United States
Environmental Protection
Agency
Office of
Emergency and
Remedial Response
E PA/ROD/R02-83/077
December 1988
&EPA
Superfund
Record of Decision
Clothier Disposal, NY
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REPORT DOCUMENTATION 1. REPORT NO. z.
PAGE
4. TMomdSubMo
SUPERFUND RECORD OF DECISION
Clothier Disposal, NY
First Remedial Action
7. Authorts)
U.S. Environmental Protection Agency
401 M Street, S.W.
Washington, D.C. 20460
X RoctptonCB AccMaton No.
5. Report D«t»
12/28/88
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800/000
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18. AteMct (Unto 200 woitf*)
The Clothier Disposal site is located in a rural area near the Town of Granby, Oswego
County, New York. It is a privately owned, 15-acre parcel of land, of which
approximately 6 acres have been used for waste disposal. Land use in the vicinity of
the site is predominantly agricultural. A wetland passes through the site to the west
of the area used for waste disposal. Ox Creek also flows through the site in a
northerly direction, feeding into the Oswego River, and a portion of the site is
located within the 100-year floodplain. Ground water flow patterns clearly indicate
that flow is toward Ox Creek. In 1973, drums of chemical waste were discovered on the
Clothier property, despite State denial of a landfill permit application. After the
New York Department of Environmental Conservation brought suit, the owner made several
attempts to clean up the property. These attempts, however, resulted in drums being
broken and drained. Subsequently, additional dumping of roofing materials, household
wastes and junked vehicles occurred at the site. Based on data from the remedial
investigation and State sampling, EPA established the need for a removal action for
2,200 drums located onsite. A number of potentially responsible parties under an
administrative order on consent removed 1,858 drums. EPA removed the remaining drums
and visibly contaminated surficial soil and debris associated with the drums. This
(See Attached Sheet)
f
7. Doc
•. D««cilptoi»
NY
Record of Decision - Clothier Disposal,
First Remedial Action
Contaminated Media: soil
Key Contaminants: VOCs (PCE, toluene, xylenes), organics (PAHs, PCBs, phenols),
e. COSATI FMd/GfOt*
19. Security CUM (Thta Report)
None
20. Security CteM(ThtePigo)
None
21. NaofPtgn
94
22. Price
(SMANSt.Z39.18)
SM AiMvetfora on femwa*
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A GPO: 1983 0 - 381-526(8393) OPTIONAL FORM 272 BACK
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EPA/ROD/R02-89/077
Clothier Disposal, NY
First Remedial Action
16. Abstract (Continued)
remedy addresses the low-level residual soil contamination remaining on-site. If the
results of ground water, surface water and sediment sampling determine a need to
remediate the groundwater and/or the wetland, a subsequent operable unit remedy will
be undertaken. The primary contaminants of concern affecting the soil are VOCs
including toluene, xylene, and PCE; other organics including PAHs, PCBs and phenols;
and metals.
The selected remedial action for the site includes placement of a one-foot soil
cover over the contaminated areas and regrading and revegetation of the site;
installation of rip-rap, as needed, on the embankment sloping towards Ox Creek to
prevent soil erosion; construction and post-construction air monitoring; institutional
controls preventing the utilization of the underlying ground water, or any land use
involving significant disturbance of the soil cover; and long-term ground water, soil,
sediment and surface water monitoring. The estimated present worth cost for this
remedy is $500,000, which includes annual O&M of $27,000.
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DECLARATION FOR THE RECORD OF DECISION
Site Name and Location
Clothier Disposal site, Town of Granby, Oswego County, New York
Statement of Basis and Purpose
This decision document presents the selected remedial action
for the Clothier Disposal site. The selected remedial
alternative was developed in accordance with the Comprehensive
Environmental Response, Compensation, and Liability Act of 1980
(CERCLA) , as amended by the Super fund Amendments and
Reauthorization Act of 1986 (SARA), 42 U.S.C. Section 9601 et
seq.. and, to the extent practicable, the National Contingency
Plan (NCP) , 40 C.F.R. Part 300, November 20, 1985. This
decision is based on the administrative record for this site.
The attached index identifies the items that comprise the
administrative record upon which the selection of the remedial
action is based.
The State of New York has concurred with the selected remedy.
Description of the Selected Remedy
All known drums of hazardous substances, surface and
subsurface, totalling some 2,200 drums, have already been
removed from the site, as has the majority of the visibly-
contaminated surface soil associated with the drums. This
remedy addresses the low-level residual soil contamination
remaining on-site. The U.S. Environmental Protection Agency
has determined that risk levels associated with this residual
contamination are minimal, and within the range considered
acceptable in Superfund remedies. The selected remedy provides
additional protection by reducing the principal remaining
threat at the site, namely, direct contact and ingestion of
low-level contaminated soil, by covering the contaminated areas
with one foot of clean soil.
This source control remedy does not address the groundwater and
the adjacent 11-acre wetland. However, groundwater, surface
water and sediment samples were collected from the site and the
adjacent wetland during December of 1988. Results of these
samples will be available for public review. If it is de-
termined that there is a need to remediate the groundwater
and/or the wetland, a subsequent operable unit remedy will be
undertaken.
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Carrying out the remedy described in this document will not
prevent or hinder any future remedial activity that may be
found necessary for the groundvater or the wetlands.
The major components of this remedial action are:
- Placement of a one-foot clean soil cover, brought from an
off-site source, over the contaminated areas. Sampling will
be performed during the design phase to determine the extent
of the areas of residual contamination requiring covering.
- Regrading and revegetating the site to prevent soil erosion
and to minimize surface water runoff towards neighboring
properties, Ox Creek, and the adjacent wetland. The
regrading plan and types of vegetation will be determined
during the design phase, and will be compatible with the
wildlife habitat.
- Installing rip-rap, as needed, on the embankment sloping
towards Ox Creek to prevent soil erosion. The extent of the
rip-rap will be determined during the design phase, and will
consider the impact on the wildlife habitat.
- Performing long-term groundwater, soil and Ox Creek
sediment and surface water monitoring to evaluate
any changes should they occur. The long-term monitoring
program will consider the installation of additional wells,
including bedrock wells. Based upon the results of the
monitoring program, sampling of the private residential wells
in areas neighboring the site, and the deeper aquifer, would
be performed, if warranted.
- Performing construction and post-construction air monitoring.
This may also include, but is not limited to, pre-construc-
tion air monitoring and/or analyses to further delineate
areas of the site requiring covering.
- Applying, to the extent possible, institutional controls to
prevent the utilization of the underlying groundwater
(e.g., through the drilling of wells in the shallow aquifer),
the future development of the site for residential use, or
any use involving excavation at the site or significant
disturbance of the soil cover. Any institutional controls,
including, without limitation, deed restrictions or
easements, shall be consistent with New York State law.
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Declaration
Consistent with CERCLA, as amended by SARA, 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 to
the remedial action, and is cost-effective. This remedy
utilizes permanent solutions to the maximum extent practicable
for this site. Because treatment of the principal threats of
the site was not found to be necessary, this remedy does not
satisfy the statutory preference for treatment as a principal
element of the remedy.
Because this remedy will result in hazardous substances
remaining on-site, a review will be conducted within five years
after commencement of remedial action to ensure that the remedy
continues to provide adequate protection of human health and
the environment. Should this review show that this is not the
case, additional action will be undertaken in full consultation
with the public.
William J/^MuszyrfSKi, P.E. Date
Acting Regional Administrator
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RECORD OF DECISION
CLOTHIER DISPOSAL SITE
GRANBY, NEW YORK
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Region 2
New York
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OP CONTENTS
Page
SITE NAME, LOCATION AND DESCRIPTION ......... 2
SITE HISTORY .................... 3
ENFORCEMENT HISTORY. . ............... 5
COMMUNITY RELATIONS HISTORY ............. 6
SCOPE AND ROLE OF RESPONSE ACTION .......... 6
SUMMARY OF SITE CHARACTERISTICS .......... 8
SUMMARY OF SITE RISKS ................ 12
DOCUMENTATION OF SIGNIFICANT CHANGES ........ 18
DESCRIPTION OF ALTERNATIVES ............. 18
SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES. . . 21
THE SELECTED REMEDY ................. 27
STATUTORY DETERMINATIONS .............. 28
ATTACHMENTS
APPENDIX 1 - TABLES
APPENDIX 2 - FIGURES
APPENDIX 3 - ADMINISTRATIVE RECORD INDEX
APPENDIX 4 - NYSDEC LETTER OF CONCURRENCE
APPENDIX 5 - RESPONSIVENESS SUMMARY
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TABLES
Table
1 Chemicals selected as chemicals of concern APPENDIX 1
at the Clothier Site
Comparison of concentration values with
Federal and New York State Groundwater
ARARs for Chemical of Concern at the
Clothier Site APPENDIX 1
Soil Cleanup Levels For PCBs and CPAHs
Direct Contact/Ingestion Routes
(Current Land-use Scenario) APPENDIX 1
Health Based Soil Cleanup Levels for PCBs
and CPAHs Direct Contact/Ingestion Routes . . . APPENDIX 1
(Future Land-Use Scenario)
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FIGURES
Figure
1 Generalized Map of Clothier Property APPENDIX 2
2 Site Location Map APPENDIX 2
3 Waste Disposal Areas APPENDIX 2
4 Principal Area of Soil Contamination APPENDIX 2
5 Contaminated Areas Above Cleanup Levels APPENDIX 2
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SITE NAME. LOCATION. AND DESCRIPTION
The Clothier Disposal site is a privately owned 15-acre parcel
of property, of which approximately 6 acres have been used for
waste disposal (see Figure 1) . It is located in a rural area
on the south side of South Granby Road, in the Town of Granby,
Oswego County, New York (see Figure 2) . This location is about
7 miles south of the City of Fulton, 18 miles northwest of the
City of Syracuse, and 16 miles southeast of Lake Ontario.
Land use in the vicinity of the Clothier Disposal site is
predominantly agricultural. Fields bounding the site on the
east and south are currently cultivated. A small sand pit is
located approximately 1,300 feet east of the site.
Due to the agricultural nature of the area, soil is considered
to be the primary natural resource. A wetland passes through
the site to the west of the area used for waste disposal. The
wetland provides a haven for aquatic life and water fowl and
birds which may migrate through the area.
The closest population center is the City of Fulton (1980 U.S.
Census population 13,312). The population of Oswego County
was 113,901 in the 1980 census. There are currently no
residents on-site. The nearest residents are located
approximately one-half mile to the east and west of the site,
along South Granby Road and Ley Creek Road.
The Clothier Disposal site consists of a large swampy area
along the margin of Ox Creek and the adjacent lands to the
east, which lie about 5-15 feet above the swampy area. An
east-west trending swale crosses the central portion of the
site and channels runoff toward the creek. Other than this
swale, surface drainage at the site is poorly defined.
,'
Ox Creek itself flows through the site in a northerly
direction, feeding into the Oswego River approximately 1 mile
to the northeast. Ox Creek originates approximately 6.7 miles
upstream from the Clothier Disposal site, and has a tributary
drainage area of approximately 26 square miles, corresponding
to an average flow rate of about 35 cubic feet per second, as
it passes the site.
A geologic investigation of the site indicated that the site
generally consists of a surficial mantle of clayey silt ranging
in thickness from 5 to 7 feet, underlain by a relatively thick
(4.5 to 30 feet) section of fine sand and silt. A layer of
glacial till underlays these two units which, in the region,
is typically found overlying bedrock. A sand and gravel layer
was encountered beneath the fine sand and silt layer at the
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south side of the site and in relatively minor thicknesses at
two other locations.
Glacial till and fine sand and silt constitute the lowest
quality aquifers in the region, with yields of only 1-2 gallons
per minute.
Bedrock underlying the site is from 35 to 55 feet below the
ground surface. Wells tapping the bedrock aquifer in Oswego
County have average depths of 85 to 90 feet, and typically
produce yields of 3 gallons per minute.
Groundwater flow patterns clearly indicate that groundwater
flow is toward Ox Creek.
A portion of the site is located within the 100 year flood-
plain, coinciding approximately with the 360-foot elevation
contour.
SITE HISTORY
In early 1971, a permit application to landfill an area now
referred to as the Clothier Disposal site was submitted by the
site owner to the New York State Department of Environmental
Conservation (NYSDEC) and the New York State Department of
Health (NYSDOH). Following an inspection by NYSDOH, the site
was deemed unsuitable for the disposal of any solid waste
materials, and a permit was denied on April 19, 1971. Written
notice to the site owner at this time cautioned against
landfill operations without a permit. In 1973, the Oswego
County Health Department found drums of chemical waste from the
Pollution Abatement Services, Inc. facility dumped on the
Clothier property, and requested an investigation by NYSDEC.
In November 1976, NYSDEC brought suit against the owner of the
Clothier Disposal site for operating an illegal dump. In 1977,
the owner made an apparent attempt to bury or cover the waste
materials dumped on the site. In doing so, drums were broken
open and drained. The owner was cited in December 1977, for
failing to meet the conditions imposed by the previous year's
suit. The case was dismissed when the State's attorney did not
appear in court at the appointed time.
Between early 1978 and the spring of 1980, additional efforts
were made by the owner to clean up the property. Again these
efforts largely entailed burying or covering previously exposed
wastes. However, in late 1982, additional dumping of roofing
shingles and/or tar paper occurred. An undetermined number of
drums were still piled on the site approximately 200 yards
south of South Granby Road, east of Ox Creek and the adjacent
wetland.
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In June 1983, Engineering-Science, Inc. performed a Phase I
Engineering Investigation and Evaluation of the Clothier
Disposal site for NYSDEC for the purpose of computing a Hazard
Ranking System (HRS) score needed to evaluate whether to place
the site on the National Priorities List (NPL) . In the Phase I
report, an HRS score of 36.18 was presented, which was above
the minimum score of 28.5 necessary for inclusion on the NPL.
Further evaluation, in October 1984, resulted in the
modification of the score to 34.48 when it was proposed by the
U.S. Environmental Protection Agency (USEPA) for inclusion on
the NPL.
By October 1984, the disposal of additional miscellaneous
household waste had occurred, but there was no appreciable
evidence that the drums had been further disturbed.
A cooperative agreement between NYSDEC and USEPA enabled NYSDEC
to initiate and direct remedial investigation and feasibility
study (RI/FS) activities at the site in 1985.
In August 1985, field work for the RI commenced at the site.
The work was conducted by NYSDEC's contractor, URS Company,
Inc. (URS), and several subcontractors. During the fall of
1985, while RI field activities were underway, a number of
junked vehicles were disposed of on the site.
As part of the RI, approximately 2,200 drums on the Clothier
Disposal site were staged and sampled; leaking or deteriorated
drums were placed in overpacks. The samples were analyzed in
the field as part of an initial waste characterization but did
not entail identification of specific compounds. Concurrently
with the RI activities, NYSDEC personnel sampled and analyzed
six of the drums for specific compounds. Upon evaluating these
data and other information, and considering the health risks
associated with the drums, USEPA established a need to remove
and dispose of them as an emergency removal action.
A number of potentially responsible parties (PRPs), operating
under a May 8, 1986 Administrative Order on Consent, removed
and disposed of about 1,858 drums from the site during the
summer and fall of 1986. The remaining 271 drums were
resampled by USEPA, and were restaged into separate areas
according to their contents (i.e., PCBs, non-PCBs). of these,
211 drums of flammable liquids and solids were disposed of by
USEPA under emergency removal authorities in July 1987. The
remaining 60 drums were removed from the site in July 1988 by
USEPA and taken to an off-site facility for disposal. All
known surface and subsurface drums, particularly those along
the embankment slope, have been removed, although refuse and
other miscellaneous debris are still present on-site. During
the drum removal activities, visibly contaminated surficial
soil and debris associated with the drums were excavated and
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staged in an area in the south central portion of the site.
This accumulation (the "soil pile") was removed from the site
by USEPA and taken to an off-site facility for disposal in July
1988.
A number of data quality problems complicated the completion of
the RI/FS activities for the site. Groundwater, surface water,
soil and sediment samples were collected at the site by URS in
February 1986. Prior to laboratory analyses, these samples
were held longer than the permitted holding times specified in
the Quality Assurance Plan. As a result, the sample analyses
were rejected, and resampling was conducted by URS, at its own
expense, in July 1986. An RI/FS report was completed in June
1987. Following the public release of this report, it was
determined that the sample results had not been validated by
NYSDEC. Subsequently, the sample analyses discussed in the
report were determined to be invalid by NYSDEC.
A third round of shallow soil and groundwater samples were
collected by URS, at its own expense, in October 1987 and
January 1988, respectively. In this round, the number of soil
samples locations was increased significantly to better
characterize the areal extent of soil contamination on-site.
It was subsequently determined that the soils data did not
allow full characterization of the depth of the contamination.
As part of a supplemental RI/FS, USEPA's contractor, Ebasco
Services, Inc. (Ebasco), conducted deep soil sampling in
February 1988 for the purpose of determining the vertical
extent of soil contamination.
In August 1988, URS1 and Ebasco's RI/FS reports were released
to the public.
The U.S. Fish and Wildlife Service (USFHS), by means of an
interagency agreement with USEPA, performed surface water,
sediment, and biological sampling in Ox Creek during June,
July, September, and October 1987. The results of the analyses
conducted on these samples are the subject of a USFWS report
issued in August 1988.
Enforcement History
Notice letters were sent in March 1985 advising the Clothier
Disposal site PRPs of USEPA's intent to fund an RI/FS at the
site.
On March 19, 1986, EPA issued notice letters for the
performance of removal activities at the site.
On May 8, 1986, EPA entered into an Administrative Order on
Consent with those PRPs who elected to voluntarily conduct
selected removal activities.
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On August 12, 1986, EPA issued a Unilateral Administrative
Order ("Unilateral AO"). The activities required by the
Unilateral AO included the performance of the remaining removal
activities at the site. Since the respondents did not comply
with the Unilateral AO, USEPA completed the removal activities.
USEPA intends to enforce the terms of the order against the
non-compliers.
In June 1987, USEPA advised the PRPs of the availability of
URS1 RI/PS report.
On September 16, 1988, USEPA advised the PRPs of the
availability of URS1 and Ebasco's RI/FS reports.
USEPA anticipates sending notice letters shortly after
execution of this ROD to initiate remedial design and remedial
action negotiations.
COMMUNITY RELATIONS HISTORY
USEPA and NYSDEC has kept the local citizens and officials
advised throughout the Superfund process. Several public
meeting were held in Grandby to discuss site developments. A
number of informal meetings were held with local citizen groups
during the course of the RI to discuss its results.
In July 1987, a public meeting was held to solicit comments on
and to discuss the findings of the RI/FS issued in June 1987.
In October 1988, a public meeting was held to discuss and
receive comments on the RI/FS issued in August 1988 and the
Proposed Remedial Action Plan (PRAP). Questions raised at the
public meeting, and letters received and their corresponding
responses, are summarized in the attached Responsiveness
Summary.
In response to a request from the public, the RI/FS public
comment period was extended from three weeks to sixty days.
The comment period ended on November 4, 1988.
SCOPE A|*P R9PE OF RESPONSE ACTION WITHIN SITE STRATEGY
This remedy considers the fact that the sources of the
contamination, approximately 2200 leaking on-site drums, and
that the majority of the contaminated surficial* soil (about 300
cubic yards) have been removed from the site, leaving the site,
currently, with only residual low-level soil contamination.
The analytical results of the soil samples have confirmed the
fact that only low-level contamination remains on-site.
The selected remedy reduces the already acceptable risk level
to humans (primarily trespassers, since there are no residents
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currently on-site) by the placement of a one-foot cover of
clean soil over contaminated areas, thereby reducing the threat
of direct contact/ingestion of the low-level contaminated
soil. (Sampling will be performed during the design phase to
determine the extent of the areas of residual contamination
requiring covering.) The remedy addresses the present threat
to the environment (e.g., Ox Creek, the adjacent wetland, and
neighboring properties) due to soil erosion and surface water
runoff by regrading and revegetating the site (the regrading
plan and type of vegetation will be detailed during the design
phase and will be compatible with wildlife habitat), and by
placing rip-rap, as needed, on the embankment sloping toward Ox
Creek. (The extent of rip-rap will be determined during the
design phase and will consider the impact on the wildlife
habitat.) Institutional controls to prevent the utilization of
the underlying groundwater (e.g., through the drilling of wells
in the shallow aquifer), the future development of the site for
residential use, or any use involving excavation of the site or
significant disturbance of the soil cover will be implemented.
Any institutional controls, including without limitation, deed
restrictions or easements, shall be consistent with New York
State law.
The selected source control remedy does not address the
groundwater, although a number of federal and New York State
groundwater organic and inorganic ARARs are marginally
exceeded. Considering that the groundwater samples were noted
as being turbid (which may have artificially inflated the level
of contamination), and that the background wells were screened
in different soil strata than those on-site, an additional
round of groundwater samples were collected in December 1988.
The results of these samples will be evaluated to determine
whether a second operable unit to address groundwater
contamination is needed. If it is determined that this
subsequent investigation is necessary, an attempt would first
be made to determine how the contaminants migrated to the
wetland (e.g., via surface water runoff or the groundwater).
The USFWS1 study found no evidence of either environmental
damage in the area around the site or contamination of Ox
Creek at levels likely to be associated with risks to
wildlife. The USFWS1 study did not include the adjacent 11-
acre wetland. Therefore, the selected source control remedy
also does not address the adjacent 11-acre wetland. Proceeding
with the recommended source control remedy, however, will help
minimize future migration of contaminants to the 11-acre
wetland. If, based upon the results of surface water and
sediment samples collected in December 1988, it is determined
that there is a need to remediate the wetland, a subsequent
operable unit will be undertaken.
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8
A long-term monitoring program will be implemented at the
completion of the remedial action to evaluate changes should
they occur. The long-term monitoring, program will consider the
installation of additional wells, including bedrock wells.
Based upon the results of the monitoring program, sampling of
the residential wells and the deeper aquifer would be
performed, if warranted. Construction and post-construction
air monitoring will be performed. This may include, but is not
limited to, pre-construction air monitoring and/or analyses to
further delineate areas of the site requiring covering.
SUMMARY OF SITE CHARACTERISTICS
Soil
The primary sources of contamination at the Clothier Disposal
site were the approximately 2200 drums of hazardous substances
dumped on the site in the early to mid-1970s. Many of these
drums leaked, were broken open, or were drained onto the
ground. All of the drums have now been removed from the site.
During the repacking and staging of the drums, visibly
contaminated surface soil was excavated and consolidated to
form a soil pile. This soil pile has also been removed from
the site.
Soil contamination characterization is based upon 36 soil
boring/sampling locations collected by URS and Ebasco in
October 1987, January 1988, and February 1988. These samples
were analyzed for the full range of compounds specified in the
target compound list (TCL) .
The only source material remaining at the site is residual low-
level contaminated soil in the areas where drums were disposed .
Six drum pile/disposal areas were identified on the site.
Other source areas include the former lagoon and drainage
pathways leading from the site into the wetland.
Figure 3 illustrates the waste disposal areas on-site, and
Figure 4 shows the principal area of soil contamination.
ile No. 1
At Drum Pile No. 1, TCL volatile organic contamination in the
soil extends to a depth of at least 20 feet. The maximum
concentration of total volatile organic (TVO) was 100,162
ug/kg, detected in the 3-5 feet sample at location 16E (see
Figure 3). The primary constituent was xylene (100,000
ug/kg) .
TCL semi-volatile organic contamination also extends to a
depth of at least 20 feet. The maximum concentration of total
TCL semi-volatiles was 8,682 ug/kg, found in the 3-5 feet
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sample at location 16E. Primary semi-volatile constituents
include phenol (1,300 ug/kg), naphthalene (3200 ug/kg) , and di-
n-butyl phthalate (1500 ug/kg) . Carcinogenic Polynuclear
Aromatic Hydrocarbons (CPAHs) were also detected at
concentrations ranging from 420 to 580 ug/kg. The maximum
concentration of PCB Aroclor 1242 was 2,700 ug/kg, detected in
the 13-15 feet samples at location 16E.
Pile No. 2
At this location, the deepest volatile organic contamination
was detected in the 8-10 feet sample at location HE (see
Figure 3) . The maximum TVO concentration was 174 ug/kg,
detected in the 3-5 feet sample at location 10. Primary
volatile contaminants were acetone and methylene chloride at
maximum concentrations of 160 and 31 ug/kg, respectively.
The deepest semi-volatile contamination was also found in the
8-10 foot sample at location HE. The maximum concentration
was 26,660 ug/kg (total semi-volatiles) , detected in the 3-5
feet sample at location HE. Primary constituents include
phenol (12,000 ug/kg), 4-methylphenol (2,700 ug/kg), 2,4-
dimethylphenol (2,300 ug/kg), and bis (2-ethylhexyl) phthalate
(8,000 ug/kg). CPAHs were detected at a concentration of 541
ug/kg in the 3-5 feet sample at location 11.
PCB contamination was detected in one sample, in the 3-5 feet
interval at location HE. A concentration of 720 ug/kg of
Aroclor 1242 was reported.
Disosal Site No. 2
At Drum Disposal Site No. 2, volatile organic contamination
extends to a depth of at least 10 feet. The maximum
concentration of total volatiles was 170 ug/kg (acetone) ,
detected in the 3-5 feet samples at location 13 (see Figure 3) .
Semi-volatile organic contamination also extends to a depth of
at least 10 feet. The maximum concentration of total semi-
volatiles was 6,000 ug/kg, detected in the 3-5 feet sample at
location 13. Principal semi-volatile contaminants at 3-5 feet
were bis (2-ethylhexyl) phthalate (5,700 ug/kg) and phenol.
CPAHs at a concentration of 880 ug/kg were detected at location
15 (3-5 feet sample) .
PCB contamination was detected in one soil sample only. The 0-
2 feet sample at location 13 contained 120 ug/kg of Aroclor
1242.
Drum Pile No. 3
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10
At this location, volatile organic contamination extends to a
depth of at least 10 feet. The maximum TVO concentration was
510 ug/kg, detected in the 3-5 feet sample at location 9 (see
Figure 3). The primary constituents were xylene (240 ug/kg),
ethylbenzene (82 ug/kg at 0-2 feet), acetone (110 ug/kg at 3-5
feet) and methylene chloride (160 ug/kg at 0-2 feet) .
Semi-volatile organic contamination extends to a depth of at
least 15 feet. The maximum concentration of total semi-
volatiles was 7,170 ug/kg, detected in the 0-2 feet sample at
location 8. Principal semi-volatile contaminants were N-
nitrosodiphenylamine (5,400 ug/kg) and bis (2-ethylhexyl)
phthalate (780 ug/kg). CPAHs were detected at nearby location
7E, in the 13-15 feet sample at a concentration of 1,330 ug/kg.
PCB contamination was detected in only one soil sample, the 8-
10 feet samples at location 9E. The concentration of Aroclor
1242 was 360 ug/kg.
Drum Pile No. 4
Volatile organics were not detected at this location. Semi-
volatiles were detected in the 0-2 feet sample only, at a
concentration of 360 ug/kg. The two semi-volatile contaminants
detected were phenol (130 ug/kg) and bis (2-ethylhexyl)
phthalate (230 ug/kg). PCB Aroclor 1242 were also detected in
the 0-2 feet sample at a concentration of 240 ug/kg. PCBs were
not detected in the 3-5 feet sample. CPAHs were not detected
in this area.
Former Lagoon
An area designated as the Former Lagoon is located near Drum
Pile No. 4 in the southern portion of the site (see Figure 3).
Both volatiles and PCBs were below detection limits in the 0-2
and 3-5 feet samples at location 5. Semi-volatiles were
detected in the 0-2 feet sample only. A concentration of 590
ug/kg total semi-volatiles was reported. Phenol (360 ug/kg)
and bis (2-ethylhexyl) phthalate (230 ug/kg) were the only two
semi-volatile contaminants detected.
Drum Disposal Site No. 1
Both volatiles and PCBs were below detection limits in the 0-2
and 3-5 feet samples from location 18. A concentration of 730
ug/kg total semi-volatiles was detected in the 0-2 feet sample.
The semi-volatile PAH contaminants fluroanthene and pyrene were
detected at concentrations of 290 ug/kg and 220 ug/kg, respec-
tively. CPAHs were detected at a concentration of 220 ug/kg.
Semi-volatiles were not detected in the 3-5 feet sample.
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11
Other Areas
In addition to those areas associated with actual drum disposal
or the removal activities, contaminated soil was found along
drainage routes leading from the site to the wetland. Two
areas were found to contain relatively high concentrations:
- Location 24E (receives drainage from the Drum Pile No. l
area): Total semi-volatile organic concentrations
ranged from 7,160 to 19,049 ug/kg. CPAH concentrations
were below detection limits. PCB concentrations ranged
from 400 to 2,500 ug/kg.
- Locations 14 and 15 (at the mouth of the swale that
drains much of the central portion of the site):
Maximum total semi-volatile concentrations range from
1,288 to 1,780 ug/kg. CPAH concentrations were 880
ug/kg in the 0-2 feet sample at location 15, below
detection limits in other samples. PCBs were also below
detection limits. The highest concentrations of barium
(342 mg/kg) and chromium (35 mg/kg) were detected in 3-5
feet at location 14.
Groundwater
Groundwater quality samples were collected in January 1988 from
the 10 monitor wells installed on or adjacent to the site, and
were subjected to complete TCL analyses. The following
conclusions were drawn from these data:
- Volatile organics were the most prevalent
contaminant and were detected in 9 of 10 wells;
semi-volatiles were detected in 3 wells. The most
common organic contaminants were methylene chloride
and bis (2-ethylhexyl) phthalate. Both of these
contaminants are common laboratory contaminants.
- Volatile organic chemicals of concern were identified as
TCE and PCE; organic contamination was restricted
largely to the shallow wells completed in the fine sand
and silt unit. Wells in the vicinity of Drum Piles
Nos. 1 and 2 and at the mouth of the swale displayed the
maximum concentrations and/or the highest number of
contaminants detected in the wells. TCE concentrations
were 1.2 ug/L (CBW-3), 1.5 ug/L (CBW-8) and 18 ug/L
(CBW-4S). PCE was detected in only two wells, CBW-3 and
CBW-8, at concentrations of 2.3 and 24 ug/L,
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12
respectively.
Inorganic contamination in site monitoring veils
included cadmium, chromium, and manganese at
concentrations above those detected in the off-site
wells CBW-1S and CBW-1D. These wells are completed in
the sand and gravel unit and may not actually represent
true background at the site. Also, it is believed that
the presence of turbidity in the groundwater samples
may have artificially inflated the level of contami-
nation present. A second round of groundwater samples
were collected in December 1988 to confirm the results
of the first round.
Water and Sediment
Sampling was conducted by the USFWS to determine whether
hazardous substances from the site had contaminated Ox Creek.
Water, sediment, fish, small mammals, and vegetation were
collected and submitted for residue analysis to assess the
impact of contamination in the Ox Creek ecosystem. The study
found no evidence of either current environmental damage in the
area around the site or contamination of Ox Creek at levels
likely to be associated with risks to wildlife.
The USFWS' study did not include an 11-acre wetland located
adjacent to the site. This area was sampled by Ebasco in
December 1988.
SUMMARY OF SITE RISKS
For the purpose of risk assessment, soil samples at the
Clothier Disposal site were arranged into three groups. The
surface soil group includes all samples at a depth from 0-2
feet as well as the six composite samples collected. A second
grouping includes unsaturated soil samples, (i.e., all soil
samples above the water table on the site). The third group,
the saturated soil samples group, consists of soil samples from
below the water table.
Chemicals were determined to be site-related if they were
present in environmental media at above-background
concentrations and/or could be related to past operations at
the site. Chemicals which were detected in less than 5 percent
of the samples collected for a specific medium were not
considered to be site-related chemicals of concern unless they
were known to be present in the original waste based on
historical site information.
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13
To estimate background at the site, the concentration of
inorganic chemicals in site=related samples were compared to
ranges of concentrations from both upstate New York and from
the eastern United States B horizon soil ranges. Contaminant
concentrations present within either of these background
ranges, and usually both ranges, were considered to be present
at naturally-occurring levels.
Surface Soils
Numerous organic chemicals were detected in the 28 surface soil
samples collected from the site. Seven chemicals were detected
in less than 5 percent of the samples. One of these infre-
quently detected chemicals, acenaphthene was evaluated as
components of the non-carcinogenic PAH group. Tetrachloro-
ethene and toluene were, likewise, detected only once.
Nevertheless, these two volatile organic compounds were found
in groundwater samples, indicating site-relatedness and were,
therefore, included in the evaluation.
Inorganic chemicals of concern are silver, cadmium, selenium,
and thallium.
Unsaturated Soils
Of the organic chemicals found in the unsaturated soil samples,
17 chemicals were detected in less than five percent of the
noncarcinogenic PAHs. Although anthracene was detected in only
one of the 60 samples, it will be considered further as a
component of the noncarcinogenic PAHs. Tetrachloroethene,
trans 1,2- dichloroethane, and 1,1,1,-trichloroethane were
likewise detected in less than five percent of the samples.
These chemicals, however, were detected in groundwater samples,
indicating site-relatedness and, therefore, were included in
the evaluation.
Identical inorganic chemicals of concern, namely, silver,
cadmium, selenium, and thallium were found in the unsaturated
soils as in the surface soils.
Saturated Soils
Because no direct exposure scenarios with these saturated soils
exist, no chemical of concern was selected for quantification
of risk.
Groundwater
There are 10 monitoring wells at the Clothier Disposal site.
Groundwater standards were reviewed to ensure that chemicals
that exceed these standards were not being eliminated from
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14
further consideration in the risk assessment based on
background considerations .
All organic chemicals detected in groundvater samples, except
methylene chloride, were evaluated in this assessment.
Methylene chloride was found in low concentrations and it is
frequently a laboratory contaminant.
Site-related inorganic chemicals of concern are cadmium,
chromium and manganese.
All chemicals of concern are summarized by area and medium in
Table 1.
Mr
Surface soils at the site are not completely covered by
vegetation. Wind entrainment of dust particles is a potential
pathway for inhalation.
Exposure Assessmen
Exposure scenarios are developed for both current-use condi-
tions and potential future-use conditions. The future-use
scenario addresses plausible development uses of the land and
considers what risk may be associated with that use of the land
assuming no cleanup of site contamination.
For each exposure scenario, two exposure cases, an average and
a maximum case, were developed.
Exposure Under Current Land-Use Scenarios
Soil Exposure Currently, the Clothier Disposal site is used
for disposal of debris, namely, abandoned vehicles. The site
is surrounded by farmland and the nearest residences are
approximately 3/4 to one mile away. Approximately 160 people
are reported to live within one mile radius.
However, the site is not adequately fenced and provides no
barrier to either the present owner or to trespassers.
Therefore, exposure to the current owner or to trespassers is
possible, and was considered in this assessment.
Air Exposure Surface soils at the site are not completely
covered by vegetation. Therefore, wind entrainment of dust
particles is a potential pathway for inhalation of
contaminants.
Groundwater Exposure The shallow aquifer is not currently
used in the area as a source of water for any type of use.
Nearby residents to the south, east, and west of the site are
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15
reported to use private groundvater wells as a source of
drinking water, but these wells are in an aquifer other than
the aquifer where contamination was found at the site.
Groundwater from the site flows to the west, towards Ox Creek.
Based on the direction of groundwater flow, wells to the east
and south are upgradient. Furthermore, discharge to the creek
is likely to intercept contamination before it can reach wells
west of the creek. This will be confirmed by long-term
monitoring.
Consequently, no groundwater exposure pathways are believed to
exist under the current-use scenario.
Surface Water Exposures Surface water may be contaminated by
discharge of contaminated groundwater from the site and/or
overland flow of contaminants from the site. These contam-
inants can migrate into the wetland and into Ox Creek, which is
used for fishing. The Oswego River, which the creek joins
about 2.5 miles downstream of the site, is the source of
drinking water for the Town of Fulton. The USFWS studied the
effects of contamination at the Clothier Disposal site on the
natural resources of the area. The USFWS study included the
sampling of surface water in Ox Creek and determined that
contaminant levels were not above background in Ox Creek. The
11-acre wetland located adjacent to the site was not investi-
gated by the USFWS. This area was sampled by USEPA in
December 1988.
The primary effects of stream contamination, if it occurs, are
likely to be environmental, not human health. This is because
the stream is not used as a drinking water source, and because
dilution by several orders of magnitude occurs between the
creek and the Oswego River, which feeds wells used by the Town
of Fulton for water supply. Therefore, surface water exposures
will be considered in the environmental assessment only.
Exposure Under Future-Use Scenario
Because the site is in a rural agricultural area, the most
likely future-use scenario that might be associated with
significant health risk is continued use by the current owner
for the disposal of debris, including abandoned vehicles, or
the building of homes on the site.
Soil Exposure To estimate risks that might be associated with
direct contact with soil, current concentrations of chemicals
of concern in soil were assumed to remain in the future.
Air exposure Air exposures similar to those considered in the
current land-use scenario are possible if the land is used for
residences. In addition, long-term exposure to vapors
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16
accumulating in the basement is possible if residences are
built on the site.
Groundvater Exposures The contaminated groundwater aquifer
has poor flow characteristics relative to other aquifers in the
area, making it unlikely that it would be used as a drinking
water source. However, since it is conceivable that it could
be used as a water supply, the possible future use of the
contaminated groundwater is considered.
Table 2 lists ARARs for the chemicals of concern in
groundwater at the Clothier Disposal site, and the geometric
mean and maximum concentration values currently detected in the
site's groundwater. Geometric mean concentration values never
exceed federal ARARs for those chemicals with ARARs.
of Risk Characterization
Current-use scenarios for the plausible maximum case were not
associated with any excess cancer risks greater than the 2xlOE-
6 for direct contact to adult trespassers. Future lifetime
residential use of the site for the plausible maximum case is
associated with a 3xlOE-5 cancer risk from direct lifetime
contact with soils at the site. These excess cancer risks are
primarily due to Aroclor 1242 and carcinogenic PAHs.
While some of the maximum concentrations of the contaminants
marginally exceed ARARs, the geometric mean values never
exceed ARARs. Excess cancer risk associated with lifetime use
of groundwater as a source of drinking water is 7xlOE-6 for
the average and 5xlOE-5 for the plausible maximum case, due
primarily to tetrachloroethene and trichloroethene . This
drinking water scenario is also associated with a total hazard
index of 5 for the average exposure case and 10 for the
plausible maximum case, due primarily to cadmium.
Cleanup Levels to Reduce Risks
In evaluating remedial alternatives, the issue of the extent to
which soil would need to be excavated and disposed of or
treated to reduce risks to specific target levels is crucial.
Table 3 summarizes the soil cleanup levels required to achieve
the various lifetime cancer risk levels; current-use scenario.
Table 4 summarizes the soil cleanup levels required to achieve
the various lifetime cancer risk levels; future-use scenario.
Determination of Contamination Area and Volumes
There are no directly applicable cleanup regulations pertaining
to the levels of PCBs and CPAHs found in soil. A health-based
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17
risk assessment must be utilized to determine the cleanup
levels.
Tables 3 and 4 include the health-based cleanup levels for
CPAHs. However, a comparison to background levels should be
made for CPAHs. The health-based cleanup levels are in some
cases much lower than background. As a result, it would be
realistic to set the soil cleanup levels for these compounds at
background. For the Clothier Disposal site, background would
be between 20 ppb to 260 ppb.
It should be noted that for the CPAHs, the contract-required
detection limits (CRDLs) required under the regular analytical
services of the USEPA Contact Laboratory Program for the
analysis of samples from Super fund sites are 330 ppb for each
CPAH. At this level, the plausible worst-case risk would be
about 2X10E-7 for the current use scenario (direct contact) or
3xlOE-6 for the future-use scenario. These risk levels could
be considered protective of human health and the environment.
Therefore, the clean-up level of CPAHs could be set at 330 ppb.
By comparing this cleanup level with CPAH-contaminated sample
points, five areas have been identified as contaminated above
this level. These areas, as depicted in Figure 5, will be
considered for remediation.
The Toxic Substances Control Act (TSCA) PCB Spill Cleanup
Policy (40 C.F.R., Part 761, Subpart 6) should be considered in
the cleanup of PCBs in soil. This policy sets a PCB cleanup
level of 10 ppm. The placement of a one-foot soil cover over
the PCB-contaminated soil would be consistent with the TSCA PCB
Spill Cleanup Policy.
As depicted in Figure 5, the highest PCB contamination on-site
that poses a potential risk due to direct contact is 2.5 ppm
at surface sample point 24E. Accordingly, there would be no
requirement for remediation if the TSCA PCB spill cleanup
standard of 10 ppm is adopted. The corresponding plausible
worst-case lifetime cancer risks, based on the health-based
risk assessment, for direct contact and incidental ingestion of
on-site PCB contaminated soil are lxlOE-5 for adults
trespassing and 2xlOE-5 for adults residing on the site.
Since remediation would not be required based upon TSCA, a PCB
"cleanup level" of 1 ppm has been assumed. Cleaning PCBs in
soil down to 1 ppm represents a plausible worst-case risk from
direct contact of 7xlOE-6 for the future-use scenario and below
4X10E-7 for the current-use scenario.
By comparing this 1 ppm PCB cleanup level to the RI results,
two areas, sample points 16E and 24E, with PCB concentrations
above this "cleanup level" are identified. One area (sample
point 16E) contains 2.7 ppm of PCBs at 13-15 feet below the
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18
surface. It is unlikely that contaminants at such depth would
pose significant direct contact risk to any unintentional
intruder.
The remaining area has PCBs at the 0-5 feet level. Therefore,
cleanup down to 5 feet below the surface of soil is considered
responsive to the remedial action objectives and protective of
human health and the environment. The five contaminated areas
identified above for both PCBs and CPAHs, are listed below:
AREA PCBs ppm CPAHs ppm
24E 2.5 0
11 0 0.5
15 0 0.9
16 0 0.6
17 0.2 0.6
In order to derive a reasonable volume of soil for evaluating
various remedial alternatives, a circle of 60 feet in diameter
encircling each sample point that residual contamination was
detected is considered large enough to adequately cover the
potentially contaminated area.
Based on the criteria discussed above, a volume of
approximately 2500 cubic yards of soil is calculated. This
volume will be used to formulate and prepare cost estimates for
the alternatives.
DOCUMENTATION OF SIGNIFICANT CHANGES
There are no significant changes from the preferred alternative
presented in the PRAP.
DESCRIPTION OF ALTERNATIVES
Approximately 2,200 drums and approximately 300 cubic yards of
highly contaminated surficial soil have been removed from the
site. The levels of soil contamination on-site present risk
levels which are in an acceptable range. The alternatives
evaluated below address the residual soil contamination
currently on-site.
A total of ten alternatives were considered for remediating the
site. They are as follows:
1. No Action
2. Limited Action
3. Excavation and off-site Disposal of Residual Contamination
4. Installation of a Soil Cap
5. On-site Thermal Oxidation of Residual Contamination
6. On-site Solidification and Stabilization of Residual
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Contamination
7. Installation of a Resource Conservation and Recovery Act
(RCRA) cap and leachate collection with off-site leachate
treatment
8. Installation of a RCRA cap and leachate collection with on-
site leachate treatment
9. Bioreclamation
10. Vitrification
Alternative 7, the installation of a RCRA cap and leachate
collection with off-site leachate treatment, and Alternative 8,
the same as Alternative 7 but with on-site leachate treatment,
were eliminated in the initial screening. This was because the
ROD does not address the groundwater, and because leachate
collection is inappropriate for the site due to the low
hydraulic conductivity of the clayey silt soil.
The poor hydraulic conductivity of the clayey silt soil present
on-site will not allow water, microorganisms, nutrients,
oxygen, or mobilized contaminants to be moved with ease.
Therefore, Alternative 9, bioreclamation, was eliminated from
further consideration.
Alternative 10, vitrification, was also eliminated during the
initial screening, since the moisture content of the on-site
soil is reported to contain from 23-28% water. The
vitrification process is reported to be applicable to soils
with a maximum moisture content of only 10%.
Of the ten remedial alternatives, six were retained for
detailed analysis.
Alternative 1 - No Action
This alternative is included to serve as a "baseline" case
against which the other alternatives are evaluated. Under this
alternative, no remedial action would be taken.
As required by SARA, a program of periodic monitoring would be
implemented for 30 years to evaluate changes in site conditions
with time. Monitoring would consist of semi-annual sampling of
the ten existing monitoring wells. In addition, four surface
soil samples would be collected. Two of the soil samples would
be collected from the wetlands. Water samples would be
analyzed for TCL of chemicals while the soil samples would be
analyzed for PCBs and CPAHs. Air monitoring would also be
performed. At least annual monitoring would be conducted for
the first 5 years. The long-term monitoring program would
consider the installation of additional wells, including
bedrock wells. Based upon the results of the monitoring
program sampling of the residential wells and the deeper
aquifer would be performed, if warranted.
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Alternative 2 - Limited Action
Under this alternative, actions would be limited to regrading
the site by placing approximately one foot of clean fill,
brought to the site from an off-site source, over contaminated
areas, supplemental soil sampling to define the areas of
contamination, regrading and revegetating portions of the site
to limit surface runoff towards Ox Creek and neighboring
properties, and installing rip-rap, as needed, on the
embankment sloping toward Ox Creek and its wetland to limit
surface soil erosion. To the extent possible, institutional
controls would be implemented to prevent the utilization of the
underlying groundwater, the future development of the site for
residential use, or any use involving excavation of the site or
significant disturbance of the soil cover. Any institutional
controls, including, without limitation, deed restrictions or
easements, would be consistent with New York State law.
A program of long-term monitoring (30 years) would be
undertaken to evaluate changes in the ground- water, soil, and
air with time. In addition, sediment and surface water samples
would be collected from the adjacent wetland to monitor its
condition. At least annual monitoring would be conducted for
the first 5 years. The long-term monitoring program would
consider the installation of additional wells, including
bedrock wells. Based upon the results of the monitoring
program, sampling of the residential wells in areas neighboring
the site, and the deeper aquifer would be performed, if
warranted. Construction and post-construction air monitoring
would be performed. This would include, but not be limited to,
pre-construction air monitoring and/or analyses to further
delineate areas of the site requiring covering.
Alternative 3 - Excavation and Off-Site Disposal,
This alternative involves excavating 2500 cubic yards of
residual contaminated soil, placing the excavated material in
trucks and hauling the material off-site to a RCRA hazardous
waste landfill.
Upon completion of the excavation, clean soil would be
backfilled and the site would be regraded to promote drainage.
The site would be revegetated to prevent soil erosion.
Long-term monitoring would not be included with this
alternative. A confirmatory monitoring program, however, would
be undertaken to evaluate the effectiveness of the remedy.
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Alternative 4 - Installation of Soil Cap
The major component of this alternative consists of consoli-
dating residual contaminated soil into a soil pile. Then an
approximately one-acre soil cap would be constructed of two
feet of top soil overlying one foot of sand (for drainage).
The cap would be graded vegetated, and rip-rap would be
installed, as needed, along the embankment to minimize erosion.
Long-term monitoring would be included with this alternative.
Alternative 5 - On-Site Thermal Oxidation
This alternative consists of excavating 2500 cubic yards of
residual contaminated soil, preprocessing the soil to meet the
thermal oxidation feed requirements, and then feeding the soil
to a mobile thermal treatment unit brought to the site. The
treatment unit would be equipped with an afterburner to destroy
organics vaporized from the soil, and a scrubber to wash and
cool the combustion air before being discharged to the
atmosphere. The bottom ash and fly ash from the incinerator
would be tested to assure that they meet the appropriate
leaching standard and, finally, when judged acceptable, used as
backfill in the excavated areas.
Long-term monitoring would not be included with this
alternative. A confirmatory monitoring program, however, would
be undertaken to evaluate the effectiveness of the remedy.
Alternative 6 - On-Site Solidification and Stabilization
This alternative consists of excavating 2500 cubic yards of
residual contaminated soil, mixing the soil with chemical
reactive additives and a cementitious grout compound, and
permitting the mixture to solidify. This would effectively
seal the waste in a hard monolithic matrix. The solidified
matrix would be disposed of on-site below the freeze-thaw
line, and would be covered with clean soil to avoid direct
contact.
The blending and mixing of the soil with the additives and
grouting materials would be performed in an on-site mobile
processing unit.
Long-term monitoring would be included with this alternative.
SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES
The remedial action alternatives described above were
evaluated in accordance with the requirements of the NCP and
CERCLA. Nine criteria relating directly to the factors
mandated in Section 121 of CERCLA including subsection 121
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(b)(1)(A-G) and DSEPA's Interim Guidance on Selection of Remedy
(December 24, 1986 and July 24, 1987) were utilized for this
evaluation, and are as follows:
- Short-term effectiveness
- Long-term effectiveness and permanence
- Reduction of toxicity, mobility, or volume
- Implementability
- Cost
- Compliance with applicable or relevant and appropriate
requirements (ARARs)
- Protection of human health and the environment
- State acceptance
• Community acceptance
Short-Term Effectiveness
With the completion of the removal actions, which resulted in
the removal of all the drums and the majority of the visibly-
contaminated surface soils, the on-site risks have been reduced
to a range generally considered protective of human health.
Since there are no residents on-site, current risks are related
to trespassers and the current owner.
The risk assessment indicated that direct contact with the
residually contaminated soil on-site is the most important
route of human exposure. The plausible maximum lifetime cancer
risk estimates for direct contact and ingestion of on-site
soils by adults trespassing on the site was 2xlOE-6. With this
in mind, all six alternatives would be an effective method of
risk control. Alternative 1, No Action, would offer the least
degree of effectiveness, but would still achieve protection of
public health and the environment.
Relative risk to on-site workers is dependent on the volume of
material handled. Since Alternative 2 involves limited on-
site remedial action, this concern would be minimal. For
Alternatives 3 and 4, which require excavation, the potential
risks are those associated with dermal contact with the
contamination media. Alternatives 5 and 6 involve treatment in
addition to excavation. The risk associated with these
alternatives would be potentially greater than the previous
alternatives because of the additional handling of the
materials. The risk associated with these alternatives would
be significantly reduced, though, through the use of proper
personnel protection equipment.
The time required to implement each alternative is between one
and two years. Except for Alternative 1, the alternative
requiring the least amount of time to implement would be
Alternative 2.
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23
Lona-Term Effectiveness and Permanence
The drum and contaminated soil removal actions described above
offer a high degree of permanence under current conditions.
The one-foot soil cover of Alternative 2 would mitigate against
direct contact or ingestion of the residually contaminated
media. Although this alternative is less permanent than the
other alternatives, since the residual contamination that is
present on-site is below health-based levels, Alternative 2
still affords a high degree of effectiveness and permanence.
Alternatives 3 and 5 would permanently remove the contaminated
media from the site.
Alternative 4, the installation of a soil cap, although less
permanent than other alternatives, effectively mitigates the
risk associated by direct contact with the contaminated media.
The long-term effectiveness is dependent on maintenance of the
cover and the adherence to imposed land-use restrictions. The
additional cost associated with this alternative as compared to
Limited Action provides somewhat greater permanence due to
greater stability of a thicker covering of soil. Risk levels
of the two alternatives are the same.
Alternative 6, which is a highly effective alternative, offers
a permanent solution to the contaminant problem by immobilizing
the contaminants in the soil matrix. Because the matrix would
be redeposited on-site under this alternative, long-term
effectiveness is dependent on inspection of the site and annual
monitoring of the affected media.
Reduction in Toxicitv. Mobility or VQ fTMVi
Alternatives 1 and 2 provide no reduction in the current
residual contaminant toxicity, or volume. Alternative 2 would
reduce the residual contaminant mobility. The current risk
associated with this site is within the range recommended by
USEPA.
Alternative 3, excavation and off-site disposal, would effec-
tively reduce the contaminant TMV from current levels on-site.
Alternative 3, however, achieves this goal by moving the
contaminated media to another location (off -site landfill)
where its mobility is reduced but its toxicity and volume are
retained.
Alternative 5, on-site thermal treatment, would effectively
reduce on-site contamination TMV.
Alternative 4 would reduce the contaminant mobility somewhat
-------
24
through the use of a soil cover, but toxicity and volume would
remain the same.
Alternative 6 would significantly reduce the contaminant
toxicity and mobility. The solidified soil volume would
probably increase.
Implementability
All components of Alternatives 1, 2, and 3, and most components
of Alternatives 4 and 5, utilize relatively common construction
equipment and materials. Little construction difficulty should
occur with any of the alternatives.
All of the technologies under consideration are proven and
demonstrated reliable in achieving the specified process
efficiencies and performance goals. Under Alternative 3,
finding an off-site disposal facility that is in compliance
with RCRA may be difficult. Solidification, while not fully
demonstrated, has undergone extensive pilot testing, and would
likely achieve the specified process efficiency.
Cost
The Limited Action alternative is the least costly alternative
after the no-action alternative, with a total present worth of
$500,000. The present worth costs of all alternatives are
shown in Table 5.
Alternative 3, excavation and off-site disposal of contaminated
soil, has a present worth of $1,633,000. The additional cost
of this alternative to that of the limited action alternative
reduces the already acceptable level of on-site risk and
increases the short-term risk due to excavation and
transportation activities.
Alternative 4, the installation of a soil cap, has a present
worth of $666,000.
Alternative 5, on-site thermal incineration, is the most costly
alternative with a present worth value of $3,062,000.
Alternative 6, on-site solidification, has a present worth of
$1,691,000, about the same as the cost of Alternative 3,
excavation and off-site disposal. However, present risk
levels are already considered to be in an acceptable range so
that the additional cost for treatment does not bring any
substantial lowering of the risk level.
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25
Compliance with ARARs
All technologies proposed for use in Alternatives 2 through 6
can be designed and implemented to satisfy all action- and
location-specific ARARs. Chemical-specific ARARs were used to
define cleanup or remediation levels.
There are no federal or New York State ARARs for soil.
Federal and New York State ARARs for groundwater are marginally
exceeded. However, considering that there are no residents or
wells currently on-site and that the shallow aquifer is a low
yielding aquifer and thus is unlikely to be used as a water
supply. Institutional controls would be employed for the
alternatives which allow residual contamination to remain on-
site, to prevent the utilization of the underlying aquifer
(e.g., through the drilling of wells in the shallow aquifer).
As noted previously, this ROD does not address groundwater
contamination .
The implementation of the Limited Action alternative would
require compliance with action and location-specific ARARs,
i.e., Occupational, Safety and Health Regulations, and
attention to floodplain and wetland regulations, since the site
is included in a floodplain and is adjacent to a designated
wetland.
Overall Protection o n Health and the Environment
Alternative 1, No Action, provides no reduction in risk to
humans and the environment. However, present risk levels are
considered to be in an acceptable range.
Alternative 2, Limited Action, provides additional protection
over No Action by covering the existing areas of low-level
contamination with a 1-foot covering and restricting future
development of the site.
All alternatives are protective of human health and the
environment. Alternatives 3, 4, 5, and 6 all achieve the same
degree of health-based risk level. However, Alternatives 5 and
6 have a higher degree of confidence because treatment
processes are considered irreversible.
STATE ACCEPTANCE
NYSDEC concurs with EPA's selection of Alternative 2 -Limited
Action.
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26
COMMUNITY ACCEPTANCE
The community has expressed concern over the use of
incineration, which was identified as the preferred remedy
previously (but not in the PRAP). However, the analytical data
upon which the remedy selection was based was later determined
to be invalid. Incineration is no longer considered
appropriate for this site. The community also expressed a
preference for bioreclamation in 1987. This alternative has
been ruled as being technically infeasible for this site.
The community has expressed two principal concerns, namely:
1) Delaying the signing of the ROD until the Fulton Safe
Drinking Water Action Committee for Environmental Concerns,
Inc. (FSDWAC), receives a Technical Assistance Grant (TAG) from
USEPA and has the opportunity to have a technical assistant
review and comment on the RI/FS documents; and
2) Investigating the adjacent 11 acre area of the Ox Creek
wetland, which was only recently sampled, before signing a ROD
for the source control remedy.
These concerns are addressed as follows:
1) In response to a request from representatives of FSDWAC, the
RI/FS comment period was extended from twenty-one days to sixty
days to allow sufficient time to perform a technical review of
the RI/FS and the PRAP.
During the public comment period, a public meeting was held to
explain the results of the study, to discuss the preferred
remedy, and to solicit public comments and concerns.
During the course of the project, USEPA and NYSDEC have
conducted a significant public outreach program. As part of
this program, a number of meetings and informal discussions
with the public and FSDWAC have been conducted to discuss
technical issues associated with the Clothier Disposal site.
USEPA is committed to citizen involvement in the Superfund
process. USEPA is equally committed to remediating sites as
expeditiously as possible. To delay the selection of the
remedy for the site until after a TAG has been awarded, a
technical advisor has been selected, and a technical review of
the documentation by the technical advisor has been completed
would seriously delay remediating the residual contamination at
this site. Instead, USEPA plans to review FSDWAC's application
and award a TAG so that technical assistance may be available
to FSDWAC during the design and construction of the remedy that
EPA selects.
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27
2) The proposed remedy will address residual on-site
contamination, and will virtually eliminate the potential for
any migration of residual contaminants from the Clothier
Disposal site to the adjacent wetland. Therefore, USEPA does
not believe that even if the samples from the wetland show
contamination, it will be necessary to modify the remedy
proposed for the site. However, if the sample results show
that contamination is present in concentrations that will make
remediation of the wetland necessary, this area will be
addressed separately.
THE SET-flCTE.fr REMEDY
The removal actions undertaken by the PRPs and USEPA have lead
to the removal of approximately 2000 drums and the associated
visibly contaminated soil. As a result, only residual soil
contamination remains on-site. The results of a risk
assessment performed for the site lead to the conclusion that
the residual soil contamination currently on-site poses an
acceptable risk to human health.
The selected remedy for the site is Alternative 2, Limited
Action.
This remedy addresses the principal threat at the site, namely
direct contact and ingestion of low level contaminated soil by
trespassers, by covering the contaminated areas with one foot
of clean soil.
The USFWS' study found no evidence of either environmental
damage in the area around the site and Ox Creek at levels
likely to be associated with risks to wildlife. The USFWS1
study did not, however, include the adjacent 11-acre wetland.
Therefore, this source control remedy does not address the
adjacent 11-acre wetland. If, based upon the results of
surface water and sediment samples collected in December 1988
it is determined that there is a need to remediate the wetland,
a subsequent operable unit will be undertaken.
The remedy also does not address the groundwater. Although a
number of federal and state ARARs were marginally exceeded, it
is believed that the presence of turbidity in the groundwater
samples may have artificially inflated the level of
contamination actually present in the groundwater. The
groundwater was resampled in December 1988. If based upon the
results of these samples, it is determined that there is a need
to remediate the groundwater, a subsequent operable unit will
be undertaken.
The major components of the selected remedy are as follows:
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28
- Placement of a one-foot clean soil cover, brought from an
off-site source, over the contamination areas. Sampling will
be performed during the design phase to determine the extent of
the areas of residual contamination requiring covering.
- Regrading and revegetating the site to prevent soil erosion
and minimize surface water runoff towards neighboring
properties, Ox Creek, and the adjacent wetland. The regrading
plan and types of vegetation will be determined during the
design phase, and will be compatible with the wildlife habitat.
- Installing rip-rap, as needed, on the embankment sloping
towards Ox Creek to prevent soil erosion. The extent of the
rip-rap will be determined during the design phase, and will
consider the impact on the wildlife habitat.
- Performing long-term groundwater, soil and Ox Creek sediment
and surface water monitoring to evaluate any changes should
they occur. The long-term monitoring program will consider the
installation of additional wells including bedrock wells.
Based upon the results of the monitoring program, sampling of
the residential wells in areas neighboring the site, and the
deeper aquifer would be performed, if warranted.
- Performing construction and post-construction air monitoring.
This may also include, but it is not limited to, baseline pre-
construction air monitoring and/or analyses to further
delineate areas of the site requiring covering.
- Applying, to the extent possible, institutional controls to
prevent the utilization of the underlying groundwater (e.g.,
through the drilling of wells in the shallow aquifer), the
future development of the site for residential use, or any use
involving excavation at the site or significant disturbance
of the soil cover. Any institutional controls, including,
without limitation, deed restrictions or easements, shall be
consistent with New York State law.
STATUTORY DETERMINATIONS
Section 121 of CERCLA mandates that USEPA select a remedial
action that is protective of human health and the environment,
attains ARARs, is cost-effective, and utilizes permanent
solutions and alternative treatment technologies or resource
recovery technologies to the maximum extent practicable.
Remedial actions in which treatment which permanently and
significantly reduces the volume, toxicity or mobility of a
hazardous substance as a principal element are to be preferred
over remedial actions not involving such treatment.
Based upon the analyses presented herein the following
conclusions are reached:
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29
- Overall Protection of Public Health and the Environment
With the completion of the removal actions, on-site risks to
trespassers and the current owner have been reduced to a
range considered protective of human health. The addition
of a 1-foot covering of clean soil over the contaminated
areas will lower the risk further by limiting direct dermal
contact and ingestion of contaminated soil.
By regrading and revegetating the site, and by installing
rip-rap, as needed, on the embankment sloping towards Ox
Creek and its wetland, soil erosion and surface water runoff
will be limited, thereby protecting the environment.
- Compliance with ARARs
No federal or state regulation specifies soil cleanup levels
for PAHs. The TSCA PCB spill policy governs the cleanup
standards for PCB spills. The policy establishes
requirements for PCB levels at 25 ppm for restricted access
areas and at 10 ppm for unrestricted access areas. The
effective date of this policy was May 4, 1987. Since the
operations of the Clothier Disposal site ceased in 1986,
those requirements would not be applicable, but would
be relevant and appropriate.
The maximum concentration in surface soil samples collected
at the site were less than 2.5 ppm for PCBs. Therefore, this
alternative would meet TSCA requirements.
Groundwater ARARs were marginally exceeded. However, due to
the presence of turbidity in the samples, the sample values
may have been artificially inflated. A confirmatory round of
groundwater samples were collected in December 1988. Should
these results show contamination, groundwater remediation
will be addressed separately in a supplemental RI/FS.
Since limited remedial activity would occur on-site under
Alternative 2, action-specific ARARs pertaining to OSHA
health and safety standards, and federal minimum technical
aid facility requirements would be relevant and appropriate.
Location-specific ARARs concerning protection of wetlands and
floodplains would be relevant and appropriate.
- Utilization of Permanent Solutions and Alternative
Treatment Technologies to the Maximum Extent Practicable
Alternative 2 is considered to be a permanent remedial action
since the concentrations of contaminants remaining on-site
are within ranges which have acceptable risk levels.
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30
Further, contaminant concentrations and related risks will
decrease over time due to natural attenuation of the
contaminants. Although this remedy is not a treatment
technology, it is as effective.
While treatment technologies (Alternatives 5 and 6)
have a greater degree of permanence relative to the Limited
Action alternative, they are not considered necessary since
existing risk levels are already acceptable. There are also
increased short-term risks associated with implementing these
technologies. New York State has concurred that treatment
is not necessary for this site.
During the remedial design phase of the project, informal
consultations would be conducted with the USFWS to comply
with the Endangered Species Act.
Care would be taken during the remedial design phase to
comply with Executive Orders 11988 (floodplains) and 11990
(wetlands).
- Preference for Treatment as a Principal Element
Alternative 2, Limited Action, does not treat the residual
on-site soil contamination. Considering the level of
residual contaminants present on-site, and the fact that the
resulting risk to human health is in a range considered to
be acceptable, the application of treatment technology to
further lower the level of contamination and related risks
does not appear appropriate.
- Cost-Effectiveness
The Limited Action alternative is the least costly of the
alternatives, other than the No-Action alternative, yet
provides acceptable protection of human health and the
environment. .;:.
Summary
In summary, Alternative 2 is the selected alternative. It
is protective of public health and the environment, attains
ARARs, and is cost effective. Because treatment of the
principal threats of the site was found to be unnecessary, this
remedy does not satisfy the statutory preference for treatment
as a principal element of the remedy.
The estimated present worth cost for implementing Alternative 2
is $500,000.
Alternative 2 provides the best balance of trade-offs among the
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31
alternatives, examined in detail, with respect to the nine
evaluating criteria.
-------
APPENDIX 1
TABLES
-------
TABLE 1
CHEMICALS SELECTED AS CHEMICALS OF CONCERN AT THE CLOTHIER SITE
SURFACE SOILS
Acetone
Bie (2-ethylhexyl) phthalate
2-butanon*
Carcinogenic PAHe
4-chloro~3-Mthylphenol
2 , 4-dlaethylphenol
Di-n-butylphthalate
Di-n-octylphthalate
Methylphenole
N-nitroeodiphenylaMine
Non-carcinogenic PAHe
PCB Aroclor 1242
Ph«nol
T«tr«chloro«th«n«
XylmtMi
Cadaivm
Silver
Thallimi
tmSATORATBD SOILS
Bis ( 2-«thyltimyl) phthalata
2-butanon*
Carcinogenic PAHa
l,2-dlchloro«thena (trans)
2 , 4-diMthylphanol
Di-n-butylphthalat«
Di-n-octylphthalate
Methylana chloride
Methylphanols
M-nitroaodiphanylaaine
Non-carcinogenic PAHs
PCB Aroclor 1242
Phenol
1,1, 1-tr ichloroethane
Tetrachloroethene
Toluene
Xylenea
Cateiim
Seleniua
Silver
Thalllua
GROUMDNATER
Bla(2-ethylhexyl)phthalate
1,2-dichloroethene (trana)
1,1, l-tr ichloroethane
Trichloroethene
Tetrachloroethene
Xylenea
ChroniuM
Manganeae
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TABLE 2
COMPARISON OF CONCENTRATION VALUES WITH FEDERAL AND NEW YOR
STATE GROUNDWATER ARARS FOR CHEMICALS OF CONCERN AT THE
CLOTHIER SITE
(all concentrations are in ug/liter)
Chemical
Groundwater
Concentration
Geometric
Mean Maximum
Federal ARARs
New York State ARA.
Proposed
MCL MCLG Standard Guideline
Organics
Bis (2-ethylhexyl)
phthalate
1 , 2-dichloroethene
(trans)
1,1, 1-trichloroethane
Trichloroethene
Tetrachloroethene
Xylenes
4.5
NR
NR
2.7
3.3
NR
6.6
1.6
1.9
18
24
2.3
—
70
200 200
5 0
0
___ ....
— 4,200
10
Inorganics
50
50
50
50
0.7
50
Cadium
Chromium
Manganese
Lead [a]
4.5
36.5
2,541
ND
6.9
58.7
23,800
63.5
10
50
—
50
5
120
—
20
10
50
300
25
--
—
—
—
MCL = Maximum Contaminant Level
MCLG = Maximum Contaminant Level Goal
MR = Not Reported. Chemical was detected infrequently, and the use
of one-half of the detection limit in calculating a mean concentration
that exceeds the maximum reported value. Therefore, a mean will not
be used.
NO = Not determined.
[a] Lead was not chosen as an indicator chemical because its presence
may not be site related. Comparison is provided as a point of
information.
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•OIL CLBMTOV UTOU
oovntcT/XMMTxoM BOUYM
(cumuvr utiD-UM acmaxo)
Clothiar Disposal aita
Oraabj, >«w York
Soil Cleanup
Worst
Av*rag«
10
10
•
*
10'
PCBa 1,566
CPAHs 463
10
-7
157
46
*
*
^ CFAH - carcinoganic polynuelaar
(total)
tie hydrocarbons
* - no elaanup raquirad - cleanup
ttrationa in on-aita aoila
axcaad highaat
-------
SOIL CLMOTOF LEVELS FOE FOB
DXEECT OOVTACT/IIIOESTXOM BOUTS*
(FtJTUBB LAVD-USE SCEXAJLXO)
Clotaiar Disposal cita
•raaby, Bsv York
10
CPAH«J
*
*
10
-5
CPAHs
§56
283
10
CPAHs
•6
28
640
230
10
-7
CPAHs
10
3
64
23
(1)
CPAH • Carcinogsnie polynuclsar
tie hydrocarbons (total)
• » no elaanup raquirad - elaanup Isvals •xeoad highast aaasurad
eoneaatrations la on-sita soils
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32
TABLE 5
ALTERNATIVE COMPARISON FOR COST
Alternative
Capital
Cost
fSxlOOO)
Alt. No. 1 No Action 0
Alt. No. 2 -
Action
Limited 60
Alt. No. 3 - Excavation/ 1,633
Off-Site Soil Disposal
Alt. NO. 4 -
of Soil Cap
Alt. No. 5 -
Oxidation
Alt. No. 6 -
Installation 223
On-Site Thermal 3,062
On-Site 1,418
Total
Annual Present
0/M* Worth
rs/vrl fSxlOOO)
27,000 443
27,000 500
27,000** 1,633
27,000 666
27,000** 3,062
35,000 1,691
Solidification
* O/N Operation/Maintenance and monitoring
** Confirmatory sampling (estimated one-time occurrence)
-------
APPENDIX 2
FIGURES
-------
SOUTH OMNBV MAD
OENERAUZED MAP of OOTHIEH PROPERTY
FIGURE
-------
SITE LOCATION HAP
.a;
-------
WASTE DISPOSAL AREAS
fc-2
-------
•cn*-t
9COJ-M
•CM*-*,
\m\f^
TSSSg
«M«-^TA ••
«PMOX. N.IS. rUMUC
PRINCIPAL AREA OF
SOIL CONTAMINATION
_J
lit
o:
o
C
i
6
M
u
c
o.
50
I
4-JS
-------
CONTAMINATED AREAS ABOVE
THE CLEANUP LEVELS
FIGURE 5
-------
APPENDIX 3
ADMINISTRATIVE RECORD
INDEX
-------
APPENDIX 4
NYSDEC LETTER OF
CONCURRENCE
-------
New York State Department of Environmental Conservation
50 Wolf Road, Albany, Ntw York 12233 .7010
ThofflM C Jertlng
Commtolontr
Mr. William J. Muszynski, P.E.
Acting Regional Administrator
U.S. Environmental Protection Agency RCP 93 1QQQ
Region II UCU40 WOO
26 Federal Plaza
New York, New York 10278
Dear Mr. Muszynski:
Re: Clothier Site (738014)
Record of Decision
The State of New York has reviewed and concurs with the source control
remedy put forth In the Final Record of Decision (ROD) dated December 23,
1988 for the Clothier Disposal Site. The groundwater and adjacent wetland
are not addressed by this remedy and will be the subject of separate
operable units If the sampling conducted 1n December 1988 Indicates a
problem.
The selected remedy calls for placement of one foot of clean soil cover
over the contaminated areas of the s1te;>egrad1ng and revegetatlng the
site to prevent soil erosion and to minimize surface water run-off from the
contaminated areas of the site into Ox Creek and adjacent wetlands;
Installation of rip-rap as needed; long-term monitoring of the remedy,
including additional wells and private water supplies as needed; pre- and
post-construction air monitoring; and potential easements to control future
development of the site.
Design and construction of the remedy must prevent diversion of run-off
onto neighboring farmlands; Include additional soil sampling and air
monitoring to further define the area of the site to be covered; and
further evaluate the extent of rip-rap and type of vegetative cover which
will be conducive to the wildlife habitat.
If you have any questions regarding this matter, please contact
Mr. Michael J. O'Toole. Jr., at (518) 457-5861.
Sincerely,
Deputy Commissioner
cc: R. Tramontane
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APPENDIX 5
RESPONSIVENESS SUMMARY
-------
FINAL
RESPONSIVENESS SUMMARY
CLOTHIER DISPOSAL SITE
REMEDIAL INVESTIGATION/FEASIBILITY STUDY
OCTOBER 5, 1988 PUBLIC MEETING
Town of Granby, Oswego County, New York
by the
New York State Department of Environmental Conservation
and
United States Environmental Protection Agency
January, 1989
-------
Clothier Drum Site
Granby, New York
Responsiveness Summary
A. Overview
The United States Environmental Protection Agency (USEPA) and the
New York State Department of Environmental Conservation (NYSDEC) held
a public participation meeting on October 5, 1988 in the Granby Town
Hall, Granby, New York to discuss the Proposed Remedial Action Plan
(PRAP) for the Clothier Drum Disposal site and the Remedial
Investigations/Feasibility Studies (RI/FS) performed by URS Co., Inc.
and Ebasco Services, Inc., under contract to the NYSDEC and USEPA,
respectively. The selected remedy outlined in the PRAP was based on
the Remedial Investigation/Feasibility Study Clothier, Town of Granby
Oswego County, New York prepared by URS Company, Inc., August 1988 and
Final Supplemental Remedial Investigation Report and final Feasibility
Study, Clothier Disposal Site, Granby, New York, prepared by Ebasco
Services Inc, July 1988. The selected remedy called for:
- placement of a 1 foot clean soil cover, brought from an
outside source, over the contaminated areas
- regrading and revegetating the site to limit soil erosion
and surface water run-off towards Ox Creek and its wetland
- installing rip-rap on the embankment sloping towards Ox Creek
to prevent soil erosion and surface water run-off
- a long term groundwater, soil, and Ox Creek sediment and
surface water monitoring program to evaluate any changes,
should they occur.
Modifications of this remedy occurred as a result of comments and
the final remedy is presented in the Record of Decision (ROD),
December, 1988.
Both RI/FS reports and the PRAP were made available for public
review on September 6, 1988 at the Granby Town Hall, City of Fulton
Public Library, Virginia Gary residence and the NYSDEC Central Office,
with the public comment period ending November 4, 1988.
The selected remedy discussed at the October 5, 1988 meeting was
a radical change from the selected remedy of thermal destruction of
wastes and highly contaminated soils presented at a July 1987 public
meeting. While this change is a result of the determination that
additional soil sampling and surface water data were needed and faulty
laboratory quality assurance and quality control (QA/QC), it does
raise public concern on the adequacy of the selected remedy.
The community, in general, expressed concern about the proposed
remedy for the remaining residual soil contamination because it was
not a permanent remedy; an 11-acre wetland adjacent from the site was
not adequately investigated; and that they desired to obtain a
technical assistance grant (TAG) to retain a technical advisor to
review the information and proposed remedial action prior to the
-------
Issuance of a ROD. It was explained to the people attending the
meeting, that the proposed remedy was to supplement the removal
actions already taken at the site by USEPA and the responsible parties
during which approximately 2000 drums of waste and 200 cubic yards of
highly contaminated soil were removed from the site. Further, it was
explained that the proposed remedy was to address the residual low
level soil contamination which, based on health risk assessment, did
not represent a significant threat to public health. It was also
explained that this was a source control remedy and that if
supplemental investigation of the groundwater and 11-acre wetland site
detected significant contamination, they would be addressed as a
separate operable unit(s). Correspondence from the Steering Committee
of Responsible Parties supports the limited action remedy.
B. Background on Community Involvement
Community interest in the Clothier Drum Site has been extremely
high throughout the RI/FS process and removal actions. Locally,
community officials and private citizens have been active at public
meetings and have routinely corresponded with the NYSDEC and USEPA.
Organized groups include: Granby Town Environmental Board, Neighbors
Organized to Mend Our Rural Environment (NOMORE), Fulton Safe Drinking
Water Action Committee (FSDWAC), and the Central New York Toxics
Coalition. Major concerns of these groups and how USEPA and NYSDEC
addressed them are:
1. Citizen groups all opposed the thermal destruction process
proposed during the July 1987 public meeting and comment
period because of concerns about an insufficient data base
and public safety and health concerns regarding potential
emissions from the thermal destruction process.
Response: Review of the data determined QA/QC problems and the
need to conduct further investigations prior to
selecting a remedy. Additional soil sampling, a
wetland study by U.S. Fish and Wildlife Service, and
resampling of groundwater resulted in the revised
August 1988 RI/FS report prepared by URS Inc. In
addition, USEPA's consultant (Ebasco Services)
prepared a Supplemental RI/FS dated July 1988.
Thermal destruction is no longer recommended.
2. Citizens questioned the adequacy of the September 1988
proposed remedial action as it does not provide a
permanent remedy.
Response: The proposed action supplements the removal of over
2000 drums of waste and over 200 cubic yards of
highly contaminated soil scraped from the site.
While Federal regulations require that preference
be given to permanent remedies, the public health
risks associated with the residual low level soil
contamination were determined to be "not significant"
and the proposed action is considered adequate to
protect public health. The Agency for Toxic
Substances and Disease Registry (ATSDR) supported this
conclusion at the public meeting.
-------
3. Citizens pointed out that the U.S. Fish and Wildlife Study
(USFWS) did not address the 11-acre wetland adjacent to the
site.
Response: The 11-acre wetland was studied in December 1988.
Results will be made available to the public. Delay
of the ROD is not necessary as the proposed remedy
is a source control operable unit. If the sampling
conducted in December 1988 indicates the need for
additional remedial actions for the wetland or
groundwater, remediation will be conducted as a
separate operable unit(s).
4. Citizens requested that issuance of the ROD be delayed
until a local environmental organization obtained a technical
assistance grant (TAG).
Response: The USEPA does not agree that the issuance of the ROD
should be delayed until a TAG is awarded. While a
"letter of intent" to apply for a TAG was submitted
on May 19, 1988, a TAG application was not submitted
until October 27, 1988. To delay issuance of a
selected remedy until a TAG is obtained and a
technical advisor is hired, would seriously delay
remediation of the residual soil contamination at
the site.
5. Several neighboring property owners expressed concern that
remedial alternatives might impact their properties. During
the July 1987 public meeting, air emissions from a thermal
destruction unit or excavation was of concern. During the
October 1988 public meeting, concern was expressed that any
regrading of the site might divert run-off onto neighboring
properties.
Response: Thermal destruction is no longer a selected remedy.
A construction and post construction air monitoring
program has been incorporated into the selected
remedy. Design of the selected remedy will minimize
run-off from the site and avoid diverting additional
water onto neighboring properties.
6. Neighboring residences and the State Health Department
expressed concern that additional sampling of private wells
was not addressed.
Response: The selected remedy has been revised to provide for
additional sampling of private wells neighboring the
site as part of the long term monitoring program, as
warranted. Details of the long term monitoring plan
will be developed after the information from the
December 1988 wetland and groundwater sampling is
evaluated, but may include additional monitoring wells
between the site and potentially downgradient
residences.
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C. Sumnary of Comments Received During Public Comment Period
Comments raised during the public comment period and at the
October 5, 1988 meeting for the September 1988 PRAP, the July 1988
Supplemental RI/FS Report prepared by Ebasco Services and the
August 1988 RI/FS Report prepared by URS Inc., are summarized briefly
below by relevant topic. A summary of comments received for the
July 1987 public meeting and earlier draft RI/FS reports which
recommended thermal treatment are appended to this document for
reference.
Remedial Alternative Preference
1. The proposed remedial action is not a remedy which will
permanently remove the hazardous wastes from the site.
Why wasn't a permanent remedy chosen?
Response: Federal regulations regarding the clean-up of
hazardous waste sites require that the NYSOEC and
USEPA show a preference for permanent remedies.
Given the fact that the levels of contaminants found
on the Clothier site were so low as to not pose a
significant public health risk, the proposed actions
are felt to be appropriate. In addition, more than
2000 drums of waste and over 200 cubic yards of highly
contaminated soil have been removed from the site.
The removal of these wastes constitute a permanent
remedy for these wastes relative to this site.
2. There is an area of wetland, approximately 10-11 acres in
size, which has not been sampled. How can a remedy be
selected which does not address this wetland or the
documented low level groundwater contamination?
Response: The NYSDEC/USEPA agree that this area of the wetland
needs to be studied. The USFWS study of the wetland,
as well as visual inspections of this area, do not
indicate that drums of hazardous waste were ever
disposed in this area. The USEPA collected samples
of water and sediment from the wetland and additional
groundwater samples in December 1988. If this
additional sampling of the wetland and groundwater
shows the presence of significant levels of
contamination, appropriate measures will be taken to
remediate the problems as a separate operable unit.
The proposed remedial action at the site will not
interfere with any potential future remedial actions
for the wetland or groundwater.
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Technical Questions/Concerns Remedial Alternatives
1: Where did the data for the Ox Creek wetland
impact assessment come from?
Response: The USFWS study.
Z: Did the locations of soil contamination
correspond to the locations where drums were
stored?
Response: Yes.
3: What areas of soil contamination does the
Ebasco RI/FS identify as the 2,500 cubic
yards needing remediation?
Response: Generally the areas where drums were once
stored, down to a depth of approximately 5 feet.
4: Will the proposed remedial actions prevent
runoff from the site to adjacent properties?
Response: Yes, the proposed remedial actions include
measures to regrade, revegetate and construct
other drainage control structures to prevent
contaminated soil from migrating off site to
adjacent properties.
5: Was any sampling done for the presence of
radioactive wastes?
Response: During the initial waste characterization done1
for the RI in 1985, two drums were found to
contain low level radioactive wastes. The level
of radioactivity was only slightly above
background levels. These drums were removed and
the area was surveyed for residual radiation,
none was detected.
6: What guarantee is there, that long-term
monitoring will be performed?
Response: The NYSDEC is bound by an agreement with the
USEPA to insure that a long-term monitoring
program is developed and implemented for a
period equal to the design life of the remedial
action or 30 years, whichever is less.
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Public Participation Process
1. There were several complaints that not enough time was
allowed for public comments for the September 1988 PRAP
and public meeting.
Response: The public participation meeting was rescheduled to
a later date, October 5, 1988, than originally
proposed and the comment period extended to
November 4, 1988. The total public comment period
was approximately 60 days.
2. The Town of Granby and several citizens requested that the
issuance of a ROD be delayed until a Technical Assistance
Grant was obtained to hire a technical advisor.
Response: No application had been received as of the date of the
public meeting. An application for a TAG was received
on October 27, 1988. Delaying the issuance of a ROD
until the grant is awarded and a technical advisor is
hired will seriously delay remediation of the site.
Cost and Funding Issues
1: Have the possible economic impacts on adjacent
property values been considered in the selection
of a remedy?
Response: The assessment of economic impacts on the surrounding
area are not considered in the selection of the
remedy. While it is desirable to protect neighboring
property values, the USEPA cannot guarantee that the
remedies chosen will restore any potential economic
loss sustained by neighboring properties. The top
priority in selecting a remedy is always the
protection of human health and the environment. The
NYSDEC and USEPA feel the proposed actions will be
adequately protective of human health and the
environment.
2: What do the" costs presented in the PRAP represent?
Response: The PRAP gives capital costs as well as present worth
costs which are a summation of the capital costs plus
annual operation and maintenance costs for 30 years,
adjusted to present worth or 1988 value.
Enforcement
1. Will Mr. Clothier have to pay for the RI/FS and remediation
of the site? Who will pay for these remedial actions?
Response: Remediation of the site can be funded by the Federal
Superfund or responsible parties. Mr. Clothier is
a responsible party and is subject to cost recovery
along with the generators of the waste material that
went to the Pollution Abatement Services site. This
would have to be addressed in future litigation.
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2. What restrictions can be placed on Mr. Clothier to prevent
future contamination of the site and remove the junk cars
from the site? How can future misuse of the site be
prevented?
Response: Restrictions of land use would have to be obtained
through taking easements or other litigation
consistent with New York State Real Property Law.
The junk cars at the site do not fall under State
jurisdiction but are subject to local ordinances.
Periodic inspections will be made to assure that
hazardous wastes are not disposed of at the property.
D. Remaining Concerns
1. What areas of the site will be covered with the one foot soil
cover? The URS Report and Ebasco Report indicate different
areas of the site as being significant.
Response: This will be determined during the design phase by
additional soil sampling and possible pre-construction
air surveys.
2. Will run-off from the site be diverted into neighboring
farmlands?
Response: Additional run-off will not be diverted onto
neighboring farmlands. The design will minimize
run-off from the site.
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Attachment #1
Summary of Questions
Clothier Disposal Site
Remedial Investigation/Feasibility Study
July 30, 1987 Public Meeting
Town of Granby, Oswego County, New York
by
New York State Department of Environmental Conservation
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Clothier Disposal Site
Summary of July 30, 1987 Public Meeting
Remedial Investigation/Feasibility Study
Granby Town Hall, Oswego County, NY
The New York State Department of Environmental Conservation
(NYSDEC) held a public informational meeting on July 30, 1987 at the
Granby Town Community Center to discuss the Clothier Site Remedial
Investigation/Feasibility Study (RI/FS) performed by URS Company,
Inc., under contract to the NYSDEC. Present at the meeting were
representatives from: NYSDEC, URS, United States Environmental
Protection Agency (USEPA), United States Fish and Wildlife Service
(USFWS), New York State Department of Health (NYSDOH), Oswego County
Health Department, Agency for Toxic Substances and Disease Registry
(ATSDR), concerned citizens groups, concerned individuals, local
government officials and the news media.
The RI/FS was made available for public review on July 7, 1987 at
the Granby Town Hall, City of Fulton Public Library, the NYSDEC
Region 7 Office and the NYSDEC Central Office. The following is a
summary of questions and comments received during the comment period.
Question: Will the proposed thermal treatment process remove metals
contamination from the soil? Would the bioreclamation
process result in the removal of the organic contamination?
Answer: Thermal treatment will remove only organic contaminants but
not inorganic contaminants such as metals. We do not
believe the concentration of metals to be high enough to
pose a problem but further testing would have to be done
to determine if the metals are Teachable.
The bioreclamation process would remove the organic
contaminants but not the inorganic contaminants. It is
also possible that the inorganic contaminants such as
the metals could be toxic to microorganisms necessary
for the biological degradation of the contaminants.
Question: Was URS told by the NYSDEC and USEPA to choose the thermal
treatment alternative because of policy?
Answer: URS was hired to provide their professional judgement and
recommendations. They are not and were not told which
remedial alternative to recommend.
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Question:
Answer:
Was URS the only consultant used?
the URS report?
Did the NYSDEC edit
URS was hired by the NYSDEC as the prime engineering
consultant. URS subcontracted portions of the work to
other firms who provided services such as: well drilling,
sample analyses and hydrogeology. The NYSDEC and USEPA
review and comment on preliminary versions of the RI/FS
reports, but do not edit or in any way try to influence
the professional judgement of the consultant.
Question: Why doesn't thermal treatment remove heavy metals?
Answer: Thermal treatment, by definition uses heat to combust or
destroy organic (carbon containing) compounds. Heavy
metals do not contain carbon. Some heavy metals may be
volatilized by the heat, buy they will not be substantially
altered.
Question: Does EPA withhold money if the remedial alternative they
favor is not chosen?
Answer: As a site on the National Priority List of Inactive
Hazardous Waste Sites (NPL), the final decision on the
selection of a remedial action is made by USEPA, who
will then provide 90 percent of the construction funding.
Question: Would the thermal treatment result in a reduction in soil
volume and a corresponding increase in heavy metal
concentration?
Answer: Given the relatively low concentrations of hazardous wastes
in the soil, there will not be a significant decrease in
volume of the treated soil. In addition, the treatment
will fluff the soil slightly.
Question: What happened to the junk cars and debris on the site?
Answer: They have been moved to the eastern edge of the site, out
of the way of the removal activities.
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Question: Has the remedial alternative been selected or is there
still the potential for a change? What legal agreements
have been made or will be made, with the Potentially
Responsible Parties (PRP) regarding their input on the
chosen remedial alternative?
Answer: The purpose of this public meeting is to provide the DEC
and EPA recommendation for a remedial action, to the
public. Your comments and concerns will be recorded and
presented to the EPA Regional Administrator who will make
the final decision. The PRP's are given the opportunity
to review and comment on the RI/FS, just as the public is.
Following the issuance of a Record of Decision (ROD), the
PRP's are given 60 days to accept responsibility for
undertaking further remedial measures. After that time,
if the PRP's do not accept responsibility, the DEC and
EPA will go forward with the action using Superfund money
and then take legal action against the PRP's to recover
all government costs incurred.
Question: Will it be the responsibility of EPA, DEC or the PRP
to obtain insurance to cover damage to the public or
the environment?
Answer: The contractor hired to undertake the remedial action will
have insurance to cover damages resulting from his
negligence. The Federal government will cover damages
resulting from incidents other than contractor negligence.
Question: Have environmental impact studies been done on the thermal
treatment process?
Answer: Thermal treatment has been used for many years for the
destruction of hazardous waste at commercial facilities
throughout the world, with little if any, adverse
environmental impacts. The thermal treatment units used
are very efficient in destroying the wastes and in removing
contaminants from the air emissions. The specifications
for the operation of the treatment unit at the Clothier
Site will be set during the remedial design process and
will be defined in accordance with State and Federal
Standards.
Question: What level of public impact is needed to have an impact on
the EPA decision?
Answer: It is up to the discretion of the EPA Regional Adminis-
trator. All public comments will be recorded and reviewed
by the Regional Administrator and will have an impact on
his decision.
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Question: What happens if you discover buried drums while excavating
the contaminated soil?
Answer: If the drums contain hazardous waste, they will be either
treated on-site in the thermal treatment unit, or removed
from the site for treatment at a commercial hazardous
waste facility.
Question: What does a thermal treatment unit look like?
Answer: They vary depending on the specific unit, but they all
contain a combustion chamber followed by numerous
systems for cleansing and cooling exhaust gases.
Question: Will there be a warning or ban on fishing in the Ox Creek
after the wetland study is completed?
Answer: That will depend on the results of the study.
Question: '.Mil the DEC and EPA wait for the Fish and Wildlife study
co be completed before making a final decision of the
remedy?
Answer: No. The findings of the wetland study will not affect
the plans for remediation of the contamination on-site.
If the wetlands study shows contamination in that area
the appropriate actions will be taken to deal with that
contamination.
Question: Are there air emission standards for specific
contaminants that are to be thermally treated?
Answer: NYSDEC publication entitled, Air-Guide 1 defines emissions
standards for the significant contaminants.
Question: Have two RI/FS's been done? What was the chosen remedy in
the first RI/FS? Why was that remedy not selected?
Answer: There is only one RI/FS, but the preliminary draft report
prepared by URS recommended bioreclamation, a form of
biological treatment. This report was not released to the
public because the DEC felt URS should investigate other
treatment technologies.
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Question: Why Is thermal treatment being encouraged so much?
Answer: Thermal treatment is a reliable and effective means of
permanently destroying hazardous wastes. Because the
technology has existed for several years, it is proven
and therefore favored over experimental processes.
Question:
Answer:
Will the chemical contaminants in the soil cause an
explosion during the thermal treatment process?
The levels of contamination in this soil is not high
enough to cause an explosion. If it were, the temperature
and rate at which the waste is fed into the treatment
unit is controlled to guard against explosion.
Question:
Answer:
How deep will the soil be excavated?
Our preliminary estimates are approximately 10 feet, or
to the water table. Further sampling will be done to
better define the areal and vertical extent of
contamination.
Question: Who owns the site and who is paying the taxes?
Answer: Richard Clothier
Question: Will there be more sampling of homeowner wells in the
vicinity of the site?
Answer: The samples taken have not shown the presence of
contamination which could be attributed to the site.
No further sampling is planned.
Question: Has consideration been given to using more than one
treatment process to remove the hazardous wastes?
Answer: Yes. It may be necessary to treat the soil beyond the
thermal treatment, in order to remove an inorganic
contaminant not removed by the thermal treatment.
-------
Question: How much of the contamination do you feel has left the site
and migrated to the Oswego River and to the Fulton
municipal wellfields?
Answer: Surface water and sediment samples collected from the Ox
Creek area, the area into which the site drains, did not
show the presence of contamination. In addition,
groundwater samples did not show the presence of
contamination exceeding NYSDEC Groundwater Quality
Standards. Visual inspection of the Ox Creek wetland did
not indicate the presence of hazardous waste. Based on
this, there is no evidence to indicate that any
contamination has migrated off the Clothier site.
Question: After thermal treatment, what can the soil be used for?
Answer: The treated soil will be decontaminated and will be
available for any normal use.
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Attachment #2
Community Relations Activities
Clothier Drum Disposal Site
Granby, Oswego County, New York
Community relations activities conducted at the Clothier Drum Disposal
site to date include:
* NYSDEC/USEPA conducted a public information meeting to
discuss the Clothier Site and discuss the ongoing Remedial
Investigation/Feasibility Study (RI/FS) (May 1986)
* USEPA conducted community interviews with local officials
and interested residents (July 1986)
* NYSDEC/USEPA conducted a public information meeting to
discuss the preliminary results of the RI/FS (November 1986)
* NYSDEC/USEPA conducted a public meeting to discuss the
final draft RI/FS prepared by URS, Inc., which recommended
thermal destruction (July 1987)
* NYSDEC/USEPA conducted a public meeting to discuss the
revised RI/FS prepared by URS (August 1988) and Supplemental
RI/FS prepared by Ebasco Services Inc., (July 1988) and the
September 6, 1988 Proposed Remedial Action Plan (October 1988)
* NYSDEC/USEPA routinely corresponded with local citizens,
local environmental groups, and local officials throughout
the RI/FS.
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Mr. Gary Kerzic
Project Manager X
NYS Dept. of Environmental Conservation
50 Wolf Avenue
Albany, N.Y. 12233
Dear Mr. Kerzic,
As a resident of the Town of Granby, member of NO MORE
(Neighbors Organized to Mend Our Rural Environment), member
of the Town of Granby Environmental Board and member of the
Oswego County EMC (Environmental Management Council) I would
like to go on record opposing the EPA - DEC Clothier PRAP
(proposed Remedial Action Plan).
First and foremost is the fact that we are in the
process of applying for TAG (Technical Assistance Grant)
money. Since FSDWAC (Fulton Safe Drinking Water Action
Committee for Environmental Concerns Inc.) has already
received their grant we are hoping that our application will
be processed promptly. We would therefore request that we be
given the opportunity to use this grant to hire a Technical
Advisor to assist us before commenting upon the PRAP.
The October 5>1988 public meeting in Granby revealed an
11 acre section of the Clothier site that had not been
sampled or studied. This omission renders the PRAP as
incomplete. We request a delay until results of this area
are available.
Health issues were also not addressed in the PRAP. Mr.
Nelson from ATSDR (Agency for Toxic Substance and Disease
Registry) reported at the October 5, 1988 meeting that his
report was in draft form and would soon be available to us
for reveiw. I question the validity of this report since it
appears to be based on the study done by USFWS (United
States Fish and Wildlife Service) which did not study
humans.
At this point I think removal of the "Hot Spots" to a
secured landfill would be an acceptable interim measure
until the final ROD (Record of Decision) is decided.
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Sincerely
Diane Hartman
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New Vbrfc State Department of Environmental Conservation
50 Wolf Road, Albany, New torfc 12233 -7010
Thomas C. Jerllng
CommlMiofMr
Ms. Diane Hartman
Granby Environmental Board
Town of Granby
RD 17, Box 369
Fulton, NY 13069
Dear Ms. Hartman:
Re:
Clothier Disposal Site
Proposed Remedial Action Plan
Thank you for your recent letter regarding the October 5, 1988
public meeting on the Proposed Remedial Action Plan (PRAP) for the
Clothier Site.
The PRAP presented at the October 5, 1988 meeting relates to the
Remedial Investigation/Feasibility Study (RI/FS) performed on the
approximately 5 acre area of the Clothier property on which hazardous waste
activities occurred. The RI/FS concentrated primarily on this 5 acres,
known as the "site", but also included limited sampling of the adjacent Ox
Creek wetland. In addition, the United States Fish and Wildlife Service
(USFWS) has completed an extensive 2 year study of the Ox Creek wetland
which Included sampling of surface water, sediment, plants, fish and small
mammals. This study did not show the presence of contamination which could
be attributed to hazardous waste activities on the Clothier Site. There
were low levels of pesticides detected In some of the samples which are not
a result of the Clothier site, but more likely due to agricultural activity
1n the surrounding areas.
•
The studies performed by both URS and the USFWS show that
contamination is present only in a few Isolated areas within the site.
These levels of contamination are so low as to not pose a significant
threat to public health. The PRAP discusses the proposed actions for
dealing with; the areas on the site which contain these low levels of soil
contamination.
The USFWS study Investigated the Ox Creek wetland for the presence of
hazardous waste contamination migrating from the Clothier site. Through
the collection of plant, fish and small mammals which Inhabit this wetland,
the USFWS was able to determine if contamination was present in this area
as well as its affect on the environment.
Based on the findings of the RI/FS, and the USFWS study, It 1s
unlikely that contamination exists in an approximately 10 to 11 acre area
between the site and Ox Creek. Visual Inspections of this 10 acre area did
not show the presence of drums of hazardous waste nor was there any
Indication of hazardous waste handling activities. In order to satisfy
public concerns with this area and to confirm our belief that this area is
not contaminated, the U.S. Environmental Protection Agency (USEPA) plans to
sample this area in late November or early December 1988.
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Ms. Diane Hartman Page 2
A major activity of the RI/FS performed by both URS and Ebasco
Services, Inc. was a public health risk assessment on exposure to
contamination detected both on and off the Clothier site. The results of
this health risk assessment play a significant role In determining what
remedial measures are most appropriate. It 1s true that the Agency for
Toxic Substances and Disease Registry (ATSDR) has not completed their
health assessment of the Clothier site. Mr. U1111am Nelson of ATSDR stated
at the October 5 meeting that he felt the actions proposed 1n the PRAP were
appropriate for dealing with any potential risk that may exist.
The use of the term "Hot Spots" 1s misleading and not a proper
descriptive terms for the contamination remaining 1n the soil on the site.
There are areas on the site 1n which contamination 1s the most
concentrated. Even at the highest detected levels though, the potential
health risk 1s not significant. The excavation and removal of hazardous
wastes for burial at a secure landfill Is the least favored option by both
the New York State Department of Environmental Conservation (NYSDEC) and
the USEPA. It serves only to move the problem from one site to another and
1s not an answer to the overall problem of contamination of the
environment.
At the request of members of the Granby community, the USEPA extended
the official comment period for review of the RI/FS and PRAP from 21 days
to 60 days. In addition, a public Informational meeting was held to
explain the RI/FS and PRAP and to discuss comments and questions from the
public. The USEPA and NYSDEC are committed to community Involvement 1n the
remediation of hazardous waste sites, but are equally commuted to the
remediation of these sites as expedltlously as possible. Having a
technical assistant during the public comment period could certainly
facilitate the community's understanding of the technical Issues associated
with this project, It 1s not essential to Involving the public 1n the
remediation process.
Sincerely,
GaryJT.Terzlc, P.E.
Project Manager
Bureau of Eastern Remedial Action
01v. of Hazardous Waste Remediation
GTK/slj
bcc: w/1ncom1ng R. Brazell - Region 7
S. Miller - Region 7
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OSWEGO COUNTY LEGISLATURE
COUNTY OFFICE BUILDING • OSWEGO. NEW YORK 13126
MARGARET I, STHEtTENBERGER TELEPHONE (315) 593-
Osw*0o County LtgiiMor
RO 1 • BOX 145
WEST RIVCR ROADNORTM November 1* 1988
FULTON. NEW YORK t30M S1WVC1UMCI. J. f 4.yOO
Gary Kerzic
Project Manager
New York State Department of
Environmental Conservation
50 Wolf Road
Albany/ New York 12233
Re: Clothier Site ROD
Response to PRAP
Dear Mr. Kerzic:
I strongly urge delaying a final selection of the remedial
•action alternative and the formalizing of this selection into a
Record of Decision regarding the Clothier Site.
The residents of Granby have been the initiators of concern
for this site and continue to be interested and concerned that
their input be considered. This is where they live....and where
their children will live. They need to be heard. Their
representatives on the Environmental Board and in the citizen's
organization of NOMORE should have the opportunity to complete
this process through the Technical Assistance Grant to satisfy
all their questions and concerns before a final decision is made.
The efforts made by DEC and EPA to clean up this site and
remain in communication with the concerned citizens have been
appreciated. I encourage you to keep this door open. Please
allow time for the "full use" of Technical Assistance by the
citizens. Share fully your reports and information with the
Environmental Board and citizens of NOMORE. They will be your
best communicators with the Town of Granby citizenry and assist
in bringing about full cooperation in the final ROD.
ery truly yours/
largaret Streitenbergertf
Oswego County Legislator
Town of Granby
MS/hr
cc: Nancy Nolan» NOMORE
Ginny Gary/ Granby Environmental Board
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New York State Department of Environmental Conservation
50 Wolf Road. Albany, New Ybrfc 12233
Thomas C. Jorling
Commissioner
Ms, Margaret Streltenberger
Oswego County Legislator NOV I 0 1368
Town of Granby
R.D. 1 - Box 145
West River Road North
Fulton, NY 13069
Dear Ms. Streitenberger:
Re: Clothier Site
Proposed Remedial Action Plan
Thank you for your letter of November 1, 1988 regarding the
remedial actions proposed by the New York State Department of
Environmental Conservation (NYSDEC) and the United States
Environmental Protection Agency (USEPA) for the Clothier Site.
In order to best respond to your letter and the issues of
greatest concern to the Granby community, I have enclosed my response
to a recent letter from Mrs. Virginia Gary, Chairperson, Granby
Environmental Board.
The NYSDEC and USEPA are both committed to public involvement in
the remediation of hazardous waste sites and feel that the citizenry
plays an essential role in the process. Though we make our best
effort, a thorough understanding of all the issues is not always
acheived.
Sincerely,
CJLJyV *fcty
GarSh.Qterzic, P.E.
Project Manager
Bureau of Eastern Remedial Action
Div. of Hazardous Waste Remediation
Enclosure
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Granby Environmental Board
Tovn of Granby
RD tl Box 369
Fulton, Hev York 13069
October 28, 1988
Gary Kerzic
Project Manager
Hev York State Department of
Environmental Conservation
50 Wolf Road
Albany, Hev York 12233
Dear Mr. Kerzic:
The Granby Environmental Board does not support the final
selection of any remedial action at this time with regard to the
Clothier Disposal Site. Neither the EPA's nor the DEC's Remedial
Investigations are complete, as approximately tvo-thirds of the
site area, or eleven acres, has not been tested for contamination.
Ho plan can legitimately be considered until the extent of con-
tamination is identified. The US Fish and Wildlife study of the
Ox Creek vetlands considered the eleven acre area in question to
be on-site and therefore did not include it as part of their study.
It appears that both the Ebasco RI and the URS RI either assumed
that the US Fish and Wildlife study encompassed this eleven acre
area, or it vas inadvertantly neglected by both consultants in their
studies of the Clothier site. In either case, the Granby Environ-
mental Board feels the data regarding this eleven acre area is
pertinent information in the formulation of proposed alternatives.
Ho final selection of alternatives for remediation should be formal-
ized by vay of a Record of Decision until testing of this area
is completed and remedial alternatives revised in accordance vith
the results of testing the area in question. The EPA has stated
that sample testing vill be initiated vithin the next fev months.
•»
The Environmental Board also is convinced that Granby residents
are in need of a Technical Advisor to assist us in the analysis
and interpretation of the data regarding contamination thus far •
provided, and vith the data that is to be forthcoming in the test-
ing of the unexamined eleven acre area. As an example: there is
a significant difference betveen the DEC and the EPA in their inter-
pretation of the extent of soil contamination on site. The EPA
has extimated that there exists 2800 cu. yds. of contaminated
soil; the DEC;s interpretation, based on analysis of the same
sets of data, is that soil contamination is much more widespread,
ten times more extensive, at an estimated 28,000 cu. yds. This
example is put forth as an indicator of why ve believe it is im-
perative to secure independent reviev of the studies, and consul-
tation regarding the remediation of the Clothier site.— Toward this
-------
end, the Environmental Board fully supports the application that
has been filed vith the EPA for a technical advisor under the
Technical Assistance Grant Program by FSDWAC (Fulton Safe Drink-
ing Water Action Committee) on behalf of the citizen's group NO
MORE (neighbors Organized to Mend Our Rural Environment). We
request that the citizens of Granby be allowed to participate in
decisions regarding the remediation of Clothier to the fullest
possible extent, and as fully informed as possible, i.e. vith
full benefit of the expertise of a technical advisor. Therefore,
a delay in the ROD pending receipt and utilization of TAG funds
as veil as completion of the on-site RI, is fully indicated and
expected by the Environmental Board.
If the DEC and/or the EPA believe that containment of any
further off-site migration of contamination is indicated nov,
the Environmental Board has no objection to the proposed action
to cover, vegetate and contain the sloped area of the site vith
rip-rap. Hovever, ve vould viev this action as an interim measure,
not a final plan.
The Environmental Board also notes its objection to the failure
to make the ATSDR Health Risk report available for public, reviev.
As of this vriting the report still has not been released, and
although it vas discussed at the public meeting, comment regarding
that report is vithheld pending the opportunity to read it.
The Environmental Board is very interested in learning more
about the role of the Presumed Responsible Parties in all activities
relative to the Clothier site. Tovard that objective, it is requested
that all minutes of meetings, copies of agreements and correspon-
dence betveen the EPA and/or the DEC and representatives of the
PRP's be forvarded to the Environmental Board, care of Chairperson
Virginia Gary. If it is necessary or requested that Freedom of
Information form(s) be filed to facilitate your compliance vith
this request, please so indicate by. contacting Ms. Gary. Since
the EPA's Removal Action vas completed in July, 1988, security
at the site has been vithdravn. It is requested that negotiations
vith the PRP's regarding the need for continued maintainence of
security and site restriction be resumed immediately. In the
interim, it is requested that the DEC accept responsibility for
securing and restricting the site.
Sincerely,
Virginia Gary, Chairperson
Granby Environmental
Board
Environmental Board members:
Diane Hartman
Lynn Lyons
nancy Nolan
Kevin Wallace
Thea Wallace
Roger Weils
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New York State Department of Environmental Conservation
50 Wolf Road, Albany, New York 12233
Thomas C. Jorllng
Commissioner
Mrs. Virginia Gary ^y .«
Chairperson !tn *
Granby Environmental Board
Town of Granby
RD *7, Box 369
Fulton, NY 13069
Dear Mrs. Gary:
Re: Clothier Disposal Site
Proposed Remedial Action
Thank you for your letter of October 28, 1988 regarding the
Clothier Site Remedial Investigation/Feasibility Study (RI/FS) and the
remedial measures proposed by the New York State Department of
Environmental Conservation (NYSDEC) and the United States
Environmental Protection Agency (USEPA).
The purpose of the Remedial Investigation/Feasibility Study
(RI/FS) was to determine the nature and extent of hazardous waste
contamination present on the "Clothier Site", which is the designation
given to the approximately 5 acre area on which hazardous wastes were
stored and handled. In addition, the U.S. Fish and Wildlife Service
(USFWS) study of the Ox Creek wetland investigated the area into which
contamination could have potentially migrated off the Clothier site.
The USFWS study involved the collection of surface water and sediment
from the creek area, as well as, plants, fish and small mammals which
inhabit the wetland. The wildlife (plants, fish, small mammals)
Inhabiting an area, will generally accumulate contaminants in their
tissues and will therefore act as an indicator of the presence of
contamination in the soil/sediment and surface water. Given the fact
that the fish, plants and small mammals did not show the presence of
contaminants from the Clothier Site and because the sediment and
surface water samples collected from the creek did not contain Clothier
contaminants, coupled with visual inspections of the wetland which did
not indicate the presence of drums of hazardous waste, the NYSDEC and
USEPA feel it is unlikely that there is contamination in this 10-11
acre area in question. As stated at the October 5, 1988 meeting, the
USEPA will sample this area in order to confirm this belief.
In the unlikely event that contamination is found in this 10-11
acre area, it will have no impact on the remedial plans presented in
the Proposed Remedial Action Plan (PRAP). If significant levels of
contaminants are found, the NYSDEC and USEPA will take the appropriate
actions to remediate the area, separately.
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Mrs. Virginia Gary Page 2
The URS RI/FS and the Ebasco RI/FS differ in their estimation of
the volume of contaminated soil to be remediated. As two engineering
consulting firms who have independently investigated this site, they
apparently have a difference of professional opinion. The estimation
of contaminated soil volumes is based primarily on public health risk
due to exposure to the soil. The determination of significant risk is
by no means exact and is subject to individual judgement. An
important point to bring out is that both URS and Ebasco have arrived
at the same level of risk through their independent risk assessments.
The difference exists in their judgements of what is a significant
risk. In any event, the exact areas to be covered as part of the
proposed remedial action would be determined by the NYSOEC, USEPA and
the New York State Health Department, with public health and
environmental protection as the major decision criteria.
The health assessment being performed by the Agency for Toxic
Substances and Disease Registry (ATSDR) will involve a review of the
RI/FS and any other pertinent information. A similar review has been
performed by the NYSDOH who feel the health risk assessments in the
RI/FS reports are accurate and who also feel that the proposed
remedial actions will be protective of the public health. Mr. William
Nelson of ATSDR stated at the public meeting that even though the
ATSDR health assessment was not complete, his agency felt the proposed
actions were adequate to remove any health risks that might exist from
exposure to the site.
The Technical Assistance Grant (TAG) Program is administered by
the USEPA through provisions set forth in the Superfund Amendments and
Reauthorization Act of 1986 (SARA). After consulting with the USEPA
on this matter, they inform me that although they are committed to
Involving the public in the hazardous waste site remediation program,
they are equally committed to expeditiously remediating these sites.
At the request of a member of the Granby community, the official
comment period for review of the RI/FS and PRAP was extended from 21
days to 60 days. A public informational meeting was also held to
present the findings of the RI/FS and to discuss comments and
questions from the public. A technical assistant would certainly be
beneficial to community understanding of the technical issues
associated with this project, but the USEPA feels a technical
assistant is not essential to involving the public in the remediation
process.
As a site on the National Priorities List of Inactive Hazardous
Waste Sites (NPL), the USEPA is responsible for all communications and
negotiations with Potentially Responsible Parties (PRP). For
Information relating to the PRP's, I suggest you contact, Mr. Gregory
Snyder, Esq., USEPA Region II, 26 Federal Plaza, New York, NY 10278 or
call (212) 264-8157.
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Mrs. Virginia Gary Page 3
The issue of Mr. Clothier's continued practice of storing junk
vehicles on the Clothier Site was discussed at the October 5, 1988
public meeting. To date, Mr. Clothier has not violated a State or
Federal law by storing vehicles on his property. The NYSDEC
periodically inspects the site to insure no hazardous wastes are
brought on the site. The presence of these vehicles is undesirable to
both the NYSDEC and USEPA as it is to you, but unless a law is
violated, there is little that can be done. If Mr. Clothier is
violating local ordinances by bringing these vehicles on his property,
it is perhaps prudent that the Town of Granby institute enforcement
actions.
Sincerely,
O
Gary T.Kerzic, P.E.
Project Manager
Bureau of Eastern Remedial Action
Div. of Hazardous Waste Remediation
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Brace Tallents
Granby Town -Super-visor
Town of Granty
R.D. 17 Box 369
Fulton, Hev York 13069
October 26, 1988
Gary Kerric
Project Manager
Nev York State Department of
Environmental Conservation
50 Wolf Road
Albany, Hev York 12233
Dear Mr. Kerzic:
The Tovn Board of the Tovn of Granby submits our vritten response
to the PRAP presented by the DEC and EPA at the October 5, 1988,
public information meeting in Granby, H.Y. as follows: The Board
is opposed to a ROD being concluded on this plan, based on:
1. Insufficient data has been collected on the site. Eleven
acres have yet to be tested for contamination. The remedial
investigation is not complete. The alternatives proposed
do not take into consideration the possibility that this
area may be grossly contaminated. A ROD finalizing any
plan vould be premature and not acceptable at this time.
2. Residents of Granby have organized a citizens' group (NO
MORE) which has applied for funds under the EPA's Technical
Assistance Grant Program to hire a technical advisor.
The Town Board of Granby supports this application for TAG
funds and believes a ROD should be delayed until the Tovn
of Granby and its residents receive full benefit of expert
technical advisement regarding remediation alternatives
to be considered at the Clothier Disposal Site.
3. The Town Board seeks to support a remediation plan that
would offer a permanent solution to the problem of contami-
nation in our environment. The FRAP presented for the
limited area that was investigated at the Clothier Site
does not meet this standard. It addresses problems result-
ing from possible further surface migration only of contami-
nants into adjacent properties by containing the site,
but does not address the clean-up of the contaminated
-------
groundvater or soil. Soil samples indicate that con-
taminants vere found in soil in depths of up to tventy
feet. The PRAP presented is not acceptable as a final
olan.
The Granby Tovn Board is very concerned about the integrity
and security of the site while further investigation and considera-
tion of remedial alternatives continue. There vere many comments
and much discussion about this issue at the 10/5/88 meeting, but
no resolution to the problem of continued dumping at the site has
been forthcoming. The Tovn Board takes this opportunity to re-
iterate our request that the DEC and/or EPA take appropriate action
to restrict access to the site and prevent any further dumping of
vehicles or other actions vhich disturb current conditions of the
site. Please advise regarding vhat actions are being considered
and vhom, specifically* vithin the DEC or the EPA the Tovn should
contact for information regarding this matter. We believe that
the need for site restriction is apparent and immediate, and that
timely implementation of a plan to achieve this objective is necessary
to protect any further degradation of the site from occurring.
Sincerely
Brace Tallents, Tovn Supervisor
Granby Tovn Board:
Rose Anthony
Jeanine Junco
William Somers
Willie Webb
-------
New York State Department of Environmental Conservation
50 Wolf Road, Albany, New York 12233 -7010
Thomas C. Jorling
Commisslontr
Mr. Brace Tallents
Supervisor
Town of Granby
R.D. #7, Box 369
Fulton, NY 13069
Dear Mr. Tallents:
Re: Clothier Disposal Site
Proposed Remedial Action Plan
Thank you for your letter of October 26, 1988 regarding the
Clothier Site and remedial actions proposed by the New York State
Department of Environmental Conservation (NYSOEC) and the United
States Environmental Protection Agency (USEPA) at the October 5, 1988
public informational meeting at the Granby Town Community Center. The
following is a response to the issues raised in your letter, in the
order in which they were presented.
1. The NYSOEC and USEPA have jointly performed extensive
sampling of the Clothier property in the area on which
hazardous waste activities occurred. A total of 70
(seventy) soil and 10 (ten) groundwater samples were
collected from this approximately 5 acre area. In addition,
the U.S. Fish and Wildlife Service (USFWS) has completed a
two year study of the adjacent Ox Creek wetland in which
sediment, surface water, plant and animal samples were
collected. This study did not show the presence of any
contamination which could be attributed to the Clothier
Site. We have identified the need to collect additional
sediment samples from a 10 to 11 acre area between Ox Creek
and the site. From visual Inspections and from our
knowledge of hazardous waste handling activities that
occurred at the site, it is unlikely that this area is
contaminated, but this additional sampling will act as
confirmation. The Record of Decision (ROD) and the proposed
remedial actions will address the 5 acre area where
hazardous waste activities occurred. In the event, the off
site (10 acre) area is found to contain contamination, the
NYSDEC and USEPA will take the appropriate action to
remediate that area. The presence of contamination in the
off site area will not have an impact of the proposed
remediation of the site.
2. The NYSDEC and USEPA also support the Technical Assistance
Grant (TAG) Program which will provide funding for concerned
citizen's group to hire technical advisors. As with any
-------
Mr. Brace Tallents Page 2
government grant program, an application requesting the
funds must be completed and submitted to the appropriate
government agency before funds can be awarded. As of the
October 5, 1988 meeting, no application had been submitted
to USEPA. I have been informed by USEPA that the
application was recently received and that it will take a
few months to process the application and award the funds,
which would result in a delay of several months in the
issuance of a ROD. At this time, the NYSDEC and USEPA feel
it most prudent to continue with plans to remediate the site
and not allow further delays.
3. Federal regulations set forth in the Superfund Amendments
and Reauthorization Act of 1986 (i.e. SARA, PL 99-499) state
that the USEPA shall,
select a remedial action that is protective of
human health and the environment, that is cost
effective, and that utilizes permanent solutions
and alternative treatment technologies or
resource recovery technologies to the maximum
extent practicable.
You will recall, during a July 30, 1987 public informational
meeting, the NYSDEC and USEPA were proposing the use of thermal
treatment to remove organic contaminants from the soil on the site.
Public sentiment appeared to be strongly against the use of this
treatment. The NYSDEC investigated the feasibility of several other
treatment technologies. With the exception of thermal treatment,
treatment technologies to remove hazardous wastes are mostly
experimental and unproven. Additional soil samples collected since the
July 30, 1987 meeting show the soil contamination to be significantly
lower and far less extensive than originally thought. The USEPA
completed a remedial action in July 1988 which removed the remaining
drums of hazardous waste from the site, as well as, 300 cubic yards of
contaminated soil. The remaining soil on the site contains only low
levels of contaminants which do not pose a significant threat to
public health or the environment. Groundwater samples did not contain
contamination which would pose a public health threat or which exceed
government standards for groundwater quality.
Since the completion of the USEPA removal activities in July 1988
and the subsequent discontinuation of the on-site security, the site
owner has brought approximately 25 junk vehicles on the site.
Although that Is undesirable, it is not in violation of any State or
Federal law pertaining to solid waste disposal. A representative of
the NYSDEC office In Syracuse regularly Inspects the site for the
presence of hazardous waste. To date no hazardous waste have been
brought on-site.
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Hr. Brace Tallents • Page 3
If you would like more Information on this matter, I suggest you
contact the legal affairs office, NYSDEC Region 7 Headquarters, 615
Erie Blvd. West, Syracuse, 13204 or call 315-426-7405.
Once again, thank you for expressing your concerns.
Sincerely,
Gary T.^Kerzic, P.E.
Project Manager
Bureau of Eastern Remedial Action
Oiv. of Hazardous Waste Remediation
bcc: w/incoming
R. Brazell - Region 7
S. Miller - Region 7
-------
a.p.D. #3
?ox 352
Fulton, r:.Y. 13069
Aur. 22, -1987 ' < •' .
Dept. of Environmental Conservation
Room 222
50 IVclf Hd.
Albany, N.Y. 12233
Attni I:r. Gary Kerzic
I..r. Kerzict
This letter advises the Dept. of Environmental Conserv-
ation of our objections and questions pertaining to the
incineration of the remaining hazardous waste at the
Clothier Site.
Cur home, located on County Route 1^, Town of Granby, is
adjacent to the Clothier Site.
V.'e have been concerned with the hazardous environment
caused by the materials dumped at the Clothier Site but
because they were bein.c removed from the site we became
less worried.
The consideration fiven to incineration revives our concerns.
There was a fire at the site prior to the start of clean up
at the site. V.'e were at work but when we arrived home, a
state representative was waiting. Ke advised us of the fire
and said we would have been evacuated had we been home dur-
ing the fire because of the possibility of hazardous elements
in the smoke.
According to what we read in the newspaper, incineration is
being considered becauset the EPA is encouraging waste
treatment on site rather than moving it, because of the
"track record" of incineration, not wanting to "Just see a
site contained"* and the thorough process of incineration;
but nothing is said about the safety of incineration.
-------
-2-
"e want answers to the followirr: what type of incineration
is bein/r considered? '•v'hat level of contamination will Ye
eiritted into the atmosphere? (In other words—how free of
contaminates will the air be after the sir.oke from incin-
eration is released?) '..'hat safeguards or protection is teir.-
taken to assure the safety of the inhabitants of the Clothier
Site area?
Please response to our concerns.
Sincerely»
John & Marilyn Barrie
-------
827 Forest Avenue
Fulton, Nev York 13069
- August 3, 1987
Mr. Gary T. Kerzic, Project Engineer
Nev York State Department of Environmental
Conservation
50 Wolf Road
Albany, Nev York 12233
Dear Mr. Kerzic:
The arguments at the Granby public meeting last Thursday
night about the use of inceration vere unconvincing.
It is proposed that $20.3 million be spent incinerating
6 feet of soil over a 42-month period. The use of the
incinerated soil is at best very limited, probably questionable,
and a house can be built on it only "if one vants to." It
received a 77 Evaluation Score.
Meanvhile, Bioreclamation received an 84 Evaluation Score
at a cost of only $2.1 million. Site Capping and Bioreclamation
received the highest score of 92 at a cost of $3.3 million.
Mr. Rothman of URS, looking very unhappy during the
discussion on incineration, says that bioreclamation has a
good chance of vorking, at much lover depths, after
a year of experimentation. The operation you said vould
take 7-10 years.
I don't knov vhat procedure should be used, but the
arguments for incineration are not persuasive.
ECEIVED
. 'JG C-V B8'
:M .2!Ai ACT::
-------
New York State Department of Environmental Conservation
50 Wolf Road, Albany, New York 12233-4011
Thomas C Joriin|
Co/nm/ss/'oncr
September 2, 1987
Mr.' Joseph Allerton
827 Forest Avenue
Fulton, New York 13069
Dear Mr. Allerton:
Re: Clothier Site
Remedial Investigation/Feasibility Study
Thank you for your letter of August 3, 1987 regarding the Remedial
Investigation/Feasibility Study (RI/FS) performed on the Clothier Site.
The New York State Department of Environmental Conservation (NYSDEC)
proposes to treat the soil contamination at the Clothier site through the
use of a thermal treatment or thermal destruction process at a conservative
cost estimate of $20.3 million. This assumes the total area of soil to a
depth of six feet would need treatment. This cost is a worst case estimate
for planning purposes and considers the maximum quantity of material likely
to be encountered. Detailed additional sampling planned for the design phase
will refine the quantitites and cost estimates. Actual implementation will
be advertised for competitive bids to achieve the lowest possible price.
The NYSDEC and it's consultant have evaluated several types of
biological, chemical and physical treatment processes. The Remedial
Investigation/Feasibility Study addresses only those treatment technologies
that are capable or providing satisfactory performance under these site
conditions. We do not feel the use of thermal treatment is "very limited,
and probably questionable." Comparing thermal treatment with other available
technologies, we feel thermal treatment has a greater range of application
and will be more successful than other technologies such as bi©reclamation.
Thermal treatment processes have been used successfully and reliabily
for several years by commercial facilities to destroy hazardous wastes at
concentrations much higher than those found at the Clothier Site. The
thermal treatment process 1s technically simpler and, therefore, less prone
to failure than experimental techniques such as bioreclamation. In-situ
biological treatment has never been used effectively to treat soil
contaminated with a variety of wastes. The theory behind the bioreclamation
process 1s similar to that used to treat sanitary sewage at facilities such
as the Fulton Sewage Treatment Plant. As I'm sure you are aware, a sewage
treatment plant efficiency id dependent on many variables which 1f not
properly maintained will negatively affect the treatment process. These
Include sufficient food to mass ratio, nutrients, temperature and acclimated
-------
Mr. Joseph Allerton Page 2
biological organisms. The organisms perform best under equalized stead-state
conditions. In-situ biological treatment is prone to many more variables
and is less capable of process control than treatment in a treatment unit.
For instance, research has shown that for every 10°C decrease in temperature,
biological activity will be decreased by 50 percent which translates into
a ceasation or at best a decrease in the biological reaction which would
remove the hazardous wastes. The presence of certain organic and Inorganic
contaminants may be toxic to the microorganisms necessary to digest the
hazardous wates. As 1s the case with sewage treatment, the biorecla/nation
process will produce waste products or sludge from the microorganisms
performing the reaction.
The bioreclamation process is sensitive to many variables which could
potentially hinder the process. The evaluation score given in the RI/FS
1s not an absolute but rather an artificial rating system created for
Illustrative purposes in comparing alternatives. It is not capable of
reflecting all concerns that the NYSOEC has for the bioreclamation process
application. The estimated cost of $2.1 million can not be readily verified
since there 1s no available cost data base due to the lack of other similar
projects. The 7 to 10 year period mentioned at the public meeting 1s the
estimated time 1t would take to perform the treatment. This 1s after the
Initial startup of the process 1s completed and assumes no delays due to
operational difficulties.
The NYSDEC does not have resources to dedicate to the type of research
project necessary to pursue a technology such as bioreclamation at a site
where the likelihood of success is marginal at best. As you are aware, there
are several hundred sites across New York State which also require action.
In the Interest of Implementing an effective hazardous waste remedial program
statewide, the most efficient remedial measures must be undertaken on a site
by site basis.
Thermal treatment 1s the only feasible treatment alternative for use
at the Clothier site. Physically removing the contaminated soil from the
site 1s unacceptable for the obvious reason that you are moving the waste
and not eliminating 1t. Without treatment, encapsulating and leaving the
wastes on the site 1s the only other option. This is not preferred by the
NYSOEC but will be Implemented 1f thermal treatment 1s rejected.
Once again, thank you for your comments. If you have questions or
comments, please feel free to call me at (518) 457-5677.
Sincerely,
Gary T. Kerzic
Project Engineer
Bureau of Eastern Remedial Action
Division of Solid and Hazardous Waste
GTK/lmd
bcc: w/1nc. 0. Brazell, Region 7
S. Miller, Region 7
-------
-------
9F COLUMN
Municipal Waste
By Michael E. Hen. attorney in EDFs A«r
York headquarters, and Dr. Richard A.
Denison, scientist in Ike H 'askington office.
Dol
MCHAtLHfNZ
DM. NJCHAMO OCNtSON
The United States is having increas-
ing difficulty finding places for its
garbage. As a result of growing
amounts of solid waste, shrinking
landfill space, stricter regulations, and
rising costs, we have seen renewed
enthusiasm in some quarters for a trash
processing method already tried—and
largely abandoned—in this century:
incineration.
Incineration previously fell out of favor
because of unacceptable air pollution.
and concern over the new wave of
"resource recovery facilities" has under-
standably focused on what comes out of
the stack. The new incinerators, although
still requiring careful scrutiny, probably
earn limit air pollutants to acceptable
levels if properly designed, sited, and
operated. EDF scientists, however, are
more concerned about the other major
product of incineration, the ash.
A» much as a third of the trash
fed into an efficient incinerator to
left behind as amh when the fire goes
out. The proposed Brooklyn Navy
Yard facility in New York, for ex-
ample, would generate l.OOO tons
of ash every day. Disposal of an that
ash to a tremendous problem, farther
complicated by the chemical
stituents of the ash.
EDF has accumulated a large amount
of troubling data on ash toxicity. Of
primary legal and public health concern
are the dangerously high levels of heavy
metals, particularly lead and cadmium.
Burning does not destroy these chemical
elements, which are already in the waste
stream, but rather concentrates and trans-
forms them into a readily dispersed form
that much more easily reaches and is
taken up by people, plants, or animals.
Though incinerator ash is not listed
as a hazardous waste, it nonetheless
qualifies as such if it has any of four
"hazardous characteristics" specified by
Federal law: ignitability. corrosivity.
reactivity.or toxicity. Data gathered by EDF
from incinerators across the U.S. show
that fly ash (the particles trapped in
pollution control devices) failed EPA's
toxicity test every time because of high
lead and cadmium levels. Bottom ash
(what's left on the furnace grates), both
alone and combined with fly ash. failed
25 to 50% of the time
Thus, under current law. incinerator
ash is often a hazardous waste This is
not only an environmental problem. It is
also a major economic problem for indus-
try and for municipalities that own or
use incinerators. Especially stringent
rules governing the storage, treatment.
transport, and disposal of hazardous
wastes make such wastes more expensive
to manage than nonhazardous wastes. Yet
all the financial planning for existing or
proposed incinerators rests on the assump-
tion that the ash can—now and forever-
be disposed of in ordinary landfills.
Economic Implications of EDF Data
Are Well Known to the Industry
When EDF released its ash toxicity data.
at a press conference in Washington.
D.C.. Wall Street's financial news wire
immediately ran the story. It also caught
the attention of San Francisco officials
considering the Bay Area Resource Re-
covery Facility (BARRF). As one city
Within days of EDF'* press conference.
Congress scheduled hearings on the ash
hazard and invited representatives of EDF.
EPA. and the National Solid Waste Man-
agenunl Association to appear. Two high-
ranking EPA officials confirmed the sen-
outness of the problem and admitted that
EPA has not been sufficiently concernedI
Nor kas it made it clear to incinerator (
?owners and operators that they must test]
? their ash. >
( Members of the Congressional panel
harshly criticiad EPA's rtqmest for more
time to study the issue. EPA then agreed to
issue new ask testing guidelines promptly to
Ike incinerator industry, but to date kas not
done so. EDF scientists and attorneys have
been meeting with EPA staff to insure that
such guidelines an adequately protective.
official acknowledged. 'The plant won't
be economical and wouldn't be able to go
forward if the ash is found to be a
hazardous waste" San Francisco later
voted against sending garbage to BARRF.
specifically citing the possible ash hazard
as one of the reasons.
n
7!
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Wiu
LETTER
tear
Norm* H. Watson
ENVIRONMENTAL DEFENS
National HcMtquarr
J57 Part Avenue South
New York. NY 10010
212505-2100
BOSDwitntWay
•rtdeyCA 94704
1554MM6
fettahiCMRce
101 Eatt Main Street
tidunond. VA 23219
04-780.1297
Capital Office
1616 P Street. N.W.
Washington.
202-3873500
RadcyMoottainOSkc
1405AnpahaeAver«K
Boulder. CO 80302
304404901
1987 Environmental Defense Fund. Inc.
Pufahshcd at New York. NY. ISSN 0163-2566.
•iieiuiun 10 ana nnanaai
support for recycling and source separa
tion. These methods can complement
incineration, not only by reducing the
amount of trash, but by targeting such
items as batteries that contain the toxic
substances which end up in the ash.
According to one industry official
treating ash as a hazardous waste "means
finite, morte the end. for the resrirce
recovery industry." While this is almost
certainly an exaggeration, iheflnancia.
implications of hazardous ash havefifiall)
drawn the attention of industry. Capito
Hill, and EPA to this important public
health and environmental issue
Contmoed scrutiny and pressure frorr
EDF and the public may produce regula
tory reforms, better ash managemeni
practices, more recycling and sourct
separation and—ultimately—reduction!
in the use of hazardous substaA| ir
manufacturing the myriad produfflftiai
end up in the solid waste stream. Any or
all of these would be important step:
toward rational management of our solic
waste. 9
-------
uling that the legal arguments
of environmentalists and orga-
nized labor were "totally convinc-
ing." a state judge ordered Cali-
fornia Governor George Deukmejian to
add 201 chemicals to the list of sub-
stances covered by the voter-enacted
Safe Drinking Water and Toxic Enforce-
ment Act of 1986.
The Governor had issued a list of only
29 chemicals, acting at the request of the
Chamber of Commerce and industry
groups. Under the new law, passed as
Proposition 65 by a 2-1 voting margin
last November, the Governor must list
all chemicals that are "known to the
state" to cause cancer or birth defects
and other reproductive disorders.
EOF, the AFL-CIO, and six other
groups sued the Governor within hours
after the "short list" was announced. In
reaching his decision. Superior Court
Judge Roger K. Warren said that the Gov-
ernor's rationale for listing only 29
chemicals was "strained and tortured."
and that the groups suing him had met
"the highest possible standard" in
showing that the additional chemicals
should be added immediately to the list.
At a press conference. Governor
Deukmejian said he had not yet decided
whether to appeal. The Governor is
being represented by a private law firm
because the state's Attorney General
declined the case, after finding that a
"short list" was legally indefensible in
light of the law's clear provisions.
An Obsolete Approach
To Cancer Protection
'The short list would not only have
reduced Proposition 65 to a fraction of its
intended coverage, but would also have
undermined fundamental cancer policy."
said EDF attorney David Roe, the law's
principal author. The Governor argued
s—inu
IMfva
\ trear
wO i.Civv
that the only chemicals that should
count as "known" cancer-causers were
those based on data from after-the-fact
studies of cancer in humans—thus
ruling out controlled testing of
lory animals.
"The 'dead-bodies' approach
cer protection has been obsolete for
decades," aaid Roe. "You either use
animals, or you have to wait to regulate
until many people have died. California';
own cancer policy has been based on
animal tests for years, as has the Federal
Government's."
"Organized labor across the country
has a very strong interest in seeing that
Proposition 65 is implemented." said
Stephen P. Berzon, attorney for the AFL-
CIO and lead counsel in the case. "Its
right-to-know provisions, among others.
are a major advance in the law, and will
give workers powerful new protections
against cancer and birth defects."
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New York State Department of Environmental Conservation
50 Wolf Road, Albany, New York 12233- 4011
Thomas C
*
September 2, 1987
Ms." Patricia C. Guarrera
95 Uhitcomb Road
Fulton, New York 13069
Dear Ms. Guarrera:
Re: Clothier Site
Remedial Investigation/Feasibility Study
Thank you for your letter of July 31, 1987 and the enclosed newsletter
from the Environmental Defense Fund.
A point I tried to articulate at the July 30, 1987 public meeting was
•that if the ash or treated soil contained concentrations of metals (e.g.
cadmium, lead, mercury, zinc) at levels high enough to define it as a hazardous
waste, treatment will be pointless and therefore not performed. We do not
believe the metals concentrations to be of concern, but we need to take additional
samples to better define the exact extent of contamination.
Since the proposed thermal treatment will not remove the metals, additional
treatment may be necessary. To ensure the efficiency of the treatment, the
ash will be regularly tested.
Once again, thank you for your letter. If you have further comments,
please feel free to call me at (518) 457-5677.
Sincerely,
Gary T.TCerzic
Project Engineer
Bureau of Eastern Remedial Action
Division of Solid and Hazardous Waste
GTK/lmd
bcc: w/1nc. 0. Brazell, Region 7
S. Miller, Region 7
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