Superfund Record of Decision: Byron Barrel & Drum, NY


            United States
            Environmental Protection
            Agency
              Office of
              Emergency and
              Remedial Response
EPA/ROD/R02-89/089
September 1989
V-/EPA
Superfund
Record of Decision
            Byron Barrel & Drum, NY

-------
50272-101
REPORT DOCUMENTATION
PAGE
1. REPORT NO.
EPA/ROD/R02-89/089
3. Recipient's Acceeaion No.
4. Tit)* and Subtitle
SUPERFUND RECORD OF DECISION
Byron Barrel & Drum, NY
First Remedial Action - Final
5. Report Dau
09/29/89
7. Autrtor(a)
8. Performing Organization Rept No.
9. Performing Organization Nam* «nd Addree*
10. Proiect/Taak/Worii UnH No.
11. Contnct(C) or Grin(
-------
16. 'Abstract (Continued)

EPA/ROD/R02-89/089
Byron Barrel & Drum, NY

The selected remedial action for this site includes pumping and treatment of ground
water using precipitation, sedimentation, and filtration to remove metals, and air
stripping and carbon adsorption to remove organics, followed by reinjection into the
aquifer and, if necessary, offsite discharge of excess treated water; disposal of ground
water residues at an offsite RCRA-permitted facility; treatment of 4,100 cubic yards of
contaminated soil using in situ soil flushing; further evaluation of 1,100 cubic yards of
inorganic contaminated soil to determine ultimate disposal; dismantling and
decontaminating debris followed by offsite disposal; and air and ground water monitoring.
The estimated present worth cost for this remedial action is $5,572,000, which includes
annual O&M costs of $259,700.
-------
RECORD Of DBCI8IOM SUMMARY

BYRON BARREL AND DRUM SITE

BYRON, GENESEE COUNTY, NEW YORK
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

REGION II

NEW YORK
-------
TABLE OF CONTENTS
SITE NAME, LOCATION AND DESCRIPTION 1
SITE HISTORY 2
ENFORCEMENT HISTORY 4
COMMUNITY PARTICIPATION 4
SCOPE AND ROLE OF RESPONSE ACTION 5
SUMMARY OF SITE CHARACTERISTICS 5
SUMMARY OF SITS RISKS 9
DOCUMENTATION OF SIGNIFICANT CHANGES 16
DESCRIPTION OF ALTERNATIVES 16
SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES 21
THE SELECTED REMEDY 26
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
-------
DECLARATION FOR THE RECORD O7 DECISION

SITE NAME AND LOCATION

Byron Barrel and Drum, Byron Township, Genesee County, New York

STATEMENT OF BASIS AND PURPOSE

This decision document presents the selected remedial action for
the Byron Barrel and.Drum 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 Superfund Amendments and Reauthorization Act of 1986.
(SABA), and to the extent practicable, the National Contingency?
plan (NCP). This decision is based on the administrative record^
for the 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.

ASSESSMENT OF THE SITE

Actual or threatened releases of hazardous substances from this
site, if not addressed by implementing the response action selected
in this Record of Decision, may present a current or potential
threat to public health, welfare, or the environment.

DESCRIPTION Qg THB SELECTED REMEDY

The selected remedy described in this document,in-situ soil
flushing to remove volatile orgaric and inorganic contaminants from
subsurface soils, represents tr.e final remedial action for the
site. It addresses residually contaminated soils at the site and
contaminated groundwater in the underlying aquifer. Prior cleanup
actions have resulted in the removal of drums containing hazardous
substances and contaminated surface soil.

The major components of the selected remedy are:

- Performance of aquifer testing to assist in the optimization of
the groundwater pumping and reinjaction system;

- Dismantling of the maintenance building, and decontamination
if necessary, with disposal of the debris at an off site
landfill;
-------
- Extraction and treatment of the groundwater via precipitation,
sedimentation, and filtration to remove the heavy metals, and
air-stripping and carbon adsorption to remove the volatile
organics; underlying the site.

- Reinjection of treated groundwater to the aquifer and, if
necessary, discharge of excess treated water to the closest
surface water body;
••i-y
- Further evaluation of elevated surface soil inorganic
concentrations in an area where organic contamination is not
present, to determine its ultimate disposition (i.e., off-site
disposal or placement on the soil to be flushed);

- Disposal of the groundwater treatment residuals at an off-site
Resource Conservation and Recovery Act Subtitle C disposal
facility; and

- Appropriate environmental monitoring and review of the
treatment process, including monitoring of residential wells,
to ensure the effectiveness of the remedy.

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
and alternative treatment technologies to the maximum extent
practicable and satisfies the statutory preference for remedies
that employ treatment that reduces toxicity, mobility, or volume
as a principal element. Because this remedy will not result in
hazardous substances remaining on-site above health based levels,
the five-year review will not apply to this action.
William J. Mus'zyfcski.^^.E. Date
Acting Regional Administrator
-------
SITE NAMB. LOCATION. AND DESCRIPTION

The Byron Barrel and Drum site is located in Genesee County, New
York, approximately 3.6 miles northwest of the Township of Byron.
The site occupies approximately 2 acres of an 8-acre parcel of
property off Transit Road in a rural area (see Figure 1) .
Approximately 20 people live within one mile of the site. The
nearest residence is approximately 0.2 miles from the site
boundary. Two large vacant buildings are located on site.

The site was used as a salvage yard for heavy construction equip-
ment such as graders, bulldozers, cement mixers, and cranes.
Numerous pieces of such equipment are present on-site. In addi-
tion, metallic and nonmetallic debris litters the site. The site
itself is relatively flat. Gravel was mined from a pit located on
the site. The site is heavily vegetated except in the gravel pit
and, to a lesser extent, along the access road.
ir .
The site is abutted by heavily wooded areas and is directly
adjacent to an active vegetable farm. The agricultural land
originated from swamp deposits and is locally referred to :a*
"muckland." This land has been classified as prime agricultural
land by the State of New York. The soils are apparently highly
organic in nature.

The closest surface-water body is Oak Orchard Creek. It originates
southwest of the site and flows in a generally northeasterly
direction, approximately 1,000 feet west of the site.

Several large wetlands exist in the vicinity of the site. The
nearest wetland is approximately 1 mile due south. In addition,
a wildlife sanctuary, the Byron-Berge Swamp, exists approximately
4 miles to the east.

Groundwater is used as a potable water source by local residents
and as a source of irrigation water by farmers.

The surficial geology of the region is characterized by glacial
debris and drift" deposited as part of the barred oscillation during
the late Wisconsinan Age approximately 12,300 years ago. These
deposits consist of eskers, moraines, terraces, coarse gravel and
sand, low swampy basins, and muckland. Glacial till is
characterized by silty clay and silty sand that is sparsely to
moderately stony, very compact, and highly impermeable. The
glacial till is generally found to be deposited directly on top of
the bedrock.
-------
The bedrocJc underlying the glacial till in this region is silurian
in age and consists of massive argillaceous limestones, calcareous
shales, and dolostones.

The natural overburden at the site consists of organic soil with
silty sands that may incorporate finer or coarser material. This
material comprises the aquifer of concern. The overburden is
underlain by relatively impermeable glacial till that separates
the over-burden and the underlying bedrock. The maximum depth at
which bedrock was encountered was 99.5 feet, and the minimum depth
was 72 feet. Groundwater encountered in the natural overburden
ranged from less than 4 feet to more than 32 feet deep. Saturated
thicknesses ranged from approximately 11.5 to 18.5 feet, caused by
the undulating surface of the glacial till.

Groundwater flows in a north-northwest direction, eventually
discharging to Oak Orchard Creek to the west.
f •
A drainage system which prevents the water table from rising into
the root zone of the crops is known to exist beneath the farmland
adjacent to the site. Excess water collected via this system id
discharged directly to Oak Orchard Creek.

Oak Orchard Creek flows northward, passes the site to the west,
and terminates in low, swampy land after it exits the onion fields
to the north. Oak Orchard Creek acts as a natural receiving
channel for runoff from the onion fields. It contains standing
water; the level of which changes with the increase/decrease of
precipitation within the region.

Site History

The Byron Barrel and Drum site was discovered in early July 1982,
when an unidentified individual reported the disposal of "appro-
ximately 400 55-gallon steel barrels that were filled with noxious-
smelling chemicals" to the New York State Police Major Crimes Unit.

As a result of this report, a police investigation was initiated.
A helicopter flight over the area on July 16, 1982 revealed the
presence of a number of drums on the property. Further inves-
tigation revealed that Darrell Freeman, Jr., who owned the
property, did not possess a permit from either the New York State
Department of Environmental Conservation (NYSDEC) or the
Environmental Protection Agency (EPA) for the storage or disposal
of hazardous waste.

As a result of the investigation, a search warrant was issued.
Two drum storage areas were located. The first area contained
121 barrels, and the second area contained 98 barrels. NYSDEC
representatives obtained 11 drum waste samples during the search.
-------
On July 23, 1982, various persons were interviewed regarding waste
disposal activities at the site. A former employee of Mr. Freeman
reported that he first noted approximately 80 drums on the Freeman
property in the spring of 1978. These drums were located off the
east side of the dirt road that runs through the Freeman property.
The source further indicated that two more shipments of drums
arrived at the site in the summer of 1979. These drums were
unloaded and deposited at a site off to the west side of the dirt
road behind a small clump of trees. These drum storage locations
correspond to those identified during the police search. The
source further reported that a fourth load of drums arrived
sometime that summer. He did not witness their arrival, but noted
that they were piled in front of two cement trucks in an area just
south of the second disposal site.

Sometime during the fall of 1980, the source indicated that
Mr. Freeman instructed him to go to the site of the fourth load of
barrels and bury them. Apparently, Mr. Freeman instructed this
individual to rip the drums open with a backhoe and bury them and
mix them in with the dirt. "

Wehran Engineering and Camp Dresser & McKee submitted a preliminary
investigation report to NYSOEC in September 1983. The results of
this investigation led to the site's inclusion on the Superfund
National Priorities List in April 1984.

In March 1984, NYSDEC requested that EPA conduct an immediate
removal action at the site with funds available under the
Comprehensive Environmental Response, Compensation, and Liability
Act (CERCLA). Subsequently, EPA issued a notice to. Mr. Freeman
regarding the intent to conduct the removal operation. Mr. Freeman
indicated that he wished to conduct the work on his own. When
subsequent contact with Mr. Freeman and his attorneys did not
result in progress on the action, EPA commenced removal work at the
site in August, 1984.

The removal action included the removal and disposal of the drums
and approximately 40 cubic yards of contaminated soil and debris.
In addition, a monitoring well was installed near the burial area,
and a groundwater sample was obtained. The removal action was
completed by December 1984. Residential well sampling was
conducted in the vicinity of the site in June 1986. Contaminants
were not detected in the residential well samples.

In June 1987, a remedial investigation and feasibility study
(RI/FS) was initiated at the site. The RI revealed that two major
sources of contamination exist at the Byron Barrel and Drum site
(see Figure 2) . The first of these sources is located in the
southwestern portion of a former drum storage and waste disposal
area (Source Area 1) . The second source is located in the
southwestern portion of the property in the vicinity of the
maintenance building (Source Area 2). This source is believed to
-------
have originated from solvent spills. Subsurface contamination in
both area* consists primarily of chlorinated aliphatic hydro-
carbons , including 1,1,1-trichloroethane, 1,1-dichloroethane,
trichloroethene, and 1,1-dichloroethene. In Source Areas 1 and 2,
chromium and lead contamination was detected in soil samples in
concentrations above background. Small quantities of elevated
chromium and lead concentrations were also detected in surface soil
samples from Source Area 3, which is located in the eastern portion
of the site. No contamination with chlorinated aliphatics was
detected in surface or subsurface soil in Source Area 3.

Groundwater contaminant plumes, consisting of chlorinated aliphatic
hydrocarbons, were found to be originating from Source Areas 1 and
2. Source Area 2 also shows high levels of methyl ethyl ketone
(MEK). There does not appear to be a groundwater contaminant plume
emanating from Source Area 3.

Although groundwater in the vicinity of the site is used as a
drinking water source, the hydrogeologic and groundwater quality
investigations revealed that no migration of contaminants to the
domestic wells has occurred.

ENFORCEMENT ACTIVITIES

In June 1984, EPA issued an Administrative Order requiring the
property owner to take immediate corrective actions to clean up
the site. The owner, however, did not comply with EPA's order.

In 1985, a Litigation Referral Package was prepared, requesting
the initiation of a civil action against Mr. Freeman. This ongoing
action seeks civil penalties, cost recovery, punitive treble
damages, and a claim for future relief.

COMMUNITY PARTICIPATION

EPA and NYSDEC have kept the local citizens advised throughout the
Superfund process at the Byron Barrel and Drum site.

The RI/FS report and the Proposed Plan for the site were released
to the public in July 1989. These documents were made available
to the public at information repositories maintained at the Gillam
Grand Library and at the Byron Town Hall. A notice of availability
from these documents was published in the Batavia Daily News on
August 8, 1989. A public comment period was held from July 29,
1989 through August 31, 1989. In addition, a public meeting was
held on August 16, 1989 to solicit comments on and to discuss the
findings of the RI/FS report and the Proposed Plan. At this
meeting, representatives from EPA and NYSDEC answered questions
about the site and the remedial alternatives under consideration.
Responses to comments and letters received during the public
comment period, as well as questions raised at the public meeting,
-------
public netting, are summarized in the Responsiveness Summary, which
is part of this Record of Decision (ROD).

8COPB AMD ROIJI OT RESPONSE ACTION

Prior cleanup actions by EPA have already addressed most of the
contamination at the Byron Barrel and Drum site. These actions
have resulted in the removal of all drums and approximately 40
cubic yards of contaminated soil and debris. The low levels of
soil contamination remaining at the site have been found to present
minimal risk to human health. The remedy authorized by this ROD
1 addresses the principal threat remaining at the site by treating
/ the two plumes of contaminated groundwater, which currently exceed
I state and federal groundwater quality standards, and the low-level
< residual subsurface soil that has been releasing contaminants into
the groundwater, through infiltra- tion of precipitation. In
addition, inorganic concentrations above background levels in the
groundwater and surface soil at the site will be addressed as part
of the selected remedy.
•.
The.selected remedy will be a permanent solution for addressing
the groundwater and the surface and subsurface soil contamination
at the site. The federal and state groundwater quality standards'
will be achieved by removing the contaminants during treatment of
the groundwater. Reinjection of the treated groundwater will
remove contaminants from the surface and subsurface soils. Hence,
the treatment of soils will result in the elimination of a long-
term source of groundwater contamination, and it will mitigate the
risk to public health and the environment associated with the
migration of contaminants off-site.

The purpose of this response is to ensure protection of the
groundwater from the continued release of contaminants from the
soil, and to restore the groundwater to levels consistent with
state and federal water quality standards. This will be the final
response action for this site.

SUMMARY OF SITB CHARACTERISTICS

Approximately 2DO 55-gallon steel barrels that were filled with
hazardous waste were abandoned at the Byron Barrel and Drum site
from 1978 to 1980, when the site was used as a salvage yard for
heavy construction equipment. Leakage and spillage from these
drums appears to have been the primary source of contamination of
the site. The drums and their contents were removed from the site
by EPA in 1984. In addition, approximately 40 cubic yards of
visibly-contaminated surface soil and debris were removed from the
site during the same period.

Analyses of soil, groundwater, sediment, and surface water from
the site and adjacent areas indicate that the environmental
contamination at the Byron Barrel and Drum site consists primarily
-------
of subsurface soil and groundwater contamination. Based on the
absence of substantial soil contamination, it appears that the EPA
removal action was effective in reducing contaminant releases.
Chlorinated aliphatic hydrocarbons such as 1,1,1-trichloroethane,
1, l-dichloroethane, trichloroethene, and 1,1-dichloroethene are the
primary contaminants. Various monocyclic aromatics such as toluene
and xylenes were also detected, although groundwater contamination
with these substances is minimal when compared to the contamination
with chlorinated species.

SURFACE SOIL

A total of 25 surface soil samples were collected during the field
investigation at the locations shown in Figure 3. The locations
were selected based on the results of the soil-gas investigation
and historical information. Of the 25 samples, 21 were collected
on-site, and 4 were collected off-site to provide background
information. Surface soil samples were collected to provide the
necessary data to assess the risks posed by dermal contact, as well
as to provide information on potential contamination migration via
surface-water erosion of soil. :

Surface soils at the Byron Barrel and Drum site contain only low-
levels of volatile organics (less than 50 parts per billion (ppb)) ,.
phthalate esters (less than 600 ppb), polynuclear aromatic
hydrocarbons (less than 300 ppb), and benzoic acid (less than
500 ppb). By contrast, much higher concentrations of various
pesticides, such as 4,4'-DOT, 4,4'-DOE, endrin, and dieldrin, were
encountered. The highest concentrations of the pesticides were
detected in surface soil samples which were collected from the
adjacent farmland. On-site samples containing pesticides were
obtained in proximity to the agricultural land and are believed to
be present as a result of atmospheric transport of pesticides
during their application to crops. Figure 3 summarizes the
volatile organics detected in surface soil samples.

Although chromium and lead were detected in site surface soils
above background, contamination with these substances is not
pronounced. Figure 4 presents the analytical results for surface
soil samples coataining chromium and lead above background levels.
As is evident from the Figure 4, chromium and lead contamination
is greatest in Source Area 3.

Based on the results of a surface soil sampling program in Source
Area 3, it is estimated that there are 1,100 cubic yards of
contaminated soil in this area.

SUBSURFACE SOIL

As shown in Figure 5, test pits and trenches were dug at 46
locations, from which a total of 130 subsurface samples were
-------
collected for analysis. No drums were detected in any of these
test pits.

As shown in Figure 6, volatile organics were detected in subsurface
soil samples at concentrations ranging from 5 ppb to 2,669 ppb.
The most pronounced contaminants based on the mobile laboratory
results are toluene, 1,1,1-trichloroethane, and trichloroethane.
Concentrations of these ranged as high as 865 ppb, 551 ppb, and
2,669 ppb, respectively.

Twenty subsurface soil samples were also obtained. As can be seen
by the analytical results summarized in Table 1, volatile organics
are the primary contaminants detected, and toluene and
trichloroethene were detected at relatively high concentrations
(2,700 ppb and 2,800 ppb, respectively). In addition, several
other volatile organics, notably xylanes and tetrachloroethene
(PCE), were detected at high concentrations. Xylene concentra-
tions ranged as high as 1,700 ppb, while PCE concentrations ranged
as high as 4,400 ppb. All of these samples were collected from thto
southwestern portion of Source Area 1. In addition, phthalate
esters were detected in several samples at concentrations ranging
as high as 2,000 ppb (di-n-butylphthalate). Arochlor 1254 wa»-
detected in one test pit sample at a depth of 4 feet. PCBs were
detected in drum samples collected by the KYSDEC prior to the
removal action. The detection of PCB Arochlor 1254 at a
concentration of 690 milligrams per kilogram (ing/kg) indicates that
some release of PCBs occurred at the site. However, only one
sample from Source Area 1 contained a PCB compound, and the
available data indicate that PCB contamination is not extensive.
PCBs were not identified in any of the other matrices sampled at
the site (i.e., surface soil, sediment, groundwater, or surface
water).

Based upon the sampling results in Source Area 1, it is estimated
that there are 1,100 cubic yards of contaminated soil in this area.

The analytical results for subsurface soil samples obtained in
Source Area 2 are depicted in Figure 7. Subsurface soil samples
contained several chlorinated aliphatic hydrocarbons, including
1,1,1-trichloroethane, 1,1,2-trichloroethane, trichloroethene,1,1-
dichloroethene, and methylene chloride. TCA concentrations ranged
as high as 410 ppb in these samples.

Based on the results of the subsurface soil sampling and analysis
program in Source Area 2, it is estimated that approximately 3,000
cubic yards of contaminated unsaturated zone soil exists in this
area.

Figure 8 depicts detections of chromium and lead above background
soil concentrations. From this figure, it is apparent that
subsurface contamination with these contaminants is not extensive
in any of the source areas.
-------
8
GROUNPWATER

The primary contaminant transport mechanism at the Byron Barrel
and Drum site is associated with groundvater advection of dis-
solved contaminants. Two contaminant pluses originating in the
vicinity of Source Areas 1 and 2 were noted to be migrating in the
dovngradient direction to the northwest. No evidence of
contaminant migration toward residential wells to the southwest
was observed during the RI. Based on the analytical results for
monitoring well samples, it is apparent that these contaminant
plumes are confined to the immediate proximity of the source areas.
It is estimated that the contaminant plumes have migrated no
further than 400 and 300 feet from the Source Areas 1 and 2,
respectively. This phenomenon is a manifestation of the shallow
hydraulic gradient and the relatively recent time frame of disposal
activities (as late as 1982).

Four distinct rounds of groundwater sampling were conducted at the
Byron Barrel and Drum site. The first two rounds were conducted
during the course of the monitoring well installation
program. The second complete sampling round included analysis for
volatile organics. The analytical results for groundwater sampling
rounds 3 and 4 are summarized in Tables 2 and 3, respectively.

As shown in Tables 2 and 3, a number of volatile organic chemicals
were detected in site groundwater samples during the third and
fourth sampling rounds. Volatile organics detected frequently
and/or at high concentrations include 1,1,1-trichloroethane, 1,1-
dichloroethane, tetrachloroethene, trichloroethene, 1,1-
dichloroethene, and 1,2-dichloroethene. Concentrations of these
compounds ranged as high as 4,400 ppb, 290 ppb, 82 ppb, 3,300 ppb,
41 ppb, and 110 ppb, respectively. Of these compounds, all but
1,2-dichloroethene are considered major site contaminants. Only
one sample was found to contain 1,2-dichloroethene at a
concentration above 1 ppb, which is the sample mentioned above.
Methylene chloride was detected in one of three samples at a
concentration of 2.8 ppb.

Figures 9 and 10 summarize the results for the predominant site
groundwater contaminants for the third and fourth sampling rounds,
respectively.

In addition to the organic contaminants detected in site
groundwater samples, a number of inorganic constituents were
detected above background levels. Table 4 provides a summary of
the inorganic sample results for the upgradient monitoring veil
(MW-4A) versus the site monitoring well samples. Chemicals
detected at concentrations significantly above background include
aluminum, arsenic, barium, calcium, chromium, cobalt, copper, iron,
lead, magnesium, manganese, mercury, nickel, potassium, sodium,
vanadium, and zinc. It should be noted that groundwater samples
-------
were not filtered prior to acidification. Hence, these results are
indicative of total inorganics in the water samples, including
those present in suspended solids. The average concentrations
presented in Table 4 indicate that there is little difference
between the overall site concentrations and background levels.
With the exception of sodium, mercury, and zinc, the average
background concentrations exceed the site average values. Figure
11 displays the results for chromium and lead detected above
background (upgradient) levels. Based on these results, it appears
that lead contamination exists in all source areas.

The analytical results for groundwater samples collected during
the supplemental activities are summarized in Figure 12.
Groundwater contamination consists of chlorinated aliphatics and
ketones. Organic contamination with 1,1,1-trichloroethane and HEX
is most pronounced. Concentrations of TCA ranged as high as 2,500
ppb while concentrations of MEK ranged as high as 3,000 ppb.

The estimated extent of the contaminant plumes originating from
Source Areas 1 and 2 is depicted in Figure 13. There is not >
contaminant plume originating from Source Area 3.

SURFACE WATER AND SEDIMENT

Surface water and sediment samples obtained from a drainage ditch
adjacent to the site property contained relatively low levels of
organic chemicals. There is no evidence of any downstream impact
on Oak Orchard Creek, the primary receiving surface water body.
Several sediment samples from another drainage ditch that runs east
to west, just north of the site, contained relatively high levels
of toluene, acetone, and MEK. However, based upon surface drainage
patterns and the absence of potential discharge of contaminated
groundwater to this drainage channel, it is not believed that this
contamination is site related.

SUMMARY 07 BITS RISKS

Organic chemicals at the Byron Barrel and Drum site, that were
apparently released through spillage and leakage of waste chemicals
stored in above ground drums, have contaminated the soil and the
groundwater underlying the site. Predominant transport routes
identified for the migration of those contaminants to other
environmental media include: 1) volatilization of the volatile
organic compounds from the soil and subsequent releases (emissions)
to air; 2) movement through soils (percolation) to groundwater; and
3) release to surface water, in the Oak Orchard Creek adjacent to
the site, through discharge of the contaminated groundwater. Based
on the nature of contamination at the Byron Barrel and Drum site
and various site-specific conditions, only groundwater transport
is considered a major contaminant migration route. The major
portion of contamination is contained in saturated subsurface soils
and groundwater.
-------
10
CONTAMINANT IDENTIFICATION

The risk assessment for the site has identified 35 contaminants of
concern. These include 16 non-carcinogenic and 19 carcinogenic
compounds. Because chemicals having nonthreshold effects can cause
adverse effects even at low concentrations, all of the organic
carcinogenic substances detected in groundwater were included as
indicator compounds, regardless of their frequency of occurrence
or concentrations. With the exception of various pesticides,
virtually all of the organic chemicals detected at the site and in
the study area were included as indicator chemicals. Background
levels of pesticides are substantially greater than any levels
detected on site (i.e., approximately one order of magnitude).
Several of the pesticides were detected only in background
locations. Site samples containing pesticides were generally from
locations near the adjacent farmland, suggesting that aerial
application or spray application of pesticides on windy days
resulted in the low-level pesticide contamination on-site. in viev
of the presence of background contamination, the various pesticides
were not included as indicator chemicals.
•

Chromium and lead were included as indicator chemicals as a result
of their detection in surface soils above background. In addition,
polynuclear aromatic hydrocarbons and phthalate esters were
included as a result of their presence in surface soils.

The indicator chemicals chosen for the Byron Barrel and Drum site
are summarized in Table 5.

EXPOSURE ASSESSMENT

The following potential exposure routes were identified for the
Byron Barrel and Drum site:

Direct dermal contact at the source
Accidental ingestion of contaminated soil at the source
Inhalation of contaminated fugitive dust
Inhalation of volatile emissions
Household use of groundwater

Several other exposure routes were also considered for inclusion
but were dismissed based on site-specific conditions. For example,
root uptake of contaminants by the adjacent crops was considered
possible. However, through direct visual inspection it was
determined that the crops grown in the adjacent field have shallow
root zones (i.e., less than six inches). The drainage system in
the field appears to be effective in preventing groundwater from
reaching the root zone.
-------
11

Furthermore, exposure through contact and non-contact recreation
in the surface water bodies were also discounted based on the size
of the drainage ditches and Oak Orchard Creek.

For each of the exposure routes tvo cases are considered for each
pathway; the first is a maximum-case scenario and the second is an
average case scenario.

Direct Dermal Contact

The site is presently unfenced. Therefore, human receptors may
come in direct contact with contaminated soil or waste.
Trespassing adolescents and adult hunters are considered the most
likely receptors via direct dermal contact.

Accidental Ingestion of Soil

Because the site is unfenced, it is considered possible that
receptors may be exposed through accidental ingestion qf
contaminated soil. Pica ingestion is generally a tendendfy
exhibited only by children of ages between 6 months and 6 years.
Adult and adolescent receptors could also be exposed in an
incidental manner through hand-to-mouth contact (e.g., smoking,*
eating, etc.).

Inhalation of Fugitive Dust

Human receptors reside in the vicinity of the Byron Barrel and Drum
site. Although site vegetation will impede the emission of
particulates via wind erosion, several sources may be susceptible
to fugitive dust emission. Therefore, the potential for inhalation
of fugitive dust exists in the vicinity of the site, and this
contaminant release mechanism and subsequent exposure route was
considered.

A particulate emission model suggested in the April 1989 EPA
Superfund Exposure Assessment Manual was used to generate the
downwind contaminant concentrations.

Inhalation of volatile Emissions

Doses resulting from the inhalation of volatilized soil
contaminants can be significant for downwind receptors. Although
surface soil contamination appears negligible at the Byron Barrel
and Drum site, this exposure route has also been considered.

Household Use of Groundwater

There are numerous routes of exposure associated with household
use of contaminated water. Receptors may be exposed via ingestion
and inhalation of volatiles emitted from showers, dishwashers,
washing machines, and other turbulent sources, as well as through
-------
12

dermal contact during bathing, dishwashing, car washing, etc.
However, previous experience has shown that ingestion and
inhalation of volatiles during showering are the predominant
exposure mechanisms in the home. Dermal uptake is essentially
negligible; similarly, doses incurred through inhalation from all
other sources (i.e., dishwashers, washing machines, etc.) generally
amount to less than 10 percent of the dose incurred through
ingestion and shower inhalation. Therefore, only ingestion and
inhalation of volatiles during showering are assessed
quantitatively for this exposure route.

Three distinct groundwater use scenarios were considered:
(1) doses based on maximum observed monitoring well concentrations;
(2) doses based on average monitoring well concentrations; and
(3) doses based on concentrations detected in distinct residential
wells.

Table 6 provides a summary of the various exposure routes and input
parameters considered. •

TOXICITY ASSESSMENT SUMMARY

Cancer potency factors (CPFs) have been developed by EPA's
Carcinogenic Assessment Group for estimating excess lifetime cancer
risks associated with exposure to potentially carcinogenic
chemicals. CPFs, which are expressed in units of (mg/kg-day)"' ,
are multiplied by the estimated intake of a potential carcinogen,
in mg/kg-day, to provide an upper-bound estimate of the excess
lifetime cancer risk associated with exposure at that intake level.
The term "upper bound" reflects the conservative estimate of the
risks calculated from the CPF. Use of this approach makes
underestimation of the actual cancer risk highly unlikely. Cancer
potency factors are derived from the results of human
epidemiological studies or chronic animal bioassays to which
animal-to-human extrapolation and uncertainty factors have been
applied.

Reference doses (RfDs) have been developed by EPA for indicating
the potential for adverse health effects from exposure to chemicals
exhibiting noncarcinogenic effects. RfDs, which are expressed in
units of mg/kg-day, are estimates of lifetime daily exposure levels
for humans, including sensitive individuals. Estimated intakes of
chemicals from environmental media (e.g., the amount of a chemical
ingested from contaminated drinking water) can be compared to the
RfD. RfDs are derived from human epidemiological studies or animal
studies to which uncertainty factors have been applied (e.g., to
account for the use of animal data to predict effects on humans).
These uncertainty factors help ensure that the RfDs will not
underestimate the potential for adverse noncarcinogenic effects to
occur.
-------
13
Rlfllt CHABACTBRIZATIOM SUMMARY

Risk characterization for the Byron Barrel and Drum site included
an assessment of risk associated with exposures to non-carcinogens
and carcinogens. Non-carcinogenic risks were assessed using a
hazard index computed from expected daily intake levels (subchronic
and chronic) and reference levels (representing acceptable
intakes).

Potential carcinogenic risks were computed by multiplying chronic
(long-term) intake levels to a respective carcinogenic potency
factor.

The quantified carcinogenic and non-carcinogenic risk estimates
associated with various soil and air exposure routes are summarized
in Tables 7 and 8, respectively. Whereas, Tables 9 and 10
summarize the carcinogenic and non-carcinogenic risk estimates
associated with the various groundwater use scenarios, including
those based on maximum monitoring well concentrations, arithmetic
average monitoring well concentrations, and maximum residential
well concentrations.

Excess lifetime cancer risks are probabilities that are generally
expressed in scientific notation (e.g., IxlO*6 or 1.0 E-06). An
excess lifetime cancer risk of l.OE-06 indicates that, as a
plausible upper bound, an individual has a one in one million
chance of developing cancer as a result of site-related exposure
to a carcinogen over a 70-year lifetime under the specific exposure
conditions at a site.

Potential concern for non-carcinogenic effects of a single
contaminant in a single medium is expressed as the hazard quotient
(HQ) (or the ratio of the estimated intake derived from the
contaminant concentration in a given medium to the contaminant's
reference dose). By adding the HQs for all contaminants within a
medium or across all media to which a given population may
reasonably be exposed, the Hazard Index (HI) can be generated. The
HI provides a useful reference point for gauging the potential
significance of- multiple contaminant exposures within a single
medium or across media.

The context within which to judge the relative risk from each of
the pathways has been established by EPA. For carcinogens, the
target risk range is a E-07 to E-04 excess lifetime cancer risk.
For non-carcinogens, where the sum of expected dose/Rfd ratios
exceeds unity (1.0), observed concentrations pose unacceptable
risks of exposure.

In conclusion, with the possible exception of inorganics located
in Source Area 3, surficial contamination at the Byron Barrel and
Drum site poses minimal risks to human receptors. The cumulative
-------
14

Hazard Index from dermal contact, accidental ingestion, and
inhalation of volatiles and dust is 4.9 x 10 , which is well below
1.0. The cumulative incremental cancer risk through these exposure
routes is 6.5 x 10'7 (1 in 1.5 million), which falls well within the
EPA target risk range of 10 to 10"*.

The Hazard Index for groundwateir use based on residential well
concentrations is 2.2 x 10"1, which is below unity. The incremental
cancer risk for groundwater use based on residential well
concentration is 3.4 x 10 (l.in 2.9 million), which falls well
within the target risk range.

However, the Hazard Index for groundwater use based on maximum
monitoring well concentrations exceeds 1.0. Therefore non-
carcinogenic effects would be likely if the aquifer at the Byron
Barrel and Drum Site were developed for potable use. Similarly,
the incremental cancer risk based on maximum monitoring well
concentrations exceeds the upper bound of the target risk range
(2.4 x 10 ). An incremental maximum cancer risk of 1 in 420 woul&
be incurred if the aquifer is developed for potable purposes under
future conditions.

ENVIRONMENTAL ASSESSMENT

Table 11 presents a comparison of the maximum contaminant
concentrations in surface waters to the Federal Ambient Water
Quality Criteria for the protection of aquatic life and to the
state surface water standards. Oak Orchard Creek is currently a
Class D stream but may be upgraded to Class C. Class D surface
waters are suitable for contact recreation and allow for survival
of aquatic life. Class C surface waters are suitable for fishing,
contact recreation, and fish propagation. None of the organics
were found at concentrations that exceed the Ambient Water Quality
Criteria. Of the inorganics in the site surface waters, only
copper exceeds the federal and state standards for chronic
toxicity, based on a calculated hardness of 763 milligram per liter
(mg/1). No acute standards are exceeded. In addition, the maximum
concentrations of zinc and vanadium exceed the state standards for
chronic toxicity to aquatic life. However, the stream is very
small and receives runoff from a large area of agriculture. It is
likely that aquatic life is more susceptible to the presence of
pesticides.

During the course of the RI, it was noted that the aquatic
ecosystem appears healthy (based on visual observations). No
stressed flora or fauna were noted in either the drainage ditches
or in Oak Orchard Creek. The site itself also appears to support
a healthy population of mammals and reptiles. Species observed in
the vicinity of the site included garter snakes, rabbits, white
tail deer, and muskrats.
-------
15
Cleanup levels based on public health and environmental concerns
and on a review of Applicable or Relevant and Appropriated
Requirements (ARARs) were developed at the Byron Barrel and Drum
site. For both source control (soil cleanup) and management
migration (groundvater cleanup) measures. ARARs were used to
determine the appropriate extent of site remediation, to scope and
formulate remedial response actions, and to govern the
implementation and operation of the selected action. CERCLA
requires that primary consideration be given to remedial response
actions that attain or exceed ARARs. The purpose of this
requirement is to make CERCLA response actions consistent with
other pertinent federal and state environmental requirements.

A requirement under CERCLA may be either "applicable1* or "relevant
and appropriate" to a site-specific remedial action, but not both.
Currently, the only enforceable regulatory standards promulgated
under the Safe Drinking Water Act are the Maximum Contaminant
Levels (MCLs) for the protection of human health. However, MCL»
have not been specified for the majority of the indicator chemical
at the site. Therefore, only regulatory guidelines were used for
comparative purposes to infer health risks and environmental
impacts. Relevant regulatory guidelines include Ambient Water
Quality Criteria, Maximum Contaminant Level Goals (MCLGs), and EPA
Drinking Water Health Advisories. The ARARs identified for the
contaminated media at the Byron Barrel and Drum site are summarized
below.

Soil

In order to provide protectiveness for future ingestion of
groundwater, it is necessary to remediate volatile organic
contaminants detected in the subsurface soil. The subsurface soil
contamination does not pose a public health threat under existing
or anticipated future conditions. There are not any ARARs for soil
remediation, therefore, the cleanup levels have been derived so
that contaminants must be remediated to concentrations where
leaching into groundwater will result in levels below MCLs. Table
13 presents a range of cleanup goals for vadose zone subsurface
soils.

The soil cleanup levels were back-calculated from groundwater
cleanup levels using an unsaturated/saturated zone linkage model
and theoretical distribution coefficients between the solid and
aqueous phases.

The soil cleanup levels were compared to the contaminant
concentrations identified in each soil boring sample. Any samples
with contaminant concentrations below the cleanup levels are
considered clean. The depth of contamination varies with each
-------
16

borehole* For a conservative estimate, it is assumed that
contamination has reached the groundwater table which is
approximately eight feet deep with the Source Areas 1 and 2 and
four feet in Source Area 3.

groundirater

The groundwater at the Byron Barrel and Drum site was classified
by New York State as class "GA", which indicates that the water is
suitable as a drinking water supply. The RI has determined that
contaminants from the site have contaminated the groundwater. The
two existing groundwater plumes originating from Source Areas 1 and
2 present a risk of off-site migration of contaminants to the
nearby Oak Orchard Creek. The remedial response action, therefore,
includes the following:

- ensure protection of groundwater and surface water from the
continued release of contaminants from soils; and
•
- restore groundwater to levels consistent with state and federal
ARARs.

The federal and New York State ARARs associated with quality of
'groundwater suitable for drinking at the Byron Barrel and Drum site
are listed in Table 13. A comparison of the concentrations of the
contaminants of concern in the groundwater to these ARARs reveals
that most volatile organic compounds exceed the regulatory
concentrations. As a result, the groundvater cleanup levels should
meet the most stringent of the federal and state ARARs listed in
Table 13. For those compounds having only non-carcinogenic
effects, cleanup levels have been derived so that the total non-
carcinogenic risk (Hazard Index) does not exceed unity (i.e., a
value of 0.9 was used as the target Hazard Index). The sources of
each of the various cleanup levels are provided in footnotes to
Tables 13.

Actual or threatened releases of hazardous substances from this
site, if not addressed by implementing the response action selected
in this ROD, may present an imminent and substantial endangerment
to public health, welfare, or, the environment.

DOCUMENTATION OT SIGNIFICANT CHANGES

There are no significant changes from the preferred alternative
presented in the Proposed Plan.

DESCRIPTION OF ALTERNATIVES

All of the drums and approximately 40 cubic yards of contaminated
surficial soil and debris have been removed from the site. The
levels of subsurface soil contamination on-site, with the possible
exception of inorganics located in Source Area 3, present risk
-------
17

levels which are within EFA's acceptable range. However,
contaminants remaining at the site have contaminated the underlying
groundwater, exceeding federal and state groundwater quality
standards. Specifically, Source Area 1 and Source Area 2 are
releasing organic contaminants into the groundwater through
infiltration of precipitation. The two plumes exceed ARARs and
pose a risk of off-site migration of contaminants to the nearby
Oak Orchard Creek. There does not appear to be a groundwater
contaminant plume emanating from Source Area 3. The alternatives
described below address the remaining subsurface soil contamina-
tion at the site and the contamination in the groundwater
underlying the site.

A total of eight alternatives were evaluated in detail for
remediating the site. Five remedial alternatives address the
contaminated subsurface soils that contribute to groundwater
contamination at the Byron Barrel and Drum site. In addition, six
alternatives address the contamination in the groundwater beneath
the site. These alternatives are as follows: *

ALTERNATIVE 1 - NO ACTION WITH MONITORING

The Superfund program requires that the "no-action" alternative be
considered at every site. Under this alternative, EPA would take
no further action to control the source of contamination. However,
long-term monitoring of the site would be necessary to monitor
contaminant migration. Monitoring can be implemented by using
previously-installed monitoring wells and residential wells.

Because this alternative would result in contaminants remaining
on-site, CERCLA requires that the site be reviewed every five
years. If justified by the review, remedial actions would be
implemented at that time to remove or treat the wastes.

The present worth cost of this alternative for a 20-year period is
approximately $265,000. The time to implement this alternative is
two months.

ALTERNATm 2 - DEED AND GROONDWATBR-OSB RESTRICTIONS

This alternative would not require implementation of remedial
actions to address groundwater or subsurface soil contamination.
Deed restrictions would be imposed to prevent excavation in areas
of contamination. Groundwater-use restrictions would be imple-
mented in the affected area to prevent the use of contaminated
groundwater for drinking or irrigation purposes. These institu-
tional controls would also alert future property owners to poten-
tial site-related risks. A long-term monitoring program would also
be implemented. Deed and groundwater restrictions can be
implemented by state and local officials. Groundwater monitoring
can be performed using previously-installed monitoring wells and
residential wells.
-------
IS

The present worth cost of this alternative, for a 20-year period,
is approximately $279., 000. The time to implement this alterna-
tive would be 2 months.

3 - DEED RESTRICTIONS AMD QROUHDWATBR POMPTNf?,

This alternative would not require implementation of remedial
actions to address subsurface soil contamination. Deed re-
strictions would be imposed to prevent excavation in areas of
subsurface soil contamination. Groundwater would be collected
using a series of extraction wells and pumped to an on-site
treatment system.

To treat the volatile organic contaminants (VOCs) in the extracted
groundwater, an air stripping column and activated carbon adsorber
would be constructed at the site. The air and VOC mixture exiting
the air stripper would be treated by a vapor phase carbon
adsorption unit. The clean air would be emitted to the atmosphere^
It is anticipated that a carbon adsorption unit would be necessary
for the removal of the MEK, since air stripping would not remove
this contaminant from the groundwater. In addition, inorganic
contaminants in the groundwater would be removed by precipitation
prior to air stripping. Discharge piping would be installed to
pump the treated water to the drainage ditch located north of the
onion field or to Oak Orchard Creek. All air and surface water
discharges would comply with state and federal standards.

The present worth cost of this alternative is approximately
$4,874,000. The time to reduce the groundwater contaminant
concentrations to levels based on ARARs is estimated to be 20
years.

ALTERNATIVE 4 - SOIL CAPPING AMD GROONDWATER PUMPING. TREATMENT.
AND DISCHARGE TO SURFACE WATER

This alternative is similar to Alternative 3, except that synthetic
membrane caps would be installed over the areas of soil
contamination.

Under this alternative, the maintenance building would be disman-
tled, and decontaminated if necessary, and disposed of off-site.
Prior to capping, the areas would be graded to control surface
-------
19

water runoff and erosion. A protective soil cover would be placed
over the synthetic membrane, topsoil would be spread, and the
capped areas would be revegetated.

The groundwater pumping, treatment, and discharge scenario would
be the same as that discussed for Alternative 3. Monitoring would
be the same as in Alternative 3.

The present worth cost of this alternative is approximately
$5,143,000. Two months would be required to construct the ^ap.
The time to reduce the groundwater contaminant concentrations to
levels based on ARARs is estimated to be 20 years.

ALTERATIVE 5 - BOIL gJCAVATIOM AND O7T-8ITB DISPOSAL AND
3WATBR PUMPING.

This alternative is similar to Alternatives 3 and 4, except that
contaminated soil would be excavated and hauled to an off-site
Resource Conservation and Recovery Act (RCRA) landfill fox
disposal. :

Under this alternative, the maintenance building would he.
dismantled and decontaminated if necessary, and disposed of off-
site. Contaminated subsurface soil would be excavated, loaded into
trucks, and hauled to an approved off-site RCRA landfill for
disposal. (So as to comply with RCRA land disposal requirements,
treatment of the contaminated soil might be required prior to
disposal.) The excavations would be backfilled with clean fill
material from an off-site source. These areas would be covered
with a layer of topsoil and revegetated.

The groundwater pumping, treatment, and discharge scenario would
be the same as for Alternative 3. Monitoring would be the same as
Alternative 3.

The present worth cost of this alternative is approximately
$7,929,000. Two months will be required to remove the contaminated
soil. The time to reduce groundwater contaminant concentrations
to levels based on ARARs is 20 years.

ALTERNATIVE 6 - SOIL BICAVATION AND THERMAL DB8ORPTION AND
GROUKDWATBR POMPINQ, TREATMENT. AND DISCHARGE TO SURfACB WATER

This alternative is similar to Alternatives 3, 4, and 5, except
that contaminated subsurface soil would be excavated and treated
on-site using low-temperature thermal desorption to remove volatile
organic contaminants.

Under this alternative, the maintenance building would be disman-
tled, and decontaminated if necessary, and disposed of off-site.
Contaminated soil would be excavated and hauled to a mobile thermal
desorption unit that would be set up at the site. Treated soil
-------
20

would be used to backfill the excavations. The areas would be
covered with a layer of topsoil and revegetated. Because of the
presence of inorganic constituents in the soil, which thermal
desorption would not remove, treatment of the residual by chemical
fixation might be necessary before backfilling to comply with RCRA
land disposal requirements.

The groundvater pumping, treatment, and discharge scenario would
be the same as for Alternative 3. Monitoring would be the same as
in Alternative 3.

The present worth cost of this alternative is approximately
$6,899,000. Two months would be required to complete soil
treatment. The time to reduce groundwater . contaminant
concentrations to levels based on ARARs is estimated to be 20
years.

ALTERNATIVE 7 - IN-8ITO SOIL VAPOR EXTRACTION AMD QROUNPWATEfl
PDMPIKQ, TREATMENT. AND DISCHARGE TO flURTACg WATBR *

This alternative is similar to Alternatives 3, 4, 5, and 6, except
that contaminated subsurface soil would be treated by in-situ vapor
extraction using air extraction and injection wells.

Under this alternative, the maintenance building would be disman-
tled and decontaminated if necessary, and disposed of off-site.
Vapor extraction wells would be installed at the centers of Source
Area 1 and 2. Air injection wells would be installed around the
perimeters of the Source Areas 1 and 2. A vacuum would be induced
and the air that would be collected would be treated using vapor-
phase carbon adsorption. A synthetic membrane would be used to
prevent air leakage from the soil surface between the air
extraction and injection wells.

The groundwater pumping, treatment, and discharge scenario would
be the same as for Alternative 3. Monitoring would be the same as
Alternative 3.

The present worth cost of this alternative is approximately
$5,200,000. Six months would be required to reduce soil
contaminants to levies that would achieve groundwater ARARs. The
time to reduce groundwater contaminant concentrations to levels
based on ARARs would be 20 years.

ALTERNATIVE 8 - IN-8ITU SOIL FLUSHING AND GROOKDWXTBR PUMPIMG,
TREATMENT. AKP RECHARGE

This alternative is similar to Alternative 3, except that a portion
of the treated groundwater would be recharged to the aquifer in the
areas of subsurface soil contamination. This alternative would
attempt to restore groundwater quality and flush the residual
contaminants from the subsurface soil.
-------
21
The maintenance building would be dismantled, and decontaminated
if necessary, and disposed of off-site.

Monitoring would be the same as for Alternative 3.

The present worth cost of this alternative is approximately
$5,572,000. The time to reduce soil contaminant concentrations to
levels that would achieve groundwater ARARs is estimated to be in
10 years. The time to reduce groundwater contaminant concentra-
tions to levels based on ARARs is 20 years.

SUMMARY O7 COMPARATIVE ANALYSIS OT ALTERHATIVES

During the detailed evaluation of remedial alternatives, each al-
ternative is assessed against nine evaluation criteria, namely
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), overall protection of human health, and the environment*
state acceptance, and community acceptance. :

Each criterion will be briefly addressed, in order, with respect-
to the preferred alternatives for both soil and groundwater.

tin an Health and t^hA Fnvl T«nm«int
Alternative 8 would eliminate the potential risk to human health
and the environment. The reinjection of treated groundwater into
the aquifer would flush volatile organic contaminants from the
subsurface soil, thereby eliminating the potential risk associated
with any excavation under future land-use scenarios.

Alternatives 3, 4, 5, 6, 7, and 8 would be protective of human
health and the environment, but Alternative 8 provides a higher
degree of confidence in its ability to permanently remove the
contaminants from the soil.

Under Alternatives 1, 2, and 3, residual subsurface contaminants
would continue to leach into the groundwater, and continued off-
site migration of contaminants would result.

The aquifer at the site has a low yield due to its low trans-
missivity. Because increasing the pumping rate would cause
excessive drawdown of the water table, Alternatives 3, 4, 5, 6, 7,
and 8 would take an estimated 20 years to decrease ground- water
contaminant concentrations to levels based on ARARs. Alternative
1 would not reduce the present and future risk to human health and
the environment. Although, under Alternative 2, the risk to human
health would be potentially eliminated by restricting groundwater
use and soil disturbance, the risk to the environment would remain
unchanged.
-------
22
All technologies proposed in Alternatives 3 through 8 would be
designed and implemented to satisfy all action, contaminant, and
location-specific requirements. Since no federal or New York State
regulations specify clean-up levels for contaminants in the soil,
soil cleanup levels were calculated such that the aquifer will be
protective of public health and the environment. Alternative 8
would achieve the federal and state groundwater quality standards
for the organic contaminants and would remove subsurface soil
contamination. Alternatives 1 and 2 are not effective in complying
with groundwater ARARs.

Alternative 1 would not comply with state or federal drinking water
standards or criteria required for protection of the groundwater
resources. This is in contrast to Alternative 2, which would not
comply with chemical-specific ARARs for ingestion of groundwater,
but would meet all other ARARs. ;

C. Lono-tern Effectiveness and Permanence

Alternative 8 would effectively treat the most mobile wastes in
on-site soil, thus, effectively reducing the source of groundwater
contamination. Alternative 8 is considered most effective since
recirculating the groundwater would prevent potential aquifer
drawdown and would enhance the removal of contaminants adsorbed to
the saturated soil.

Under Alternative 6, which include excavation, thermal desorption,
and back-filling, inorganic contamination in subsurface soil would
not be removed. Hence, further treatment might be necessary before
ultimate disposal of the soil could occur.

Alternatives 3 through 8 would effectively reduce the potential
risks associated with the migration of contaminants in the
groundwater by extracting and treating them. Alternative 3 would
not be as effective in mitigating the leaching of subsurface soil
contaminants with subsequent migration to groundwater.

lobility.
Alternative 8, as well as Alternatives 3 through 7, would reduce
the toxicity, mobility, and volume of the organic contaminants in
-------
23

the groundwater. Under Alternative 8, the recharge of the treated
effluent would result in in-situ flushing of subsurface soil
contaminants that then would be collected by the extraction system
and treated. In contrast, Alternatives 6 and 7 would reduce
toxicity by in-situ vapor extraction and thermal treatment,
respectively. Alternatives 3 through 5 do not employ treatment to
reduce the toxicity, mobility, or volume of soil contaminants.
However, in Alternative 4, capping would reduce the mobility of
subsurface soil contaminants.

Alternatives 1 and 2 do not reduce the toxicity, mobility, or
volume of contaminants.

B. Short-Tern Effectiveness

Alternatives 4 through 8 would effectively reduce the potential
risks posed by groundwater contamination. For all of the
groundwater treatment remedies (Alternatives 3 through 8) , an
estimated pumping time of 20 years would be required to attain
ARAKs for groundwater. :

Under Alternatives 4 through 8, dust may be generated during
excavation and other material handling activities; therefore, dust
control procedures would be needed. Air- monitoring would be
required to determine whether steps are needed to protect on-site
workers and the general public from adverse air emissions.

Alternatives 3 through 8 include activities that could result in
potential exposure of workers and residents to volatilized
contaminants during the installation of the groundwater extraction
and reinjection systems. The threat to on-site workers, however,
would be mitigated through the use of protective equipment.

There would be minimal risk to the public and on-site workers
during implementation of Alternatives 3 and 8. In contrast,
Alternative 5 could pose a risk to the public if a spill occurred
during off-site transport.

Groundwater sampling under Alternatives 1 and 2 would not result
in a risk to Che public, on-site workers, or the environment.
However, workers would need protective clothing during sampling of
on-site wells.

P. Implamentability

The technologies and process options proposed in Alternatives 3
through 8 for pumping and treatment are all demonstrated and
commercially available. These systems are reliable, if properly
maintained.

All components of Alternative 8 utilize relatively common
construction equipment and materials and could be easily
-------
24

implemented. Also, in-situ soil flushing has been successfully
pilot tested and has performed on a full-scale basis for similar
organic contaminants. In contrast, the treatment technology for
Alternative 7 (in-situ soil vapor extraction), although
successfully demonstrated for the removal of volatile organics from
unsaturated soil, has had limited use to date. Furthermore, in-
situ soil vapor extraction is currently available from only a few
vendors nationwide.

All components of Alternatives 1 and 2 would be relatively easy to
implement. Groundwater monitoring can be performed using
previously installed monitoring wells and residential wells.

Under Alternative 4, approximately 2 months would be required to
construct the cap. It would take approximately 6 months to remove
the contaminated soil under Alternative 5 (excavation and
landfilling), Alternative 6 (excavation and thermal desorption),
and Alternative 7 (in-situ vapor extraction). Under Alternative
3, the cap could be constructed within 2 months. It would take an
estimated 10 years to remediate the soil under Alternative 8 (soil
flushing). The groundwater treatment scenario for Alternatives 3
through 8 would require an estimated 20 years for the groundwater
to meet state and federal standards. -'

Table 14 summarizes the implementation times for the eight
alternatives for comparison purposes.

a. cost

Only those technologies considered to be cost-effective and
appropriate to the magnitude of the problem were considered for
site remediation. Since groundwater pumping, treatment, and
discharge scenarios, with the exception of Alternative 8 in which
treated groundwater is reinjected into the aquifer, are similar
for Alternatives 3 through 8, the estimated cost associated with
groundwater remediation for any of these alternatives will be
approximately $4,874,000. Therefore, the difference in cost within
each alternative reflects the soil remediation component which
varies froa capping in Alternative 4 to excavation and off-site
disposal in Alternative 5.

The capital cost of Alternative 8 (in-situ soil flushing) is
estimated to be $1,917,000. Annual operation and maintenance costs
are estimated to be $259,700. Alternative 8 is cost-effective
because it has been determined to provide overall effectiveness
proportional to its cost, the net present worth value being
$5,572,000. The capital cost and present worth associated with
Alternative 5 (off site disposal) are $3,899,00 and $7,929,000,
respectively. The operation and maintenance costs for Alternative
5 are $285,800. It should be noted that Alternatives 5 and 8 are
the only alternatives which address both organic and inorganic
contamination present in both groundwater and subsurface soil.
-------
25
Under Alternatives 4, 6, and 7 inorganic and organic contamination
will be addressed in groundvater; however, only organic contamina-
tion will be addressed in subsurface soil. For Alternative 4
(capping) the. capital cost will be $1,716,000, while the present
worth cost will be $5,143,000. The operation and maintenance cost
of capping will be $237,400. The associated capital cost and
present worth for Alternative 6 (thermal treatment) will be appro-
ximately $3,319,000 and $6,899,000, respectively. The operation
and maintenance costs for thermal treatment will be $249,700. As
for in-situ vapor extraction, Alternative 7, capital cost and
present worth will be $1,761,000 and $5,200,000, respectively.
Operation and maintenance costs are estimated at $238,400 for the
in-situ soil vapor extraction alternative.

Table 14 summarizes the costs for the eight alternatives for
comparison purposes.

H. State Acceptance
*
Since groundwater in the vicinity of the site is used as a drinking
water source, the primary remedial action objective for the Byro'n
Barrel and Drum site is the restoration and protection of the
aquifer. Remedial alternatives that restore contaminated
groundwater to concentrations attaining federal and state
standards, and to some extent ensure protection of groundwater and
surface water from continued release of contaminants from soils,
are preferred by the State of New York.

Accordingly, under Alternatives 3 through 8, the restoration of
the aquifer at the site will be achieved by effectively treating
and removing groundwater contaminants and, hence, by eliminating
the potential risks to human health and the environment. However,
NYSOEC has concurred that Alternative 8 represents the maximum
extent to which permanent solutions and treatment technologies can
be utilized in a cost-effective manner for final remediation for
the site.
I . C^roTBUpitv Acceptance

Although groundwater ARARs are being violated at the site, the RI
and risk assessment have indicated that the site does not pose a
current threat to public health, since the contaminant plumes are
not currently threatening residential wells. As a result, the
community has expressed concern that remediation is unnecessary.

In addition, the Byron Town Board passed a resolution recommen-
ding that only institutional controls (deed restrictions in areas
of subsurface soil contamination and groundwater use restrictions
in the aquifer area) be employed at the site.
-------
26
Based upon consideration of the requirements of CERCLA, the
detailed analysis of the alternatives, and public comments, both
EPA and NYSDEC have determined that for Source Areas 1 and 2,
Alternative 8, in-situ soil flushing and groundvater pumping,
treatment, and recharge, is the most appropriate remedy for the
Byron Barrel and Drum site.

The major components of the selected remedy are:

- Dismantling, and decontamination if necessary of the
maintenance building, with disposal of the debris at an off-
site landfill;

- Extraction and treatment of the groundwater, via precipitation,
sedimentation, and filtration to remove the heavy metals, and
air-stripping and carbon adsorption to remove volatile organics
underlying the site. .

- Reinjection of treated groundwater to aquifer and, if
necessary, discharge of excess treated water to the closest
surface water body;

- Further evaluation of elevated surface soil inorganic
concentrations in Source Area 3, where organic contamination is
not present, to determine its ultimate disposition (i.e., off
site disposal or placement on the soil to be flushed);

- Disposal of the groundwater treatment residuals at an off-site
RCRA Subtitle C disposal facility; and

- Appropriate environmental monitoring, including monitoring of
residential wells, to ensure the effectiveness of the remedy.

Based upon modeling conducted during the RI/FS, it has been
estimated that 20 years will be required to remediate the aquifer.
Aquifer testing will be performed in an attempt to optimize the
pumping and reinjection system so as to minimize the time required
to remediate the aquifer. In addition, an annual review will be
conducted of the plume removal so that the system can operate in
the most efficient manner.

The contaminated media present at the Byron Barrel and Drum site
that will be addressed under the selected remedy are:

- Unsaturated subsurface soil in Source Areas 1 and 2;

- Saturated subsurface soil and groundwater originating from
Source Areas 1 and 2; and
-------
27

- Surface soil in Source Area 3.

Contaminated groundwater will be removed from the sand and gravel
unit of the aquifer by a system of extraction wells. It will be
treated on-site using a combination of precipitation, sedimen-
tation, and filtration for the removal of heavy metals, and air
stripping and carbon adsorption for the removal of organic
contaminants. Then, the treated groundwater will be reinjected
into the aquifer underlying the site. The exact number and
location of the extraction wells, the pumping routes, and the type
of the reinjection system (wells, french trench, etc.) will be
determined during the design phase.

Approximately 4,100 cubic yards of contaminated soil from Source
Areas 1 and 2 will be treated via in-situ soil flushing. In
addition, approximately 1,100 cubic yards of contaminated soil from
Source Area 3 will be further evaluated during the remedial design
to determine the ultimate disposition of the inorganic contamina-
tion, j

Air monitoring will be performed prior to, during, and following
construction at the site. Environmental monitoring will be
required during the life of the treatment process.

While the levels of contaminants present in the subsurface soils
do not pose a risk to public health, localized "hot spots" in
Source Areas 1 and 2 may be contributing to the contamination of
the aquifer. The concentrations of contaminants present in the
aquifer exceed state and federal standards. Flushing the residual
contaminants from the soil would prevent possible leaching of
contaminants into the aquifer once groundwater treatment ceases.

Groundwater treatment will continue until the federal and state
standards for the organic contaminations have been achieved and
until the levels of inorganic constituents are returned to
background.

Remediation Qoals

The risk assessment has concluded that the Hazard Index for
groundwater use based on maximum monitoring well concentrations
exceeds 1.0. Therefore, non-carcinogenic effects would be likely
if the aquifer at the Byron Barrel and Drum Site were developed for
potable use. Similarly, the incremental cancer risk based on
maximum monitoring well concentrations exceeds the upper bound of
the target risk range (2.4 x 10'3). An incremental maximum cancer
risk of 1 in 420 would be incurred if the aquifer is developed for
potable purposes under future conditions.

The purpose of this response action is to restore the groundwater
underlying the site to levels consistent with state and federal
ARARs and to ensure protection of the ground and surface water (in
-------
28

OaJc Orchard Creek adjacent to the site) from the continued release
of contaminants from soils. Since no federal or state ARARs exist
for soil remediation, the action level for the organic and
inorganic contaminants in soil was determined through a site-
specific analysis. This analysis used fate and transport modeling
to determine levels to which contaminants in soils should be
reduced in order to ensure no leaching of contaminants to
groundvater above MCL levels.

STATUTORY DETERMINATIONS

Under its legal authorities, EPA's primary responsibility at
Superfund sites is to undertake remedial actions that achieve
protection of human health and the environment. In addition,
Section 121 of CERCLA establishes several other statutory
requirements and preferences. These specify that when complete,
the selected remedial action for this site must comply with
applicable or relevant and appropriate environmental standards
established under federal and state environmental laws unless .a
statutory waiver is justified. The selected remedy also must tfe
cost effective and utilize permanent solutions and alternative
treatment technologies or resource recovery technologies to the
maximum extent practicable. Finally, the statute includes ~a
preference for remedies that employ treatment that permanently and
significantly reduce the volume, toxicity, or mobility of hazardous
wastes as their principal element. The following sections discuss
how the selected remedy meets these statutory requirements.

Protection of Human Health and the Environment

The low levels of soil contamination remaining at the site,
following the removal of all above-ground, drums and 40 cubic yards
of contaminated soil and debris, present minimal risk to human
health. The selected remedy further protects human health and the
environment through the removal and treatment of contaminants via
precipitation, sedimentation, and filtration to remove inorganics
and air stripping and carbon adsorption to remove organic
contaminants in groundwater. In addition, treatment of the
contaminated subsurface soils through the in-situ soil flushing
process will remove the most mobile wastes from the soil, resulting
in the elimination of a long-term source of groundwater
contamination, and it will mitigate the risks to public health and
the environment associated with the migration of those contaminants
off-site. There are no short-term threats associated with the
selected remedy that cannot be readily controlled.

Compliance with Applicable or Relevant and Appropriate Requirements

The selected remedy, in-situ soil flushing of contaminated soils
along with air stripping and carbon adsorption of the groundwater
will comply with all chemical-, action-, and location-specific
ARARS.
-------
29
Regulations in 40 CFR 144, the Underground Injection Control (UIC)
program, may be appropriate for discharge of the treatment plant
effluent to the subsurface. The UIC program prohibits injection
activities that allow movement of contaminants into underground
sources of drinking water, which may result in violations of MCLs
or result in adverse health effects. The treatment plant was
designed so that the effluent would meet 10"6 incremental cancer
risks and a cumulative Hazard Index below unity. Because the
groundwater recovery wells are designed to capture all released
contaminants, and since the remedial action will continue until
the remedial objectives for both groundwater and soil are attained,
this alternative complies with the intent of the UIC program.

State ARARs include State Permit Discharge Elimination System
regulations (6 NYCRR Part 750 through 758), groundwater quality
standards (6 NYCRR 703.5), air regulations (6 NYCRR Parts 200, 201,
212, and 257), and effluent standards and/or limitations fgr
discharge to groundwater (6 NYCRR Parts 703.6 and 703.7). ARAtfs
and federal, and NY State Air Guide-1, and the treatment systems
will be designed to meet state and federal monitoring during the
remedial action would be conducted to demonstrate that remedial
objectives for both subsurface soil and groundwater are obtained.
guidelines for the control ambient air quality standards (40CFR
50.6, 50.7, 50.12) are also applicable.

Cost-Effectiveness

The selected remedy is cost effective because it has been
determined to provide overall effectiveness proportional to its
cost; the net present worth value being $5,572,000. The cost of
the soil treatment component of the selected remedy is only 23
percent of the cost of the excavation and off-site disposal
alternative and only 34 percent of the cost of the alternative
involving on-site incineration, yet the selected remedy mitigates
as effectively as those alternatives all the risks posed by the
contaminants at the site. The cost of the groundwater component
of the selected remedy is approximately $4,874,000, similar to the
cost for th« groundwater components of the other alternatives,
offering th« same degree of certainty with regard to the effective
removal of all the organic and inorganic contaminants from the
contaminated groundwater.

Utilization of Permanent Solutions and Alternative Treatment
Technologies to the Maximum Extent Practicable

EPA and New York State have determined that the selected remedy
represents the maximum extent to which permanent solutions
and treatment technologies can be utilized in a cost-effective
manner for .the final source control operable unit at the Byron
Barrel and Drum site. Of those alternatives that are protective
of human health and the environment and comply with ARARs, EPA and
-------
30

NYSDEC have, determined that this selected remedy provides the best
balance of trade-offs in terms of long-term effectiveness and
permanence, reduction in toxicity, mobility, or volume achieved
through treatment, short-term effectiveness, implementability, and
cost, also considering the statutory preference for treatment as
a principal element and considering state and community acceptance.

The selected remedy is as effective as the other remedial action
alternatives in the short-term offering the additional advantage
of on-site treatment, thereby reducing potential risks to residents
along transportation routes. The implementability of the selected
remedy is comparable to the other alternatives. The selected
remedy is also the least costly treatment option and also is less
expensive than off-site disposal.

The selection of treatment of the contaminated groundwater is
consistent with program expectations that indicate that highly
toxic and mobile waste are a priority for treatment and often
necessary to ensure the long-term effectiveness of a remedy. All
the alternatives that consider remedial action are reasonably
comparable with respect to long-term effectiveness and
implementability, therefore, the major tradeoffs that provide the
basis for the selection of the remedy are reduction in toxicity,
mobility or volume, and cost effectiveness. The selected remedy
can be implemented with less risk to the area of residents and at
less cost than the other remedial action alternatives and is,
therefore, determined to be the most appropriate solution for the
contaminated groundwater at the Byron Barrel and Drum site.

With regard to implementability, the components of the selected
remedy are easily implemented, proven technologies and are readily
available.

Preference for Treatment as a Principal Element

By treating the contaminated soils via in-situ soil flushing and
by treating the groundwater by air stripping and carbon adsorption
the selected remedy addresses the principal threats posed by the
site through the use of treatment technologies. Therefore, the
statutory preference for remedies that employ treatment as a
principal element is satisfied.
-------
APPENDIX 1 - TABLES
-------
TABLE 1
OCCURRENCE AND DISTRIBUTION OP SUBSURFACE SOIL CONTAMINANTS
CONTRACT LABORATORY PROGRAM SAMPLES*M
BYRON BARREL AND DRUM SITE
BYRON, NEW YORK
Contaminant
acetone
toluene
ethylbenzene
•ylenes . •
1, 1,1-tr ichloroe thane
1, 1,2-tr ichloroethane
tetrachloroethene
tr ichloroethane
1,1-dichloroethene
•ethylene chloride
1 , 3-dichlor opropene
bU(2-ethylheiyl)phthalate
di-n-butylphthalate
naphthalene
pyrene
4, 4 '-DDT
4. 4 '-DDE
PCB 1254
aluminum
antimony
arsenic
Contract Required
Detection Limit
(CRDL)
(wg/kg)
10
5
5
5
5
5
5
S
5
5
S
330
330
330
330
16
16
160
200
60
10
Mo. of
Positive
Detections/
Mo. of Saaplei
1/20
9/20
2/20
3/20
4/20
1/20
10/20
10/20
2/20
5/20
1/20
4/20
1/20
1/20
1/20
1/20
1/20
1/20
20/20
1/20
17/20
Concentration
Range
-------
TABLE 1
OCCURRENCE AND DISTRIBUTION OP SUBSURFACE SOIL CONTAMINANTS
CONTRACT LABORATORY PROGRAM SAMPLES U)
BYRON BARREL AND DRUM SITE
BYRON, NEW YORK
PAGE TWO
Contaminant
bar i UN
cadmium
calcium
chromium
cobalt
copper
iron
lead
magneaium
manganese
nickel
potaaaium
ailver
aodium
vanadium
line
Contract Required
Detection Limit
(CROL)

6.8-69
1.2
1.670-91,600
1.7-15.5
1.7-1.2
3.2-12.1
3,210-12.300
4.7-22.6
1,970-26.500
137-536
3.7-8.8
240-699
57.7-144
61.4-756
4.0-14.4
17.4-122
arithmetic
Average
Concentration
(Mg/kg)O>
36
0.06
39.000
2.7
3.1
6.7
7,200
4.6
11.000
310
2.9
380
10
77
8.5
57
Geometric Mean
Concentration
-------
TABLE
OCCURRENCE AND DISTRIBUTION OF GROUNDMATER CONTAMINANTS
ROUND 3 MONITORING NELL SAMPLES(U
BYRON BARREL AND DRUM SITE
BYRON, NEW YORK
Contaminant
toluene
xylenet
1,3-dichlorobeniene
1,4-dlchlorobenzene
1,1, 1-tr ich lor oe thane
1, 1-dichloroe thane
tetrachloroethene
tr ichloethene
1,2-dichloroethene
1,1-dichloroethene
M-nitroaodiphenylamine
arsenic
bariiui
beryllium
cadmium
calcium
Contract Required
Detection Limit
(CftDL)
(pgA)
5
1 5
5
5
5
5
5
5
5
5
10
10
200
s
5
5,000
Mo. of
Positive
Detection*/
Mo. of Sample*
2/20
3/20
4/20
1/20
11/20
10/20
1/20
4/20
1/20
9/20
2/20
20/20
20/20
5/20
20/20
20/20
Concentration
Range
(M«/L)<2)
1.0
2.0-3.0
2.0-3.0
2.0
9.0-4,400
1.0-290
• 2
5.0-3,300
110
2.0-41
2.0
2.0-26
14-2,170
3.0-5.0
3.0-24
125.000-
549,000
Arithmetic
Average
Concentration
(U9/L)(3)
0.10
0.35
0.45
0.10
310
11
4.1
170
5.5
5.3
0.20
9.6
• 40
0.90
11
420,000
Geometric Mean
Concentration
(M9/L)«>
2.3
2.5
4.2
4.1
33
4.5
3.0
4.3
3.0
4.4
4.6
7.1
610
2.7
9.2
390,000
-------
TABLE 2
OCCURRENCE AND DISTRIBUTION OP GROUNDWATER CONTAMINANTS
ROUND 3 MONITORING WELL SAMPLESID
BYRON BARREL AND DRUM SITE
BYRON, NEW YORK
PAGE TWO
Contaminant
chromium
cobalt
copper
iron
lead
magnesium
manganese
mercury
nickel
potassium
silver
•odium
vanadium
sine
Contract Required
Detection Limit
(CROL)
(M9/L)
10
50
25
100
5
5.000
IS
0.2
40
5,000
10
5,000
50
20
Mo. of
Positive
Detections/
No. of Samples
19/20
20/20
20/20
20/20
20/20
20/20
20/20
5/20
20/20
20/20
1/20
20/20
11/20
20/20
Concentration
Range
IM9/LM2I
13-19
5.0-105
31-611
5,794-44,300
13-260
34,200-151,000
552-9,460
0.2-0.5
30-144
2,510-1.920
6
3,300-37,900
12-54
62-2,020
Arithmetic
Average
Concentration

33
23
110
25.000
73
•3.000
3.000
0.13
64
4,100
5.0
7,900
27
380
Calculated using "•" for nondetections.
Ml Calculated using 1/2 the CLP CRDL for nondetections.
-------
TABL
OCCURRENCE AND DISTRIBUTION OF GROUNDWATER CONTAMINANTS
ROUND 4 MONITORING WELL SAMPLESUl
BYRON BARREL AND DRUM SITE
BYRON, NEW YORK
Contaminant
benzene
toluene
chlorobenzene
1.2-di chlorobenzene
1, 3-d i chlorobenzene
1, 4 -di chlorobenzene
1.1.1-trichloroethane
1, 1,2- trichloroe thane
1. 1-dlchl or oe thane
tetrachloroethene
tr ichloroethene
1,2-d ichloroethene
1 , 1-d ichloroethene
vinyl chloride
chloroform
broatodichloroM thane
2-chloroethylether
aluminum
arsenic
bar iun
Method Detection
Limit (MDL)
(M9/L)
0.2
0.2
0.2
0.4
0.4
0.3
0.03
0.02
0.07
0.03
0.12
0.10
0.13
0.18
0.05
0.10
0.13
200
10
200
Mo. of
Positive
Detection*/
Mo. of Samples
1/20
5/20
2/20
1/20
2/20
t/20
11/20
•/20
11/20
1/20
4/20
1/20
11/20
1/20
3/20
2/20
1/20
20/20
1/20
20/20
Concentration
Range

2.3
1.7
1.1
2.0
1.6
0.46
26
0.49
2.7
2.9
4.2
2.4
2.4
4.0
1.4
1.6
5.7
24.000
5.6
480
-------
TABLE 3
OCCURRENCE AND DISTRIBUTION OP GROUNDWATER CONTAMINANTS
ROUND 4 MONITORING WELL SAMPLES
2.1
3.1
290,000
100
33
120
50,000
35
71,000
1.600
0.13
75
• .100
4.9 '
7.700
51
370
U) Organic analyses conducted using EPA Methods 601/602 (volatiles)
(2) Concentration range for positive detections only.
(3) GamVculated using "0" for nondetections. 4JL
using 1/2 the CLP CRDL for nond^Blctions.
-------
TABLE 4
INORGANIC RESULTS FOR OPGRADIENT AND
SITE GROUNDWATER SAMPLES
BYRON BARREL AND DRUM SITE
BYRON, NEW YORK
Cheaical
•luainun
arsenic
bariua
berylliua
cadaiua
calciua
chroaiua
cobalt
eopp«r
iron
lead
aagnesiua
manganese
mercury
nickel
potassiua
silver
sodiua
vanadiua
zinc
Maxiaua Concentration
( ug/1 )
UpgradientU)
58,900
8.0
1.490
4.6
20
549,000
171
69
406
159,000
170
151,000
8,340
-
143
12,900
6.0
9,370
129
917
Sit. (2)
279,000
24
5,230
22.6
24
2,070,000
479
377
2,110
666,000
631
500,000
19,800
0.7
606
35,300
8.9
50,800
574.0
7,580
Average Concentration
(ug/l)<3)
UpgradientU)
29,450
4.0
1,159.5
4.3
10
494,000
130
64.05
395
96,300
147.5
147,000
5,755
-
141.5
9,500
5.6
9,190
87
835
Sit. (2)
28,072
3.967
1,003.3
2.8
6.8
449,160 :
87.8
48.8
295.4
77,575
117.96
102,932
3,939
0.0933
97.38
7,475
1.3
10,769
72.2
1,116
(i) Upgradient samples from MW-4A.
(2) Site samples do not include wells 4A, 11B, 12B, 13B, or
14B.
H) Average concentrations determined using only one of any
two duplicate samples collected.
-------
TABLE 5
INDICATOR CHEMICALS
BYRON BARREL AND DRUM SITE
BYRON, NEW YORK
Carcinogens
benzene
1 , 4-dichlorobenzene
1,1, 2-trichloroethane
1 , 1-dichloroethane
1 , 2-dichloroe thane
tetrachloroethene
trichloroethene
1 , 1-dichloroethene
carbon tetrachloride
chloroform
methylene chloride
chloromethane
bromodichlorome thane
chlorodibromomethane
benzo(a)pyrene
benzo ( a ) anthracene
benzo(b) f luoranthene
bis(2-ethylhexyl)phthalate
N-nitro«odiphenylamine
Noncarcinogens
acetone
2-butanone
4-methyl-2-pentanone
toluene
xylenes
chlorobenzene
1 , 2-dichlorobenzene
1 , 3-dichlorobenzene
phenol
4-methylphenol
di-n-butyl phthalate
1,1, 1-trichloroethane
1 , 2-dichloroethene
benzoic acid
chromium
lead

-------
TABLE 6
EXPOSURE ROUTES AND INPUT PARAMETERS
BYRON BARREL AND DRUM SITE
BYRON, NEW YORK
Matrix
Exposure Rout*
Input Parameters
Soil
Dermal Contact
Maximum Surface Soil Concentration*
Average Surface Soil Concentrations
Soil Adherence factor: 1 og/ea?
Exposed Surface Area of Skint
Adult - 2,950 c»2
Adolescent - 2,330 ca2
Relative Absorption Fraction:
Volatile^ - 10%
Semivolatilas - si
Inorganics - 5%
Body weight:
Adult - 70 kg
Adolescent * 43 kfc
Exposure Frequency:
30 days/year
Soil
Accidental Ingestion
MaxiBUB Surface Soil Concentrations '
Average Surface Soil Concentrations
Soil Ingestion Rate: 100 mg/day
Body Weight:
Adult - 70 kg
Adolescent - 45 kg
Exposure Frequency: 30 days/year
Air
Oust Inhalation
Maximum Surface Soil Concentrations
Average Surface Soil Concentrations
Breathing Rate:
Adult -
Child -
Disturbance Frequency:
Vegetative Cover Factor
Source Surface Area:
Body weight:
Adult -
Child -
Exposure Frequency:
20 m3/day
10 m3/day
30 events/month
0
400 02

70 kg
10 kg
365 days/year
-------
TABLE 6
EXPOSURE ROUTES AND INPUT PARAMETERS
BYRON BARREL AND DRUM SITE
BYRON, NEW YORK
PAGE TWO
Exposure Rout*

[volatile Inhalation
water
' Ingestion/Inhalation
Input Parameters
Maxiaua Surface Soil Concentrations
Average Surface Soil Concentrations
•reathing Rate:
Adult - 20 aVday
Child - 10 aVday
Source Surface Area: 2,000 •?
•ody Weight:
Adult - 70 kg
Child- - 10 kg
Exposure Frequency: 363 days/year

Maxiaua Monitoring well Concentrations
Average Monitoring Well Concentrationa
Maxisma Residential Well Concentration*
Ingestion Rate:
Adult - 2 L/day
Child - 1 L/day
Inhalation Rate:
Adult • 20 eVday
Child - 10 aVday
Body Weight:
Adult - 70 kg
Child - 10 kg
Exposure Frequency: 36S days/year
-------
TABLE 7
NONCARCIMOGEN 1C RISK ESTIMATES
SOIL AND AIR EXPOSURE ROUTES
BYRON BARREL AND DRUM SITE
BYRON. MEM YORK
Indicator Ch«Blcal
1,1.1'tf Ichloi o«th«n«
totrachloro«th*na
trlchloioothon*
chlofofoia
b«nioic *cld
b«oio|a)«nthiac«n«
b«nio(b)f luocanthcn*
b«aso(«)py(«na
t>l*(]-«lhrlh«irl)plUh*Ut«
dt-n-butyl phth«l«t«
chfoalua (III)
U«4
Total (••••rd liuUi)
Do*«/M(«r«»c« OoM
OotMU C*al«ct<»
IUila*ia-Cat«
«.»«io-»
J. OilO-^
-(11
•.)*IO**
i.tiio-i
-
.
-
».»«io-»
l.4«10->
i.i«io-<
4.1.10-J
4.1*10-)
Av«ra««-C««*
).)•!•->•
i.i«io-«
-
i.uio-*
t.OBl*-*
-
-
-
••••10-'
1. »•!•-•
l.SalO-S
l.tilO-4
).««10-4
•ccidaatal l»«««tlo«l >)
HoBlaua-Cai*
4. !•!•-•
1. )•!•->
-
).!•!•-•
!.]•!•-•
-
-
-
».••!•-•
l.]il«->
l-Sil*'4
J.J.10-*
I.1.10-*
*••!•§• -€•••
1. Ill* tB
4. 1»IO->
-
4.iiie->
2. ••!•-•
-
-
-
l.1«l«-'
7.4.1*-*
1. !•!•-*
1.J.JO-*
».«•!•«
Ou«( lBlMl«tl«al»
IUllBU«-C«t«
4.*ilO-»
J.l.lO »1
-
-
-
-
-
-
-
-
-
-
».««!•-»»
•••(•••-£•••
l.lilO-D
l.lil|-l>
-
-
-
.
-
-
-
-
-
-
a.iiio-i)
VoUtllo l»h«lat !••<>)
IU«laua-C«i«
».4«1« »
>.«iio->
-
-
-
-
-
-
-
-
-
-
».«>io-*
•••r*fo-Ca««
•.••1«-V
».?«io-'
-
-
-
•
-
-
-
-
-
-
l.tilO-*
(1) Kink estimates based on adolescent receptor* exposed at the source.
(2) Risk estimates based on child receptors exposed at downwind locations.
(3) - Not applicablei Reference Dose unavailable for ingestlonal and/or inhalatlonal exposure.
-------
TABLE I
CARCINOGENIC BISK ESTIMATES
SOIL AMD AIR EXPOSURE ROUTES
BYRON BARREL AND DRUM SITE

Indicator Chanical
1,1.1-tf ichloioothano
totrachloroolhono
trlchloroothoa*
chloioforai
boa.oic acid
boaio(a)anthracono
bon.o(b)f luoranthana
boB.o(a)pyrono
bU(2-othylho.yl|phthalato
dl-B-butyl phthalato
chfoaltM. (III I
load
Total
BYRON, NEW YORK

Oorv^l CoatactHI
Ma.iau«-Caao
-
7.1.10-11
1.0.10-10
2.4.10-"
-
I.7.IO-"
2.2.10-*
1.1.10-i
j.*.io-»«
-
-
-
J...10-"
a.ota«o-Caao
-
l.ftalO-19
4.4B10-U
l.laW'H
-
• .2.IO-"
i.s«io-»
4.2Bl«-»«
l.2.IO-»«
-
-
-
2.U10-*
iBC.OMBtal
Accidoatal
NaalaMa-Caao
-
2.4110-11
j.».ia-«
i. 2.10-11
-
1. !•!•-•
1. ».!*-•
1.7.10-*
J. 2.10-H
-
-
-
2.4.10-i
lM«*tiea(H
»....«. C...
-
o.t.io-iJ
1. »•!•-"
l.lalO'H
-
4.2«10"H
t.«BlO-l«
2.t.lO-l»
0.0.10-11
-
-
-
1.4.10-*
Caacoi atak
Oust lahalatloaO)
Ha.tM.-Ca.o
-
J.1.18 »»
7.J.18-U
i.«.io-»«
-
I.I.IO 12
1.4B10-H
I. 1.10 U
-
-
-

2.t.lO-'
*«o(a«o-Caao
-
i.o.io-i*
j.i.io-i*
2.S.IO «
-
4.0.10 l«
•.4.10 1»
2.7.10-12
-
-
-
-
I.7.10-
Volatllo latkalatloaO)
Ha.l^.Caao
-
I.4.IO-*
1.7alO->
1 . 1.10''
-
S. I.IO'I'
i.s.io-ii
o.«.io-is
-
-
-
-
J.o.io-'
a«orafo-Caa«
-
s. i.io-ii
7.3alO-*
I.I. 10-*
-
2.0.10-1'
t.».io-i»
J. 2.10-1*
-
-
-
-
2.4.IO-*
(1) Risk estimates baaed on adult receptor* eipoaed at the alt*.
(2) Riak eatlauitea baaed on adult receptora eipoaed at downwind locatlona.
(3) - Not applicablei Surface aoll Indicator chemical haa no known carcinogenic effects or will not be aubject to volatile
ealaalona (Mtala).
-------
TABLE 9
NONCARCINOGENIC RISK ESTIMATES
GROUNDWATER USE
BYRON BARREL AND DRUM SITE
BYRON, NEW YORK
Indicator Chemical
k
benzene
toluene
xylenes
chlorobenzene
1 , 2-dichlorobenzene
1 , 4-dichlorobenzene
1,1, 2-trichloroethane
1,1, 1-t r ichloroethane
1,2-dichlorpe thane
1 , 1-dichloroethane
tetrachloroethene
trichloroethene
1 , 1-dichloroethene
vinyl chloride
carbon tetrachlor ide
Dose/Reference Dose
Maximum Monitoring
Well
Concent rat ions ( * )
-O)
1.1 x 10-4
1.7 x 10-«
1.1 x 10-3
2.8 x 10-6
-
2.6 x 10-3
1.6 x 100
-
8.3 x 10-2
2.5 x 10-1
-
1.3 x 10-1
-
-
Average Monitoring
Well
Concent rational 2)
-
1.6 x 10-5
2.0 x 10-&
1.8 x 10-«
1.4 x 10-'
-
1.4 x 10-«
1.5 x 10-1
-
5.0 x 10-3
1.2 x 10-2
-
1.7 x 10-2
-
-
Residential Well
Concentrations
-
-
-
-
-
-
-
-
-
-
7.5 x 10-«
t-
-
-
-
3.8 x 10-«
-------
TABLE 9
NONCARCIMOGEN1C RISK ESTIMATES
GROUNDWATER USE
BYRON BARREL AND DRUM SITE
BYRON, NEW YORK
PAGE TWO
Indicator Chemical
t
chloroform
methylene chloride
bromodich lor ome thane
d ibromoch lor ome thane
N-nitrosodiphenylamine
chromium
lead
Total (Hazard Index)
Do«*/R«t«r«nc« Dot*
Maximum Monitoring
Well
Concent rational)
1.5 x 10-3
1.3 x 10-3
-
2.0 x 10-5
-
1.4 x 10-2
1.3 x 101
1.5 x 101
Average Monitoring
Well
Concentrations^)
2.7 x 10-5
-
-
-
-
2.5 x 10-3
2.4 x 100
2.6 x 100
Residential Well
Concentrations
-
-
-
-
-
-
8.2 x 10-2
8.3 x 10-2
(D Based on four rounds of monitoring well sampling and analysis.
(2) Based on round 3 and round 4 monitoring well sampling and analysis.
(3) - Not applicable: No Reference Dose available or contaminant not detected.
-------
TABLE 10
CARCINOGENIC RISK ESTIMATES
GROUNDWATER USE
BYRON BARREL AND DRUM SITE
BYRON, NEW YORK
Indicator Cheaical
k
benzene
toluene
xylenes
chlorobenzene
1 , 2-dichlorobenzene
1 , 4-di chlorobenzene
1,1, 2- 1 r ichloroe thane
1 , 1, 1-trichloroethane
1 , 2-dichloroethane
1 , 1-dichloroethane
tetrachloroethene
trichloroethene
1,1-dichloroethene
vinyl chloride
carbon tetrachloride
Incremental Cancer Risk
Maximun Monitoring
Nell
Concent rat ionsU)
4.0 x 10-7
-HI
-
-
-
7.8 x 10-'
5.0 x 10-*
-
9.4 x 10-7
4.3 x 10-«
7.1 x 10-5
1.0 x 10-3
9.3 x 10-«
2.5 x 10-«
-
Average Monitoring
Well
Concent rations (2)
2.0 x 10'*
-
-
-
-
3.9 x 10-»
2.6 x 10-7
- ' ' • "
-
2.6 x 10-5
3.5 x 10-*
5.0 x 10-*
1.2 x 10-«
1.2 x 10-'
-
Residential Well
Concentrations
-
-
-
-
-
-
- • • '•.••'•:
-
-
-
2.2 x 10-7
9.7 x 10-«
.
'
3.1 x 10-§
-------
TABLE 10
CARCINOGENIC RISK ESTIMATES
GROUNDWATER USE
BYRON BARREL AND DRUM SITE
BYRON, NEW YORK
PAGE TWO
Indicator Cheaical
»
chloroform
methylene chloride
bromodichlorome thane
dibromochlorome thane
N-nitrosodiphenylamlne
chromium
lead
Total
Incremental Cancer Risk
Maximum Monitoring
Well
Concent rat ions ( * >
4.4 x 10-7
7.5 x 10-7
4.9 x 10-7
1.9 x 10-7
1.6 x 10-7
-
-
2.4 x 10-3
Average Monitoring
Well
Concent rational 2)
8.1 x 10-9
-
4.7 x 10-»
-
1.6 x 10 •
-
-
2.0 x 10-4
Reaidential Well
Concentrations
-
-
-
-
-
-
-
3.4 x 10-7
U) Based on four rounds of monitoring well sampling and analysis.
(2) Based on round 3 and round 4 monitoring well sampling and analysis.
O) - Not applicable: Contaminant not detected or noncarcinogenic.
-------
TABLE 11
COMPARISON OF MAXIMUM SURFACE WATER CONTAMINANT CONCENTRATIONS
AND AMBIENT WATER QUALITY CRITERIA
BYRON BARREL AND DRUM SITE
BYRON, NEW YORK
\
Chemical
toluene
1,1,1, -tr ichloroethane
1 , 2-dichloroethene
chloromethane
phenol
4-methylphenol
arsenic
copper
lead
nickel
vanadium
zinc
Maximum Surface
Water
Concentration
(M9/L)
9
7
0
39
13
62
31.9
97
28.2
17
51
391
Ambient Water
Quality Criteria*!)
(U9/L)
Acute
17,500
18,000
11,600
11,000
10,200
—
360
120
1,082
7,913

654
Chronic
—
—
—
—
2,560
—
190
67
48
880

592
NY State Surface
Water Standard
(P9/L)
Class D

5.0

360
120
1,082
8,641
190
1,735
Class C

5.0

190
67
48
448
14
30
Ambient water quality criteria for the protection of freshwater aquatic
life. Inorganics are based on a calculated hardness of 763 mg/L.
-------
TABLE 12
SOURCE CONTROL (SOIL) CLEANUP LEVELS
BYRON BARREL AND DRUM SITE
BYRON, NEW YORK
Chemical
ethylbenzene
toluene
xylenea
1,1,1-trichloroethane
tetrachloroethene
trichloroethene
Soil Cleanup Level (ug/kg)
ARAR-Basedd)
56,000
45,000
8,200
2,300
140 <4)
47
Risk-Based
(10-«)<2>
52,000 <5)
36,000 (5)
58,000 (5)
5,500 (5)
8.4
4.9
Risk-Based
(10-4)0)
52,000 (5)
36,000 (5)
58,000 (5)
5,500 <3)
840
490 ;
(1) Cleanup level based on groundwater cleanup level
corresponding to the MCL or MCIX3 unless otherwise noted. ; .
(2) Cleanup level based on a cumulative incremental cancer risk
of 10-* (groundvater use) unless noted otherwise.
(3) Cleanup level based on a cumulative incremental cancer risk
of 10-4 (groundwater use) unless noted otherwise.
(4) Cleanup level based on an assumed groundwater cleanup level
of 5 ug/1 (similarity to other chlorinated aliphatics)
(5) Cleanup level based on a Hazard Index below 1 (i.e., 0.9).
-------
TABLE 13
MANAGEMENT OP MIGRATION (GROUNDWATER) CLEANUP LEVELS
BYRON BARREL AND DRUM SITE
BYRON, NEW YORK
Chemical
benzene
toluene
xylenes
chlorobenzene
1 , 2-dichlorobenzene
1 / 4-dichlorobenzene
1,1,2-trichloroethane
1,1, 1-t r ichloroe thane
1 , 2-dichloroethane
1 , 1-dichloroethane
tetrachloroethene
trichloroethene
1,1-dichloroethene
vinyl chloride
chloroform
methylene chloride
bromodichlorome thane
chlorodibromome thane
N-nitrosodiphenylamine
2-butanone
carbon tetrachloride
ARAR-B*sedU)
2,000(50)0)
440(50)
488(20)<«)
620/4.7
75/4.7
5(0.6)0)
200(50)
5(0.8)
5(50)0)
5(0.7)0)
5/10
7(0.07)
2/5
100/100
100(50)
100(50)
100(50)
4.9(50)<«)
172(7)
5
(1) ARAR-b««ed^cleanup levels based on MCLs/MCLGs unless
noted otherwise.
(2) The first value is the Federal ARAR-based value. The
second is the State Ambient Water Quality Standard for
Class GA groundwater (NO - not detectable).
(3) Value in parentheses is the State Ambient Water Quality
guideline.
(4) AWQC for the protection of public health through drinking
water exposure.
(5) Based on MCL/MCLG for 1,2-dichloroethane.
(6) Based on MCL/MCLG for trichloroethene.
(7) EPA Lifetime Drinking Water Health Advisory.
-------
TABLE 14

COMPARATIVE COST ANALYSIS OF ALTERNATIVES
BYRON BARREL AND DRUM SITE
BYRON, NEW YORK
Alternative 1
lie further Action vlth Monitorlaf
Alternative 2
end GrouMivater U*e
•ectrlctioea
Alternative J
6reun4vater Puaiplof, Treatment,
••4 Discharge to furfaca Water
1 !
Alternative 4
CapoI09. Cieundvater rwej>i*f.
Treatment, ana* Dlacharfe te
•urfac* W*t«r
COSTS
Capital: M
Annual (UN: fll.tOO
rraiant Hoith: fltS.OOO
Capltali |1S, 000
Aaaual OftMl fll.aOO
»<«t«at Mtrtfci $a?t.OOO
Capltali |l, SOt, 000
Anaual OtMi 1212. TOO
fra««nt Mortbi f«, •74.000
C«pU»li 11,714.000
Annual O4«i 1117,400
rtacant Mnrtbi fl.141.000
TINE TO IMPLEMENT
Co! If
Croundttoter :
•oili
Croundwater I
•elli
6roun4vateri 20 years
*«Ui 2 awntha
Crauedvatari 20 veara
Alternative S
Otfatte Olsposel, Crouo4«atar
Pumping, Treatment, and Discharge
to Curfece Mater
Alternative 4
The ratal Treatment, Croundwater
fuaplof, Treatment, an4 Olscharfe
te Surface Meter
Alternative 1
In-iltu taper Satractloa,
6reue4»eter rumpinf, Treatawnt,
an4 Ol*char«e te fur face Meter
Alternative 0
• la-fltu foil riuahlef,
Creundvater tuaylef, treatment and
Olschargeiite the fuhaurface
COSTS
Capltali fl.Ott.OOO
Annual O&Ni «24>,400
rreeent Morthi I7.929.000
Capital! »1. lit, 000
Annual 0»M| |24*,700
rreaent Mortal f4,*tt,OOO
Capltali 11,741,000
Annual OtMi 1210,400
•reaent Morthi IS, 200. 000
Capltali ||. 917.000
Annual OtMi I2S9.700
treaeat North: IS.S72.000
TINE TO IMPLEMENT
folli 2 •entb*
Croundnater: 20 jraar*
Solli 2 •eetna
Crouodvateri 20 year a
ftolli 4 •oath*
Oreuadwateri 20 rear a
•«lli <10 yeara
Crouadoateri 20 feare
-------
APPENDIX 2 - FIGURES
-------
GENE8EE CO
*nrnn^

ALBION QUADRANGLE
HOLLEY QIJAfMAMRI F
BATAVIA NORTH QUADRANGLE
BYRON QUADRANGLE
SCAKMFHT tL\^ / . \ *2u~I'^S~""~ • . > ^—"1 *-
BASE MAP IS A PORTION OF THE BYRON, ALfitiN, HOLLEY, AND BATAVU NORTH, NY QUADRANOLES (U&0&, 73 MNUTE SERCS) CONTOUR INTERVAL TEN FEET
FIGURE I
LOCATION MAP ,; ,..
BYRON BARREL AND DRUM SITE. BYRON. NY
-------
LOCATION OF SOURCES/FORMER DRUM STORAGE AREAS
BYRON BARREL AND DRUM SITE. BYRON. MY
FICUflC 2
-------
.. K*.

. Ki. Kl. M I.

Ik! HIM MUlllM IUII |.*rulB>Ulr » •*/'!> "°
Ki
1.1.1-lrlUUra.ltow
Ult*c*~
Irlcftl*
CHUORINATtD ALIPHATIC SURFACE 9OL CONTAMXAT10N (uo^
BYRON BARREL AND DRUM SITE. BYRON. NY
FIGURE 3
-------
INORGANIC SURFACE SOU. CONTAMINATION (mo/^)
BYRON BARREL AND DRUM SITE. BYRON. NY
FIGURE 4
-------
\
lEGEMD

MO MDTVICATKM
LOCATION OF TEST PITS
BYRON BARREL AND DRUM SITE. BYRON. NY
•So
FIGURE 3
-------
Vfr -* -** - —r
\ " T^K?.
j —^te»J^~^-
MM*
-------
, ^ , I .
/,.. HU.
/ •••••/I to/I
StM-OZ
Itt IM
ICAJ t.l
Uf IS
BUI i.1
SIOI-OS (i'l
1CA «
SMI-0? (2')
1C* 4 It
ICt It
KCI 14
SM/-0& It')
1CA 41
ICA - 1.1.1-trtckUrwlMM
ICU • I.I.I-trlchUrwtlUM
ICt -
KCI -
ICI •.«
SMW-07 (D
1C* ft
ICAJ f.l
t *UcU* •*•«• UM MtiMd AlUcltM I tot I
CHLORINATED ALIPHATIC SUBSURFACE SCTL COMTAUIMATION
MAINTENANCE BUILDING SOURCE
BYRON BARREL AND DRUM SITE. BYRON. NY
FIGURE 7
-------
tl
to • IM*
• 19 •
FjCUME 8
INORGANIC SUBSURFACE SOL CONTAMINATION (ma/kg)

BYRON BARREL AND DRUM SITE. BYWONL NY
tuu mnn
-------
•"" /"V-:

"I ( !•• •
I liu«/. \ /• ,
^ •••nil • . ••• • • 'IV./

4 '
FIGURE 9
CHLORINATED AUPtUTtCS DETECTED M MONITDRINQ WP-L SABLES lua/l^-11/7-9/88

BYRON BARREL ANO DRUM SITE. BYKON. NY
-------
Hs
MS-2
I.
,....... v
IV..., , ^_

( <
«•*• \^
Ito IMlfttal fMlU l»r IM >iH»ln«t tIM

* II*. to. WL «. W. KII.

fc« 4MKU« ikOTi IM •»»< OUdfaa IMI
FIGURE to
CHLORINATED AUPHATK3 QCTtCTH) 9t MONITORIN9 K€U. 3AMPIXS (*l/l)

BYRON BAHgL AMD DRUM SITE. BVHOM. MY
-------
• • * »

FMt UBTMG UQMTOMMG «CU
FIGURE II
INORGANIC CONTAMINANTS DETECTED IN MOMTDRING WELL SAMPLES (uq/l|
BYRON BARREL AMD DRUM SITE. BYRON. NY
-------
MB- 7A« OU» MMKMM MIL |V-M««I)
CHLORINATED ALIPHAT1CS AND KETDNES DETECTED
IN MONITORING WELL AND WELL POINT SAMPLES (ug/l)-4/21/89 TO S/ll/89
BYRON BAIWgL AND DRUM SITE. BYBQM. MY
FIGURE 12
-------
K-UOTM MOMTUWM WLL
1-Sr :
i c=>
•VrtlrUVOTMVI
FIGURE 13
ESTIMATED EXTEMT OF CONTAMINANT PLUMES
BYRON BARREL AND DRUM SITE. BYRON. NY
-------
APPENDIX 3 - ADMINISTRATIVE RECORD INDEX
-------
BYRON BARREL AND DRUM SITE
ADMINISTRATIVE RECORD FILE *
INDEX OF DOCUMENTS
REMOVAL RESPONSE

Sampling and Analysis Plans

P. 1-58 Letter to Mr. Eduardo Gonzales, U.S. EPA, from Mr.
Robert Hubbard, NUS Corporation, re: Residential
well sampling results, 11/13/87. The following
are attached:

a) A laboratory analysis summary,
b) A record of communication concerning the CLP
Organic Data Package,
c) Standard Operating Procedures,
d) A Supplemental Organic Analytical report. ;

Correspondence

P. 59-104 Letter to R. Salkie, F. Rubel, W. Mugdan, J.
Czapor, G. Pavlou, T. Fields, and G. Turner from
Mr. Bruce E. Sprague, U.S. EPA, re: Transmittal
of the On-Scene Coordinator report, 12/8/87. The
report is attached.
REMEDIAL INVESTIGATION

Sampling and Analysis Plans

P. 105-332 Report: Final Field Operations Plan, Remedial
Investigation and Feasibility Study, Byron Barrel
and Drum, Byron, New York:, prepared by Ebasco
Services, Inc., 3/88. References are listed on
P. 221.
* Administrative Record File available 8/22/89.

Note: Organizational and company affiliation is mentioned only
when it appears in the record.
-------
Work Plans

P. 333-346 Final Work Plan Memorandum for Remedial
Investigation/ Feasibility Study/ Byron Barrel and
Drum Site, Byron, New York, prepared by Ebasco
Services, Inc., 9/89.

P. 347-492 Report: Final Work Plan, Remedial Investigation/
Feasibility Study, Byron Barrel and Drum Site,
Byron, New York, prepared by Ebasco Services,
Inc., 2/88. References are listed on P. 458.
FEASIBILITY STUDY

Feasibility Study Reports

P. 493-681 Report: Final Remedial Investigation/Feasibility
Study, Volume I, Remdedial Investigation Reportt_ :
Byron Barrel and Drum Site/ Byron, New York,
prepared by Ebasco Services, Inc., 7/89. : .
References are listed on P. 679.

P. 682-828 Report: Final Remedial Investigation/Feasibility
Study, Volume II, Feasibility Study, Byron Barrel
and Drum Site, Byron, New York, prepared by Ebasco
Services, Inc., 7/89. References are listed on
P. 825.

P. 829-1355 Report: Final Remedial Investigation/Feasibility
Study/ Volume III, Appendices A-E, Byron Barrel
and Drum Site, Byron, New York, prepared by Ebasco
Services, Inc., 7/89.

P. 1356-1615 Report: Final Remedial Investigation/Feasibility
Study, Volume IV, Appendices F-I, Byron Barrel and
Qrum Site, Byron, New York, prepared by Ebasco
Services, Inc., 7/89.

Proposed Plan

P. 1616-1631 Report: Proposed Plan for Byron Barrel and Drum
Site, Byron, New York, prepared by U.S. EPA, 8/89.
-------
ENFORCEMENT

Endangermcnt Assessments

P. 1632-1710 Report: Final Work Plan, Private Water Supply
Sampling, Byron Barrel and Drum Site/ Byron, New
York, prepared by Ebasco Services, Inc., 7/1/86.
References are listed on P. 1645.

PUBLIC PARTICIPATION

Community Relations Plans

P. 1711-1737 Report: Final Community Relations Plan for the
Byron Barrel and Drum Site, Byron, New York,
prepared by Ebasco Services, Inc., 4/88.

Documentation of Other Public Meetings

P. 1738-1773 Report: Final Public Meeting Summary Report,
Byron Barrel and Drum Site, Byron, New York,
prepared by NUS Corporation, 10/5/88.
-------
BYRON BARREL AND DRUM SITE
ADMINISTRATIVE RECORD FILE *
UPDATE
INDEX OF DOCUMENTS
RECORD OF DECISION

Record of Decision

P. 1774-1943 Declaration for the Record of Decision, prepared
by the U.S. EPA, signed September 29, 1989.
Record of Decision is attached.
* Administrative Record File Update available October 11,
1989.

Note: Organizational and company affiliation is mentioned only
when it appears in the record.
-------
APPENDIX 4 - NY8DEC LETTER OF CONCURRENCE
-------
New York Slat* Department of Environmental Conaervatlon
50 Wolf Read, Albany, New *xt 12239
ThoniM C. Jodlnf
Mr. Stephen D. Luftig, P.E. QFP 9 fl
Director ocr * 7
Emergency and Remedial Response Division
United States Environmental Protection Agency
Region II
26 federal Plaza
New York. New York 10278

Re: Byron Barrel and Dram Site, Genesee County, Site No. 8-19-005,
Record of Decision

Dear Mr. Luftig:

The revised draft Record of Decision (ROD) for Byron Barrel and Drum site,
received by the New York State Department of Environmental Conservation
(NY3DEC) on September 25 1989, has been reviewed. The NYSDEC concurs with the?
selected remedy as presented in the draft ROD for in-situ soil flushing of :
contaminated soils in Source Areas 1 and 2, treatment of the contaminated
groundwater emanating from Source Areas 1 and 2, and further evaluation of the"
inorganic contaminated surface soils in Source Area 3.

Notwithstanding this concurrence on the technical aspects of the remedy, the
NYSDEC still objects to the United States Environmental Protection Agency
(US2PA) assertions that the operation and maintenance (0 & M) of the treatment
system will not be funded at 90 percent with Federal funds after 10 years of
operation. These objections are based on the fact that soil flushing is the
remedy and should be funded just as any capital remedial cost i.e., excavation.
Therefore, EPA should participate in all costs associated with the soil
flushing remedy until its conclusion, including dismantling, while it is
acknowledged that 0 & M of the groundwater treatment system will become
NYSDEC' s responsibility as per Section 104 (a) (6) of C2HCLA as amended,
however, the 10 year period should not start until after soil flushing i*
complete. EPA should acknowledge in the ROD this time table and make
provisions for demobilization of the soil flushing system, as well as, the
ground water treatment system/recovery wells at a 90/10 cost share once the
project is complete. Also, the ROD should clarify whether EPA retains
ownership of all equipment or this reverts to NYSDEC.

If you have any questions concerning this natter, please contact Mr. Michael J.
O'Toole, Jr., P.E. at 518/457-5861.
Sincerely
Edward \$>. Sullivan
Deputy Commissioner
cc: William McCahe, USEPA, Region II
Joel Slngernan, USEPA, Region II
Sandra Stanish, NYSDOH, Albanv
-------
APPENDIX 5 - RESPONSIVENESS SUMMARY
-------
EPA WORK ASSIGNMENT NUMBER: 161-2LD6
EPA CONTRACT NUMBER: 68-01-7250.
EBASCO SERVICES INCORPORATED
RESPONSIVENESS SUMMARY
BYRON BARREL AND DRUM SITE
BYRON TOWNSHIP, NEW YORK
SEPTEMBER 1989
NOTICE

THE INFORMATION IN THIS DOCUMENT HAS BEEN FUNDED BY THE UNITED
STATES ENVIRONMENTAL PROTECTION AGENCY (USEPA) UNDER REM III
CONTRACT NUMBER 68-01-7250 TO EBASCO SERVICES INCORPORATED
(EBASCO).
-------
September 22, 1989

Ms. Lillian Johnson
Community Relations Coordinator
U.S. Environmental Protection Agency
26 Federal Plaza
New York, New YorJc 10278

SUBJECT: REM III PROGRAM - EPA CONTRACT NO. 68-01-7250
WORK ASSIGNMENT NO.: 161-2LD6
BYRON BARREL AND DRUM SITE
RESPONSIVENESS SUMMARY

Dear Ms. Johnson:

Ebasco Services Incorporated (EBASCO) is pleased to submit thisV *
Responsiveness Summary for the Byron Barrel and Drum site. If
you have any comments, please call me at (201) 460-6463 or Joseph*
Rlcciani at (201) 906-2400.

Very truly yours,
Oev R. sachdev, PhD, PE
Regional Manager-Region II
cc: M. Shaheer Alvi
P. EBneJcing
E.
'••A.--
-------
Ms. Lillian Johnson
ACZHOWLZDOBCEHT OF RBCXZPT
Please acknowledge receipt of this enclosure on the duplicate
copy of this letter and return the signed duplicate letter to:
Or. Dev sachdev, Ebasco Services Incorporated, 160 Chubb Avenue,
Lyndhurst, New Jersey 07071.
Lillian Johnson Oats
-------
EPA WORK ASSIGNMENT NUMBER: 161-2LD6
EPA CONTRACT NUMBER: 68-01-7250
EBASCO SERVICES INCORPORATED
RESPONSIVENESS SUMMARY
BYRON BARREL AND DRUM SITE
BYRON, NEW YORK
AUGUST 1989
Prepared by:
Approved by:
Joseph Ricciani
REM III Community Relations
Specialist
ICF Technology, Inc.
Bert. Hubbard
REM III Site Manager
NUS Corporation
Approved by:
Approved by:
Sheila Conway
REM III Region II
Community Relations
Manager
ICF Technology/
Dev R. Sachdev, Ph.D, P.E.
REM III Region II
Manager
Ebasco Services, Inc.
-------
TABLE OF CONTENTS
INTRODUCTION
RESPONSIVENESS SUMMARY OVERVIEW 1
Results of the Remedial Investigation 2
Proposed Alternative ' 3
Information Repositories 4

BACKGROUND ON COMMUNITY INVOLVEMENT AND CONCERNS 5
Public Health Effects : 5
LacJc of Information to Citizens 6
Batavia Landfill and Other Issues 6

SUMMARY OF MAJOR QUESTIONS AND COMMENTS AND EPA'S ANSWERS. . *.

APPENDIX A - EPA'S PROPOSED PLAN FOR REMEDIAL ACTION AT
THE BYRON BARREL AND DRUM SITE

APPENDIX B - SIGN-IN SHEETS FROM THE PUBLIC INFORMATION MEETING
HELD 8/16/89

APPENDIX C - WRITTEN COMMENTS SUBMITTED TO EPA DURING THE
PUBLIC COMMENT PERIOD

APPENDIX D - PUBLIC NOTICE INFORMING RESIDENTS OF PUBLIC MEETING

APPENDIX E - TRANSCRIPTS OF BYRON TOWN MEETING
-------
RESPONSIVENESS SUMMARY
BYRON BARREL AND DRUM SITE
BYRON TOWNSHIP, NEW YORK

The U.S. Environmental Protection Agency (EPA) held a public
comment period from August 1, 1989 through August 31, 1989 for
interested parties to comment on EPA's draft Remedial
Investigation/Feasibility Study (RI/FS) and Proposed Plan for the
Byron Barrel and Drum site.

EPA held a public meeting at 7:00 pm. on August 16, 1989 at the
Fire Department Recreational Hall on East Main Street in Byron,
New York. The objectives of the meeting was to outline the
results of the RI/FS and to present EPA's preferred remedy for
cleaning-up the Byron Barrel and Drum site.

A responsiveness summary is required by Superfund policy. It
provides a summary of citizens' comments and concerns received
during the public comment period, and EPA's responses to those
comments and concerns. All comments summarized in this document
will be considered in EPA's final decision for selection of a -
remedial alternative for the Byron Barrel and Drum site.

This responsiveness summary is organized into four sections.
Each of these sections is described briefly below.

I. RESPONSIVENESS SUMMARY OVERVIEW. This section briefly
describes the background of the Byron Barrel and Drum
site, and outlines the proposed remedial alternative
for cleaning-up the site.

ZZ. BACEOROUMD OM COMMUNITY INVOLVEMENT AMD COMCERM8. This
section provides a brief history of community concerns
and interests regarding the Byron Barrel and Drum site.

III. SUMMARY OF MAJOR QUESTIONS AMD COMMENTS RECEIVED DURING
TEE PUBLIC COMMENT PERIOD AMD EPA RESPOM8E8 TO THESE
COMMENTS. This section summarizes both oral and
written comments submitted to EPA at the public meeting
and during the public comment period, and provides
DA'S'responses to these comments. Letters received
from the public are included in Appenix C.

Z. RESPONSIVENESS SUMMARY OVERVIEW.

The Byron Barrel and Drum site is located in Genesee County, New
York, approximately 3.6 miles northwest of the Township of Byron.
The site consists of approximately 2 acres of an 8-acre parcel of
property off Transit Road.
-------
The site was used as a salvage yard for heavy construction
equipment such as graders, bulldozers, ceaent mixers, and cranes.
Numerous pieces of such equipment are present on-site. In
addition, metallic and nonmetallic debris litters the site.
The site itself is relatively flat. Gravel was mined from a pit
located on the site. The site is heavily vegetated except in the
gravel pit and, to a lesser extent, along the access road.

The Byron Barrel and Drum site was discovered in July 1982, when
an unidentified individual reported observing the disposal of
approximately 400 55-galIon steel barrels that were filled with
"noxious-smelling chemicals" to the New YorJc State Police Major
Crimes Unit.

A helicopter flight over the area by State Police revealed the
presence of a number of drums on the property. Oarrell Freeman,
Jr., who owned the property, did not possess a permit from either
NYSOEC or EPA for the storage or disposal of hazardous waste.

As a result of the investigation, a search warrant was issued and
executed. Two drum storage areas were located at the site. The
first area contained 121 barrels; the second contained 98
barrels. NYSOEC representatives obtained 11 drum waste samples*
during the search.

In 1983, NYSOEC initiated a preliminary investigation of the
site. The results of this investigation led to the inclusion of
the site on the Superfund National Priority List (NPL) in April
1984.

In response to a request froa NYSDEC, in August 1984, EPA removed
and disposed of the drums and approximately 40 cubic yards of
contaminated soil and debris. In addition, soil and groundwater
samples were collected. The primary contaminants detected were
chlorinated aliphatic hydrocarbons, such as 1,1,l-trichloro-
ethane, 1,1-dichloroethane, trichloroethene, and 1,1-dichloro-
ethene. Various monocyclic aromatics, such as toluene and
xylenes, were also detected in soil and groundwater, although
groundwater contamination with these substances is minimal in
comparison to contamination with chlorinated species. The
ingestioa of surface soils and subsurface groundwater are risks
associated with the Byron Barrel and Drum site.

RESULTS OF THE REMEDIAL INVESTIGATION

In June 1987, a RI/FS was initiated at the site. The RI revealed
that two major sources of contamination exist at the Byron Barrel
and Drum site. The first of these sources is located in the
southwestern portion of a former drum storage and waste disposal
area (Source Area 1). The second source is located in the
southwestern portion of the property in the vicinity of the
-------
maintenance) building (Source Area 2). These sources are believed
to have originated froa solvent spills. Subsurface contamination
in both areas consists primarily of chlorinated aliphatic
hydrocarbons, including 1,1,1-trichloroethane, 1,1-
dichloroethane, trichloroethene, and 1,1-dichloroethene. In
Source areas 1 and 2, chromium and lead contamination was
detected in soil samplas in concentrations above background.
Elevated chromium and lead concentrations were also detected in
soil samples froa a third source (Source Area 3), located in the
eastern portion of the site.

Groundwater contaminant plumes, consisting of chlorinated
aliphatic hydrocarbons, were found to be originating from Source
Areas 1 and 2. Source Area 2 also shows high levels of methyl
ethyl ketone (HEX). There does not appear to be a groundvater
contaminant plume emanating from Source Area 3.

Although groundvater in the vicinity of the site is used as a
drinking water source, the hydrogeologic and groundvater quality
investigations revealed that no migration of contaminants to th*
domestic veils has occurred or is likely to occur in the future:.
These veils will, hovever, continue to be monitored.

A baseline health risk assessment vas performed and indicated
that significant carcinogenic and noncarcinogenic risks vill be
incurred if the aquifer at the Byron Barrel and Drum site vere
developed for potable use. The cumulative incremental cancer
risk for use of site groundvater exceeds the upper bound of the
EPA target risk range. The risk associated with direct contact
to the site is minimal. There is, hovever, a risk associated
with ingestion of surface soil in Source Area 3.

PROPOSED ALTERNATIVE FOR BYRON BARREL AND DRUM SITE

ALTERNATIVE: In-Situ Soil Flushing, Groundvater
Pumping, Treatment and Discharge to
the Subsurface
PRESENT WORTH COST: $5,572,000
IMPLEMENTATION TIME: Soil <10 years/Groundvater 20 years

This remedy addresses the principal threat remaining at the site
by treating the most highly contaminated groundvater and lov-
level residual surface and subsurface soil contamination.
Groundvater vill be collected using a series of extraction veils
and pumped to an on-site treatment system. Treated groundvater
vill be reinjected to aquifer.

The groundvater extraction scenario vill consist of a line of
veils located betveen the source areas and the onion field. The
veils vill intercept contaminated groundvater in the vater table
aquifer.
-------
To treat the volatile organic contaminant (VOCs) in the extracted^
groundwatar, an air stripping column and activated carbon
absorber will b« constructed at the site. The air and voc
mixture exiting the air stripper would be treated by a vapor
phase carbon absorption unit. The clean air would be emitted to
the atmosphere. It is anticipated that a carbon absorption unit
will be necessary for the removal of the HEX, since air stripping
will not remove this contaminant from the groundwater. In
addition, inorganic contaminants in the groundwater will be
removed by precipitation prior to air stripping. The treated
groundwater will be reinjected into the aquifer. Groundwater
treatment will continue until federal and state standards for
organic contaminants have been achieved, and until the levels of
organic constituent are returned to background.

Environmental monitoring will be required during the life of the
treatment process. In addition, monitoring of the groundwater at
the site and its environs will continue for at least five years
after the completion of the remediation to ensure that the goals
of the remedial action have been met. Pre-construction, ^
construction and post-construction air monitoring will also b« ;
performed.

While it does not appear that residential wells are threatened by
contamination from the site, monitoring of these wells will be i
undertaken as part of the remedy. Interim measures will be
provided to protect the wells if it is determined that the site
poses a threat to them. In addition, the groundwater underlying
the adjacent onion fields will be monitored. This will also
attempt to restore groundwater quality and flush the residual
contaminants from the subsurface soil.

A comprehensive description of all remedial alternatives is
included in the Proposed Plan which can be found in Appendix A of
this document, or at one of the following information
repositories:
Gillam Grant Library
6966 West Bergen Road
Bergen, N.Y. 14416

New York State Department of
Environmental Conservation
50 Wolf Road
Albany, N.Y. 12233
New York State Department
of Environmental Conservation
6274 East Avon-Lima Road
Avon, N.Y. 14414
Byron Town Hall
Tovnline Road
Byron, N.Y. 14422

U.S. Environmental Protection
Agency
Emergency and Remedial
Response Division
26 Federal Plaza, Room 10278
New York, N.Y. 10278
-------
IZ. BACXOaOUHD OH COJOCDHITY INVOLVEMENT AND CONCERNS

According to local officials and residents interviewed during the
preparation of this community relations plan, community interest
in the site has been low with the exception of a few residents
who live nearby. Community involvement was limited during the
removal action conducted by EPA in August 1984. However,
community interest and concern about the site did increase in
April 1987 when a series of articles were reported in the Batavia
Daily News.

The initial newspaper report advised residents with a drinking
water well living within a three-mile radius of the site to have
their wells periodically tested for contamination. This news
account, reported by the Daily News, cited a NYSDEC report filed
with the Genesee County Clerk's Office. Subsequently, many
residents contacted the County Health Department and requested
that both an explanation of the contamination problem, and
testing to their domestic water wells. All inquiries were
referred to NYSDEC. Several follow-up articles appeared in ther
Daily News during the weeks following the initial report. The :
reports focused on the lack of government action regarding well'
testing and jurisdiction disputes between the County Health
Department and NYSDEC regarding testing authority.

The major concerns expressed by the community during preparation
of the Community Relations Plan of 1988 are listed below.

• Public Health Effects
Residents interviewed expressed concern that residential
well water and groundwater in the area may be contaminated.
They expressed fear that such a possibility could
potentially pose a threat to the drinking water supply of
nearby residents and irrigation water of neighboring
farmers.

One family, that lives in close proximity to the site,
expressed concern about effects on family members from
drinking potentially contaminated well water. Another
resident interviewed expressed concern that cancer and
mental retardation cases in the community may be
attributable to the site. Another resident interviewed
questioned whether there may be any health effects to
approximately ISO migrant farm workers who are housed near
the site. She speculated that the proximity of migrant
farmers workers to the site may be cause for possible
additional health concerns. While most residents
interviewed expressed concern about possible crop
contamination, local farmers did not share this concern
according to one farmer and the local officials interviewed.
-------
of Information to Affected Citizens
Residents expressed a desire for more information regarding
the site. They stated that past attempts to seek
information from government agencies have been futile, one
resident has not as yet been informed about the results of
water samples taken from his and his neighbors wells in July
1986. He stated that his efforts to obtain this information
have been unsuccessful. A farmer stated that, approximately
two years ago, soil samples were taken from a drainage ditch
on his farm that borders the northern edge of the site. He
has never been informed of the results of the analysis.
Conversations with EPA officials indicate that analysis of
off-site soil sampling was not conducted since the results
of on-site soil sampling revealed very lov concentrations of
contaminants.

• Batavia Landfill and Other Hazardous Waate Issues
Recent press coverage of other hazardous waste issues in
Genesee County has also stirred an interest in the Byron
Barrel and Drum site problem. Local officials and residents
interviewed stated the Batavia Landfill hazardous waste site
is an issue of local concern. The Batavia Landfill sit* is
also listed on the Superfund National Priority List (NPL)V -
The Batavia Landfill site and the Byron Barrel and Drum site,
have been linked in recent newspaper reports. One resident
interviewed mentioned that he has heard rumor that another
hazardous waste site exists in nearby Sweden. He was
uncertain as to the accuracy of this report, but was curious
as to whether this alleged site was related to the Byron
Barrel and Drum site.

XXX. SUMMARY OF MAJOR QUESTIONS AMD COMMENTS RECEIVED DURING THE
PUBLIC COMMENT PERIOD AND EPA RESPONSES TO THESE COMMENTS

Oral and written comments raised during the public comment period
for the Byron Barrel and Drum site remediation are summarized
below. The public comment period was held from August 1, 1989
through August 31, 1989. Comments received during this time were
organized into three categories: Technical Questions/Concerns:
Cost/Funding Issues; and Health Risk Assessments.
COMMENTi One resident was interested in knowing the actual
process for removal of chemicals from the soil, and also how the
treatment system operates.
EPA's RESPONSE: EPA explained that contaminated groundwater will
be extracted (by pumping wells), and discharged to a treatment
plant. The treated groundwater will then be recharged to the
surface recharge basins where it will return (percolate) to the
subsurface. This cycle is repeated until clean-up criteria are
met. EPA made note that this remedial action is only a
-------
conceptual design, and the actual treatment system will be
determined during the remedial design phase for this site.

COMMENTS The same resident inquired into how long the whole
process would take.

EPA's RESPONSE: EPA estimated that it would take approximately 7
years to flush the contamination out of the soil, and
approximately 20 years to clean the groundwater, due to the fact
that the contaminated groundwater is contained in a poor yielding
aquifer.

COMMENT: One resident wanted to )cnow what the source was for
contamination in the north ditch.

EPA's RESPONSE: EPA stated the toluene that is present in the
north ditch may be from paint strippers or gasoline, that was
spilled in that area. It is not believed to site related.

COMMENT: One resident inquired into the relationship of the •
contamination detected throughout the site, questioning if what
was found in Source Area 1 was the same or similar to what was -
found in Source Area 2. :.

EPA's RESPONSE: EPA replied that the primary contamination in
Source Areas 1 and 2 is chlorinated aliphatic hydrocarbons,
whereas the contamination in Source Area 3 are metals present in
the surface soils.

COMMENT: The same resident wanted to know in what direction the
contamination was traveling.

EPA's RESPONSE: EPA stated that contamination is migrating
north, which is consistent with groundwater flow in the area.
The only way contamination could be redirected would be if a
large production well was installed to the south, and pumped at a
high capacity, then the contamination could be drawn in a
southerly direction.

COMMENT: A resident stated that much of this area is designated
as wetlands), and cited Executive Order 11190 of the clean Water
Act which prohibits the development of wetlands. This resident
questioned why EPA would want to clean up land for developmental
purposes (as stated by EPA) when the lav forbids development in
such areas.

EPA'S RESPONSE: EPA stated they are not advocating development
in the area. EPA, under the Superfund Program is mandated to
protect the environment as well as the public health, whether
future development in the area is to take place or not.
-------
COMMENTS On* citizen wanted to know why 5 years expired before
any action was taJcen at the Byron Barrel and Drum site.

EVA'S RESPONSE: In 1984, at the request of NYDEC, EPA removed
drums and contaminated soil from the Byron Barrel and Drum site
to reduce an immediate threat to public health and the
environment. In April of that year the site was included on the
Superfund National Priority List (NPL). In 1986 the Superfund
Amendment Reauthorization Act (SARA) was approved by Congress. As
part of this amendment, funds were allocated for site cleanup.
In 1987 a worJc plan was approved by EPA to perform a Remedial
Investigation and Feasible Study at the Byron Barrel and Drum
site. Pursuant to this approval, site access was thwarted by Mr.
Freeman, the property owner, and subsequently an Immediate Order
in Aid of Access had to be obtained through the court system.
This order was not issued until the end of 1987. From 1988
through May of 1989 the Remedial Investigation was conducted.

COMMENTt The same citizen asked if the community was opposed to
the site's clean-up, would EPA clean it up regardless. j

EPA's RESPONSES EPA indicated the purpose for the public meeting
was to discuss the remedial action proposed for the Byron Barrel-
and Drum site, and to solicit comments. These comments will be
taJcen into consideration before a remedy is selected for the
site.

COMMENTS Residents and local officials expressed concern about
EPA1s proposed remedial alternative since there is no threat to
public health. Furthermore, the Byron Town Board passed a
resolution recommending to EPA that the only institutional
controls to the Byron Barrel and Drum site be deed and
groundwater use, and that no further action be taken. One
resident stated that the "environment will heal itself.1*

EPA's RESPONSES EPA is mandated to protect public health as well
as well as the environment. The groundwater in this area does
not comply with federal and state water quality standards, and
therefore groundwater contamination on-site must be remediated.
Public health could be at risk if conditions were to continue as
they presently"exist.

COMMENTS One resident referred to the presentation of the
proposed plan for the site, stating the areal extent of the
contamination plume was mentioned. He wished to know what the
vertical migration of contaminants were in the aquifer.

EPA's RESPONSES EPA stated that a number of monitoring wells and
soil borings were clustered in each of the source areas. They
found a water bearing zone housed in sand and gravel overlaying a
very compact layer of till fifty feet thick beginning at

8
-------
approximately twenty feet below surface level. EPA installed two
veils, on* in the water table and one at the base of the water
bearing zone*. They conducted hydraulic conductivity tests to
see how the water would permeate into the till. Based on their
finding*, the till contained very impermeable material
essentially equivalent to what would be used to install a cap
over a landfill. EPA found the potential for vertical migration
of contaminants through the till to be highly unlikely.

COMMENT: The same resident wanted to Jcnow if the contamination
had settled, and what was the flow velocity of the contamination
with respect to groundwater.

SPA's RESPONSE: EPA indicated they sampled both deep and shallow
wells in the source areas, and found only the shallow wells to be
contaminated. As they sampled farther downgradient, indications
were found that the plume has dispersed in a vertical direction,
resulting in contaminant concentrations roughly similar in both
deep and shallow wells. However, there appears to be no potential
whatsoever for degradation of the contaminants into the till. •
EPA stated that the contamination is moving very slowly. Their
measurements indicate a horizontal migration of approximately 55
feet per year. : -

COMMENT: Another resident noticed there was no treatment
designated for the groundwater in Source Area 3, and questioned
why.

KPA's RESPONSE: EPA confirmed this by stating no groundwater
contamination plume existed in Source Area 3.

COMMENT: One citizen noted that in Source Area 3 all drums were
above surface, and believed all were retrieved.

BPA's RESPONSE: EPA stated that to the best of their knowledge,
all drums had been removed from Source Area 3.

COMMENT: A resident recalled the sampling of residential wells
approximately one week prior, and inquired into obtaining the
analytical results.

EPA's RESPONSE: EPA replied that the State Health Department in
Albany requested the county Health Department to obtain
residential well samples. They are currently being analyzed in
Albany, and the results would be available in approximately 2
weeks to one month.

COMMENT: One resident wished to know how EPA decides and
documents the remediation plan for the Byron Barrel and Drum
site.
-------
EPA1* RESPONSE: EPA stated that once the consent period closes,
all comaents that are received will be discussed by EPA and DEC.
EPA will then prepare a Record of Decision (ROD) . If the
Regional Adainistrator agrees with the recommendations and
findings of the ROD, he will sign it, formally selecting a remedy
for the site.

COMMENT: A citizen asJced EPA how deep the plumes were in the
onion fields, and how will they be treated.
« RESPONSE: EPA responded that the plumes in the onion
fields are approximately 15 feet in depth. EPA proposes inducing
degradation in the fields by drawing down the aquifer to enable
the contaminated groundwater to flow froa between the fields back
to the source of contamination.

COST/rUNDIKO
COMMENT: One resident wished to know who would be responsible
for the operation and maintenance of the treatment plant. ;

EPA's RESPONSE: The responsibility of maintaining the treatment
facility once it is fully operational would be that of the state.
It is responsible for all operation and maintenance activities." '
The State may wish to delegate such responsibility to a lover
authority, such as the county. The State, also, may decide to
have a contractor perform the operation and maintenance at the
facility, with respect to the funding for the remedy, the EPA
will finance 90 percent of the remedial action, and the state
will finance 10 percent. The operation and maintenance of the
facility will also be funded 90 and 10 percent, respectively for
ten years of operation. After 10 years, it becomes entirely the
State's responsibility to finance the operation and maintenance
of the facility.

COMMENT i Several residents questioned why EPA proposes spending
$5 million dollars to cleanup the Byron Barrel and Drum site for
conditions that do not appear to be too threatening. Many
residents questioned if the proposed method is the most cost
efficient and beneficial use for the funds allotted.

EPA's RESPONSE: The aquifer, a source of drinking water, is a
natural resource that has been contaminated. EPA is mandated not
only to protect the public health, but to restore impacted
natural resources. The quality of groundwater in this area does
not comply with federal and state drinking water standards, and
therefore, groundwater contamination on-site must be remediated.
The EPA would rather address the situation now while it is still
localized, and remediate it so as to negate possible future, more
widespread adverse effects. In addition, if conditions were to
continue as they presently exist, public health could be at risk
in the future.

10
-------
COMMENTS On* resident suggested putting a deed restriction on
the property/ and giving the $5 million dollars to the township
for a water systea.

EPA's RESPONSE: This does not address the contamination present
in the aquifer. State and federal water quality standards are
not being met. Under CERCLA, EPA is required to protect both the
public health and environment.

COMMZHT: One citizen wanted to know why the site owner, Mr.
Freeman could not pay for the clean-up.

BVA's RESPONSH: Currently, EPA is attempting to obtain
compensation for damages to the Byron Barrel and Drum site and
vicinity, however, to date has yet been successful. Any party
who contributed to the contamination of the site, may ultimately
be held responsible for the clean-up or the financing of the
clean-up.

HEALTH AND RISK CONCERNS ?

COMMENT: Several citizens were concerned whether private
drinking wells were affected by the contamination. :~

SPA's RESPONSE: In 1988, private wells were tested in the area
surrounding the site, the wells are not threatened by
contamination from the site. The results indicated the wells are
not threatened by contamination froa the site.

COMMZHTx One resident inquired about the risk to crops growing
in the area.

EPA's RESPONSE* The contaminants that are migrating do not bio-
accumulate in crops. Furthermore, drainage systems have been
installed which help prevent contaminated water from being
elevated into the root zone of the crops.

COMMENTJ Several residents were concerned about what would
constitute a risk at the site.

EPA's RESPONSEf A drinking water well installed in one of the
contaminated plumes would constitute a risk.

COMMENTt One resident wanted to know what the risk to citizens
in the immediate area are.

EPA's RESPONSEt Contamination is present on-site even though the
drums and contaminated soil have been removed. The primary risk,
however, is the potential exposure to groundwater contamination
due to the contamination plume moving off-site.
11
-------
COXMZBTs Onm resident expressed concern with respect to what
risks would be involved once work on the site began.

ETA's RBCVOHSBi In remediating the site, we will operate in a
manner that will not adversely affect the surrounding population
and on-site workers. Dust, vapor emissions, and surface water
controls, would be employed as necessary to prevent migration of
contaminants off-site.
12
-------
APPENDIX A

EPA'3 PROPOSED PLAN FOR REMEDIAL ACTION AT
THE BYRON BARREL AND DRUM SITE
-------
PROPOSED PLAIf
FOR
BYRON BARREL AMD DRUM SIT!
BYRON, NEW YORK
PREPARED BY
U.8. ENVIRONMENTAL PROTECTION AGENCY
AUGUST 198f
-------
introduction

This Proposed Plan describes the remedial alternatives considered
for the Byron Barrel and Drum site and identifies the U.S. Environ-
mental Protection Agency's (EPA's) and the New York State Depart-
ment of Environmental Conservation's (NYSDEC's) preferred remedial
alternative and the rationale for this preference.

Site Location and Description

Site History

The Byron Barrel and Drum site was discovered in July 1982, when
an unidentified individual reported the disposal of "approximately
400 55-galIon steel barrels that were filled with noxious-smelling
chemicals'* to the New York State Police Major Crimes Unit.

A helicopter flight over the area by the State Police revealed the
presence of a number of drums on the property. Darrell Freeman,
Jr., who owned the property, did not possess a permit from either
NYSDEC or EPA for the storage or disposal of hazardous waste.

As a result of the investigation, a search warrant was issued and
executed. Two drum storage areas were located at the site. The
first area contained 121 barrels; the second contained 98 barrels.
NYSOEC representatives obtained 11 drum waste samples during the
search.

In 1983, NYSDEC initiated a preliminary investigation of the site.
The results of this investigation led to the inclusion of the site
on the Superfund National Priorities List in April 1984.

In response to a request from NYSDEC, in August 1984, EPA removed
and disposed of the drums and approximately 40 cubic yards oM
contaminated soil and debris. In addition, soil and groundwatej
samples were collected. Residential well sampling was conducted
in the vicinity of the site in June 1986. No contaminants were
detected in the residential well samples.
-------
In June 1987, a remedial investigation and feasibility study
(RZ/FS) wa« initiated at the site. The RZ revealed that two major
sources of contamination exist at the Byron Barrel and Drum site.
The first of these sources is located in the southwestern portion
of a former drum storage and waste disposal area (Source Area 1) .
The second source is located in the southwestern portion of the
property in the vicinity of the maintenance building (Source Area
2). This source is believed to have originated from solvent
spills. Subsurface contamination in both areas consists primarily
of chlorinated aliphatic hydrocarbons, including 1,1%, 1-trichloroe-
thane, 1,1-dichloroethane, trichloroethene, and 1,1-dichloro-
ethene. In Source Areas 1 and 2, chromium and lead contamination
was detected in soil samples in concentrations above background.
Small quantities of elevated chromium and lead concentrations were.
also detected in soil samples from Source Area 3, which is located
in the eastern portion of the site.

Groundwater contaminant plumes, consisting of chlorinated aliphatiic
hydrocarbons, were found to be originating from Source Areas 1 and
2. Source Area 2 also shows high levels of methyl ethyl katone
(MEK). There does not appear to be a groundwater contaminant plume
emanating from Source Area 3.

A baseline health risk assessment was performed and indicated that
significant carcinogenic and noncarcinogenic risks would be incur-
red if the aquifer at the Byron Barrel and Drum site were developed
for potable use. The cumulative incremental cancer risk for use
of site groundwater exceeds the upper bound of the EPA target risk
range. The risk associated with direct contact to the site is
minimal. There is, however, a risk associated with the ingestion
of surface soil in Source Area 3.
-------
PUKPOSB 07 THB PROPOSED PLAH
The Proposed Plan outlines the remedial alternatives evaluated for
the site, and presents the rationale used in making the preliminary
selection of the preferred alternative to protect human health and
the environment from exposure to any residual contamination remain-
ing on-site.

The Proposed Plan is distributed to solicit public comments per-
taining to all the remedial alternatives evaluated and the prefer-
red alternative.

The detailed information and data used in determining the nature
and extent of the residual contamination remaining on-site, and in
the development of remedial alternatives, is contained in the RI/F.S
report. f

Copies of the RI/FS report and supporting documentation are
available at the Gillam Grant Library, Byron Town Hall, NYSDEC's
Albany office, and EPA's Region II office. Addresses for these
repositories are listed below:
Gillam Grant Library
6966 West Bergen Rd.
Bergen, N.Y. 14416
Albany, N.Y. 12233

Byron Town Hall
Townline Road
Byron, N.Y. 14422

New YorJc State Department
of Environmental Conservation
6274 East Avon-Lima Road
Avon, N.Y. 14414
• New YorX State Department of
Environmental Conservation
Division of Hazardous Waste
Remediation
50 Wolf Road, Room 222
Albany, N.Y. 12233

U.S. Environmental Protection
Agency
Emergency and Remedial
Response Division
26 Federal Plaza, Room 747
New YorX, N.Y. 10278
8UXXAAY 07 REMEDIAL ALTERNATIVES

The Comprehensive Environmental Response, Compensation and
Liability Act (CERCLA), commonly Jcnown as Superfund, requires that
each selected site remedy be protective of human health and the
environment, be cost-effective, comply with other statutory laws,
and utilize permanent solutions and alternative treatment tech-
nologies and resource recovery alternatives to the maximum extent
practicable. in addition, treatment as a principle element for
reduction of toxicity, mobility, or volume of the hazardous
substances, is preferred.
-------
The findings of the RI, which establishes the basis for the
development of remedial alternatives, are summarized as follows:

- Prior federal clean-up actions have already addressed most of
the soil contamination at the Byron Barrel and Drum site and
have significantly reduced health or environmental risks posed
by the site;

- Environmental contamination at the site consists primarily of
residual organic and inorganic subsurface soil and groundwater
contamination in tvo locations: Source Area 1 and Source Area
2. Elevated inorganic concentrations were detected in Source
Area 3 soils.

The remedial alternatives considered in the FS were developed to
meet the following objectives:

Ensure protection of groundwater and surface water from the
continued release of contaminants from soils; •

- Prevent exposure (ingestion and inhalation) to groundwater
having contaminant concentrations in excess of state and
federal standards;

• Prevent migration of residual contaminants from the sub-
surface soil such that groundwater concentrations will
not exceed standards; and

- Restore contaminated groundwater to concentrations attaining
standards.

Accordingly, eight remedial alternatives for addressing the
contamination at the Byron Barrel and Drum site were evaluated in
detail in the FS report.

These alternatives are:
The Superfund program requires that the "no-action" alternative be
considered at every site. Under this alternative, EPA would take
no further action to control the source of contamination. However,
long-term monitoring of the site would be necessary to monitor
contaminant migration.

Because this alternative would result in contaminants remaining on-
site, CERCLA requires that the site be reviewed every five years.
If justified by the review, remedial actions would be implemented
at that time to remove or treat wastes.
-------
2 - PCTP mm gaorapirxTgR-OBg M;PTRICTIQMB

TREATMENT. AMD PIBCHXRQg TO BURTACB WATER

This alternative would not require implementation of remedial
actions to address subsurface soil contamination. Deed tre-
strictions would be imposed to prevent excavation in area* of
subsurface soil contamination. Groundwater would be collected
using a series of extraction wells and pumped to an on-site
treatment system. Treated groundwater would be discharged to thfl
drainage ditch located north of the onion field or to OaJc Orchafl
Creek.

The groundwater extraction scenario would consist of a line of
wells located between the source areas and the onion field. The
wells would intercept contaminated groundwater in the water table
aquifer.

To treat the volatile organic contaminant (VOCs) in the extracted
groundwater, an air stripping column and activated carbon absorber
would be constructed at the site. The air and VOC mixture exiting
the air stripper would be treated by a vapor phase carbon adsorp-
tion unit. The clean air would be emitted to the atmosphere, it
is anticipated that a carbon adsorption unit would be necessary
for the removal of the HEX, since air stripping would not remove
this contaminant from the groundwater. In addition, inorganic
contaminants in the groundwater would be removed by precipitation
prior to air stripping. Discharge piping would be installed to
pump the treated water to the drainage ditch located north of the
onion field or to Oak Orchard Creek. All air and surface water
discharges would comply with state and federal standards.

Environmental monitoring would be required during the life of the
treatment process. In addition, monitoring of the groundwater at
the site and its environs would continue for at least five ye
after the completion of the remediation to ensure that the go
of the remediation action have been met. Pre-construction,
construction and post-construction air monitoring would also be
performed.
-------
4 - SOIL CAPPING AMD GROUlTOWATgR PUMPING.
xim
TO atravxrc
This alternative is similar to Alternative 3, except that synthetic
membrane caps would be installed over the areas of soil contamina-
tion.

Under this alternative, the maintenance building would be disman-
tled, decontaminated, if necessary, and disposed of off-site.
Prior to capping, the areas would be graded to 'control surface
water and erosion. A protective soil cover would be placed over
the synthetic membrane, topsoil would be spread, and the capped
areas would be revegetated.

The groundwater pumping, treatment, and discharge scenario would
be the same as that discussed for Alternative 3. Monitoring would
be the same as in Alternative 3.

ALTERNATIVE 3 - SOIL EXCAVATION AHD OT7-BITS DISPOSAL
TO
This alternative is similar to Alternatives 3 and 4, except that
contaminated soil would be excavated and hauled to an off-site
RCRA landfill for disposal.

Under this alternative, the maintenance building would be
dismantled, decontaminated, if necessary, and disposed of off-site.
Contaminated subsurface soil would be excavated, loaded into
trucks, and hauled to an approved off-site RCRA . landfill for
disposal. (So as to comply with RCRA land disposal requirements,
treatment of the contaminated soil might be required prior to
disposal.) The excavations would be backfilled with clean fill
material from an off-site source. These areas would be covered
with a layer of topsoil and revegetated.

The groundwater pumping, treatment, and discharge scenario would
be the same as for Alternative 3. Monitoring would be the same as
Alternative 3.
This alternative is similar to Alternatives 3, 4, and 5, except
that contaminated subsurface soil would be excavated and treated
on-site using low-temperature thermal desorption to remove volatile
organic contaminants.

Under this alternative, the maintenance building would be disman-
tled, decontaminated, if necessary/ and disposed of off-site.
Contaminated soil would be excavated and hauled to a mobile thermal
desorption unit that would be set. up at the site. Treated soil
would be used to backfill the excavations. The areas would be
-------
covered with a layer of topsoil and revegetated. Because of the
presence of inorganic constituents in the soil, which thermal
desorption would not remove, treatment of the residual by chemical
fixation might be necessary before backfilling to comply with RCRA
land disposal requirements.

The groundwatar pumping, treatment, and discharge scenario would
be the same a* for Alternative 3. Monitoring would be the same as
in Alternative 3
7 - IB-BITTI SOIL VAPOR EXTRACTION AMD QROUNDWATgR
XVD DTBcxxsaB TO arayics WXTER
This alternative is similar to Alternatives 3, 4, 5, and 6, except
that contaminated subsurface soil would be treated by in-situ vapor
extraction using air extraction and injection wells.

Under this alternative, the maintenance building would be disman-
tled, decontaminated, if necessary, and disposed of off-sifce.
Vapor extraction wells would be installed at the centers of Source
Area 1 and 2. Air injection wells would be installed around the
perimeters of the Source Areas 1 and 2. A vacuum would be induced
and the air that would be collected would be treated using vapor
phase carbon adsorption. A synthetic membrane would be used t
prevent air leaJcage from the soil surface between the air
extraction and injection wells.

The groundwater pumping, treatment, and discharge scenario would
be the same as for Alternative 3. Monitoring would be the same as
Alternative 3.^

ALTgRHATITB 8 -• IM-8ITP SOIL FLUSHING XHD GROUKDWATER PUMPING.
TRZATMZHT . AMD •
This alternative is similar to Alternative 3 , except that a portion
of the treated groundwater would be discharged to the aquifer
through recharge basins constructed over the areas of subsurface
soil contamination. This alternative would attempt to restore
groundwatar quality and flush the residual contaminants from the
subsurface) soil.

The maintenance building would be dismantled, decontaminated, if
necessary, and disposed of off-site to allow construction of one
of the recharge basins.

Monitoring would be the same as in Alternative 3 .

PREFERRED ALTgRNATTVg

Based upon an evaluation of various alternatives, EPA and NYSDEC
recommend, for Source Areas 1 and 2, Alternative 8, in-situ soil
flushing, for treatment of the residually-contaminated subsurface
-------
soil, and air stripping and carbon adsorption, for treatment of the
groundwater, followed by the recharge of a portion of the treated
water through recharge basins, as the proposed sits remedy. in
addition, a saall quantity of soil in Source Area 3 with elevated
inorganic concentrations will be further evaluated to determine
what its ultimate disposition (i.e., off-site disposal or placement
on the soil to be flushed) will be.

Upon completion of the remedy, the recharge basins would be closed
consistent with RCRA requirements.

While the levels of contaminants present in the subsurface soils
do not pose a risk to public health, localized "hot spots'* in these
areas may be contributing to the contamination of the aquifer. The
concentrations of contaminants present in the aquifer exceed state'
and federal standards. Flushing the residual contaminants from the
soil would prevent possible leaching of contaminants into the
aquifer once groundwater treatment ceases.

Groundwater treatment would continue until the federal and stkte
standards for the organic contaminants have been achieved. It. is
estimated that 20 years would be required to meet these standards.

Section 121 (c) of CZRCLA, as amended, requires review of remedial
actions at least every 5 years, for as long as site contaminants
pose a threat to public health or the environment. This review
would not be required once aquifer restoration has been achieved.
If the remedy is not determined to have effectively remediated the
site, further remedial action would be necessary.

While it does not appear that residential wells are threatened by
contamination from the site, monitoring of these wells would be
undertaken as part of the remedy. Interim measures would be
provided to protect the wells if it is determined that the site
poses a threat to them. In addition, the groundwater underlying
the adjacent onion fields would be monitored.

RATIONAL! FOR 8BLZCTZOH

During th« detailed evaluation of remedial alternatives, each al-
ternative is assessed against nine evaluation criteria, namely
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), overall protection of human health and the environment,
state acceptance, and community acceptance.

Each criterion will be briefly addressed, in order, with respect
to the preferred alternatives for both soil and groundwater.
-------
10
The preferred alternative, Alternative 8, would eliminate the po-
tential risJc to human health and the environment. The discharge
of treated groundwater to recharge baains would flush volatile
organic contaminants from the subsurface soil, thereby eliminating
the potential risk associated with any excavation under future
land-use scenarios.

Under Alternatives 1, 2, and 3, residual subsurface contaminants
would continue to leach into the groundwater, and continued off-
site migration of contaminants would result.
•.
* •
The. aquifer at the site has a low yield due to its low
transmissivity. Because increasing the pumping rate would cause
excessive drawdown of the water table, Alternatives 3, 4, 5, 6/7,
and 8, would take approximately 20 years to decrease groundwatea|
contaminant concentrations to levels based on ARARs. Alteraativ^
1 would not reduce the present and future risk to human health and
the environment. Although, under Alternative 2, the risk to human
health would be eliminated by restricting groundwater use and soil
disturbance, the risk to the environment would remain unchanged.

B. Compliance with XRXRs

All technologies proposed in Alternatives 3 through 8 would be
designed and implemented to satisfy all action-, contaminant-, and
location-specific requirements. Since no federal or New York State
regulations specify clean-up levels for contaminants in the soil,
soil cleanup goals were calculated such that the aquifer will be
protective of public health and the environment. The preferred
alternative, Alternative 8, would achieve the federal and state
groundwatar quality standards for the organic contaminants and
would reaove subsurface soil contamination. Alternatives 1 and 2
are not effective in complying with groundwater ARARs.

Alternative 1 would not comply with state or federal drinking water
standards or criteria or those ARARs required for protection of the
groundwater resources. This is in contrast to Alternative 2, which
would not comply with chemical-specific ARARs for ingestion of
groundwater, but would meet all other ARARs.

C* Long—tern Effectiveness and Permanence

The preferred alternative, Alternative 8, would effectively treat
the most mobile wastes in on-site soil, thus, effectively reducing
-------
11

the source) of groundwater contaaination. Alternative s is consi-
dered morsj effective sine* recirculating the groundwater would
prevent potential aquifer drawdown„and would enhance the removal
of contaminants adsorbed to the saturated soil. Although Alterna-
tives 4 through 7 would also provide a high degree of effectiveness
for the removal of volatile organics from the unsaturated soil,
aquifer drawdown could lengthen the time required to complete the
remedial action.

Under Alternative 6, excavation, thermal desorption, and back-
filling, inorganic contamination in subsurface soil would not
be removed. Hence, further treatment might be necessary before
ultimate disposal of the soil could occur.

Alternatives 3 through 8 would effectively reduce the potential
risks associated with the migration of contaminants in the ground-
water by extracting and treating them. Alternative 3 would not be
effective in mitigating the leaching of subsurface soil contami-
nants with subsequent migration to groundwater. ?

Alternatives 1 and 2 would not be effective in mitigating potential
risks associated with future development of the aquifer and future
land-use scenarios, including excavation in areas of subsurface
soil contamination. In addition, the contaminants would be left
untreated in the subsurface soil and groundwater and a long-term
monitoring program would be implemented to determine if the con-
tamination is migrating from the site.
The preferred alternative, Alternative 8, as well as Alternatives
3 through 7, would reduce the toxicity, mobility, and volume of the
organic contaminants in the groundwater. Under Alternative 8, the
discharge of treated effluent to recharge basins would result in
in-situ flushing of subsurface soil contaminants that then would
be collected by the extraction system and treated. In contrast,
Alternatives 6 and 7 would reduce toxicity by in-situ vapor ex-
traction and thermal treatment, respectively. Alternatives 3
through 5 do n«t employ treatment to reduce the toxicity, mobility,
or volumes of soil contaminants. However, in Alternative 4, cap-
ping, would reduce the mobility of subsurface soil contaminants.

Alternatives 1 and 2 do not reduce the toxicity, mobility, or
volume of contaminants.

E. Short-Term Effectiveness

The preferred alternative, Alternatives 8, as well as Alternatives
4 through 7, would effectively reduce the potential risks posed by
groundwater contamination. For all of the groundwater treatment
remedies (Alternatives 3 through 8) , a pumping time of 20 years
would be required to attain ARARs for groundwater.
-------
12

Under Alternatives 4 through 8, dust may be generated during
excavation and other material handling activities; therefore, dust
control procedures would be needed. Air monitoring would be
required to determine whether steps are needed to protect on-site
workers and the general public from adverse air emissions.

Alternatives 3 through a include activities that could result in
potential exposure of workers and residents to volatilized contami-
nants during the installation of the groundwater extraction and
rein ject ion systems. The threat to on-site workers, however, would
be mitigated through the use of protective equipment.

There would be no risk to the public and on-site workers during
implementation of the preferred alternative. Alternative 8, and*
Alternative 3. In contrast, Alternative 5 could pose a risk to the
public if a spill occurred during off -site transport.

Groundwater sampling under Alternatives 1 and 2 would not resblt
in a risk to the public, on-site workers, or the environment.
However, workers would need protective clothing during sampling' of
on-site wells.
The technologies and process options proposed in Alternatives 3
through 8 for pumping and treatment are all demonstrated and
commercially available. These systems are reliable, if properly
maintained.

All components of the preferred alternative, Alternative 8, utilize
relatively common construction equipment and materials and could
be easily implemented. Also, in-situ soil flushing, the preferred
alternative, has been successfully pilot tested and has performed
on a full-scale basis for similar organic contaminants. In con-
trast, the treatment technology for Alternative 7 (in-situ soil
vapor extraction) , although successfully demonstrated for the
removal of volatile organics from unsaturated soil, has had limited
use to data. -Furthermore, in-situ soil vapor extraction is cur-
rently available from only a few vendors nationwide.

All components of Alternatives 1 and 2 would be relatively easy to
implement. Groundwater monitoring can be performed using previous-
ly installed monitoring wells and residential wells.

Under Alternative 4, approximately 2 months would be required to
construct the cap. It would take approximately 1 to 6 months
remove the contaminated soil under Alternative 5 (excavation *
landfilling) , Alternative 6 (excavation and thermal desorption)
and Alternative 7 (in-situ vapor extraction) . Under Alternative
3, the cap could be constructed within 1 to 2 months. It would
take approximately 10 years to remediate the soil under Alternative
-------
13

8 (soil flushing). The groundwater treatment scenario for
Alternatives 3 through 8 would require approximately 20 years for
the groundvater to meet state and federal standards.

Table 1 summarizes the implementation times for the eight
alternatives for comparison purposes.

a. cost

The capital cost of the preferred alternative. Alternative 8, to
achieve the clean-up goals, is estimated to be $1,917,000. Annual
operation and maintenance costs are estimated to be $259,700. The
total present worth of the alternative is approximately $5,572,000.

Table 1 summarizes the costs for the eight alternatives for
comparison purposes.

R« State Acceptance

NYSOEC concurs with the preferred alternative.

Z« community Acceptance

Community acceptance of the preferred remedy will be assessed in
the Record of Decision (ROD), the document which formalizes the
selection of the remedy, following a review of the pubic comments
received on the RI/FS report and the Proposed Plan.

CONCLUSION

EPA considers the preferred remedy for the site to represent
the best balance among the evaluation criteria, and anticipates
that it will satisfy the following statutory findings of being:

1. Protective of human health and the environment;

2. In compliance with ARARs; and

3. Cost-effective.
COMMUNITY ROLE ZH SELECTION PROCESS

EPA and NYSDEC rely on public input to ensure that the concerns of
the community are considered in selecting an effective remedy for
each Superfund site.

To this end, the RI/FS report has been distributed to the public
for a comment period which concludes on August 31, 1989. The
Proposed Plan is being provided as a supplement to this report and
to inform the public of EPA's and NYSDEC's preferred remedy.
-------
14

A public •••tin? will be held during the comment period at Byron
Fir* D«p«rtnent Recreation Hall, Byron, N.Y. on August 16, 1989 at
7:00 p.a., to allow EPA to present^ th« conclusions of the RI/FS,
to further elaborate on the reasons* for recommending the preferred
remedy, and to receive public comments. written and verbal com-
ments will be documented in the Responsiveness Summary section of
th« subsequent ROD.

All written comments should be addressed to:

Eduardo R. Gonzalez
Project Manager
U.S. Environmental Protection
Agency
26 Federal Plaza
New YoriC, N.Y. 10278

It is important to note that the remedy described above is the
preferred remedy for the site. The final selection wilj, be
documented in the ROD only after consideration of all comments on
any of the remedial alternatives addressed in the Proposed Plan and
the RI/FS report.
-------
I
I
ON ION I FIELDS

*J -*1 •" ~J n o
1* Q
: a 4

.3 •— v..«
|TUOY AREA

BARREL AMD DMM 8ITF. BYHQM. HY
• -»•
ficunt
-------
TAIL! 1

COMPARATIVE COST ANALYSIS Of ALTERNATIVES
BYRON BARREL AND MUM SITE
BYRON. NEN YORK
•Itafaatlva 1
•a Ptifikat ActUa altk Maaltailaf
COSTS
Capital! M
•aaual O4Mi II1.4M
•raaaat Maftki IIAS.MA
•Itafaatlva I
•aa4 aatf 6i*u*4walat M*a
•attt Utlaaa
k

Caaltali I1S.M4
•aaual OkMi 111. AM
Vtaaaat Mattki Illt.M*
AltafaatUa 1
6fa«iM»ataf taaplaa,, ffaattNat.
aa4 •lackaifa ta Autfaca Matat

Cf^ltali |l. MA. AM
•aaMl O4«i II11.IAA
Pfaaaat M*ftki |«.AI«.AM
TINE TO IMPLEMENT
••111 - |«*!!i
C..0.4..1.., - |fifa»a4.ataf i

•Itafaatlva S
Oflalta •Icpaaal. fifauadv/atat
PtMplaf, Ttaataaat. aatf •iackatfa
ta Butlaca Matat
COSTS
CapUali fl.4tt.MA
•aaual OtNi fm.AAA
»taaaat Maftki !).•>•. Mt
TIME TO IMPLEMENT
••111 > *••!*•
Cf*ua4«atcn !• faat*
•Itafaatlva A
Tkataal Tfaataaat. Cfauaa^atat
rua^laf, Traataaat. aa4 Blackatfa
ta Suflaca Matat

Caaltali |I.)I«.*M
•aaual OaMi II49.1M
ftaaaat Maftki ••.•••.AM

•alii > a*atka
«••«—•••• " »"'•
Aalli
efaM^atait JA ,••••

•Itafaatlva 1
la-Clta Waaa« latfactlaa.
••aaatfaatat ttMAiaf, tcaatfMat.
aa4 •lachataa ta Suffac* Natal

Capliali II.IAI.AM
AaaMl OiMl M1A.4M
Vfaaaat Maftki IS.1AA.A44

••III A ftaatk*
Cfayatfvataf I >• »••••
•Itafaatlva 4
Cappta«. «t«M«4««taf tMpiMf.
tfaataaat. aat AUckaffa ta

Capltali II.IIA.AM
kaaital O4Mi |I1I.«AA
Vfaiaat Maftki IS.I41.AAA

Mill J aaatka
6f»u*4»at«fi 10 yaata

•Itafaatlw* A
la-lltu *•!! rl«*kla«.
6(*u*4««tat Pu«plaf, Tfaataaat aa4
•lackaffa ta tka Bukauffaca

Capltali II. All. MA
•aaual O4Mi flSA.lAA
!>!•••• t Maftki IS.S11.AAA

••III
-------
APPENDIX B
SIGN-IN SHEETS

The following Sign-in sheet(s) are froa the Public Information
Meeting held 8/16/89 in the Byron Fire Department Recreation
Hall on East Main Street, Byron Township, New YorJc
-------
Superfuod Update-
EPA Region 2-
NAME
_^ fty .o

jJL. It).
r9iA
10

12
13
14
15
16

t
SIGN-IN SHKET
3
Byron Barrel and
Drum Site
Byron, New York
— August 1989
ADDRESS
A/y / y y^-
f\Li.
S
^*&**s*
19
-------
Superfund Update
EPA Region 2-
NAME
39
47

54
Byron Barrel and

Drum Site
Byron, New York
Aafw 1989
SIGN-IN
ADDRESS
40 3%/ZAi* \ c
K A
'+.r*vt
-2.8A-
x:/9 ^ /
•r/ &£*-
56

57
-------
APPENDIX C
WRITTEN COMMENTS

The following are written comments submitted during
Public Comment Period held from August 1, 1989 to August 31, 1989
-------
TOWN OF BYRON
Byron. N.Y. 14422
August 28, 1989
Mr. Edvardo Gonzalez, Project Manager
U.S. Environmental Protection Agency
26 Federal Plaza
Mew Yorlc, New Yorfc 10278

Dear Mr. Gonzelez, Project Manager:

This letter is to certify a true and exact copy of the resol-
ution, regarding the "3yron Barrel and Drum Site", that was passed
by the Byron Town Board, Byron, New YorK on August 9, 1989.
• _
RESOLUTION »93

Councilman SacJcett offered the following resolution and moved for its
adoption:
RESOLVED, that the Town Board recommend to the Environmental Protec-
tion Agency that the only restrictions are deed and ground water use and
that no further action be taken.
Councilman Bater seconded the resolution which was adopted by the
following vote:

Vote: Ayes 4 Nays 0 Absent 1

Sincerely,
Mr. Gerald Ivison
Byron Town Supervisor
Gl/jf
-------
If I
SL^- 0'
®f*r

. \
'f^C
y-
/ r
-------
UN 1UUK UJlYllVlUNin UUAL111UN
September 28, 1989
Joel Slingerman, Chief
W.N.Y. Remedial Action Section
USEPA Reg. II
Jacob Javits Federal Building
New York, NY 12233-7010

Dear Mr. Slingerman,

The Byron Barrel and Drum site in Byron, New York, has
recently come to my attention. As the regional representative
for the Toxics In Yor Community Coaltion (TIYCC), I am writing to
express our concerns about the site and offer comment on the
proposed remedial activities.

In reviewing the Record of Decision draft, I noticed several
inconsistencies which I felt should be brought to your attention:

It was noted that all contaminated soil had been excavated.
from the site. This statement is contradictory because the report
indicted that approximately 40 cubic yards of contaminated soil
and debris had been removed (pg 4) while areas one and two list a
total of over 4,000 cubic yards of contaminated soil (pg 8)
which is continuing to migrate into the groundwater and drainage
ditch. This drainage ditch, as well as the north-northwest flow
of groundwater, eventually discharges into Oak Orchard Creek.

Oak Orchard Creek, although currently a Class D stream, is
the major water source for Iroquois National Wildlife Refuge,
New York State's Tonawanda Refuge and DEC's- Oak Orchard
Environmental Learning Center. This creek and the surrounding
wetlands, covering tens of thousands of acres, provide habitat for
many endangered and threatened speices, including the Bald Eagle.
As is evident, the classifation of Oak Orchard Creek should be
upgraded. All measures must be taken to protect it from
contamination.

Another inconsistency in the report deals with private wells.
The report stated that no migration of contaminants to domestic
wells had occured (pg 5). Yet in June of 1986, residential .
sampling revealed that contaminants were present, (pg 4)
A STATEWIDE COALITION WORKING TO CLEANUP THE ENVIRONMENT
AND PRrn"c'^T TUC QIIQJ "•• UCAITIJ TO/nv .Tnv« n'nr-"-r
-------
In light of the above inconsistencies, as well as others not
mentioned, further investigation and expedient cleanup of the
site ia warranted. In an effort to achieve EPA's goal of
permanant cleanup of hazardous substances that threaten
environmental .and public health, it is most important not to
delay the selection and implementation of a groundwater treatment
program.
For a safer environment,
' '
Diane Heminway
cc: Ronald Tramontane, NYSDOH
Gerald Ivison, Byron Town Supervisor
-------
APPENDIX 0
PUBLIC NOTICE

The following is the Public Notice announcing the Public Meeting for
the Byron Barrel and Drum site
-------
Affidavit nf $ubliratinn
STATE OF NEW YORK I
GENESEE COUNTY \ **"
....... *•.'••«. P.?.. P.rW.e.h ................ baim, duly sworn,

deposes and sa va that he u ..... k* 9.*A . .? .'. ! .1 I ." 9. . P. ] « T.1* . .
of Batavia Newspapers Corporation. Publishers of "Tha Daily
News." a newspaper | >n tiled and published in Batavia. and that a
notice, of which ihi- .iimc.xcd is a copy, waa duly prtntajt and
published in ':
on* 1 1 me
said Newspaper ........................... . . ......... ~ . .on tn«

9th
. . ,.-
day of ---- r ...................... 19 ..:..
..„_ w
Sworn to and subscribed before me this | ^^EBfctClM L HICH6LS
,«. W«_ , . MttfT P«MC. SIM 01 MM Tort
... day of ^LLLSJ***'. 19/^.1 S*m*tou«
• / My C40MMM ElWTM
JIMVT 41.
-------

UOM,
IIOU.
LIOM.
UOAt
THE UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
ANNOUNCES
PROPOSED REMEDIAL ALTERNATIVE
FOR THE
BYRON BARREL AND DRUM SUPERFUND SITE
BYRON TOWNSHIP, QENESEE COUNTY, NEW YORK
The UJL Environmental Protection Agency (EPA) recently completed e Remedial Investigation/Feaaioittty Study
tnat evaluated alternative* for dealing wtth contamination at ttie Byron Barrel and Drum Supernind site In Byron
Townahlp, New York. Baaed on me work done at me stto to date, EPA la afmounJng a propoaed remedy for me
dean-no.
Before selecting a final remedy, EPA wM consider written and oral cmmneiita on this propoaed alternative, aa
wen aa the other altemetlvea mat were considered. Comments must be received on or before August 31,1969.
The final decision document win Include a summarf of public commenta and EPA responses.
EPA wM hold sn Informational public meeting on August 16, 19ft, at 7:00 pan. In the Rre Oepertment
Recreational Halt, located on East Main Street (Route 362) In Byron, New York. The purpose of thla meeting la to
discuss me findings of me Feasibility Study and me preferred remedial alternative.
EPA's Feasibility Study evaluated S altemetlvea for remediation of the Byron Barrel and Drum site. These are:
1. No Action Wtth Monitoring :
2. Deed and QreundwateMlse Restrictions
3. Deed Restrictions and Qroundwater Pumping, Treatment, and Discharge to Surface Water
4. SoM Capping and Qroundwater Pumping, Treatment and Discharge to Surface Water
5. SoU Excavation and Offstta Disposal, and Oroundwatar Pumping, Treatment, and Discharge to Surface Water
6. Soil Excavation and Thermal Oosorptlon of SoU, and Qroundwater Pumping, Treatment, and Discharge to
Water
Excavation and In-SItu SoU Vapor Extraction, and Qroundwater Pumping, Treatment, and Discharge to
Surface Water
S. In-Sltu SoU Rushing snd Qroundwater Pumping, Treatment and Discharge to the Subsurface
All of the altemativee are outlined and discussed In the Proposed Plan. EPA'a proposed remedial alternative la
Alternative S. Under thla alternative, the groundwater would be treated to remove volatile organic* and metals,
wtth a portion being recharged to the ground In order to flush organic contaminants from the soU. Treetment of
the groundwater would continue until aU pertinent federal and state cleanup requirements have been achieved.
In addition, a small quantity of surface soU, wtth elevated organic concentrations, located In the •astern part of
the site, wiU be further evaluated to determine what Its ultimate disposition (Le^ off-site disposal or placement
on the soU to be fluahed) wHI be.
The Remedial Investigation/Feasibility Study, Proposed Plan, and other site-related documents can be consult-
ed at the information repoattorlee listed below:
Qniam Qrant Library
6966 West Bergen Road
Bergen. N.Y. 14416

U.S. Environmental Protection Agency
Emergency and Remedial Response Division
26 Federal Plaza. Room 747
New York, N.Y. 10278

n commenta on the Proposed Plan should be sent to:

Eduardo R. Gonzalez. Project Manager
U.S. Environmental Protection Agency
26 Federal Plaza
New York, New York 10278
New York State) Department of
Environmental Conservation
SO Wolf Road
Albany, N.Y. 12233
Commenta submitted ta MM
-------
APPENDIX E
TRANSCRIPTS

The following are the transcripts from the Byron Town Meeting held on
August 16, 1989
-------
:: PROPOSED PLAN
I

3 j for

4 i 5YRON BARREL and DRUM SITE

!I Byron. New York
i

5 !

7 ! Prepared by

• 3 I the

3 U. S. Environmental Protection Agency

10 i

11 Public Hearing at the Byron Fire Department

August 16. 1989. 7:00 p.m.
13

13 Appearances: Joel Slngerman. Chief Western New York
j

Remedial Action Section

17 U. S. EPA (New York City!

19 " Bert Hubbard, Site Manager

20 NUS (Consultants to EPA)

Eduardo Gonzales.

.23 . . Project Manager. EPA.

25
-------
Page 2
1 MR. SINGERMAN: Before we get start this
2 meeting, I would like to call your attention to the sheet
3 over there. We'd like you to sign In to make sure you have
4 your name on the mailing list. Me also have an agenda
5 which looks like this, and we have a proposed plan which
5 looks like this.
7 So before you leave the meeting, If you
3 haven't signed In. please sign In. .
T '
? The purpose of tonight's meeting Is to -
10 discuss the results of the remedial alternatives
^^
11 for the site report and the EBA's and DEC'S proposed remedy
12 for the Byron site.
13 There are reports available In several
14 possibilities. The exact locations are Identified In this
15 proposed plan handout over there on Page 4. Just to
16 summarize, locally they are throughout the Grant library.
17 on Bergen Road and the Town Hall on the Town Line Road.
18 There Is also. If you happen to be In New York City, at
19 tlMlr office in the Federal Plaza, you can look at copies
20 there. There Is also the Albany office of the DEC, and
21 there Is also the Environmental office.
22 Right now, we are during the — this Is
23 part of the public commentary which ends on August 31st.
24 If. after tonight's meeting, if you think of any questions
25 you might have or any comments you want to make, you can
-------
Page 3
1 contact either Eduardo. the*address is identified by Page
I
2 14 of the proposed plan of our New York office by writing
3 or you can call him at 212 284-5714.
4 If you do submit comments in writing, we
3 ask that you postmark them by the 31st of August. If you
5 wish to call to submit the comments, we ask you call by the
7 31st.
8 | Okay. Well, we are going to have several
9 very short presentations: and afterwards, we'll allow ample
10 time for any questions you might have. We'd ask you to
11 defer any questions you might have and hold then until the
12 end of the presentation.
13 Just to give you a brief overview of the
14 history of the sits. In the late 70's or early 80's there
13 were drums that were present along the site. The State
16 Police identified the presence of the drums in 1982 and
17 they did investigate the site. A subsequent investigation
18 by the New York State Department of Environmental
19 Conservation led to the removal of the drums and
20 contaminated soil by the EPA in '84.
21 Between 1984 and '86. residential wells
22 were sampled. In addition to a consultant sampled wells in
23 April and August and December of '88 and dewage. I believe.
24 sammple wells as evidenced last week. Those of you that
23 were here in April of '88 when we had the scoping meeting.
-------
1
I
4
9
10
11
12
13
14
13
15
17
18
19
20
21
23
24
23
Page 4
at that time, we identified*that the fact we were starting
2 | to re-investigate a feasibility study: and at this point in
3 j time, we lust completed, reinvestigatlon a remedial study
and proposed a remedy and the purpose of this meeting is to
5 j solicit public comments.
3 I Now. Bert Hubbard will discuss the results
I
7 | of the investigation of these remedial feasibility studies
a I that he prepared.
•
MA. HUBBARD: I am going through this
pretty rapidly, so we can leave a lot of time for
questions. This figure shows the location of the Byron
barrel and drum site. This is essentially right along this
area here. The major features in this area are adjacent
farmland, a hill along one side of the site, and a couple
surface water bodies. One is a drainage ditch that runs
along here into Oak Orchard Creek and there is another
drainage creek that rungs along here, right along the
boundary of the site.
This figure shows the general location of
source areas that we identified at the site. Source Area
No. 1. consists of two source areas actually. In the work
22 i zone we have identified two former drum storaoe areas in
this area, they are so close together, we are now
considering them to be one soruce.
Source Area No. 3. here, is also drum
-------
I . Pag* 5
1 i storage area, and Source Area No. 2 is an area that was
I
2 unknown at the time we initiated the investigation that was
i
3 | identified near the close of the investigation.
i
4 | Briefly, summarizing the field
5 Investigation for you. we did a number of different
5 investigations out at this site, in more or lees a phased
7 approach. We Installed 293 soil gas borings to search for
3 I volatile organic chemicals which are believed to be the;
9 i primary contaminants. We also obtained 29 surface soil.
I
10 samples, most of which were obtained in a specified source
11 area. Others were obtained in areas that we believed to be
12 locations where erosion soils may be deposited.
13 A 130 subsurface samples were collected at
14 the site from soil borings and from test pits. The test
19 pits were excavated so that we did search for burled drums
16 and also to allow us to obtain samples and to visually
17 Inspect for the presence of contamination.
IS He Installed a total of 27 permanent
19 monitoring wells at the site and 7 temporary well points.
20 We tested those wells for hydraulic productivity which is
21 kind of an indication how fast the water can move through
22 the material. We conducted 9 rounds of water level
23 measurements to determine which way the groundwater was
24 falling. We took 5 rounds of samples from these monitoring
29 wells. The first 2 rounds were conducted in a phase
-------
: Page 5
1 i manner, to assist us in locating additional wells. 2
i
2 ! complete rounds of samples were taken from all the wells
3 i that were installed during the initial phases of the
41 remedial investigation.
I • —
3 I When we discovered there was additional an
!
5 source we went out and installed 7 more permanent
7
10
11
12
13
17
18
19
20
21
23
24
23
monitoring wells and 7 temporary well points. The well
9 l points are removed.
i r-
3 I We also conducted 2 rounds of residential
well sampling, as Joe alluded to. in August and September
of 1908. We did geophysical survey using a magnetometer.
which is more or less a fancy metal detector and that was
deelgned to help us located any possible burled drums.
14 We also did some topographical mapping of
15 the site. We had a fly-over done by an airplane to help us
IS generate some of the figures that — the figure that I
showed you earlier for example.
I am going to briefly run through all the
staples* of the locations for you.
This is the original soil gas grid that was
laid out on the site. We took the soil gas samples and a
majority of the nodes that are shown on this, okay, so a
number of the points couldn't be accessible because of the^
presence of heavy construction equipment.
When we discovered the additional source
-------
Page 7
1 area. we also conducted a soil gas survey In that area.
2 Those locations will show on this figure, they were around
3 this maintenance program here. This figure displays the
4 locations of the 23 surface soil samples that we took.
9 These here are source — what is normally called Source
5 Area 1. These are in the former Source Area 2 here. This
7 is — the entire thing is now called Source Area 1. These
3 I were taken in Source Area 3. the ones with the triangles.
9 around them are background samples.
10 This figure displays the location of the
11 test which they excavated. As you can see we had a number
12 of test pits in the 3 — the 3 source areas that were known
13 at the time w« Initiated the investigation. The most
14 concentrated test being operated was conducted in this
19 Source Area 1 because that's where we found contamination.
16 We also installed a number of soil borings
17 around the maintenance building source. We had samples
18 from those borings analyzed to determine the extent of
19 contamination in that area.
20 This figure displays the 20 monitoring wells
21 that were initially installed at the site. We had a number
22 of them in the vicinity of the Source Area 1. several in
23 Source Area 2. and a number in the downgrading well. The
24 groundwater is falling in this direction. We put these
5 wells in to track how far the contamination had migrated

-------
! Page 8
1 down-grading.
i
t
2 | We also have a number of walls around the
3 maintenance building source here. This figure shows
4 I additional wells that were installed in the vicinity of the
5 maintenance building source, and the locations of the
5 contemporary well points that were installed. These were
7 Installed long enough to obtain samples and then were
!
3 I removed so as not to infringe upon the agricultural •,
9 practice that takes place in the area.
* _
10 This figure displays the location of the)
11 surface water and sediment samples that were obtained. A
12 number were obtained In the drainage ditch along the site
13 and a number were obtained In this drainage ditch to the
14 north of the site.
13 In addition, we obtained samples along Oak
16 Orchard Creek, both above and below the concourse of the
1? drainage ditches and its streams.
IS To briefly summarize, what we found at the
19 site contamination consists prlnmarily of volatile organic
20 chemicals which Is what we expected when we initiated the
21 investigation. The priority contaminate sources area is on
22 the southwestern Source Area No. 1. Contamination and
23 soils in that area consists of clorinated organic chemical
24 such as l. l. 1-trichloroethane. dichloroethane.
29 trichloroethene. They are common salts.
-------
Page 9
We also found contamination in the vicinity
of this maintenance building, although the concentrations
were much lower in that location. We found some
concentrations of metals that were above background levels
3 in both Source Area No. 3 and in Source Area No. i.
5 As a result of the installation of samplings
7 of the well points and the permanent monitoring wells, we
3 j identified 2 contaminant pluses originating from the sife.
I
9 I They are depicted on this figure. Source Areas 1 and 2.
10 have a contaminate plume originating from what is shown
11 here, and the maintenance building also has a contaminated
12 farm.
13 These photos are constrained pretty much to
14 the vicinity of the source, groundwater flows relatively
15 slowly and they haven't moved far. You can see that they
16 are following in a general direction of the groundwater
17 flow.
18 I might also, while we are on this figure.
19 point out that, as I said, we did sample a number of
20 residential wells in the area. One was located about 2.000
21 feet north of where the map is up here, and there are a
22 number of others, one here. here, one here and one here.
23 We found some low level contamination in a couple of these
24 samples. We don't believe it originated from the site and
25 it's well below any of the maximum contaminant levels that
-------
I
! Page 10
1 ! are permitted under the safe drinking water act and also it
i
2 I is on the order of the instrument detection levels, which
i
3 | we use a pretty sophisticated analytical method which
i
4 [ detects the down flow, about 10 parts per foot.
Based on the analytical results that we
have gathered and what we know about the land and water use
7
a
i
1C
11
32
15
16
17
18
19
20
21
22
23
24
29
in the area, we conducted a risk aseessment. Risk
assessment takes into consideration 4 components, one is
exposure, how can possibly people be exposed. The next'
thing you do is select indicator chemicals. These ar»
environmental
etcetera. Once we have determined the exposure roots and
the indicator chemicals, we can estimate those using — who
are general worse case assumptions. Base on those
assumptions we can make estimates of what the
noncarcinogenic and carcinogenic risks are to the public.
The exposure roots we consider were dermal
contact, ingestion of soils, inhalation of dust that's
emitted by wind erosion, inhalation of chemicals that are
emitted as a result of their volatility and exposure just
through groundwater use. That includes both ingestion and
inhalation of volatile chemicals emitted during like taking
-------
2
3
4
3
7
I
9
10
11
12
13
14
IS
ie
17
18
19
20
21
22
23
24
25
Page 11
a shower. We also considered the Impact of residential
monitors.
As a result of ths public health
evaluation, we determined that with ths exception of the
groundwater us* on ths sits itself, noncarciongenic risks
and carcinogenic risks are acceptable: and by acceptable. I
mean, they are below the advisory level. The EPA has a
3i level developed. If you were to develop groundwater oit'the
site Itself, or in one of the contaminate pluses, and use
that for a drinking water source, that Is pretty likely
that some adverse health effects would occur.
I have asterlsksd a couple of these things
here because right now there is a slight amount of
disagreement between us and the Department — New York
Department of Health regarding some of the concentration of
metals that are present in ths soil. That is something we
are presently working out and will ultimately be
considering in the remedial design phase.
Once the risk assessment is completed, we
establish some objectives for remedial action at the site.
One of the objectives is we want to protect the public
health and the environment. Not only that, the EPA is also
being charged to restore all remedial resources to their
best practical uses. The specific criteria we use to
obtain these objectives or to meet state and federal
-------
I
3
4
3
S
7
3
9
10
11
12
13
14
13
16
17
18
19
20
21
22
23
24
23
Page 12
requirements and to obtain acceptable noncarclnogenlc and
carcinogenic risks for the groundwater on the site itself.
To achieve these goals. 8 remedial
alternatives were designed. -First of these is no action
with monitoring, really doesn't obtain a goal, but is
required under the national contingency plan. This is kind
of a base-line information that you can measure the
efficacy of all the remaining alternatives. The second*,
alternative is to restrict any development of the acquirer
within the plume areas and to restrict any excavation or
building within the areas of the contaminated soil.
The remaining alternatives are all
basically oriented towards cleaning up the groundwater. and
all the groundwater treatment scenarios in the Alternatives
3 through 8 are the same. The major difference is the
various approaches taken to clean the soil.
No. 3, does not require any soil cleanup
and cleaning of the soils would occur as a result of
natural" flushing by rain water.
Alternative No. 4 would include placing of
caps over the areas of contaminated soil to prevent this
infiltration and therefore protect the acquifer from any
further degradation.
Alternative No. 3 calls for excavating the
soil and disposing it in an off-site location, such as an
-------
; Page 13
1 approved facility.
2 Alternative No. 6 calls for excavating the
3 soil and treating It In a low temperature Incineration
I
4 i unit, essentially.
i
3 Alternative Mo. 7, calls for using vacuum
6 wells to extricate volatile chemicals from soils above the
I
7 I water table.
3 I Alternative No. a calls for accelerating*
.9 the flushing of contaminant from the subsurface soils by
10 discharging the treated groundwater back to the surface of
11 the site.
12 The feasibility study report states all of
13 these alternatives are analyzed with respect to how well
14 they meet these 9 criteria. They hav« to be protective of
IS the huaan health and the environment, effective and
16 permanent, etcetera, and. in general, treatment
17 technologies that are conducted on site or favored by the
18 EPA.
19 This is basically the bottom line here.
20 How much it is all going to cost. As you can see. the
21 costs vary quite a bit, depending on whether we take no
22 action and the capital cost of no action is zero dollars.
23 However, if we were to pursue no action, we have to
24 continue to monitor the migration of the plumes, and also
23 to monitor the residential area. Hence, there are some
-------
I Page 14
1 costs incurred for long tsrar.
2 The most expensive alternative includes
3 off-site disposal of excavated soils. You can see that
4 these alternatives generally range on the order of about
5 39,000,000 for those that deal with both the soil and
6 groundwater.
7 And at this time I would like to turn it
8 back over to Joe. »,
9 MR. SINOERMAN: Based upon the evaluations
10 of the alternatives of the EPA and DEC, they are
11 recommending for Source Area 1, the source area here, and
12 Source Area 2. the Alternative No. 8. which includes
13 groundwater pumping and treating followed by.recharge and
14 treated water to help flush out the contaminants of the
15 soil. These are essentially the components, the ground
16 recovery wells, the treatment plants at the various
17 treatment system facilities, the metal partakes of metal
18 and absorption, the organ!cs and any water would be
19 recharged for flushing and continued flushing of
20 contaminants from the soil.
21 For Source Area 3. which is this area right
.22 here, a small quantity of the. soil in this area would be
23 detected to build up and elevated in organic
24 concentrations. We are going to further evaluate that
23 during the time phase to determine whether its ultimate
-------
1
2
3
4
5
6
7
9
9
10
11
12
13
14
13
16
17
18
19
20
21
&
2
23
24
25
Pag* 13
disposition would be such as off-site disposal and perhaps
placement on top of the soil would be flushed to remove
metals.
While It appears that the residential wells
are not Impacted by any contamination at the site, we would
continue to monitor the wells to make sure to see what Is
happening: and If necessary, Implement measures to be put
In place for future, for some reason if contamination P:
appears to be showing up In residential wells.
In addition, throughout the life of the
remedy, we will continue to monitor the media, the
groundwater area, whatever Is around the site, to make sure
the public and the environment would not be adversely
effected.
At the completion of the remedy for 5 years
afterwards we will monitor and make sure the remedy is
dblng what It is supposed to be doing, essentially cleaning
up the site.
How. the reason we prefer Alternative No.
8. is that remedies protectred of the public health and the
environment, resource goundwater — contlmlnated soil and
groundwater. Includes demonstrated and effective
technologies, enhancing the flushing of groundwater
contaminants, employs site treatment technologies which EPA
prefers and it is a permanent long-term solution and it is
-------
I
Page is
l | cost effective. This is a preferred remedy, even though it
2 I is EPA's and DEC'S preferred remedy. It is not a selected
3
4
5
7
8
9
10
11
12
13
14
13
16
17
18
19
20
21
22
23
24
23
remedy for the site. We won't make a final selection until
after we consider all public comments and concerns.
Returning once again, this is a Superfund
process. We are at this point right now. soliciting public
comments. Upon consideration of public comments, we will
sign the document called record of decision which ?:
essentially selects the remedy and the decision document
* .*
which identifies — it is like a remedy. It is signed t
administrator of the EPA.
Subsequent to selecting a remedy, we will
design and implement the remedy and then once the remedy is
implemented, the site will be closed and monitored, if
necessary.
In a moment, we will give you an
opportunity to ask me questions, if you want, but just as a
reminder, if you have any questions or comments subsequent
to the meeting, make sure you get them to us, either
verbally by August 31st: or if you send them in writing.
make sure you have them postmarked by August 31st, so w«
can consider any concerns you have before we make our flna
selection. And before you do ask any questions or make an
comments, we have a court stenographer recording the
transcript of the meeting. So we would appreciate it if
-------
Page 17
1 you would identify yourself'before speaking. So if there
2 are any queetions. I will be happy to entertain then.
3 MS. SPARKS: Sir. my naae is Karen Sparks.
4 What I am trying to find out is. how we pay. Me ended up
5 living on the site for a year and a half about 3 or 4
5 months ago. We finally moved. What I aa trying to find-
7 out is there is 2 wells contained in the house. One that
8 j was listed as a well to use for drinking water, the other
i :
9 comes from a buried pond in the back that was used for *
10 bathing and such. I aa trying to find out. if I understand
11 correctly, there is really no risk levels for these wells.
12 for us being exposed or to our children for that amount of
13 tlae.
14 MR. HUBBARO: We sampled both of those
13 wells. One is a dug well and one was a well used for
16 drinking water purposes, on 2 separate occasions. The
17 first sampling round analysis was done using EPA method
18 624. which has an instrument detection limit of about 5
19 part* per billion. We didn't find anything in either of
20 those wells at that detection level.
21 Slmilarily, the previous times those wells
22 were sampled in 1934 and '86. the same result was found,
23 The second sampling round we analyzed the samples with a
24 much more sensitive analytical method. EPA method 601 and
23 602. Those have detection levels below l part per billion.
-------
I
I
I
Page 13
i
1 ; The water that is used for flushing and so forth we found
i
2 I carbon tetrachcloride in one of the samples at a
i
3 I concentration of 9 parts per trillion, which actually
i
4 I reported below the detection llait. for that method it
5 could either indicate there is contamination there, there
6 | are laboratory artifacts, or there is a misidentifcation.
i
7 at that concentration it is really hard to say what is the
I
8 I origin of what that was. At any rate the bottom line 1*
i
9 that concentrate at that compound takes a risk that is well
10 I below the guidelines the agency comes up with.
11 Specifically. It constitutes a carcinogenic
12 risk on the order of 1 and 10 millions chance.
13 MS. SPARKS: Thank you.
14 MR. SINGERMAN: Any more questions?
13 MR. IVISON: What is going to be the
16 actual process now for removing the chemicals from the
1? soil? Jerry Ivlson.
18 MR. SINGERMAN: The removing process
19 itself?
20 MR. IVISON: Yes. how is it actually going
21 to happen?
22 MR. SINQERMAN: The actual process itself.
23 we'll show you some generalized plan, how it is set up, t
24 actual setup itself will be determined during the design,
25 but if you want, we can generalize the scenario.
-------
I Page 19
l This is essentially the process. The
2 groundwater will be extracted froa the; contaminated areas
3 which are here and here. We'll go to the treatment system
4 and then the water will be treated, essentially placed baclc
5 in the area of contamination and this is just a generalized
6 cross-section of how it would be set up. Water will be
7 extracted drawing down the acquifer. contaminated
3 groundwater. going to a treatment plant right here. :
9 discharged to recharge basins will trickle through and :
10 picking up the contamination and picking it up again in a
11 continued cycle. Again, the exact details will be
12 determined during design. This is just a general conceptual
13 plan how it is going to work.
14 MR. IVISON: What is the treatment plant
15 type? How does it actually treat the water, the treatment
16 plant Itself?
17 MR. SINGERMAH: The metals would be
18 precipitated out. adjusting the pH causing it to
19 precipitate out. The organ!cs will be removed. This is
20 kind of complex, but basically, the — the metals — this
21 is the adjustment of pK, the metals — some metals may be
22 removed here. They are attached so far or what — the
23 organlcs will be stripped in this air stripper, where
24 essentially air is blown in and removes the organics. and
23 they will be cleaned before they are emitted to the
-------
Page 20
1 environment. And there are-various other polishing
i
2 procedures: but. again, this is all conception. We have to
3 do treatability studies, both mentioned policy, at the site
4 to determine what the exact scenario will be. This is Just
3 a standard boiler plate scenario for this particular
6 treatment. Does that answer you question?
7 MR. IVISON: Yes.
3 I ' MR. SINGERMAN: Just again, it is just V
9 conceptual design right now. We are going to have, say..
10 six months to a year's worth of actual design to fine
11 the actual prograa.
12 MR. IVISON: Any guess how long the whole
13 process would take?
14 MR. SINGERMAN: It's been estimated it
15 would probably take 7 years to flush the soils.
16 contamination out of the soils and it's estimated it may
17 take 20 years to clean the groundwater. Again, that's just
18 an estimate. Apparently, one of the problems with the
19 groundwater it is a poorly yielding acquifer and as a
20 result, you can't get much water out of the acoTaifer. So.
21 as a result, it is going to take a long time to flush it.
22 So. at most. 20 years, perhaps, it will be much less time.
23 Again, that's a lot of fine tuning, depending on — all th'
24 groundwater treatment scenarios take 20 years. There is
25 really no way around it. This particular alternative, such
-------
i
1 I
2 I
!
3 |
i
* I
i
3 i
5
7
a
Q
10
11
12
13
14
13
16
17
18
19
20
21
22
23
24
29
Page 21
as flushing soil. there is an added benefit for cleaning
the soil as well. It would be concurrent activities.
MR. CHAPEL: Edgar Chapel. I understand
now that-this water, that is flowing north?'
MR. HUBBARD: Yes, generally north, a
northwest direction.
MR. CHAPEL: Under the farmlands?
MR. HUBBARD: That's correct. f.
MR. CHAPEL: Is there any risk there with
crops?
MR. HUBBARD: The chemicals that are
migrating do not bio-accumulate. Furthermore, there is a
drainage system installed in that field that helps to
prevent the water to be elevated into the root zone of
crops.
MR. CHAPEL: Old you find any contaminants
in that ditch to the north, the one on the north side of
that plan?
MR. HUBBARD: Yes. we did. We found — we
had 2 hits of toludlne and metalefelsotone.
MR. CHAPEL: What were the limits on it?
MR. HUBBARD: I believe we found toludlne
upon 1.600 parts per billion in one of these samples
MR. CHAPEL: That isn't considered a risk?
MR. HUBBARD: Ho.
-------
Page 22
i
1 ! MR. CHAPEL:' So what you are saying is
2 | actually this water is not a risk to anybody at this point?
3 | MR. HUB8ARD: That's correct.
4 j MR. CHAPEL: What would make it a risk in
3 the future?
5 MR. HUBBARD: If you were to put a well in
7 a contaminant plume and started to use it for portable use.
i
3 i MR. CHAPEL: Pardon? '?-•
I :
91 MR. HUBBARD: If you were to put a well* in
• -
10 one of the contaminant pluaee and to develop that for hum,
12 consumption, that would constitute a risk.
12 MR. CHAPEL: But. ae this moves out of the
13 area, what you are saying is that the risk is less, as far
14 as the parts per billion that you just mentioned? So if
IS a well was put in the area of that ditch to the north, it
I
16 would not create a test that would not be acceptable to the
17 Qenesee County Health Department or New York State?
18 MR. HUBBARD: The groundwater contaminated
19 pita* could not extend that far. We can't really figure
20 out a way we found toludine in that ditch that we were
21 working. It is possible that it is as a result of —
22 . . MR. CHAPEL: You didn't find much in the
23 ditch right next to it.
24 MR. HUBBARD: No. we didn't, right.
25 . MR. CHAPEL: You found .more farther off,
-------
Pag* 23
1 Arc you sure that stuff came from that particular site or
2 could It have come from some other site, from some other
3 material, we'll say. or some other source?
4 MR. HUABBARD: Well, that's my belief, it
3 originated from some other source.
5 MR. CHAPEL: What would be a source — what
7 would that — the ones that you are talking about on that
8 north ditch, what would be some of the sources that can*:
9 come from, anything in the spray material or anything -7
• _
1C MX. HUBBARD: Well. Toludlne is a component
11 of paint stripers.
12 MR. CHAPEL: I» a component of paint
13 stripers? Just put that cover down. I could hear you
14 better. I can't hear you.
15 MR. HUBBARD: I am sorry. It is a
16 component of paint strippers. Toludlne. It is also a
1? constituent of gaaoline or diesel fuel.
IE MR. CHAPEL: Right.
19 * MR. HUBBARD: I know a lot of things.
20 MR. CHAPEL: But. really, you have no way
21 of knowing that this is part of this particular site,
22 accept that — it is not right, but you have no way of
23 knowing where that water came from when your first ditch
24 doesn't show it.
25 MR. HUBBARD: Hell, we didn't find It in
-------
Page 24
l the water samples from the ditch.
2 MR. CHAPEL: Right.
3 MR. HUBBARD: We found it In the sediments.
4 MR. CHAPEL: But what you —- what you are
5 saying, though, if they want to eat the potatoes out of
6 that lot. they can harvest the potatoee. but what you are
7 also saying is that we should spend 5 million dollars to
•.
8 clean this up when what are we going to do. what are we\'
9 going to accomplish by spending 5 million dollars? : .
10 MR. HUBBARD: The acquifer is a source of
11 drinking water, it is a natural resource that has been
12 contaminated and the EPA charter dictates that not only do
13 you protect the public health, but you try and restore all
14 natural resources.
13 MR. CHAPEL: But what you are saying within
16 a 150 feet of where this source was. that water is not
17 contaminated in that well, you just told that lady just
18 now.
19 MR. HUBBARD: That's correct.
20 MR. CHAPEL Than why are we concerned about
21 this outside of the area of 1 and 3. I don't understand —
22 I don't understand where the 1 came in. because that was
23 not any in the dump. Mow, all at once we find it in No. 1.
24 Where did that come from? Was there a gas tank leak or
25 something, do you know what I mean? No. 1. where the
-------
Page 25

1 building was. you didn't find that until the last — when

2 I you found that, could that have com* froa gasoline, dleeel
i
I
3 I fuel or whatever. You said that other did, well, that
I
i
4 ) source is not —
I
5 MR. HUBBARD: Wo. that source is not —

6 j It's clorinated salts, similar to the ones that were found
i

7 I in the other area.

31 MR. CHAPEL: But not the same thing though,
j
9 i similar, but not the same. In other words, it isn't ths>.

10 same stuff that was found where the drums were.

11 MR. HUBBARD: That's correct. Okay.

12 MR. CHAPEL: 3o. I think you've got — what

13 you have got here. Is the situation that you are not

14 finding the same stuff all over and still it isn't going

15 anywhere. This is what I am concerned with. It isn't

16 going north.

17 MR. HUBBARD: Hell, it is migrating very

18 slowly to the north.

19 MR. CHAPEL: It is not going south.

20 MR. HUBBARD: That's contrary to the

21 direction of the groundwater flow.

22 MR. CHAPEL: Thank God.

23 MR. HUBBARD: But we know a very shadow

24 hydraulic reading, that's like how deep the water table is.

25 Some of you may be more familiar with hydroeology, it is
-------
Page 26
1 very similar. the water table Is steep and you have got a
2 coarse material. you can have the water move there very
3 rapidly. But If the water table Is essentially flat, which
4 Is very much the condition that we have, the water even, if
5 It Is a real permeable material, the water won't move
6 rapidly, and that's pretty much the situation we have.
7 MR. CHAPEL: That water table, that's a
a I considerable amount of feet in the year. *:''
9 MR. HUBBARD: That's true, but it flow* ,
10 essentially uniformly, across the area of the site. It
11 raises up in the onion field and It raises up over on the
12 site and escar as well. It does move quite a bit.
13 MR. CHAPEL: There is no way of any of that
14 movement coming south, is what you are saying?
19 MR. HUBBARD: If you were to put In a big.
16 production well to the south and start pumping it like
17 crazy, you could draw contamination In that direction, but
18 sine* the acqulfer is pretty low yielding, it is unlikely
19 yo« are going to do that. He don't antdlcipate that
20 contaminants are going to migrate in any direction contrary
21 to what they have and it is consistent with the
22 hydrogeology.
23 MR. SINGERMAN: Just to supplement the
24 answer to your question regarding why we are spending so
29 much money to address the problem that doesn't appear that
-------
Page 27
significant. You are right*, it doesn't appear to be a
2 significant threat to public health. We are tying to
3 protect the environment. We are also mandated to protect
4 the environment as well as the public health. And if we
3 were allowed to continue the way it is going, we could
6 jeopardize public health. So we are trying to address the
7 situation now while it is still localized and clean it up
•.
\ •
3 so it won't become a problem in the future. So this area
9 is something we can use in the future. As it is now we> -
10 can't develop it or use it.
11 MR. GRANT: John Grant.
12 MR. SINGERMAN: The gentleman over there
13 has a question. Re w*s cut off.
14 MR. HUPPA: At the time you were showing
IS this treatment plant, it looks like quite an operation
16 there. I was wondering who would be responsible for the
17 operation of that thing, what agency or person is going to
18 operate, it.
19 MR. SINGERMAN: You have to identify
20 yourself.
21 MR. HUPPA: My name is Francis Huppa.
22 MR. SINGERMAN: The responsibility of the
23 maintenance of the facility would be that of the state, the
24 state is responsible for all operations and maintenance.
29 They may delegate to a lower authority, such as the county
-------
Page 28
1 or SOB* other authority, but the ultimate reaponsiblity is
2 the state's.
3 MR. HUPPA: Would that ultimately be the
4 responsibility of some contractor of the state?
3 MR. SXNGERMAN: Perhape, the state may
6 decide to have a contractor do the operation and
7 maintenance, it is really up to them.
f '
8 MR. HUPPA: Thank you. :
9 MR. SIKGERMAN: See. the thing is, as far
10 as the remedy goes, the EPA will finance 90 percent of th
11 remedy and the state will finance 10 percent and for a
12 certain period of years, the operation maintenance facility
13 won't be costing you anything. But eventually, after 10
14 years, the state's responsibility to operate a 100 percent
IS — to finance and operate it is a 100 percent.
16 MR. GRANT: My name is John Grant. Talking
17 about the government, but a lot of that is wetland and the
18 food and security act of 198? prohibits a lot of that
19 development of wetland because it is wetland and that will
20 preclude a lot of the development up there. So you have
21 one law that says you can't develop it a great deal and now
22 you are talking about protecting it so it can be used for
23 development, and by law you can't develop it.
24 MR. SINGERMAN: Well, we are trying to
25 protect the environment. The main reason we are trying to
-------
Page 29
I
1 j protect the environment, if-for some reason in the future
i
2 i it is devleoped —
i
3 ! MR. GRANT: Congress passed a law that
i
4 I said it can't be developed because it is wetland.

3 I MR. SINOERMAN: Hell, if for some reason —

6 j essentially the rules are no net loss, or if you develop a

7 wetland somewhere or some area in the vicinity, you
I f
3 I transmit another. ?:
i
9 MR. GRANT: That's not what that law sav.s.

10 MR. SZNQERMAN: It is either something of

11 higher quality or something, the bottom — regardless

12 whether or not it's developed or not. we are not advocating

13 development of the area. We are saying that If for some

14 reason in the future it is devleoped, or we are just trying

IS to protect it, if it is developed or if not developed, we
i
16 are mandated to protect the environment as well as the

17 public.

18 MR. GRANT: You also have to be cost

19 efficient, right?

20 MR. SINGERMAN: Right.

21 MR. GRANT: And I don't see any benefit for

22 5 million dollars.

23 MR. SINGERMAN: Well, the benefit is we are

24 cleaning up the environment, there is a threat to the

25 environment.
-------
Page 30
1 MR. GRANT: * You are cleaning up a very
2 small threat to the environment.
3 MR. SINGERMAN: Well, it may be a small
4 threat, but it is still a threat. I mean, the mandate of
5 the Superfund is to clean it up to a level that protects of
6 the public health and the environment, for us to. for
7 example, to take no action and not remediate the site is
8 not consistent with our environment. v:
9 MR. GRANT: You are like all the other : -
10 federal agencies, you do not have an unlimited budget, an
11 if you use 3 million dollar*, that's S million dollars you
12 can't use somewhere* else?
13 MR. SINGERMAN: That's right.
14 MR. GRANT: And is this the environment —
19 and living in a clean environment, but is this the most
16 beneiflcial use for this 9 million dollars?
17 MR. SINGERMAN: Well, perhaps another site
18 may be more dangerous, but we are not necessarily
19 prioritizing money that has to be spent. Our feeling is
20 this site poses a risk and we need to remediate it. Doee
21 that answer your question?
22 MR. CHAPEL: It doesn't answer mine. To
23 the point that you've got a risk.
24 MR. SINGERMAN: We do have a potential
29 risk, due to the contaminant plume moving off site.
-------
Page 21
1 MR. CHAPEL: ' Pardon?
2 MR. SINGERMAN: It we are not remediating
3 the contamination. the plum* would continue to move.
4 MR. CHAPEL: I understand what you are
5 saying.
5 . MR. SINGERMAN: Just to let it to continue
7 going, continue to move. I mean, sometime eventually it is
fl going to effect someone. f:
9 MR. CHAPEL: But you have taken the
10 contaminants out of it. all right, all of the stuff hae
11 been taken out. all of the drume have been removed, so
12 there is no more contaminant there. So the only thing that
13 we have got is what is there right now in the water, right.
14 and you can't develop any more, right?
15 MR. SINGERMAN: We have contamination
16 present there even though we have taken out the drums, and
17 taken out the contaminant odor, there is still
18 contamination — reeldual contamination left.
19 MR. CHAPEL: Where?
20 MR. SZNGERMAN: In the soil.
21 MR. CHAPEL: In the water or in the soil?
22 MR. SINGERMAN: Well, in the soil.
%
23 MR. CHAPEL: Okay. Then, let's get the
24 soil out of there and forget the water, you won't have any
29 more contaminant in the water, if we remove the soil.
-------
Page 32
1 MR. SINGERMAN: (toll, we have contamination
2 In the acquifer as well. In the saturated portion of the
3 soil and because of that — in order to get it out. we have
4 to excavate it. we have to take it somewhere, we have to
3 treat it. Me looked at various alternatives, and one of
6 the alternatives was to take it out and take it somewhere,
7 but the meet appropriate alternative that the EPA and DEC
8 feel is appropriate for the site is Alternative No. 8. v"
9 MR. CHAPEL: But you can treat that soil.
10 there is an alternative in there, that that can be treate
11 on site, put right back, aa I right?
12 MR. HUBBARO: Maybe I can answer your
13 question this way. Most of the cows have already gone out
14 of the fence.
IS MR. CHAPEL: Pardon?
16 MR. HUBBARO: Most of the cows have alreay
17 gone out of the fence.
18 MR. CHAPEL: No, but you have got them all.
19 supposedly.
20 MR. HUBBARD: They are in the groundwater.
21 Residual contamination, low level of residual contamination
22 will flow, or the contaminants that were left in the
23 flushing of water.
24 MR. CHAPEL: Okay. I will give you that.
29 Another question. Why did it wait 5 years before we got
-------
Page 33
1 rid of It. Why wasn't it done in 1982 when it was first
2 developed? Who is to blame for this going as far as it
3 has? Why should ths federal fund or Super fund or
4 whatever — I msan. somebody had a responsibility to that.
3 Who took acceptance to that when they found it. ths state.
6 right? EPA OR DEC. ons of them, or both of them. Those
7 people did nothing with this site for 5 years. Now, in 2
1 ?••
8 I years, they took the drums. Now. there is testament and: I
9 got much smart, but I don't see the point to this, somebody
10 should had dons this a long time ago, and we wouldn't have
II the contaminants in ths water. Now, we have got to go
12 ahead and fix all this.
13 MR. HUBBARD: The EPA was requested to
14 conduct a removal as of April, 1984.
15 MR. CHAPEL: Who requested it?
16 MR. HUBBARD: The DSC did.
17 MR. CHAPEL: Okay. Then, why didn't the
18 D1C do something between '82 and '84?
19 MR. HUBBARD: I can't really say.
20 MR. CHAPEL: You've got the DEC man here.
21 MR. HUBBARD: I can't really say that the
22 EPA conducted any removal action and at that time they
23 installed monitoring wells and conducted some surface soil
24 sampling as well as sampling residential wells to determine
25 —
-------
Pag* 34

1 MR. CHAPEL:' Not In '84?

2 MR. HUBBARD: Yes. in r84. Yes. thsy did.

3 MR. SINGERMAN: The site was already

4 identified in July of '32 and subsequent to the stage they

S performed the investigation and took saaples to determine

6 what the threat was and based on ths state's request, the

7 EPB went in.
•
8 MR. CHAPEL: Well, nevertheless, it is hire,
i
9 but the next thing —

10 MR. SIlfGERMAN: We are Just finishing up

11 the job. We started the job in '84, took off the drums,

12 took off the contaminated soil and if we hadn't done that

13 probably ths situation would had been much worse. We would

14 have had a much greater plume and a much greater problem.
i

19 MR. CHAPEL: But it would had been a lot •

16 quicker and a lot less — <
i
17 MR. SINQERMAH: Well, the problem is we .!
i
18 can't just go out and create a site without an |

19 Investigation. We are allowed to go out as to what is an ;

20 immediate threat to the public health environment. If we

21 have drums sitting there readily leaking, we are going out

22 and we can immediately address them. We did. But as far

23 as a long term threat, such as we have this plume moving,

24 we have to do a very detailed inveetlgatlon because since

25 we have limited funds we want to make sure we take the
-------
Page 33
1 appropriate action, and we really can't take action unlese
2 we know what the problem Is. and we know what exactly the
3 problem Is. and we had to do this very Intense
4 .Investigation.
5 MR. CHAPEL: What you are also saying Is
6 that out of the SO people here tonight that if we all said
7 we didn't want to fix It. you would still fix it anyway?
•.
a MR. SINOERMAN: The reason we are here/:is
9 to get your input as far as —
10 MR. CHAPEL: What you are also saying that
11 If we say we don't want it fixed, you are going to fix it?
12 MR. SINGERMAJf: No. we are not saying that.
13 We identified the remedy. Alternative Ho. 8, that's
14 addressing the contamination problem. The reason we are
IS here tonight, is to get your comments. We will take Into
16 considratlon your comments and select a remedy.
17 MR. LOMNEY: Jeffrey Lomney. Your
IS presentation tonight addressed the aerial extent of the
19 contajBlnant plume. What I — part of your investigation
20 defined the vertical instrument that you considered,
21 leaking and deeper acqulfers in your remedial scenario.
22 MR. HUBBARD: We installed a number of
23 monitoring well clusters, particularly in the 3 source
24 areas. We Installed a cluster of wells and each of the 3
23 sources that we knew were there originally. We ran a
-------
Pag* 36
1 number of borings down to about 89 or 90 feet, and we found
2 there is a very compact layer of till both beneath the
3 site. Zt is overlaying by land, gravel and cobbles and
4 with water bearings out. and there is a real dense till.
3 We ultimately — we originally planned on installing deeper
6 wells down, essentially on top of the bedrock, and once we
7 discovered the till is there and over 50 feet thick, we
8 decided to cluster our wells since the water table and \once
9 at the base of that water bearings of the till. We :
10 conducted the hydraulic conductivity testing In the till
11 place, by driving casings into the drill and then
12 essentially doing slug tests to see how fast the water
13 would permeate into the till itself. Now. based on that we
14 found the till has a permeability that's essentially
15 equivalent to what you would use to fill a cap over a
16 landfill, really permeable material.
17 MR. LOMKEY: Had the amount settled?
18 _ MR. HUBBARO: Approximately, yes. We also
19 found in our shadow well clusters, there is no verital
20 grading whatsoever. Additionally, when we sampled the deep
21 and the shadow wells, we found that the shadow wells were
22 contaminated and the deeper wells were not in the source
23 areae. As you move down radiant, into the onion field.
24 did have some well clusters there and they indicated the
25 plume that disbursed in the vertical direction and the
-------
' Page 37
l concentrations were roughly"similar in the deep and shadow
2 well, but there appears to be no potential whatsoever for
i
3 | degradation of the contaainants into the fill.
i
41 MR. LOWZY: What type of flow volacltiea
3 were calculated?
5 MR. HUBBARD: Really can't recall off the
7 top of my head, but baaed on the most recent ground level
3 I measurements we took and use is average hydraulic :'
9 contamination, moat of the sitee were not included novloe_
10 areas. I came up with 65 feet per year. It is not moving
11 real fast.
12 MR. GRANT: During this cleanup, you are
13 still going to allow them to grow onlona. right?
14 MR. SINGERMAN: Well, the plume is not
19 impacting onions.
16 MR. GRANT: If it is permissible to grow
17 human food in the plume area, it seem* to show an extremely
IS minimal risk because there is very few things that you do
19 with an onion before you eat it, except for washing it off.
20 and slicing it and putting it on your hamburger, there is
21 not much more preparation to it. unless you like fried
22 onions. It would be the same as drinking the water.
23 because the onions are going to absorb a lot of water to
24 produce it. and if it is safe to eat onions out of that
29 field. I can't see spending 9 million dollar* to proect
-------
Pag* 38
1 well sites that are not going to be there to start with.
i
2 MR. HUBBARD: If we can expand a little bit
3 on ths> envlronaent Impact condition. Ultimately these
4 pluses are going to reach the drainage ditch to the north
5 of the/ adjacent farmland. Once they get there, they are •
6 going to end up In Oak Orchard creek and It's my belief
7 that Oak Orchard Creek ultimately goes Into Oak Orchard
8 swamp, there Is a sensitive eco system. While we are V
9 dealing with outcasts, the surface water volume. It can':t.
10 be absorbed, some of these things are not particularly
11 Involved.
12 MR. GRANT: Yon have a known — you have X
13 amount of contaminants and the amount of contaminants Is
14 not Increasing, not X plus Y and I. As the plume expands.
IS the concentration has got to decrease?
16 MR. HUBBARD: That's correct.
17 MR. GRANT: And If It Is no risk level to
18 start with, how can It get to the risk level by expanding
19 it over a orach larger surface.
20 MR. HUBBARD: W«il. If It were — If the
i
21 concentration of the ground water right now were present In j
i
i
22 the surface. It could be a risk. It certainly would be a i
23 risk If people were drinking It.
24 MR. GRANT: Only In the plume area?
29 MR. HUBBARD: Under existing conditions
-------
Page 39
1 there is no risk, but in the future, there could be a risk.
2 MR. GRANT: I think to me anyway you arc
3 having a hard time proving your cost effective benefit
4 ratio.
5 MR. HUBBAJID: Hell, again. we ar« trying to
6 remediate th« cits. We feel it's a risk to tha
7 environment.
3 MR. GRANT: And I realize that our rule* -and
9 regulations require that, but thsy are like every othsr: .
10 federal law that is ever written and 16. others that cone
11 into play on it also and there is no federal regulations
12 that stands by itself and that in order to show the — you
13 aust show some sort of cost benefit ratio, you want to
14 spend a tremendous fortune unless you work for 000 to do
15 something very small.
16 MR. SIRGERMAN: One of the things we have to
17 comply with, state and federal drinking water strandards
18 and also any other standards that apply. And this
19 standard, the groundwater in the plumes, doesn't comply
20 with the state's standards. So therefore we are required
21 to remediate the site.
22 Mr. SACKZTT: May I make a comment, please?
23 John Sackett. I think you have got about 2 acres, you
24 might have 3 acres now with the plume, possibly 4. Why not
29 put a deed reetrlction on, give the 9 and a half million to
-------
Page 40
1 the Town of Byron and we'll*put in a water system for those
2 people that don't have good water In the town. I think
3 that would be the perfect situation.
4 UNIDENTIFIED SPEAKER: Amen.
3 UNIDENTIFIED SPEAKER: I second the action.
6 MR. SINOERMAN That doesn't solve the
7 problem. Any more questions?
8 MR. KAUFMAN: David — ^'
9 UNIDENTIFIED SPEAKER: It's obvious that
10 most of your gentlemen that are up here directing this hai
12 never worked in your life for a living. You always worked
12 off the taxpayers and it's quite obvious tonight froa your
13 comments. That's all I have got to say. I'd say anybody
14 that works would not come to the conclusion you have. Amen.
19 Nature will heal itself. Give it a chance.
16 MR. KAUFMAN: David Kaufman. In your map
17 of the treatment areas, you don't show any treatment for
18 Source Area 3. why is that? There is also - I didn't see
19 anything in the plume map either, is it because there is no
20 plume there?
21 MR. HUBBARD: That's correct.
22 MR. SINQERMAN: There is no plume. Also
23 as far as our treating the soil, we have to learn to
24 determine the full extent of any contaminated area. It's
25 primarily metals contamination and exactly how we addrees
-------
Pag* 41
i
I it we have to determine that during the design, whether
2 taking It outside or placing It on top of the areas that
3 would be flush or some other approach.
4 MR. CHAPEL: Also. Joe, those were all above
5 ground, thsoe barrels were above the ground In No. 3. so I
6 think they got them before anything ever happened, before
7 they — I think they got then. Mo. 1 was the one that —
i i
SI Mo. 3 — I think they were all above ground and they've got
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
them all.
drums.
MR. SINGERMAN: I hope we have got all the
MX. CHAPEL: Pardon?
MR. 3INOERMAN: Hopefully we've got all the
drums.
MX. CHAPEL: Yes.
MR. SINQERMAN: That Mo. 3 was above ground.
It was very obvious. I think there Is no problem there.
That's why I think you found very little.
MX. SINOERMAN: In relative terms, the
threat from that area Is much less than the other areas. '
i
MR. CHASER: Al Chaser. You mentioned here i
:
i
you wanted one — you know, one of the things on here Is i
i
i
closing the site. How far does that extend; I mean, does j
that mean — does that affect the housing there?
MR. SZGNERMAN: What do you mean, closing?
-------
; Page 42
1 MR. CHASER* Well, you mentioned on —~"
2 MR. SINGER: Essentially closing means the
3 site has been remediated and it's closed up, that's what we
4 meant by closing, not restricting or anything liks that.
S MR. CHASER: Because I live about SO foot
6 from that entrance or whatever. I wondered what effect that
7 would have on me and my family.
8 MR. SINGERMAN: Whatever operation is V
9 implemented at the site, we would take into consideration
10 the people living at the area, such things as noise and
11 dust and whatever which is being generated in the process.
12 We would keep down the level as to not effect the people in
13 the area. I mean, all these things we have to determine in
14 the design and when the remedy is finally completed we
IS provide this cover over the area that was remediated, that
16 means the closing sits.
17 MR. CHASER: I was just wondering about
18 the) situation, once work begins if I would have to leave
19 that house.
20 MR. SINQERMAK: We hope we'll be able to
21 do it in a way that we would implement — in a way we would
22 adversely have an Impact on the area so you would be able _
23 to stay in your house and would not be impacted, because w^~
24 don't want to spread the problem. In treating the
23 situation, we don't want to create a situation where we
-------
Page 43
spread duat or scrapers or Anything else in the vicinity,
but impact other areas or potentially threaten the health
3 and the people in the vicinity.
4 MR. CHASER: Only other thing I an
3 wondering about, wae there some sampling of the residential
5 well }uat last week. All right. I have been told the only
7 way I could get reeults of that is going through the
3 Freedom of Information Act to find out if they are now i:
9 contaminated or anything like thia at all?
10 MR. SIMGERMAII: I believe these were
11 sampled by the county.
12 UNIDENTIFIED SPEAKER: It was the state.
13 department of health.
14 MR. MIFACHI: I woris for the state, for the
13 DEC. and it was my understanding that the health
16 department, the state health department in Albany requested
17 the county health department actually obtain stamples. I
18 understand they are being analyzed in Albany, and the
19 rvtmlt* would be available upon order in s. couple of weeks
20 to a month. I will be happy to get that Information
21 directly back to you. if you'd like.
MR. CHASER: Yes.
-3 MR. MIRACHI: Are you on the sign-up sheet?
MR. CHASER: I will be.
MR. MIRACHI: I will make sure I have your
-------
Page 44
name and address and I v/ill give you my card before I leave
and as soon as we near anything back en the results. I will
3 get in touch with you directly.
4 MF. SIJIOERMAN: Any other questions? Going
5 once, going twice —
5 UNIDENTIFIED SPEAKER: How is the ultimate
T decision finally made, a group, a single person or what?
3 MR. SINGERMAN: Well, once the comment •
period closes, we ta^e all the comments that r;ere collected
10 and v;e'll essentially discuss it amongst ourselves. SPA
11 DEC. and we'll come up to a consensus as to what remedy
12 preferred, or if not a remedy, and then we'll make a
13 recommendation to the regional administrator.of the EPA.
14 and if he agrees with the recommendation, and he signs off
IS the decision which raaices that a. selective remedy. It is
15 not one person. It is a collective bodv of both agencies
17 having input in the DOH and various other agencies. Any
18 more Questions?
19 MR. I1AUPMAN: Dave Kaufman. Again.
20 basically you are not going to treat the plume in the
21 fields to the north at all. right, you are just going to
treat — you are going to treat the berra around the areas
23 to the 2 source areas, treat those 2 areas and then let tii
24 plume in th* fields go?
2S MR. SINQERMAN: No.
-------
Page 43
MR. i:AUFMAN: rfow will the plumes in the
fields be treated?
3 MR. HUEEAKD: Well, includes the reversal
4 of the degrading in the fields, by drawing down — to
9 induce the gradation change in the fields by drawing down
the acguifer so the water will flow from between the fields
back.
MR. KAUFMAN: Go back this way. Mow i
flowing this way and now going back this way, pulling i-t
•
10 back?
11 MX. HUBBARD: That's one of the reasons it
12 takes so long to achieve it. it's 20 years. Not only is
13 the water out there contaminated, but the contaminant is
14 also absorbed in the soil. We have to pull all that stuff
IS off. If the water doesn't move fast, you have to pump it
If out.
17 UNIDENTIFIED SPEAKER: Mow deep is the
18 plume in the fields?
19 ~ MR. HUEHARD: About 13 feet deep.
20 MR. 3INQERMAN: Any more questions? No more
21 questions. I guess the meeting is over. Again, if you do
have any questions when you go home tonight or anytime in
the next few weeks. either write to us at the address of
-4 the proposed plan or give us a call. If you stay around for
23 a while we'll — question?
-------
Page 4*5
UNIDENTIFIED SPEAKER: 'toy can't Mr.
Freeman nay for it?
3 MR. SINGERMAN Can you identify yourself?
4 UNIDENTIFIED SPEAKER: Let him pay the
9 government to clean it up.
5 MR. SINGERMAN: What we are attempting to
7 do. if we can convince the people responsible for the
8 problem of the site to clean up the site, we'll atetmp-j to
v. '
3 recover in court after we expend the monies. So anyone.
10 that means Mr. Freeman as well as anyone who contributed'
11 the waste to the site is responsible for the cleanup or
12 financing the cleanup, if we do it ourselves.
13 UNIDENTIFIED SPEAKER: Should be the owner
14 of it and since I heard he is in Florida, where he is or
13 not. I don't Icnow.
15 MR. SI1TGERMAN: We are pursuing him for the
17 cost.
18 Any further questions. We'll stick around
19 h«rt). we won't leave.
20 (Proceeding adjourned at 8:09.)
21
23
24
23
-------
2
3 1
4
5
8
3
4
7
3
6
8
7
9
8
10
stenotype notes,
forty-eeven is an accurate and correct record of my
i:
1312
143
iy«i E.
1314
17
18
18
19
19
20
20
233
2*4
70
Page 47
CERTIFICATE
I. Edith E. Forbes, do hereby certify that I have
reported in stenotype shorthand the proceedings in the
matter of the Public Hearing of the Byron Barrel and Drum
Site, reported at the Byron Fire Department Recreation
Hall. Byron. New Yoricr
And that such transcript, numbered pages one through

Edith E. Forbes, Notary Public
EDITH E. FORBES (716)343-8612
-------