will be required to operate.
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Alternative 3 - On-Site Enhanced Volatilization
The major features of this alternative include pumping the pool
of liquid waste (sediment and sludge) from the drywell, removal
of the concrete drywell structure and removal of contiguous soils
with volatile organic concentrations of greater than 4ppm PCE.
It is estimated.that approximately 100 cubic yards (cy) of waste
and debris requires remediation. Waste and soils would be treated
on-site in accordance with RCRA by a thermal process to vaporize
contaminants from the waste and soils» after which the vaporized
contaminants would be destroved by incineration in an afterburner.
The treated soils would be used as backfill. The concrete drywell
structure would be decontaminated by steam blasting and disposed
of off site at a RCRA Subtitle C facility.
Estimated capital costs for this alternative are $244,420. This
alternative will result in the remediation of site soils to
health based levels. This remedy could be implemented in a
matter of months from the start of remedial action.
Inasmuch as the PCE and TCE wastes were discharged to the drywell
by the dry cleaner, reportedly until 1983, the drywell, its
contents and contiguous contaminated soils are RCRA wastes under
40 CFR 261. The following standards are applicable to the
removal, transport, treatment and disposition of those wastes,
and closure of the site.
0 40 CFR 262 - Standards Applicable to Generators
of Hazardous Waste
0 40 CFR 263 - Standards Applicable to Transporters
of Hazardous Waste
0 40 CFR 264 - Standards of Owners/Operators of Hazardous Waste
Treatment, Storage and Disposal Facilities
0 40 CFR 268 - Land Disposal Restrictions
At the completion of remedial action, direct contact health risks
posed by residual site soils (at less than 4ppm PCE) would be no
greater than lxlO~6. RCRA regulations, 40 CFR Subpart N (Landfills),
Subpart G (Closure and Post Closure Care), and Subpart F (Releases)
are applicable to the closure and post closure care of residual site
soils contiguous to the drywell excavation. The details of
proposed remedial actions for complying with RCRA closure and
post closure regulations would be developed as part of remedial
design activities.
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The removal and abandonment, or replacement and permitting of the
drywell, if necessary, is subject to UIC Program standards under
40 CFR 144 regulations for underground injection wells.
Standards for dust, particulates and other emissions from response
actions are to be considered relative to federal and state air
quality regulations (e.g. NYS Air Guide 1, 40 CFR 50).
Alternative 4 - Off-site Incineration
Under this alternative the pool of liquid waste (sediment and
sludge) would be removed from the drywell, the concrete drywell
structure would be removed, and contiguous soils with volatile
organic concentrations of greater than 4ppm PCE would be removed
(approximately lOOcy). Waste and soils would be taken to a RCRA
Subtitle C disposal facility, incinerated and disposed of under
appropriate air and land disposal regulations. The site would
be backfilled with clean soil from off-site sources. The concrete
drywell structure would be decontaminated by steam blasting and
disposed of off site at a RCRA Subtitle C facility.
Estimated capital costs for this alternative are $241,940. This
alternative will result in the remediation of site soils to health
based levels. This remedy could be implemented in a matter of
weeks from the start of remedial action.
Inasmuch as the PCE and TCE wastes were discharged to the drywell
the dry cleaner, reportedly until 1983, the drywell, its contents
and contiguous contaminated soils are RCRA wastes under 40 CFR
261. The following standards are applicable to the removal,
transport, treatment and disposition of those wastes, and closure
of. the site.
0 40 CFR 262 - Standards Applicable to Generators
of Hazardous Waste
0 40 CFR 263 - Standards Applicable to Transporters
of Hazardous Waste
e 40 CFR 264 - Standards for Owners/Operators of Hazardous
Waste Treatment, Storage and Disposal
Facilities
0 40 CFR 268 - Land Disposal Restrictions
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At the completion of remedial action, direct contact health risks
posed by residual site soils (at less than 4ppm PCE) would be no
greater than lxlO~6. RCRA regulations, 40 CFR Subpart N (Landfills),
Subpart G (Closure and Post Closure Care), and Subpart F (Releases)
are applicable to the closure and post closure care of residual site
soils contiguous to the drywell excavation. The details of
proposed remedial actions for complying with RCRA closure and
post closure regulations would be developed as part of remedial
design activities.
The removal and abandonment, or replacement and permitting of the
drywell, if necessary, is subject to UIC Program standards under
40 CFR 144 regulations for underground injection wells.
Standards for dust, particulates and other emissions from response
actions are to be considered relative to federal and state air
quality regulations (e.g. NYS Air Guide 1, 40 CFR 50).
SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES
The retained alternatives were evaluated based on the following
nine criteria:
- Overall protection of human health and the environment;
- Compliance with all federal and state applicable or
relevant and appropriate requirements (ARARs);
- Reduction of toxicity, mobility or volume;
- Short term effectiveness;
- Long term effectiveness;
- Implementability;
- Cost;
- Community Acceptance; and
- State Acceptance.
A summary of the relative performance of the alternatives with
respect to each of the nine criteria is provided in this section.
Protection of Human Health and the Environment
Protection of human health and the environment is the central
mandate of CERCLA as amended by SARA. Protection is achieved
primarily by reducing health and environmental threats to
acceptable levels and taking appropriate action to ensure that
there will be no unacceptable risks to human health and the
environment through any exposure pathways. Without remediation,
contaminated soils would present unacceptable direct contact
health risks and continue to act as a source for groundwater
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contamination, thereby extending the groundwater cleanup period.
Both Alternatives 3 and 4 would eliminate these risks. Alternat
3 and 4 are protective of human health and the environment under
the standards mandated by CERCLA as amended by SARA.
Appropriate measures would need to be taken during excavation,
handling and.transportation, and treatment of waste and soils to
protect workers and the community. In addition, prior to
implementing treatment, measures would have to be taken to assure
that implementation does not pose a threat to human health or the
environment. A few of the potential problems are outlined below.
Workers and the residents would be protected through measures
outlined in project specific health and safety plans and through
contractor adherence to Occupational Safety and Health Act (OSHA)
regulations.
Dust and particulate matter could be generated during materials
handling and pretreatment. The potential for air releases of
products of incomplete combustion also exists. Adjustments in
handling and treatment would be made to ensure that all these
potential hazards are controlled.
Compliance with ARARs
The drywell and.surrounding soils contain PCE and TCE, which are
RCRA listed wastes. The wastes were discharged via a floor drain
to the drywell until 1983. (They are now recovered by a licensed
hauler.) Without remedial action the wastes deposited in the
drywell violate RCRA standards applicable to the disposal of
hazardous wastes and the drywell violates UIC standards applicable
to underground injection wells. Without source control, the
remediation of contaminated groundwater under OU One to comply
with Federal and State ARARs would be prolonged.
The primary ARARs for source control under OU Two are the RCRA
regulations relating to the management of hazardous wastes.
Under Alternative 3 treated soils would be disposed of on site
as backfill. Under Alternative 4 soils would be removed to a
Subtitle C facility, incinerated and the residue landfilled.
Both options would be required to comply with RCRA regulations
under 40 CFR 262, 263, 264, and 268 for the removal, transport,
treatment and disposition (land disposal) o'f hazardous wastes, and
closure of the site.
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The drywell would be removed and abandoned, or if necessary/
replaced and permitted under UIC standards under 40 CFR 144
(regulations covering underground injection wells). The drywell
would be replaced and permitted only if necessary to service
the building occupied by the dry cleaner and only if the
replacement were paid for by the building owner/PRP's. A
decision on whether to abandon or replace the drywell will be
made at the time of remedial design after speaking with the
building owner/PRP's.
Fugitives (i.e. dust) and emissions from remedial actions are
to be considered relative to federal and state air quality
regulations (e.g. NYS Air Guide 1). Both the volatilization
alternative and incineration alternative are expected to meet
these air quality standards.
Reduction of Toxicity, Mobility or Volume
This evaluation criterion relates to the performance of a remedial
alternative in terms of eliminating or controlling risks posed by
the toxicity, mobility or volume of hazardous substances.
Alternative 3 would accomplish all of these objectives by de-
stroying the volatile organic contaminants by on-site volatiliza-
tion. Alternative 4 would accomplish this by off-site incineration.
Both alternatives would in turn reduce the volume of contaminants
leaching into the aquifer to be treated under the OU One groundwater
remedy. '
Short Term Effectiveness
No action requires no time to implement, nor does it result in
any short term impacts, but it provides no effectiveness in
meeting cleanup goals. .
Alternatives 3 and 4 provide a high degree of effectiveness in
the short term by achieving prompt protection of human health
with little significant adverse impact resulting from the
implementation of the remedy. Under both alternatives there is
some risk of exposure during excavation of soils and decontamination
of the drywell. Under Alternative 3 risks are posed while soils
are stockpiled and treated on site and also by exposure to air
emissions from afterburning of soils vapors. .Measures (such as
restricting site access and adjusting the treatment process)
would be taken to ensure that these potential hazards are
controlled. Under Alternative 4 only minor additional on-site
risks are presented during transportation of contaminated materials
off site. Alternative 3 could be implemented in months.
Alternative 4 could be implemented in weeks.
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Long Term Effectiveness
Both Alternatives 3 and 4 are effective in providing long term
protection of human health. Both alternatives will remove the
drywell (and contents) that is the source of site contamination.
This will assure the viability of the groundwater management
system to be constructed under OU One by protecting the groundwater
from further contamination. The amount of contamination removed
directly affects the length of time the OU One groundwater
remedy will take to meet clean-up standards. Both alternatives
will also remove and treat, thereby permanently destroying
contaminants, those most heavily contaminated soils that pose
unacceptable health risks.
Implementability
The implementability of alternatives is based on the technical
feasibility, administrative feasibility and the availability of
services and materials for the alternative. Alternative 3 is
somewhat less implementable and technically feasible than
Alternative 4 in that Alternative 3 requires on-site mobilization
of innovative specialized equipment. The implementation of
Alternative 3 could be restricted by the availability of equipment
and lack of adequate site space. Incineration, as proposed under
Alternative 4, is a common technology with a demonstrated
performance record, and it is expected that an off-site facilty,
with adequate capacity for the relative minor quantity of waste
that will be generated, should be available.
Cost
The capital cost for Alternative 3 is $244,420 and Alternative 4
is $241,940 (see Table 2). Site operation and maintenance costs
are covered under the OU One groundwater response action.
Community Acceptance
The community supports Alternative 4 as the preferred alternative.
Community comments can be reviewed in the public meeting transcript
which is included in the Administrative Record. A responsiveness
summary which summarizes all comments received during the public
comment period is attached.
State Acceptance
The State of New York, through the New York State Department of
Environmental Conservation (NYSDEC), has been actively involved
in remedial activities at the Brewster Well Field site. NYSDEC
concurs with EPA's selected alternative. A copy of NYSDEC's
letter of concurrence is attached.
-------
- 13 -
SELECTED REMEDY
Based upon available data and analyses conducted to date, EPA has
selected Alternative 4 as the most appropriate solution for meet-
ing the goals of Operable Unit Two at the Brewster Well Field
site. Alternative 4 was chosen as being more effective in the
short term and as being more readily implementable than Alternative 3
The primary elements of Alternative 4 are:
- The alternative removes the drywell (and contents) that is
the source of site contamination.
- The alternative removes and treats site soils that pose
unacceptable health risks. Site soils and sediment, in-
cluding those contiguous to the drywell and site drainage
systems, will be tested during response actions, and those
materials containing more than 4ppm PCE will be remediated.
By eliminating the source of groundwater contamination, the
selected alternative ensures the viability of the groundwater
management system to be installed under Operable Unit One.
Groundwater remediation under OU One can be expected in 10 years
as opposed to 30 years or more if contaminant migration were
not controlled and the source not removed. It is estimated that
approximately 100 cubic yards of contaminated debris and soil
will be excavated, decontaminated or incinerated, and disposed of
at a RCRA Subtitle C facility. This action will reduce health
risks due to direct contact with contaminated site soils to lxlO~^
and comply with RCRA regulations for the closure and post
closure care of residual site soils.
STATUTORY DETERMINATIONS
EPA believes that this remedy will satisfy the statutory require-
ments of providing protection of human health and the environment,
will be cost-effective, will utilize permanent solutions and
alternative treatment technologies or resource recovery technologies
to the maximum extent practicable, and will satisfy the preference
for treatment as a principal element.
Protection of Human Health and the Environment
The selected remedy eliminates all outstanding"threats posed by
the site. It reduces contamination of site materials down to
health based levels. It removes a continuing threat to groundwater
thereby ensuring the achievement of groundwater remediation under
OU One in approximately 10 years as opposed to 30 years or more
if migration and source controls were not instituted.
-------
- 14 -
Attainment of ARAR's
At the completion of response actions the selected remedy will
have complied with all of the following ARARs and considerations.
0 40 CFR 262 - Standards Applicable to Generators of Hazardous
Waste, Subparts A through D* for the management of RCRA
hazardous waste, are applicable.
0 40 CFR 263 - Standards Applicable to Transporters of
Hazardous Waste, Subpart A (General), Subpart B (Manifests
and Recordkeeping), and Subpart C (Hazardous Waste
Discharges), for handling of RCRA hazardous waste off-
site, are applicable.
0 40 CFR 264 - Standards for Owners/Operators of Hazardous
Waste Treatment, Storage and Disposal Facilities, Subpart
I (Containers) and Subpart L (Waste Piles), for storage/
treatment of hazardous waste; Subpart O (Incinerators),
for off-site incineration; Subpart F (Releases), for
groundwater monitoring; and Subpart G (Closure and Post-
Closure Care), for closure and post closure care; Subpart
N (Landfills); are all applicable.
0 40 CFR 268 - Land Disposal Restrictions, for treatment
standards for land disposal of hazardous waste, are
applicable.
0 40 CFR 144 Underground Injection Control Program, for
removal and abandonment, or replacement and permitting,
of the drywell, are applicable.
0 New York State Air Guide 1 Control of Ambient Air
Contaminants, 40 CFR 50 Ambient Air Quality Standards, 40
CFR 264 Standards for Owners/Operators of Hazardous Waste
Treatment, Storage and Disposal Facilities, for control of
fugitives from excavation and emissions from incineration,
are to be considered.
Cost Effectiveness
Selected Alternative 4 provides overall effectiveness proportionate
to its cost. It is slightly less costly than-Alternative 3 yet
it offers comparable performance, is more implementable and is
more effective in the short-term.
-------
-15-
Utilization of Permanent Solutions and Alternative Treatment
Technologies or Resource Recovery Technologies to the Maximum
Extent Possible.
Incineration under Alternative 4 will completely destroy the
contaminants of concern found in the source soils and debris.
Alternative 4 is comparable to Alternative 3 with respect to long-
term effectiveness and the degree of permanence afforded, reduction
in toxicity, mobility and volume achieved, but poses fewer on-site
short-term impacts, is more implementable, slightly less costly
and preferred by the community.
Preference for Treatment as a Principal Element
The incineration remedy satisfies the statutory preference for
treatment as a principal element in that it addresse-s, to health
based levels, the principal threat posed by the site, i.e. the
drywell that is the source of site contamination.
-------
-16-
FIGURES
-------
CATSKILL
PARK
o
NE
80
FIGURE 1
REGIONAL LOCATION
APPROXIMATE SCALE 1'-14 MILES
-------
SCALE I 24000
o
CONTOUR INTERVAL 10 FEET
DATUM IS. MCAN SEA Ltvtl
JREWSTER. N. Y. -CONN.
N4122 6--W7330/7 5
1958
CMOTQW:vistc i':?o
AMS 6766 I MC-SEPlCS V82i
FIGURE 2
BREWSTER STUDY
AREA LOCATION
-------
VILLAGE
BREWSTEfl
PROPERTY
O S4Q-1
SiG-4
VILLAGE
A C C E S S i I
ROAD M
S4G-
BRAOY
STANNARO
ALBEN
CLEANERS
MIDLAND
BANK
FIGURE 3
VILLAGE OF BREWSTER, N.Y
WELL FIELD AND VICINIT
LEGEND
. SHALLOW WELL
DEPTH : 20'- 25'
n SHALLOW WELL
0 DEPTH : 40'-50'
A BEDROCK WELL
DEPTH : 350'
Y LOCATION MAP
-------
-20-
x//$v/n;^.r'
\ (M*M{T
N\\%«?'
\\\\^|M;
Kx\\ \ v w.J/:fe\<
SCALE IN FEET
.)
Ov-- >O& \^»x-;'
\o xfe^:.
« > '-A . <£
\ \\ |"r ^>'\
4\ ' } \ fy * \
^"vA* / -> y ai*(j«-4O . /
.....-// 3°-^ O.GC.-J2 V/1//V
: /- '-SfW.!/ //
PGC-13 ' /'- ,/
FIGURE 4
ISOCONCENTRATION MAP. TOTAL CONCENTRATION OF
VHO AT MONITORING WELL LOCATIONS
BASED ON SAMPLE ROUND NO. 1 (OCTOBER. 1985)
LEGEND
OQC-7 MONITORING WELLS
(10-JO) SCREENED INTERVAL TO NEAREST FOOT
IS - TOTAL VHO
F - FILL
T - GLACIAL TILL
OL - OLACIOLACUSTRINE
0 - OLACIOFLUVIAL-DELTAIC
OW - OLACIOFLUVIAL-OUTWASM
SG s-N
DW- PEEP
-------
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V.V_1\_ EXTRACTION
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ALTeRN
AP"«OX. SCALE ,-:200-
-------
P-12
Y WELL
WELL/SOIL BORING u-UNDETECTED
PCE (ppb)
TCE (ppb) u'-UNDETECTED. SEMIQUANTITATIVE
SB-1 SOIL BORING (EBA5CO 1967)
MW-A$ MONITORING WELL (EBASCO 1887)
DGC-6B MONITORING WELL (GHR 1985)
TP-12 EB TEST PIT (GHR 1985)
d-DETECTED,SEVIIOUANTITATIVE
ENVIRONMENTAL PROTECTION
AGENCY
BREWSTES WELL FIELD
FIGURE 6
AVERAGE SOIL CONTAMINATION
ABOVE THE WATERTABLE AND
IN THE DRYWELL
EBASCO SERVICES INCORPORATED
-------
-23-
TABLES
-------
BREWSTER WELL FIELD
SELECTED VHO CONCENTRATIONS IN SOIL BORINGS NEAR ALBEN CLEANERS
PRESENT STUDY
APPROX
DEPTH
(feet)
0-2
2-4
4-6
6-8
8-10
10-12
12-14
u =
J =
VHO
Compounds
oob
DCE
TCE
PCE
DCE
TCE
PCE
OCE
TCE
PCE
DCE
TCE
PCE
OCE
TCE
PCE
DCE
TCE
PCE
DCE
TCE
PCE
undetected
estimated value
SfcJ.
]
:
"
830
1.100
7.400
:
SB-2
(VGA vial)
u
u
1.200
-
=
u
u
1.700
-V
:
SP-2
u
u
1.200
u
u
93
u
u
u
~
, detected below contract
5Jb3
-
u
u
u
u
u
u
u
u
u
:?
_-
required
SB-4 SB-5 SB-S-5a
u u -
u u -
u 4.100
u
u
- - u
u - u
u u
u - 4.000
u -T u»
u - u
u - u
u
u - -
u - -
~r ~ ~
- - -
detection limits
SB-7
SB-6 (AUG)
u
u
u -
7
5J
u -
- r
-
-
- 4.1xlOJJ
- 2.1xl06
- u
- 7.2xl05
- 1.9x10'
SB-8
SB-7 (VOA
(SEP) Vial)
u
u
27
u
u
- u
-
-
-
u -f
3.0x10* -
5.7xl06 -
3. 2x10* -
6.2xl08 -
SB-8
u
u
12
u
u
u
u
u
79
-
101?
u
u
-
SB-9
u
u
IJ
u
u
u
u
u
u
-
u
u
-
-
SB- 10
u
u
(1
u
u
u
_r
-
-
-
SB- 11
u
u
-
u
u
u
u
u
u
-T
r
SB- 13
u
u
u
u
u
-
SB- IS SB- 16
u u
u u
u u
u* u
u . u
u u
u u ^
u u
u u
-
^ ^
-
= no sample collected
= watertable
7033b
-------
TABLE 2
CAPITAL COST ESTIMATES (1968 Dollars)
Tacil i tv/Const ruction
1 . Site Preparation & Sample
a. Site Preparation
b. Field Portable GS (Lease)
ALTERNATIVE
Estimated
Quantities
Moni taring
1
3 - ON-SITE ENHANCED VOLATILIZATION
Material
Unit
Price Cflii
1,000/wk 4.000
Installation
Unit
Price Cflit
500/day 15.000
Direct
Construction
Cost
$ 6.000
$ 19.000
2. Removal of Asphalt Pavement &
Excavation Around Dry Well
3. Sheet Piles
a. Lease of Sheet Piles
b. Installation of Sheet Piles
4. RemovaJ of Dry Well
a. Saw Cut
b. Removal
5. Decontamination of Drv Well
a. Steamblasting
42 cy
32 ton
1,200 sf
15 cy
800 sf
6. Qff-S'te.PCPA Pis.posa.1 nf Decontaminated
Concrete Debris
a. Hauling & Transportation
b. RCRA Landfill Disposal '
15 cy
22.5 ton
200/ton
6.400
33.4 cy
8.83/Sf
350/ton
10.600
2.270
1.520
740
4.300
-7,880
$ 1,400
$ 6.400
$ 10,600
$ 2,270
$ 1.520
$ 740
$ 4.300
$ 7.880
7507b
-------
TABLE 2 (Cont1
CAPITAL COST ESTIMATES M9BB Dollars)
ALTERNATIVE 3 - ON-SITE ENHANCED VOLATILIZATION
Materials Installation
Estimated Unit
Faci 1 ity/Construction Quantities Price
7. Removal of Liauid Waste and Sludae
a.
b.
c.
8.
9.
a.
b.
10
a.
b.
c .
Settling Tank (Lease 2 weeks) 3,000 gal
Pumping
Settled Wastewater Hauling 3,000 gal
Tanker Truck (Lease 1 Week)
Excavation of Contaminated Soil 63 cy
On-Site Enhanced Volatilization
Mobilization & Demobilization
Low Temperature Thermal Stripping . 135 ton
. Site Restoration
Backfill & Compaction of 90 cy
Treated Soil
Borrowed Fill & Compaction 15 cy 15/cy
Asphalt Pavement 250 sf 2/sf
Unit (
tttii Price Cflil
1,000
3.200
29.60 cy 1,870
300/ton 40.500
10/cy 900
225 5/cy 75
500 3/sf 750
Total Construction Cost (TDCC)
Contingency ? 25X of TDCC
Engineering 9 15% of TDCC
Legal & Administrative 0 2% of TDCC
Total Construction Cost
Direct
.'onstruction
Cost
$
$
$
$
$
$
$
$
s
$
$
$
s
$
3,000
1,000
3,200
1.870
60,000
40,500
900
300
1.250
172.130
43.030
25.820
3.440
244.420
7507b
-------
TABLE 2
CAPITAL COST ESTIMATES (1988 Dollars)
ALTERNATIVE 4 - OFF-SITE INCINERATION
Materials Installation Direct
Estimated Unit Unit Construction
Faci1i ty/Construction Quantities Price Cost Price tftit Cost
1. $ite Preparation & Sample Monitoring
a. Site Preparation $ 3,000
b. Field Portable GS (Lease) 1 1.000/wk 2.000 500/day 5.000 $ 7.000
1. Removal of Asphalt Pavement & $ 1.400
Excavation Around Dry Well (See Table B-l)
2. Sheet Piles
a. Lease of Sheet Piles (See Table B-l) $ 6.400
b. Installation of Sheet Piles (See Table B-l) $ 10.600
I
M
3. Removal of Dry Well "
a. Saw Cut (See Table B-l) $ 2.270
b. Removal (See Table B-l) $ 1,520
4. Decontamination Qf Pry Hell
a. Steamblasting (See Table B-l) $ 740
5. Off-Sit* Dispoal of Decontaminated
Concrete Debris
a. Hauling & Transportation (See Table B-l) $ 4,300
b. Municipal Landfill Disposal (See Table B-l) $ 7,880
7507b
-------
TABLE 2 (Cont'd)
CAPITAL COST ESTIMATES (1988 Dollars)
ALTERNATIVE 4 - OFF-SITE INCINERATION
Estimated
Quantities
Facili ty/Constructjon
6. Removal of Liquid Waste and Sludge
a. Settling Tank (See Table B-1)
b. Pumping (See Table B-1)
c. Settled Wastewater Hauling (See Table B-1)
Unit
Price
.Materials
Cost
Installation
Unit
Price
Direct
Construction
Cost
$ 3.000
$ 1,000
$ 3.200
7. Excavation of Contaminated Soil (See Table B-1)
1.870
8. Contaminated Soils Containerization.
Hauling and Transportation
a. Drumming and Hauling
b. Transportation
135 tons
7 load
500 mile
30/drum 11.300 33.5/ton 4,520
3.5/mile/load 12.250
$ 15.820
$ 12.250
9. Off-Site Incineration
130 ton
700/ton
130.000
$ 91,000
10. Site Restoration
a. Borrowed Fill & Compaction
b. Asphalt Pavement
105 cy
250 Sf
15/cy
2/sf
1.580
500
5 cy
3/sf
525
750
Total Direct Construction Cost (TOCC)
Contingency 9 20* of TOCCC)
Engineering § 15K of TDCC
Legal & Admins it rat ion £ 2% of TDCC
Total Construction Cost
$ 2,100
t 1.250
$ 176.600
$ 35,320
$ 26.490
j 3.530
$ 241,940
() A 20% contingency factor is assumed for this case as compared to 25% for the on-site mobile enhanced volatilization
operation because of the higher potential for operation problems and down time associated with a mobile unit as compared to
a stationary uni t.
7507b
-------
APPENDIX-A
Ntw York Statt Dtpartment of Environmtntil Constrvation
*0 Wolf Read, Albany, Ntw York 12233
Thomai C. Jodlng
CemmlHlontr
SCP27 1988
Mr. Stephen D. Luftlg, P.E. ' ,-o
Director ~^
Office of Emergency and Remedial Response -?
U. S. Environmental Protection Agency J_ .
Region II ~r
26 Federal Plaza
New York, NY 10278
Dear Mr. Luftig:
The New York State Department of Environmental Conservation
(NYSDEC) reviewed the Remedial Investigation (RI) rtport and the
Feasibility Study (FS) for the Second Operable Unit of the Brewster Nell
Field site. We concur with the U. S. Environmental Protection Agency's
selection of Alternative 4, off-site Incineration of contaminated soils
and off-site 1andf1ll1ng of decontaminated concrete, as the preferred
remediation alternative.
The draft Record of Decision (ROD) states, "Site soils and
sediments, Including those contiguous to the drywell and site drainage
systems, will be tested during response actions, and those materials
containing more than 4 ppm PCE (tetrachloroethylene) will be
remediated." Please be aware that NYSDEC and the New York State
Department of Health (NYSDOH) define this "drainage system" as one that
begins at the catch»bas1ns on site and continues through the culvert
out-wash to the northeast of Alben Cleaners (see enclosure).
Also, please be advised that Air Guide Ms net an Applicable or
Relevant and Appropriate Requirement (ARAR). Rather, it is a tool to be
used while examining the NYSDEC air regulations which must be considered
ARARs for all remedial programs. The NYSDEC regulations relating to air
quality which are considered ARARs Include: 6 NYCRR, Parts 200.6, 201,
211,2, 212, and 257.
-------
Mr. Stephen D. Luftlg, P.E. Page 2
An estimate of emissions from the remedial activities must be made
during the design phase of this project. During these activities,
monitoring of off-site emissions shall be conducted. Any missions
deemed unacceptable by NYSDEC will be cause for emission controls
necessary to bring these emissions to an acceptable level.
If you have any questions, please call me at (518} 457-5861 or
James Qulnn, of my staff, at (518) 457-1708.
Sincerely,
J. O'Toole, Jr., P.E.
Director
Division of Hazardous Waste
Remediation
Enclosure
-------
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-------
APPENDIX B
RESPONSIVENESS SUMMARY
A public comment period was held from August 18, 1988 through
September 12, 1988 to receive comments from the public on the
draft FS and EPA's preferred remedial alternative for the
Brewster Well Field site. A public meeting for the site was
held on August 31, 1988 at 7:00 p.m. at the Brewster, N.Y.
Village Hall. The meeting was attended by EPA officials, a
representative of EPA's consultant engineer, state, county
and local officials, media representatives, and a limited
number of local citizens. The purpose of the meeting was to
present and discuss the draft FS for the site, to apprise
local officials and residents of the agency's preferred
alternative for remediating the site, and to provide an
opportunity for interested parties to present oral comments
and questions to EPA. Comments received during the comment
period are categorized below by topic.
A. Liability of potentially responsible parties (PRP's).
B. Origin, nature and extent of contamination.
C. Other concerns.
A. LIABILITY OF POTENTIALLY RESPONSIBLE PARTIES
1. Comment: A local official wanted to know if past and
present property owners and tenants at the source location
were notified of the site contamination, and their potential
liability.
EPA Response: Site contamination and response actions
have been widely publicized in public fact sheets and
press releases. Notice letters have been mailed to PRP's
including the property owner and Alben Cleaners. Enforcement
efforts are continuing. If identified, additional PRP's
will be notified.
2. Comment: The site owner asked whether, as a buyer of the
property, he was liable for waste disposal practices of
past owners or tenants.
EPA Response: Innocent property owners are not normally
liable for disposal practices of past owners or tenants.
A determination as to his innocence will be made in the future,
Also see comment 4 below.
3. Comment: A local official asked whether the village is
considered a PRP.
EPA Response: We presently have no reason to believe that
the village is a PRP.
-------
-2-
4. Comment: The site owner asked that Superfund's "de minimis"
rule be explained.
EPA Response: When practicable and in the public interest
settlements can be reached with PRPs if the settlement
involves a minor portion of the response cost, and the
amount and toxicity is minimal, or the PRP is the owner of
the site'but did not conduct or permit the generation,
transportation, storage, treatment or disposal of hazardous
substances and did not contribute to the release.
5. Comment: The site owner asked whether Alben Cleaners, as
the operator, is solely responsible.
EPA Response: Not necessarily. Costs may also be recovered
from past and present site owners and, possibly, other
tenants (e.g. under subleasing arrangements.)
6. Comment: A local official asked whether New York City
(NYC) or the New York State Department of Transportation
(DOT) are considered PRPs since the contaminated groundwater
plume is located under NYC and DOT property.
EPA Response: No; not by virtue of the location of the
plume. The plume represents the migration, but not the
source, of contamination. . .
B. ORIGIN, NATURE AND EXTENT OF CONTAMINATION
1. Comment: A local official questioned whether the contaminated
source materials (i.e. drywell and contents) pose any
dangers to the building occupants.
EPA Response: The source is presently effectively buried
and presents no direct contact danger but would be a
danger if left in place and accidently exposed (e.g. as a
result of excavation) in the future.
2. Comment: The site owner asked when the drywell was installed.
EPA Response: We don't know for certain. Records indicate
that an adjacent septic tank was installed in 1949. The
drywell may have been installed at that same time.
-------
-4- .
8. Comment: The owner asked whether the drywell system was
tested when installed.
' EPA Response: We don't know. Typically, county or local
agencies run percolation tests on septic and drywell
systems.
9. Comment: A local official asked how much waste would be
excavated at the source and how long it would take.
EPA Response: We expect that approximately 100 cubic
yards (cy) of wastes will be removed and that the response
action will take a matter of weeks from the start of
excavation.
10. Comment: A local official asked whether the adjacent East
Branch River is being contaminated.
EPA Response: No. Only one surface water sample at the
discharge from the culvert from the Alben parking lot
showed trace amounts (4ppb) of PCE.
11. Comment: The site owner questioned whether a large (4-8ft.)
culvert from the interstates ran under the site and whether
a highway spill, via the culvert, could have been the
cause of site contamination.
EPA Response: A culvert that large would terminate in an
endwall at the river or large drainage basin and none is
evident at the site. Such a culvert would probably have
been constructed by DOT. We have coordinated our remedial
efforts with DOT and are not aware of any large culvert.
Finally, in the absence of a drainage basin, a spill to a
storm drain would discharge to the river, and not the
groundwater aquifer.
12. Comment: The owner asked where the drywell is physically
located.
EPA Response: Records indicated that the drywell is
located approximately 25 feet east of the southeast corner
of the Alben building. A soil boring taken during the
remedial investigation confirms this.
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13. Comment: The owner asked if we could determine how long
the contamination has been accumulating in the drywell.
EPA Response: There are too many variables (e.g. groundwater
flow, geology, rate of discharge) to determine, from data,
just how long the discharge took place or has been
accumulating, with any meaningful accuracy.
14. Comment: The owner asked whether relatively recent highway
construction could have affected groundwater conditions in
the area since 1960.
EPA Response: Construction may have mildly affected the
local recharge of surface water to groundwater but would not
have substantially affected pre-existing groundwater
conditions.
15. Comment: One commenter asked how many gallons of contaminants
it took to contaminate the site.
EPA Response: Theoretically five- gallons of a pure
contaminant, such as the volatile organic compounds found
at the Brewster site, could contaminate one billion gallons
of water to maximum contaminant levels (MCLs) under the
Safe Drinking Water Act (e.g. 5ppb for TCE). It is unlikely
that the contaminants were disposed of in pure form, but
rather as an unknown part of a total 'waste. As a result
of pumping and natural attenuation some unknown part of
the contamination has been removed or lost. Therefore we
could not, with any reasonable accuracy, estimate the
quantity of waste that was disposed of at the site.
C. OTHER CONCERNS
1. Comment: A local official asked who will pay for and
operate the groundwater management system.
EPA Response: EPA will pay for 90% and the State will pay
for 10% of the costs of construction and the ten year
remediation effort. The State will pay for operation and
maintenance after ten years if it is necessary. The State
is also responsible for physically running the system but
may arrange for local authorities to do -so.
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2. Comment: The site owner asked whether any programs were
in place in the late 1970's that regulated the disposal
of hazardous wastes such as those from a dry cleaner.
EPA Response: The Resource Conservation and Recovery Act
(RCRA) of 1976 typically regulates the discharge of
hazardous waste depending on the quantity generated.
There may also be State, local, and industry regulations
or guidelines that have application to dry cleaning waste
disposal.
3. Comment: A local official asked why the effluent from the
groundwater management system is going to be reinjected
into the groundwater rather than be pumped into the distri-
bution system.
EPA Response: Pumping to distribution would have required
that the discharge be piped across the river and would
have been more difficult to implement and more costly.
Reinjection of the effluent dilutes the groundwater
contamination and creates a barrier to the migration of
further contamination.
4. Comment: A local official asked when the groundwater
management system will be built.
EPA Response: Funding for construction is shared 90% by
EPA and 10% by the State. Federal funding has been
obligated. It is expected that the State cost share will
be approved shortly. Construction should take approximately
six to nine months.
5. Comment: A local engineer asked what the groundwater
management system well construction will be.
EPA Response: The groundwater management wells will be
gravel packed wells.
6. Comment: The engineer asked what the groundwater management
system capacity will be.
EPA Response: The system is designed to operate at 50
gallons per minute (gpm)
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7. Comment: The engineer asked how deep the groundwater
management wells will be.
EPA Response: The groundwater management wells will vary
from 20 to 40 feet deep.
8. Comment: A local official asked whether town permission
was necessary to construct the groundwater management
system.
EPA Response: With regard to property access, the system
is to be constructed on DOT, NYC, and Brady Stannard
property, from whom we have permission or conditional
permission to construct the system. Local construction
permits, if necessary, will be obtained by th« construction
contractor.
9. Comment: A local official asked whether .NYC was apprised
of the construction of the groundwater management system.
EPA Response: NYC has been so advised and supports EPA's
remedial efforts.
10. Comment: A local official asked whether health risks due
to emissions from the groundwater management system packed
tower air stripper were re-evaluated as part of the most
recent study. .
EPA Response: Data from the most recent study indicates
that calculated air pathway health risks have decreased.
This is due to a corresponding decrease found in groundwater
contamination.
11. Comment: The site owner asked whether any other local
properties were listed on any Superfund type lists.
EPA Response: The commenter was advised to call both
State and Federal environmental offices for a list of
sites.
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