Superfund Record of Decision: American Thermostat, NY


          United States
          Environmental Protection
          Agency
              Office of
              Emergency and
              Remedial Response
EPA/ROD/R02-90/110
June 1990
oEPA
Superfund
Record of Decision
          American Thermostat, NY

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50272-101
I REPORT DOCUMENTATION 1. REPORT NO. 2.
I PAGE EPA/ROD/R02-90/110
I Title and Subtitle
I SUPERFUND RECORD OF DECISION
I American Thermostat, NY
I Second Remedial Action - Final
I 7. Author)*)
1 8. Performing Organization Name and Address
I 12. Sponaorlng Organization Name and Addreaa
U.S. Environmental Protection Agency
401 M Street, S.W.
Washington, D.C. 20460
3. Recipient's Accession No.
5. Report Date
06/29/90
6.
8. Performing Organization RepL No.
10. Proiect/Taak/Work Unit No.
11. Contract^) or Grant(G) No.
(C)
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EPA/ROD/R02-90/110
American Thermostat, NY
Remedial Action - Final
Abstract (Continued)
>
The selected remedial action for this site includes excavating and treating 6,500 cubic
yards of contaminated soil using low temperature enhanced volatilization; removing 300
cubic yards of contaminated sediment from a residential pond and treating it concurrently
with the soil; backfilling the treated soil and sediment and covering the area with clean
soil; pumping and treatment of ground water using filtration, air stripping, and
carbon adsorption, followed by reinjecting treated water onsite; decontaminating the AT
building; removing 18 waste oil drums, debris, and less than 5 cubic yards of drain
sludge from the building for offsite treatment and disposal; disposing of all treatment
residuals offsite; and conducting ground water and air monitoring. The estimated present
worth cost for this remedial action is $26,102,200, which includes an annual O&M cost of
$1,304,300 for 30 years.

PERFORMANCE STANDARDS OR GOALS: Chemical-specific goals for soil include PCE 1.0 mg/kg
and TCE 0.4 mg/kg. Ground water chemical-specific cleanup goals include PCE 5.0 ug/1,
TCE 5.0 ug/1, arsenic 25.0 ug/1, chromium 50 ug/1, and lead 25 ug/1, all of which are
state MCLs.
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Declaration for the Record of Decision
9

Site Name and Location

American Thermostat site, South Cairo, Greene County, New York

Statement of Basis and Purpose

This decision document presents the selected remedial action.for the
American Thermostat site, located in South Cairo, Greene County, New
York, which was chosen in accordance with the requirements of the
Comprehensive Environmental Response, Compensation, and Liability
Act of 1980 (CERCLA) , as amended by the Superfund Amendments and
'--rization Act of 1986 (SARA) and, to the extent practicable,
the National Oil and Hazardous Substances Pollution Contingency .Plan
(NCP). This decision document explains the factual and legal basis
for selecting the remedy for this site.

The New York State Department of Environmental Conservation (NYSDEC)
concurs with the selected remedy. The information supporting this
remedial action decision is contained in the administrative record
for this site.

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 (ROD) , may present an imminent and
substantial threat to public health, welfare, or the environment.

Description of the Selected Remedy

This operable unit is the second of two operable units for the
site. The first operable unit involved the establishment of an
alternate water supply for the residences affected and potentially
affected by the groundwater contamination at the site. This final
operable unit addresses the source of the soil and groundwater
contamination at the site, the contamination inside the building
standing at the site, as well as the contamination in the
groundwater in the entire contaminated plume emanating fir cm the
site. This action addresses the principal threats remaining at the
site by treating the most highly contaminated soil and waste
materials/ by decontaminating the building at the site, and by
treating the contaminated groundwater in the plume emanating from
the site. Treatment residuals will be disposed of off-site and
treated soils that will be redeposited on-site will contain
contaminants well below health-based levels, so that the site will
not require any long-term management. Treatment of the groundwater
will require a comprehensive management and maintenance program to
ensure the effectiveness of the treatment and reinjection system
throughout the treatment period which is estimated at 30 years.
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The major components of the selected remedy include the
following:
r
- Excavation and treatment, via on-site low temperature
enhanced volatilization, of approximately 7,000 cubic yards
of contaminated soil;

- placement of the treated soils into the excavated areas;

- Extraction and treatment, via air-stripping and carbon
adsorption, of the groundwater in the contaminated plume
emanating from the site and reinjection to recharge the
- treated water into the ground. The combined volume of the
contaminated groundwater in the bedrock and shallow aquifers
is estimated to be 16,000,000 gallons;

- Decontamination of the on-site building via vacuuming,
dusting and wiping of the contaminated surfaces and off-
site treatment/disposal of the collected hazardous dust;
removal and off-site treatment/disposal of 18 waste oil
drums contaminated with hazardous materials stored in the
building; and, removal and off-site treatment/disposal of
sludges from drain pits inside the building; and

- Disposal of the treatment residuals at an off-site Resource
Conservation and Recovery Act (RCRA) hazardous waste
facility.

Declaration of Statutory Determinations

The selected remedy is protective of human health and the
environment, complies with federal and state requirements that are
legally applicable or relevant and appropriate to the remedial
action, and is cost-effective. This remedy utilizes permanent
solutions and alternative treatment (or resource recovery)
technologies to the maximum extent practicable, and it satisfies the
statutory preference for remedies that employ treatment that reduce
toxicity, mobility, or volume as their principal element.
Regional Administrator // / Date
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ROD FACT SHEET

SITE

Name: American Thermostat

Location: South Cairo, Greene County, N.Y.

HRS Score:

,NPL Rank:

ROD

Date signed: 6/29/90

Remedy: Low Temperature Enhanced Volatilization (SOIL)
Pumping,Air Stripping,Carbon Adsorption,Reinjection (GW)
Capital Cost:
$ 6,052,500

O & M/Year: $ 1,304,300

Present Worth Cost: $ 26,102,200

LEAD

EPA Remedial

Primary contact: Christos Tsiamis (212) 264-5713

Secondary contact: Joel Singerman (212) 264-1132

Main PRPs: Harry Moskowitz (ex-president,AT Corp.)
AMRO Realty Corp. (property owner)
PRP Contact:

WASTE

Type: Volatile Organics

Medium: Soil,groundwater,surface-water.building.

Origin: Dumping of Volatile Organics during plant operations

Est. quantity: Contaminated soil: 6,500 cubic yards

Contaminated groundwater: 16,000,000 gallons
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DECISION SUMMARY

AMERICAN THERMOSTAT SITE
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

REGION II

NEW YORK
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TABLE OF CONTENTS
SITE NAME, LOCATION AND DESCRIPTION 1
SITE HISTORY 2
ENFORCEMENT ACTIVITIES 3
HIGHLIGHTS OF COMMUNITY PARTICIPATION 4
SCOPE AND ROLE OF RESPONSE ACTION 4
SUMMARY OF SITE CHARACTERISTICS 5
SUMMARY OF SITE RISKS 9
DOCUMENTATION OF SIGNIFICANT CHANGES 22
DESCRIPTION OF ALTERNATIVES 22
SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES 30
THE SELECTED REMEDY 35
STATUTORY DETERMINATIONS 38
ATTACHMENTS

APPENDIX 1 - TABLES
APPENDIX 2 - FIGURES
APPENDIX 3 - ADMINISTRATIVE RECORD INDEX
APPENDIX 4 - NYSDEC LETTER OF CONCURRENCE
APPENDIX 5 - RESPONSIVENESS SUMMARY
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SITE NAME, LOCATION, AND DESCRIPTION
9
The American Thermostat (AT) site is located in a rural residential
area in the hamlet of South Cairo, the Town of Catskill, Green
County, New York. The AT site is approximately 30 miles southwest
of Albany, New York and 5 miles west of the Village of Catskil'l, New
York.

The AT site, approximately 8 acres in area, is bordered on the north
and south by Route 23 B and Route 23, respectively (see figure 1).
A residential property (formerly Rath, now Hook) borders the site
on the west and a property owned by the State of New York borders
the, site on the east. The site is not fenced. Access to the AT
site is from Route 23 B.

A detailed site plan depicting existing AT site features is shown
. ..^._re 1. As shown, the existing structure includes the former
plant building, approximately 66,630 square feet in area. Addition-
al structures include a pumphouse, located to the south of the plant
and utility construction material storage sheds, located to the
northeast and immediately west of the plant. The two structures
shown within the vicinity of the pumphouse are temporary wooden
sheds constructed to house air stripping equipment. The air
stripping units were installed by the Environmental Protection
Agency (EPA) as part of an ongoing emergency remedial response
action initiated at the AT site in 1985.

Subsurface structures include three underground sanitary waste
disposal.systems, two coolant water disposal discharge lines and a
roof drain. All known subsurface structures are shown in Figure 2.
The area within the AT site vicinity is rural-residential in
character. The surrounding area is sparsely developed by residences
and vacation homes. The remaining tracts of land are vacant or are
utilized for agricultural purposes. The American Thermostat
Corporation is the only manufacturing property in the area. In
addition, there are several small businesses, including restaurants
and motels within the immediate site vicinity. All of the resi-
dences and businesses within the immediate vicinity of the AT site
rely on groundwater for water supply.

South Cairo is primarily a residential community with approximately
5,500 people residing within a 3-raile .radius of the site. It is
estimated that approximately 250 persons reside within the immediate
site vicinity. The population is primarily composed of elderly and
retired persons who occupy their residences year round. Several
residences within the immediate site vicinity are maintained as
vacation homes and are occupied only during the summer months.

The topography within the vicinity of the AT site may be charac-
terized as gently rolling foothills of the Catskill Mountains which
are deeply incised by stream channels. The AT site is located on
a slight ridge overlooking the Catskill Creek Valley. On-site
ground surface elevations are relatively uniform but fall quickly
to the Catskill Creek to the north and to two small tributaries on(
the east and west. Surface drainage follows the ground surface
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elevation with drainage from the site to the east, west, and north.
Catskill Creek, /located within a quarter mile north of the site, is
classified as a trout stream and therefore has considerable'
recreation value. Catskill Creek is also an auxiliary water supply
for the Village of Catskill.

SITE HISTORY

During April and May 1981, water samples were collected from several
residential wells in the vicinity of the AT site by the New York
State Department of Health (NYSDOH). Analysis of the water samples
indicated the presence of TCE and PCE in five wells. The affected
residents were advised by NYSDOH not to use their water for cooking
or drinking purposes. Several law suits were filed by the plant's
neighbors in late 1981.

Because of high levels of PCE in several nearby wells, AT began
supplying bottled water to local residents in April 1982. By
November 1982, AT had installed carbon filters on its own well and
the five affected wells. The nearest neighbors, the Raths, were
connected to AT's water system.

In February 1983, New York State entered into an interim consent
order with AT and Amro Realty Corporation (property owner) in which
the companies agreed to clean up the site and its surroundings, to
supply bottled water to the five affected residences for cooking and
drinking purposes and to install, monitor and maintain carbon filter
systems for these residences. The order also stipulated that two
groups of bordering private wells had to be monitored to determine
whether any contamination had spread beyond the original affected
area.

In May 1985, AT ceased operations. Since June 1985, EPA and the
State of New York have been sampling wells in the area and have been
monitoring and maintaining the previously installed carbon filtra-
tion units. In addition, EPA installed two new carbons units on
contaminated private wells and installed air stripping systems on
two highly contaminated wells.

In April 1986, NYSDEC requested that EPA assume the responsibility
for the operation and maintenance costs of the carbon filters that
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• %fc " *
had been previously .installed. EPA has also installed and operated
airlift stripping' systems at two existing wells. The stripping
systems have treated, to date, over 7 million gallons of contami-
nated groundwater. PCE concentrations have been. reduced, in the
Rath well, from a high of 131,000 to 25,000 parts per billion'(ppb)
and, in the AT well, from 3,200 to 400 ppb.

A Focused Feasibility Study (FFS) for Alternate Water Supply was
issued in November 1987 as the first operable unit for the AT site.
The purpose of the FFS was to develop, screen and evaluate various
alternatives for an alternate water supply system for the
affected area and potentially affected residences at the AT site.

In January 1988, a Record of Decision (ROD) was signed, selecting
the extension of the Village of Catskill's water supply to the
affected and potentially affected residences.

Following the signing of the ROD, the Village of Catskill questioned
the ability of its water system to handle the additional demand
associated with adding the affected and potentially affected
residences to the system. In response, EPA prepared a technical
assessment of the Village of Catskill's water supply system. The
assessment, which was finalized in June 1988, indicated that the
Village's water supply had sufficient capacity to accommodate the
demand associated with including the affected and potentially
affected residences. Further work on the alternate water supply
selected in the ROD was suspended while negotiations between EPA
and the Village of Catskill continued. Recent meetings, from
February to May 1990, between EPA, NYSDEC, NYSDOH, and the Town and
the Village of Catskill have resulted in the resolution of the major
issues regarding the alternate water supply. As a result, EPA
intends to initiate the design of the alternate water supply this
summer.

In January 1988, EPA initiated a remedial investigation and
feasibility study (RI/FS) to determine the nature and extent of
the contamination at and emanating from the AT site, and to evaluate
remedial alternatives.

ENFORCEMENT ACTIVITIES

Four potentially responsible parties (PRPs) have been identified in
connection with the AT site: Amro; AT; Mr. Harry Moskowitz and Mr.
David Moskowitz. Amro is the owner of the property on which the AT
facility is located. AT was the company which operated the
manufacturing facility at the site. Harry Moskowitz was the
president of the now bankrupt AT; he is also the president of Amro.
David Moskowitz is the president of AT, and was formerly the vice
president and executive vice president of AT.

EPA filed a proof of claim on December 12, 1986, in the bankruptcy
proceeding of AT, seeking recovery of costs incurred at the site.
In addition, on October 30, 1987, the United States commenced a
civil action against Amro, Harry Moskowitz and David Moskowitz
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pursuant to Section 107 of CERCLA for recovery of EPA's costs at
the site. EPA has also sent several notice letters to the PRPs
offering them the opportunity to agree to conduct or finance various
response actions at the site. To date, none of the PRPs have
offered to undertake or finance such activities.

HIGHLIGHTS OF COMMUNITY PARTICIPATION

The RI/FS Report and the Proposed Plan for the AT site were released
to the public for comment on May 11, 1990. These two documents were
made available to the public in both the administrative record and
an information repository maintained at the EPA Docket Room in
Region II, and at the Town of Catskill Offices, Cairo Town Hall,
Village of Catskill offices and at the New York State Department of
Environmental Conservation in Albany, New York. A public comment
period on these documents was held from May 11, 1990 to June 11,
^9-0. In addition, a public meeting was held on May 23, 1990. At
this meeting, representatives from EPA, NYSDEC and NYSDOH answered
questions about problems at the site and the remedial alternatives
under consideration. Responses to the comments received during the
public comment period are included in the Responsiveness Summary,
which is part of this ROD.

SCOPE AND ROLE OF RESPONSE ACTION

EPA has organized the work into two operable units (OUs):

OU One: Alternate water supply

- OU Two: Contamination in soil, sediments,
groundwater, surface water and building.

EPA has already selected a remedy for OU one (January 7, 1988, ROD) .
Since the contaminated groundwater is a principal threat to the
residents in the vicinity of the site because of the direct
ingestion of drinking water from wells that contain contaminants
above health-based levels and because of the anticipated length of
groundwater remediation, an alternate source of clean water has to
be provided to the area residents. That remedy consists of the
extension of an existing nearby water supply system (Village of
Catskill water supply) to the affected and potentially affected
residences in the vicinity of the site. Approximately 43 residences
would be served by the alternate water supply. Implementation of
this remedy has been delayed due to on-going negotiations with the
owner of the water supply. Several meetings, from February to May
1990, between EPA, NYSDEC, NYSDOH and the Town and the Village of
Catskill have resulted in the resolution of the major issues
regarding the alternate water supply. The Town and the Village of
Catskill passed resolutions on May 1 and May 8, 1990, respectively,
agreeing in principal to implement the remedy. The design of the
alternate water supply is anticipated to begin in the summer of
1990.

This ROD sets forth the following remedy for the second OU:

4
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1. The contaminated soils in the southwestern portion of the
site. This area of the site poses the principal threat to human
health and the environment because of the risks from possible
ingestion or dermal contact with the soils. Also, the treatment of
soils to remove the mobile volatile organic contamination will
result in the elimination of a long-term source of contamination of
the groundwater, that is a source of drinking water for the local
residents. Cleanup of the soils will also mitigate the risks to
public health and the environment associated with the migration of
the soil contaminants off-site via surface water run-off.

2. The contaminated aroundwater throughout the contaminated
aquifer. The contaminated groundwater poses a principal threat to
human health and the environment because of ingestion of drinking
water from contaminated wells in the area. Extraction and treatment
of the contaminated groundwater will contain the migration of the
contaminated plume and in time will achieve federal and state
groundwater quality standards for the volatile organic contaminants
by providing the required contaminant removal during treatment
utilizing air stripping and carbon adsorption.

3. The contaminated surface water in the pond in the residen-
tial property adjacent to the site. The pond water will be treated
along with the contaminated groundwater to meet federal and state
standards.

4. The contaminated sediments in the bottom of the pond in
the residential property adjacent to the site. These sediments will
be treated along with the contaminated soils on-site.

5. The contamination in the AT building. So that the building
can be utilized in the future, hazardous dust will be removed from
contaminated surfaces and all hazardous waste materials stored in
drums and drainage pits in the building will be transported off-
site, treated and disposed.

The purpose of this response is to prevent current or future
exposure to the contaminated soils, sediments and surface water, to
ensure protection of the groundwater and surface water from the
continued release of contaminants from soil, to decontaminate the
AT building for future use 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 SITE CHARACTERISTICS

The AT facility was constructed by the AT Corporation for the
assembly of thermostats for small appliances. Site development
began in 1954 and the plant was in continuous operation until i
closure in 1985.

During plant operations, a series of chemicals were used within the
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manufacturing process to operate and clean the plant machinery. -The
chemicals known to be used were machine oil&, lubricants and organic
solvents including 'TCE and PCE. .

During the 1960s and 1970s, waste TCE and PCE sludges were poured
down the drains inside the building and dumped outside on the plant
grounds for dust control. The drains were connected to the septic
systems, shown in Figure 2, which discharged directly to a tributary
of Catskill Creek.

The primary contaminants of concern (including volatile organic
compounds used as solvents and degreasers for parts and equipment
in the thermostat assembly process) are associated with the .previous
assembly process and waste handling practices at the AT site.
Therefore, these activities are believed to be the source of
contamination of the soil, surface water and .groundwater at the
site.

Soil

The soils investigation included the analysis of 22 surface soil
samples obtained from the AT plant grounds and the adjoining
residential property. An analytical summary is presented in Table
1.

Based on the analytical results, the extent of surface soil
contamination is limited to on-site locations coincident with the
reported dump area in the southwestern corner of the site property
as shown in Figure 3. In addition to the surface soil samples, 22
subsurface soil samples were obtained from building foundation
borings completed beneath the AT plant structure and from unconsoli-
dated monitoring wells installed on the AT site and within the
project study area. These locations are shown on Figures 3 and 4.
An analytical summary is presented in Tables 2 through 4.

Volatile organics (TCE, PCE, 1,2-DCE and vinyl chloride) constituted
the primary contaminants. Low levels of base/neutral extractables
polynucleararomatic hydrocarbons (PAHs), pesticides, PCBs and toxic
metals (lead and cadmium,) were also detected in the soil samples
obtained from beneath the existing structure. The extent of soil
contamination beneath the AT plant structure is limited to the
southern portion of the building, corresponding to boring BF-04, as
shown in Figure 3. Volatile organic, base/neutral extractable arid
toxic metal compounds were detected in the subsurface soil samples
obtained from on-site well boring locations. Volatile organic and
toxic metal compounds were detected in the subsurface soil samples
obtained from the adjacent properties. PAH, pesticides and PCB
compounds were not detected in any well boring samples. The nature
and extent of surface soil contamination is directly attributed to
the waste handling practices utilized at the AT facility except with
respect to metal compounds which are attributed to background
levels.
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The extent of subsurface soil contamination is primarily limited to
the southern portion of the site, coincident with the surface
contamination and reported dump area. The extent of contaminated
surface and subsurface soils in this area is estimated at -26,000
square feet to a depth of 7 feet (approximately 6,740 cubic yards)
as shown in Figure 3. In this area, the detected PCE concentration
in the soil exceeds 1.0 milligrams per kilogram (mg/kg). This area
is considered to be the primary site source for contaminant
migration into both surface water and groundwater.

Groundwater

Groundwater samples were obtained from both the unconsolidated and
bedrock aquifers. The findings of the groundwater investigation
.-_j.-r,te that both aquifers .are contaminated mainly with volatile
organic compounds. The well locations and the extent of the
volatile organic contamination of the unconsolidated and bedrock
aquifers are shown in Figures 5 and 6, respectively. Analytical
summaries are presented in Tables 5 and 6. A total of eight samples
were obtained from the unconsolidated aquifer and 33 samples were
obtained from the bedrock aquifer, which included samples from the
bedrock monitoring wells and from residential wells, designated as
R-X in the figures and tables.

Within the bedrock aquifer, the extent of contamination is con-
trolled by groundwater flow through the fractured bedrock. The
volatile organic contamination within the bedrock aquifer is
significant with respect to federal and state maximum contaminant
levels (MCLs). The volatile organic contamination plume extends
approximately 53 acres from the AT site with unknown depth, in a
general northwesterly direction as shown in Figure 6. The maximum
detected bedrock PCE concentration of 31,000 micrograms per liter
(ug/l) was found in a residential well (R-14) adjacent to the site.

In the case of the unconsolidated aquifer, the contaminant plume
extends approximately 26 acres in a general northwesterly direction,
as shown in Figure 5. Within the contaminant plume, the entire
unconsolidated aquifer (average 50-foot depth), is contaminated with
PCE exceeding 5 ug/l (MCL). The volume of the contaminated plume
in the unconsolidated aquifer is estimated at 1.72 x 108 gallons.
The maximum detected PCE concentration in the unconsolidated aquifer
of 24,000 ug/l was found in. the on-site well established at BF-04.

The volatile organic compounds detected in the groundwater sample
analyses are attributed to the former waste handling practices at
the AT facility. As with the soil media investigated, the presence
of toxic metal compounds in the groundwater is attributed to natural
background levels. Elevated levels of toxic metal compounds were
detected in the bedrock aquifer at the residential well (location
R-14) adjacent to the site, as shown in Table 5. This anomaly in
the data cannot be explained based on the current available data.
It is possible that a suspension of fine particles from the soil
into the water sample occurred during the purging of the well, and
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metals from the soli entered the liquid phase during preparation of
the samples for analysis. Supplemental soil sampling around the old
leaching cesspool area during the remedial design phase will be
performed to define the source of heavy metals contamination.

Surface Water and Sediment

Surface water samples were analyzed from both on-site and off-site
locations (Figure 7) . All of the on-site surface water samples
obtained were contaminated with volatile organics (TCE, PCE and 1,2-
DCE) . These sample locations include the swale south of the AT
plant (SW-8), the leach field discharge pipe south of the AT plant
(SW-26), the leach field drain pit east of the plant (SW-30), the
leach field overflow east of the AT plant (SW-29) and the abandoned
coolant water discharge swale (SW-28). The maximum total volatile
organic concentrations (VOC) were detected in on-site samples
obtained at location SW-8 (VOC = 48,800 ppb) and SW-26 (VOC =1,700
ppb) as shown on Figure 7.

Off-site, the surface water was contaminated with volatile organic
(TCE, PCE and 1,2-DCE) and toxic metal compounds including zinc,
chromium and lead. The toxic metal compounds are attributed to
background levels derived from area soils. Volatile organic
contamination was found in both upgradient and downgradient surface
water samples obtained in Tributaries A (SW-18 and SW-6) and B (SW-
19 and SW-7) and in the pond in the residential property adjacent
to the site (SW-20, SE-21). Volatile organic contamination was not
detected in the Catskill Creek (SW-2, SW-3 and SW-5) or in springs
flowing from the subsurface downgradient from the site (SW-24, SW-
25).

Base/neutral extractable compounds, primarily phthalates, were
detected in only one surface water sample obtained from a leach
field overflow east of the site "(SW-27) . The leach field is
operated by the National Guard armory located southeast of the site,
and the leach field overflow discharges directly into Tributary A.
The concentrations of these detected compounds are not considered
hazardous based on the risk assessment.

Volatile organic compounds were detected in the sediment samples
obtained from upgradient and downgradient locations in Tributary B
(SW-7 VOC =20 ppb and SW-2 VOC =91 ppb) and from the downgradient
location in Tributary A (SD-3 VOC = 70 ppb). Volatile organic
contamination was detected in the sediment sample obtained from the
pond location adjacent to the site (SD-8 VOC = 600 ppb).

Surface water and sediment analytical summaries are presented in
Tables 7 through 9. Based on the above sample analytical results,
significant surface water and sediment volatile organic contamina-
tion is limited to the stretch of Tributary B from the site to Route
23B and to the Rath pond adjacent to the site. The volume of water
in the Rath pond is estimated at approximately 10,000 gallons.
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Building

The building investigation included the analysis of eight samples
obtained from building surfaces, five sludge samples obtained from
interior building drain pits and eight waste liquid samples obtained
from the existing 55-gallons drums stored, inside the building.
Sample locations are shown in Figure 8.

The building floor surfaces, totaling 66,630 square feet, were
contaminated with 9 base/neutral extractable compounds, two
pesticides, one PCB compound and toxic metals. The 8 dust wipe
samples represent data which indicated that the compounds were
present, although the precise amounts of the compounds present were
not-determined. The base/neutral extractable compounds detected
include phenol, benzoic acid, dimethyl phthalate, diethylphthalate,
di-n-butyl-phthalate, fluroanthrene, butyl benzylphthalate, bis (2-
ethyl-hexyl) phthalate and. di-n-octyl phthalate. Pesticides
detected in the dust wipe samples included 4,4'-DDT and chlorodane.
Arochlor 1245, a PCB compound, was detected in the dust wipe
samples. The toxic metals detected in the dust samples included
arsenic, cadmium, chromium, lead and mercury. On the basis of this
data, it is not possible to delineate specific source areas within
the building; therefore, floor decontamination would be required
throughout the building prior to any reuse of the building.

Interior building drain pit sludges were contaminated with volatile
organic compounds, including TCE, PCE and 1,2-DCE, as well as
base/neutral extractables, pesticides, polychlorinated byphenyls
(PCBs) and toxic metal compounds including arsenic, cadmium,
chromium, lead and mercury. The quantity of sludge at the AT site
is estimated to be less than 5 cubic yards, and is limited to the
3 identified drain pits located in the existing AT plant structure.

A total of 18 55-gallon steel drums of waste generated from AT's
operations are currently stored within the AT plant (Figure 8) .
The materials contained within these drums are not considered
hazardous based on federal standards, and on the New York State
Identification and Listing of Hazardous Wastes, 6 NYSDEC Part 371.
Eight drum samples were contaminated primarily with waste oil and
grease. TCE was detected in two of the drum samples (DR-004 and
005) . One base/neutral extractable and one pesticide compound were
detected in one drum sample (DR-003A). Analytical summaries of the
existing facilities sampling data for the sludge and drum samples
are presented in Tables 10 and 11.

SUMMARY OF SITE RISKS

The baseline public health evaluation in the RI report evaluated
11 exposure pathways to define cumulative risks from carcinogenic
and noncarcinogenic chemicals detected during the AT site field
investigation. Six risk evaluation scenarios assumed current uses,
including: l) ingestion of treated residential well water; 2)
ingestion of untreated residential groundwater; 3) inhalation of
volatilized organics while showering (treated and untreated
-------
groundwater); 4) direct contact with on-site soils (assuming young
adult receptors); 5) inhalation of volatilized organics from on^site
surface soils (children) and 6) direct contact with on-site and off-
site surface water and sediments. Five scenarios were evaluated for
future risks' assuming industrial development of the AT site. These'
included: 1) ingestion of on-site groundwater; 2).ingestion of off-
site groundwater; 3) inhalation of volatilized organics' while
showering (on-site and off-site groundwater); 4) direct contact with
on-site soils (assuming adult worker receptors); and 5) inhalation
of volatilized organics from on-site surface soils (adults) .
Potential risks associated with future surface water and sediment
exposures were assumed to be the same as for current use.

CONTAMINANT IDENTIFICATION

The risk assessment for the AT site has identified 13 contaminants
f concern. These include three non-carcinogenic and ten carcino-
genic compounds. These compounds or elements were selected because
of their highly toxic effects, frequency of detection, potentially
critical exposure pathways and higher concentrations present in
comparison to other contaminants. The indicator chemicals (contami-
nants of concern) selected for each exposure pathways are summarized
in Table 12.

Seven volatile organic compounds were selected as indicator
chemicals for the groundwater pathways. TCE and PCE are the primary
contaminants in groundwater exhibiting high concentrations and high
frequencies of detection and are known carcinogens. The remaining
VOCs were selected on the basis of their toxic effects and/or
elevated frequencies of detection. N-nitrosodiphenylamine was
selected as an indicator chemical on the basis of its elevated
frequency and the fact that it is a potential human carcinogen.
Finally, the four inorganics were selected as indicators because of
their elevated frequencies of detection in groundwater and because
in many instances their concentrations exceeded federal and state
standards.

For surface water, three VOCs were selected as indicator chemicals
(PCE, TCE and vinyl chloride) on the basis of their high frequency
of detection and the fact that the majority of the detected
concentrations exceeded the ambient water quality criteria (AWQC)
for fish (ingestion) and drinking water.

The indicator chemicals selected for the sediments included the
three VOCs selected for surface water and one metal compound (lead).
Lead was chosen as a noncarcinogenic indicator because of its
relatively high concentrations.
10
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For the surface and subsurface soils, two VOCs (TCE, and PCE) one
semi-volatile (bis (2-ethylhexyl) phthalate) and one metal (lead).
were chosen as indicator chemicals. The VOCs were selected because
of their high concentrations, their frequency of detection and their
toxic effects. The semivolatile compound was chosen because of its
high frequency and its toxic effect. Finally, lead was chosen on
the basis of its elevated concentrations, which were above site-
specific and regional background levels.

EXPOSURE ASSESSMENT

Groundwater

Results from the AT field investigation indicated that groundwater
in the vicinity of the site was heavily contaminated with PCE and
j.v>r... Exposure to groundwater contaminants either through direct
ingestion or contaminant volatilization during showering are primary
pathways of concern as all residences within one-half mile of the
site use private wells.

Baseline risks have been developed for direct ingestion of ground-
water and volatilization of contaminants during showering, assuming
current use of contaminated groundwater. The current use scenario
takes into account the fact that the contaminated wells are equipped
with organic contaminant reduction devices (carbon filters) that are
being monitored by EPA and NYSDOH. Only TCE and PCE were measured
during the monitoring program. Therefore, current ingestion pathway
risk calculations represent only risks associated with these two
contaminants. Because only these two organics were monitored, upper
and lower bound risks associated with each exposure pathway have
been developed, utilizing contaminant concentrations upstream and
downstream of the removal devices respectively.

Two future risk scenarios for each groundwater exposure pathway have
been developed. The first scenario applies on-site monitoring well
results to calculate best-estimate and reasonable maximum exposures.
The second future use groundwater exposure pathway uses off-site
monitoring well data to calculate upper bounds on the risk calcula-
tions (worst case scenario). Exposure assumptions for groundwater
ingestion and inhalation of volatilized contaminants during
showering are defined as follows:

[1] Current and Future Use Pathway: Groundwater Ingestion
(GI)

Carcinogens Noncarcinogens
(Adult) (Children )

Body Weight: 70 Kilograms (kg) 35 Kg [77 Ibs]
[154 Pounds (Ibs)]

11
-------
Exposure Period: 70 years cominuou. wuchnx.* *.po*ur.
Ingestion Rate: 2 liters/day ... 1 liter/day
GI Absorption:' 100% 100%

[2] Current and Future Use Pathway; Inhalation of Volatil
ization Contaminants While Showering

Assumed receptors, body weights and exposure periods
are the same as those defined above for groundwater
ingest ion. Additional assumptions include:

Inhalation Rate: Children : 1.7 cubic meters
per hour (m3/hr)

Adults : '1.3 m3/hr

Exposure Duration: 10 min/shower
Lung Absorption: 100%

Surface Water and Sediments

Surface water bodies in the drainage area of the AT site include
Catskill Creek and Tributaries A and B. On-site surface water
bodies are limited to drainage swale and septic system overflow
areas. Off-site, three impoundments lie within the drainage basin
of Tributary B: the Schmidt, Rath, and mueller ponds. The Rath
pond, located within 50 feet of the western site boundary, is not
currently known to be used for recreational purposes. However,
horses and geese regularly use the Schmidt pond (located in an open
field immediately west and downgradient from the Rath property) and
the Muller pond has been stocked with fish.

Assuming the potential attraction of these standing water bodies to
children, incidental ingestion and dermal contact with contaminants
detected in surface water and sediments have been evaluated. While
the likelihood of children playing on the site is low, worst case
risks associated with surface water ingestion of on-site drainage
swales have been evaluated. More probable exposure pathways assume
recreational use of any of the off-site impoundments. Exposure
assumptions utilized for all surface water and sediment pathway
scenarios are summarized in Table 13.

Soils

Surface and subsurface soils at the AT site are contaminated with
TCE and PCE as a result of prior dumping activities. The site,
which is unfenced and contains a large empty manufacturing building,
is located in an area sparsely developed with residences and
vacation homes. Individuals from adjacent residences could
potentially be exposed to contaminants in surface and shallow
subsurface soils (e.g., children playing/digging on-site) . Specific

12
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pathways of exposure include incidental ingestion and/or dermal
contact. Given potential reuse of the existing building, a future
use scenario has also been developed which assumes subsequent '
industrial development of the American Thermostat property.
Specific exposure assumptions for both current (children) and future
(adult worker) pathways are defined below.

[1] Current Use Pathway; Soil Contact/Inaestion

Table 14 summarizes exposure assumptions associated with
current use direct contact exposures. Although the
current asphalt pavement and vegetative surface cover at
the site would probably limit exposure magnitudes, the
analysis conservatively assumes that surface soils are
exposed. Average (best estimate) and upper bound as-
sumptions are defined for exposure frequencies, duratiors
and intake rates.

[2] Future Use Pathway; Soil Contact/Inaestion

Table 15 presents average and upper bound assumptions
for exposures to adult workers given future industrial
development of the site. Assumed frequencies, contact
rates and receptor characteristics for dermal contact
with and incidental ingestion of surface and subsurface
soils are summarized.

Inhalation Pathways

Given the magnitude of PCE and TCE contamination in on-site soils,
potential inhalation exposures to volatile organics released from
soils were evaluated for both current and future site uses.
Inhalation exposures to children playing/digging on-site have been
assumed concurrent with direct contact exposures defined above.
Inhalation exposures to adult workers were also evaluated, assuming
future industrial use of the site property. Best estimate and
reasonable maximum inhalation exposures were evaluated for both
current and future use pathways.

Groundwater Increstion Exposure Contact Concentrations

Current ingestion pathway risks were evaluated for TCE and PCE only.
Minimum, median and maximum contaminant concentrations measured in
residential wells during the residential well monitoring program
(1986-1987) were used to define a range of potential risks associ-
ated with exposures to both "raw" and treated groundwater.
Future risk calculations used contaminant levels quantified during
the field investigation. Geometric mean and maximum contaminant
concentrations were used to represent average and worst-case
exposures to both on-site and off-site groundwater. In calculating
geometric means, values reported below detectable levels were
assumed to be equivalent to half the detection limit value.
13
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Inhalation of Volatilized Oraanies While Showering
^^*^^^^^^^^^^^^^^^^^^^^^^^ ^•• %
9
Exposure point, concentrations assumed for groundwater ingestiori, as
defined above, were used to derive contaminant concentrations in
indoor air resulting from showering. Additional assumptions
include:

Volatilization rate: 100%
Bathroom Volume: 12 m3
Liters used/shower: 95 liters

Resulting contaminant concentrations in air, expressed in milligrams
per., cubic meter (mg/m3) , were then used to determine chronic daily
intake rates.

Surface Water and Sediment Exposure Point Concentrations

Due to the limited number of off-site surface water and sediment
sample collections, contaminant exposure point concentrations
assumed for the Schmidt and Mueller ponds used the single respective
measurements. Two surface water/sediment samples were collected in
the Rath pond. The average of these two measurements is used to
calculate representative exposures; the maximum is assumed for
calculation of worst case risks. Average and worst-case concentra-
tions assumed for on-site surface water exposures are median and
maximum reported contaminant concentrations, respectively.

Soil Ingestion/Dermal Contact Exposure Point Concentrations

Contact concentrations for both current and future use direct
contact pathways are the contaminant-specific geometric mean
concentrations reported for on^site surface soil samples.

Inhalation Exposure Point Concentrations

For those pathways that involved on-site inhalation of vapors,
contaminant release and transport models were required to estimate
average and peak release rates of TCE and PCE from surface soils
using representative (geometric mean) and maximum surface soil
concentrations. Associated models and calculations are summarized
in Table 16.

Cancer potency factors (CPFs) have been developed by EPA's Carcino-
genic 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)"1, 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

14
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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 health effects. 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 RfD will not
underestimate the potential for adverse noncarcinogenic effects to
occur.

The cancer potency factors and the RfDs for the contaminants of
concern at the AT site are listed in Tables 17 and 18.

RISK CHARACTERIZATION SUMMARY

Risk characterization for the AT site included an assessment of risk
associated with exposures to noncarcinogens and carcinogens.

Excess lifetime cancer risks are determined by multiplying the
intake level with the cancer potency factor.. These risks are
probabilities that are generally expressed in scientific notation
(e.g., IxlO"6 or 1E-6) . An excess lifetime cancer risk of 1x10*
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 noncarcinogenic effects of a single contami-
nant 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 10"6 to 10~* excess lifetime cancer risk. For
noncarcinogens, where the sum of expected dose/RfD ratios exceeds
unity, observed concentrations pose unacceptable risks of exposure.

The results of the risk characterization for each pathway of
exposure evaluated are summarized below:

15
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Groundwater

[1] Groundwater Inqestion; Current and Future Uses

The most plausible current exposure risk calculations used residen-
tial well data downstream of the organic removal devices and
resulted in a baseline, current use risk estimate of 4.69xlO'9.
Given EPA's acceptable risk from carcinogens which ranges from 10"8
to 10"4, calculated risks to residents adjacent to the American
Thermostat site using the control devices are minimal. Worst-case
estimates, which assumed no treatment and used contaminant concen-
trations measured upstream of the control device, ranged from
1.77xlO"9 to 1.92x10", indicating the need to maintain control
measures.

_ne analysis for future ingestion of groundwater with no treatment
resulted in unacceptable risks attributable to exposure to carcino-
genic and noncarcinogenic groundwater contaminants. Average and
upper-bound cancer risks associated with on-site groundwater
exposures were 1.2xlO"3 and 3.710"2, respectively which represent
increased risk levels above current usages due to increased
ingestion by plant workers, assuming the site is developed for
industrial use in the future. Associated hazard indices ranged from
2.52 to 5.44, both exceeding unity. The average cancer risk
associated with off-site groundwater exposures was 5.5x10"*, almost
an order of magnitude lower than that associated with on-site
exposures.

Hazard indices for average and worst-case noncarcinogen exposures
were 2.96 and 52.2, respectively. These noncarcinogen risks
associated with off-site exposures are directly attributable to the
elevated concentrations of lead and arsenic measured in certain off-
site residential wells (particularly the residence adjacent to the
site).
j
[2] Contaminant Volatilization While Showering: Current and Future
Uses

Current use volatilization exposures represented risks for treated
groundwater (2.05xlO"9) and for untreated water (2.35xlO's) that are
within EPA's acceptable risk range. Calculated risks associated
with future residential household use of untreated, contaminated
groundwater indicated unacceptable risks from groundwater contami-
nant concentrations representative of both on and off-site ground-
water.

Surface Water/Sediment [Current and/or Future Uses]

[1] Rath Pond [Direct Contact by Children]

Cumulative excess cancer risks associated with dermal contact and
incidental ingestion of surface water in the Rath pond, based on

16
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two observations, were 3.3x10'* and 3.7x10"* for best estimate and
reasonable maximum exposures, respectively. The risk associated
with average exposure scenarios falls within EPA's target risk
range. However, £he reasonable maximum cumulative risk is
3.7x10"*, which indicates the need to remediate the water contamina-
tion in the pond.

Cumulative excess cancer risks associated with direct contact with
sediments in the Rath pond were negligible: l.7xlO"11 and S.lxlO"10
for best estimate and reasonable maximum exposures, respectively.
His calculated for lead exposures were similarly low, ranging from
0.004 to 0.7, both of which are below the target HI criterion of
1.0.

[2] Schmidt Pond [Direct Contact by Children]

Cumulative excess cancer risks associated with dermal contact and
.dental ingestion of surface water in the Schmidt pond, based on
a single observation, are 3.4x10* and 3.8xlO's for best estimate and
reasonable maximum exposures, respectively. Both values fall within
EPA's target risk range.

Cumulative excess cancer risks associated with direct contact with
sediments in the Schmidt pond were negligible: 8.9xlO'12 and
2,6xlO'10 for best estimate and reasonable maximum exposures,
respectively. His calculated for lead exposures were similarly low,
ranging from 0.002 to 0.03, both of which are below the target HI
criterion of 1.0.

[3] Mueller Pond [Direct Contact by Children]

Cumulative excess cancer risks associated with dermal contact and
incidental ingestion of surface water in the Mueller Pond were
negligible. Based on a single observation, cumulative risks are
4.7X10"8 and 5.2xlO'7 for best estimate and reasonable maximum
exposures, respectively. Values are within the EPA's target risk
range.

[4] On-site Drainage Swale [Direct Contact by Children]

Cumulative excess cancer risks associated with dermal contact and
incidental ingestion of surface water in on-site drainage areas
ranged from 2.2x10"* to S.OxlO'5, with a best estimate (based on the
median detected on-site concentration) of 8.0xlO"s. All values fall
within EPA's target risk range.

Soils

[1] Current Use? Dermal Contact/Soil Increstion by Children

Cumulative cancer risks associated with average and upper bound
exposures were 2.7x10"* and 3.2x10"*, respectively. Exposures to
tetrachloroethene accounted for the majority (>99%) of calculated
risks. His for noncarcinogens were less than one for both scenar-

17
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ios, ranging from 0.005 to 0.112. These results indicate that soil
exposure risks .to children at the AT site are within EPA's target
risk range.

[2] Future Use; Dermal Contact/Soil Inaestion by Industrial
Workers

Cumulative risks to industrial workers from exposure to carcinogens
in American Thermostat soils ranged from 8.9xlO"9 to 1.5x10"* for
average and reasonable maximum exposures. Exposures to noncarci-
nogens did not indicate any unacceptable health risks from non-
carcinogens as hazard indices are both less than one, ranging from
0.005 to 0.11. Cancer risks associated with assumed worker
exposures, though not significant for average exposure scenarios,
are at the higher limit of EPA's target risk range under assumed
upper-bound exposure conditions (1.5x10"*). The latter conclusion
indicates the need for "hot-spot" mitigation of on-site soils to
reduce potential contaminant exposures.

Air

[1] Current use; Inhalation of Volatile oraanics from Soils

Carcinogenic risks associated with volatilized PCE and TCE
exposures to children playing on the AT site were 6.7x10"* and
9.2xlO"5 for average and reasonable maximum exposures, respectively.
Both values are within the EPA target risk range.

[2] Future use; Inhalation of Volatile Orqanics by Industrial
Workers

Carcinogenic risks associated with volatilized PCE and TCE
potential future exposures to workers on-site were 3.4x10"* and
4.6xlO"5 for average and reasonable maximum exposures, respectively.
Both values are within the EPA target risk range. Therefore,
potential risks posed for both current and future use volatilization
pathways are not considered significant.

CLEANUP LEVELS FOR .CONTAMINATED MEDIA

Groundwater

The groundwater at the AT site is classified as Class I, which
indicates that the water is suitable as a drinking water supply.
The RI has determined that contaminants from the site have contami-
nated the on-site groundwater and that a plume of contaminated
groundwater emanating from the site has resulted in the contamina-
tion of residential wells in the vicinity of the site extending over
an area of 53 acres for the bedrock (deep) aquifer and 26 acres for
the unconsolidated (shallow) aquifer. The remedial response
objectives, therefore, include the following:

- ensure protection of groundwater from the continued release of
contaminants from soils and

18
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'
restore groundwater in the affected area to levels consistent
with state and federal groundwater standards.

Table 19 presents the chemical concentrations and action levels
(Applicable or Relevant and Appropriate Requirements (ARARs)) for
contaminants of concern at the AT site. Chemical concentrations
are expressed as the geometric mean and maximum contaminant
concentrations in on-site and off-site groundwater samples taken,
which were applied in the Risk Assessment. Table 19 indicates that
geometric mean and maximum concentrations of PCE, TCE, vinyl
chloride, arsenic and 1,1,2,2-tetrachloroethane in on-site ground-
water exceed most ARARs and nearly all risk-based criteria.

Lead is the only noncarcinogenic parameter evaluated that exceeds
_^.j ^25 ug/1) in both the geometric mean (95.8 ug/1) and maximum
(1,610 ug/1) observed concentrations for both on- and off- site
groundwater samples. As shown in Table 19, chromium and cadmium
ARAR exceedances correspond to maximum observations only.

The health-based levels are more stringent than ARARs for carcino-
gens, but because they are below instrument detection limits
(typically 1-5 ug/1 for volatile organics), the most stringent of
the ARARs (New York State MCLs and groundwater standards) shall be
used as the cleanup objectives for all contaminants in AT groundwa-
ter.
Table 20 summarizes the calculated soil action levels that corre-
spond to an acceptable risk of 10"* for three carcinogenic chemicals
detected in AT site soils: PCE and TCE and (bis 2-ethylhexyl)
phthalate. The cleanup action levels were not derived for lead, the
only noncarcinogenic indicator evaluated for soil exposure pathways.
The baseline Risk Assessment indicated that levels of lead detected
in the AT site soils present no significant risk based on current
and/or future site uses. (His were all less than one).
^
Table 20 indicates that only PCE concentrations in AT site soils
exceed the health-based cleanup objectives under both current and
future exposure assumptions. Geometric mean (2.41 mg/kg) risks and
median (4.65 mg/kg) PCE concentrations are well below action levels
derived for current and future use scenarios (18.6 mg/kg and 893.5
mg/kg). However, both upper quartile (1200 mg/kg) and maximum (2700
mg/kg) PCE concentrations found in the hot spot area greatly exceed
action levels derived using best estimate and upper bound exposure
assumptions for both current and future pathway scenarios. As shown
in Table 20, maximum concentrations of trichloroethene (9.3 mg/kg)
and bis (2-ethylhexyl) phthalate (0.4 mg/kg) were less than both best
estimate and upper bound (10"8 risk) action levels assuming current
and/or future site uses.
19
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Therefore, to include a margin of safety) an allowable exposure
level based on risk assessment of 18 mg/kg for tetrachloroethene is
established for site soils.

Cleanup Objectives Derived from ARAR3

In order to eliminate future ingestion of groundwater contaminants,
it is necessary to remediate volatile organic contaminants detected
in the soil to concentrations low enough to ensure that residual
leaching of such contaminants will not result in groundwater
contamination which exceeds federal drinking water and state
groundwater standards.

PCE and TCE were selected as indicator chemicals for this assessment
because of their frequency of occurrence and relatively high
concentrations detected on site.

Based on calculations utilizing EPA's Multimed fate and transport
model and assuming that, following clean up of the soil, the
groundwater will have to meet the federal and state standards at
the first receptor well at a distance of more than 200 feet
downgradient of the area of soil contamination, it was determined
that the soil cleanup levels would have to be:

PCE 1.0 mg/kg
TCE 0.4 mg/kg

The soil cleanup levels were compared to the contaminant
concentrations identified in the reported dumping area south of the
AT plant. Any samples with contaminant concentrations below the
cleanup levels are considered clean.

Since the soil cleanup criteria derived from ARARs (1.0 mg/kg of
PCE and 0.4 mg/kg of TCE) are much lower than the criteria derived
from the health-based risk assessment for exposure to contaminated
soils (18.6 mg/kg of PCE and 86.5 mg/kg for TCE) soil cleanup
criteria of 1 mg/kg for PCE and 0.4 mg/kg for TCE are established
for the AT site. Thus, a cancer risk level of less than 10"8 will
be achieved. Based on these cleanup levels the approximate boundary
of soil contamination includes the area depicted in Figure 3.

The depth of contamination varies from location to location. For
a conservative estimate, it is assumed, that contamination has
reached the unconsolidated aquifer, which is approximately 7 feet
below existing site ground surface elevations. For source control
remediation it is not necessary to excavate and remediate soil below
the water table, as any contaminated soil below the water table will
be mitigated by the groundwater management of migration alternative.
Therefore, the depth of contamination for the source control
alternatives will be defined as 7 feet below the surface. The
volume of contaminated soil is estimated to be 6,440 cubic yards.
20
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Surface Water and Sediment

Among the surface water bodies investigated on-site and off-site,
only the pond in the residence adjacent to the site (Rath pond)
exhibited carcinogenic risks that exceeded EPA's acceptable levels.

No enforceable federal or state ARARs exist for surface water which
is not used as a drinking water source. However, federal Ambient
Water Quality Criteria (AWQC) provide a basis for evaluating
concentrations of chemicals in surface waters on or adjacent to the
AT site. In addition, there are State Surface Water Guidance Values
that are more stringent in some cases which should also be consid-
ered.

A comparison of the concentrations of contaminants of interest
detected in Rath pond with Federal AWQC and State Surface Water
Guidance Values for the protection of human health are presented
below.
Maximum Detected
Concentration Federal State Surface
in Rath Pond AWQC Water Guidance
Contaminant (ug/1) fug/1) Values
PCE
TCE
Vinyl chloride
1,000
200
31
0.8
2.7
2.0
Note: AWQC values correspond to a risk of 10"6.
all carcinogens are otherwise zero.
0.7

3.0

0.3

AWQC values for
This comparison indicates that the contamination in Rath pond water
exceeds levels that are considered protective of human health.
Although Rath pond water in not currently used as a drinking water
or fishing source, because it exceeds these acceptable levels there
is an ongoing potential risk to human health if ingestion were to
occur. For this reason, the Rath pond will be remediated to below
5 mg/1 for each compound listed above, which is the analytical
detection limit for the compounds listed above.

Sediments in the Rath pond, although they present no health risk,
will be removed and remediated in accordance with the soil cleanup
levels described above, in order to eliminate another source of
groundwater contamination through leaching.

Building

No federal or state standards exist for contaminated dust in
buildings. In order to ensure that the building can be reused in
the future, the contaminants . in the hazardous dust in the building
floor will be removed to below the analytical detection limits for
these compounds.
21
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NEED FOR REMEDIATION

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

DOCUMENTATION OF SIGNIFICANT CHANGES

There are no significant changes from the preferred alternative
presented in the proposed plan.

DESCRIPTION OF ALTERNATIVES

A total of eleven alternatives were evaluated in detail for
remediating the site. Four alternatives for addressing the
ontarr.inated soils that contribute to groundwater contamination at
the AT site were evaluated. A fifth alternative, Alternative SC-2,
capping of the contaminated soil, was preliminarily evaluated in the
FS and was eliminated from further consideration, as it was
determined that it would not prevent the migration of the volatile
organics to the groundwater and to the air. In addition, five
remedial alternatives for addressing the contamination in the
groundwater were evaluated. A sixth alternative, Alternative GW-5,
treatment of the groundwater via activated carbon adsorption, was
preliminarily evaluated in the FS and was eliminated from further
consideration since it was determined that it would be less
effective in removing the groundwater contaminants and more costly
than the combined air stripping/carbon adsorption alternatives.
Finally, two alternatives are evaluated for the decontamination of
the AT building.

These alternatives are:

SOIL ALTERNATIVES

Alternative SC-1; No Action

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 evaluate the
performance of Alternative SC-1, and to monitor contaminant
migration. Monitoring would consist of annual soil, sediment, and
surface water sampling and analyses for a variety of contaminants.
Samples would be analyzed for Target Compound List parameters.
Finally, an eight foot high chainlink fence would be installed
around the site.

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 might be implemented
at the time to remove or treat wastes.

22
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The estimated present worth cost for this alternative is $736", 800.
•». »
Alternative SC-3/; Excavation/On-Site Incineration/Qn-Site
Redeposition

This alternative would include the excavation and on-site treatment
by incineration of 6,740 cubic yards of contaminated soil. The
treated soil would be used as backfill and the disturbed areas would
be regraded and revegetated to prevent erosion.

The approximate area of contaminated soil that would be excavated
is shown in Figure 3.

Soil excavation using a backhoe would remove the contaminated soil
from the hot spot area (approximately 26,000 ft2 including the old
leaching field) to a depth of about 7 feet. The length of time it
: "11 take to excavate this soil will be determined by the process-
ing rate of the incinerator which is approximately 48 tons per day
(2 tons per hour).

The six 55-gallon drums which contain contaminated soil generated
from the RI activities would be emptied and treated together with
the contaminated soil. The Rath pond sediments would also be
treated with contaminated soil. Sediments upstream of Tributary B
would be resampled during remediation. If contaminant concentra-
tions exceed cleanup level they would be treated with the contami-
nated soil.

The incineration process consists of a feed system, rotary kill*
incineration unit, secondary combustion chamber and three stage
scrubber. The excavated contaminated soil and the soil from RI
drums would be placed in the feed hopper with a backhoe. Soil would
then conveyed from the hopper to the rotary kiln. The incinerator
would be operated at a temperature of 650 to 760°C (1200 to 1400°F) .
The soil would be incinerated in the rotary kiln. Exhaust gases
from the kiln would enter a secondary chamber afterburner operating
at temperatures between 760°C and 1316°C (1400°F and 2400°F) to
complete oxidation of the combustible waste. Prior to release to
the atmosphere, exhaust gases from the afterburner would pass
through air pollution control units for particulate and acid gas
removal. Ash residue and soils would be discharged at the bottom
end of the kiln and are quenched to cool the residue.

Listed RCRA hazardous wastes are contained in the contaminated soil.
The soil will no longer be deemed to contain hazardous wastes after
it is treated below health-based levels and the treatment standards
required by RCRA Land Disposal Restrictions (LDRs). The treated
soil will be subjected to the Toxicity Characteristic Leaching
Procedure (TCLP) to determine whether it still contains any listed
RCRA hazardous wastes above the treatment standards, required by the
LDRs. All soil emerging from the treatment that fails the TCLP test
will be retreated so as to meet these standards. All soil will be
treated so that it does not RCRA hazardous wastes above the health

23
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based levels determined by the risk assessment. Because the soil
will no longer contain any listed RCRA -hazardous wastes above
health-based levels, and because it will meet the LDR treatment
standards (TCLP concentrations) it will not be subject to regulation
under Subtitle C of RCRA and may be used to backfill the excavated
areas on-site.

The 53 55-gallon drums which contain non-hazardous soil generated
from the RI activities would be emptied and also used to backfill
the excavation areas on-site. TCLP tests would be used to ensure
that these drums contain non-hazardous soil. If they were found to
be hazardous, they would be incinerated on-site with contaminated
soil. The particulates and water from acid gas scrubbing collected
in the air pollution control systems and the waste water used in the
quenching processes would be shipped for treatment and disposal at
an off-site facility.

The estimated present worth cost for this alternative is $8,322,800.
The estimated time to implement the alternative is approximately 3
years (including design).

Alternative SC-4; Excavation/Off-Site Incineration/Backfill With
Clean Soil

This alternative would include the excavation and off-site thermal
treatment of 6,740 cubic yards of contaminated soil. The excavated
material would be placed in dump trailers or drummed, covered and
transported to a licensed thermal treatment facility. The facility
would be responsible for disposing of the treated soil.

Following excavation, the contaminated materials would be placed
into 20 cubic yard trucks for shipment. The loaded trucks would
proceed to the nearest available incinerator permitted to receive
bulk solid wastes. The receiving facility would be responsible for
proper disposal of the incinerator ash. Clean fill would be used
to backfill the excavation area, and the site would be regraded and
revegetated. No long-term monitoring would be required.

Incineration of the contaminated soil at the off-site facility would
be conducted in conformance with all applicable RCRA requirements.

The estimated present worth cost for this alternative is
$17,9ib,700. The estimated time for the implementation of this
alternative is 2.5 years (including design).

Alternative SC-5; Excavation/Low Temperature Enhanced
Volatilization/On-Site Redeposition

24
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nants to be volatilized into gases and escape from the soil. - The.
organic vapors extracted from the soil would then be treated -in am
air pollution control unit to ensure acceptable air quality*
emissions. Several thermal treatment methods (such as heated screw^
conveyors, rotary calcination devices, etc.) may be applicable. A*
variety of air pollution control options are also available, in-
cluding after-burners, activated carbon absorbers, and condensers.
The specific type of the thermal treatment method and of the air
pollution control would be determined in the remedial design phase
through engineering design and analysis and the competitive bidding
process.

All the residuals from the treatment (such as spent carbon from the
carbon adsorption units) would be sent to an off-site hazardous
waste facility for treatment and disposal. Air pollution control
systems would be an integral part of the treatment plant to limit
-i csions to within the regulatory requirements.
The soil would be treated so that it would no longer contain
hazardous wastes above health-based standards and LDR treatment
standards. As discussed above, for Alternative SC-3, after such
treatment the soil will no longer be subject to Subtitle C of RCRA
and may be used to backfill excavated areas. Since all contaminated
soil above the cleanup level would be treated to below health-based
levels and the existing data indicates that the treated soil would
pass the TCLP test and meet the LDRs, it is expected that clean
closure of the site would be achieved.

At the completion of the implementation of this alternative, the
most mobile of the organic contaminants in the soil would be reduced
to concentrations that would result in groundwater levels below the
federal and state standards at the receptor nearest to the site when
leached to the groundwater through rainwater infiltration. The
estimated present worth cost of this alternative is $2,772,400. The
estimated time to implement this alternative is approximately 2
years (including design).

GROUNDWATER ALTERNATIVES

All groundwater alternatives, with the exception of Alternative GW-
1, assume that the operation and maintenance of the existing
individual treatment systems (5 carbon filters and 2 air strippers)
will continue until either the implementation of the alternate water
supply selected in the 1988 ROD, or the cleanup of the aquifer by
means of a particular groundwater alternative.

Alternative GW-1; No Further Action

Under the No Further Action Alternative, the existing individual
treatment systems operated and maintained by EPA would be termi-
nated. This alternative would consist of restricting the use of
contaminated groundwater, to the extent possible, by deed restric-
tions and other institutional controls. A long-term monitoring
program and distribution of fact sheets that would explain the

25
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monitoring results and would include warnings and recommendations
for water usage would be established. ... -

This alternative'was not considered to be protective of human health
and the environment and it was not evaluated as a viable alternative'
for implementation. This alternative was used only as a baseline
for comparison to the remaining alternatives being analyzed.

This alternative would also require a five-year review because the
contaminants would remain on-site. The estimated total present
worth cost for this alternative would be $757,000.

Alternative GW-2I Limited Action

The Limited Action alternative for the contaminated groundwater
aquifers includes both a long-term monitoring program and an
institutional control program to regulate the vise of the aquifers.
This alternative would continue operation and maintenance of
existing carbon filters at five houses and two air-stripping
systems, one at the Rath residence and one at the AT Pumphouse. In
addition, new individual carbon filters would be installed at 25
other houses and operated for at least 30 years. The long-term
monitoring program would consist of semiannual sampling for Target
Compound List (TCL) metals and TCL volatile organics at six existing
bedrock aquifer wells and three existing unconsolidated aquifer
wells. In addition, two new wells would be installed to the east
and west (one on each side) of the unconsolidated aquifer plume
area. The information gathered would be used to check whether the
concentrations of contaminants of concern have been lowered to
levels below the federal and state standards through natural
attenuation and to monitor potential migration of contaminants
downgradient of the site. Institutional management would also be
required to monitor and review the site every five years as required
by CERCLA.

The present worth cost for this alternative is estimated to be
$8,911,300.

Alternative GW-3; Pumpinq/Pretreatment/Air Stripping/
Reinjection

The major features of this alternative would include pumping,
treatment, and reinjectiotv crj. treated .groundwater and a perfor-
mance monitoring program. Groundwater would be extracted-from
both the unconsolidated and bedrock aquifers and would be pumped
through a series of air strippers (2 air strippers). The treated
water would be reinjected into the ground. This alternative would
also include treatment of surface water from the Rath Pond and the
drums containing contaminated water generated during the Remedial
Investigation. These drums would be emptied and mixed with ground-
water in an equalization tank before treatment.

The treatment system would consist of a pretreatment system for
metals removal by chemical precipitation, flocculation, clari-

26
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fication and filtration, followed by an air stripping system for
volatile organic contaminants removal.

Groundwater extracted from wells placed over the entire area
overlying the contaminated aquifer would enter the air stripping
unit. The air laden with volatile organics would leave the air
strippers and enter vapor phase carbon absorber (1000 lb 'carbon
each) equipped with a duct heater/dehumidifier. The exiting vapor
stream from the vapor phase carbon unit would be free of volatile
organic compounds and could be discharged to the atmosphere. The
treated groundwater from the air stripping tower would be collected
in a 2500 gallon water sump. From here water would be pumped
through a second stage air stripper identical to the first one. It
should be noted that the system described above is a representative
air stripper system. The exact specifications for the air stripper
at the AT site would be determined during the remedial design phase
of the project.

The estimated annual amount of carbon required for the vapor phase
adsorber would be 16 tons. The spent carbon would be collected by
the carbon supplier and shipped for off-site disposal or regenera-
tion and reuse. The treated groundwater would be collected in a
collection tank. From here the groundwater would be discharged into
leaching fields for reinjection.

The treated groundwater would be reinjected through an existing
leaching field located just south of Route 23B and a new leaching
field proposed just north of Route 23 near the building. ' In
addition, six existing wells along the western boundary of the site
would be used for reinjection.

Environmental monitoring would be required during the life of the
treatment process. In addition, monitoring of the groundwater at
the site would be conducted for a period of 3 years after completion
of the remediation, to ensure that the goals of the remedial action
have been met.

The present worth cost of this alternative is estimated at
$18,821,900. The time estimated for completion of this alterna-
tive is 30 years.

Alternative GW-4; Pumpincr/Pretreatment/Air Stripping/
Carbon Adsorption/*;sin-jection

The process options used in this alternative are similar to that of
Alternative GW-3 with the exception of the volatile organics removal
system. Organics removal is achieved by air stripping followed by
a carbon adsorption system in this alternative compared to the two
stage air stripping system in Alternative GW-3.

Groundwater would be extracted from both the unconsolidated and
bedrock aquifers, pretreated for removal of metals and particulates
and pumped to an air stripper. Contaminated groundwater would enter
the air stripper which would be designed to strip out the VOCs. The

27
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air and VOC mixture exiting the air stripper would then be treated
by a vapor phase carbon adsorption unit.,for the' removal of the
stripped VOCs. The clean air would be emitted to the atmosphere.
The treated groun'dwater would be directed to a reinjection system
as described under Alternative GW-3.

Environmental monitoring would be required during the life of the
treatment process. In addition, monitoring of the groundwater at
the site would be conducted for a period of 3 years after completion
of the remediation to ensure that the goals of the remedial action
have been met.

Groundwater would be treated to drinking water standards before
reinjection. The discharges from the air stripper would meet the
requirements of federal and state laws, regulations and policy
including, 52 FR 3748, 6 NYCRR 201, 211 and 212, and Air Guide 1.
The residues resulting from the treatment system include filtered
-Mspended solids (precipitated metallic hydroxides and fine
particles) and spent carbon. The filtered suspended solids would
be shipped to an off-site RCRA facility for treatment and disposal.
The estimated annual carbon usage would be approximately 14.5 tons
for vapor phase carbon and 10 tons for the liquid phase granular
activated carbon adsorption process. The spent carbon would be
collected by the carbon supplier and shipped for off-site disposal
or regeneration and reuse.

The present worth cost for this alternative is estimated to be
$23,044,900. The time required to complete the implementation of
this alternative is 30 years.

Alternative GW-6; Pumpincr/Pretreatment/UV Oxidation/Rein-iaction

The major features of this alternative would include pumping,
treatment, and reinjection of the treated groundwater and a
performance monitoring program as in the case of Alternatives GW-3
and GW-4. The process options used in this alternative are similar
to that of Alternative GW-3 with the exception of the organic
removal system. Organic removal is achieved by an ultraviolet light
UV-chemical oxidation system in this alternative compared to the air
stripping system in Alternative GW-3.

Groundwater pumping and collection in this alternative would be the
same as that outlined in Alternatives GW-O and GW-4. Groundwater
treated for metals removal would then be pumped to a ultraviolet
(UV) chemical oxidation reactor. Hydrogen peroxide would be used
as the oxidizing agent. The UV/chemical oxidation system includes
a stainless steel oxidation chamber equipped with UV lamps and
hydrogen peroxide feed system. Before the pretreated groundwater
enters the oxidation chamber, it is mixed with a 50% hydrogen
peroxide solution. Hydrogen peroxide is readily converted to
hydroxyl radicals under the influence of UV light. High intensity
UV light and the hydroxyl radials synergistically promote rapid
breakdown of organic molecules of the organic contaminants of
concern. With a retention time of 4 minutes in this oxidation

28
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chamber, the organic contaminants are converted to C0a, HjO and
chlorides. Most of these are highly soluble. Potential volatile
organic emissions ^from the reactor are negligible with UV/hydrbgen
peroxide systems. ' All the volatile organic contaminants would be
removed to below the target groundwater cleanup levels, and the
treated groundwater would be reinjected into the ground as discussed
under Alternatives GW-3 and GW-4 .

The pretreatment residues from metal removal would be disposed of
off-site in a RCRA facility.

The estimated present worth cost for this alternative is
$21,845,200. The time estimated for completion of this alternative
is 30 years.

BUILDING DECONTAMINATION ALTERNATIVES

BD-1; Ko Action
Remedial action would not be taken other than a long-term building
security and maintenance program. Fact sheets would be distributed
in order to increase public awareness. The estimated present worth
cost for this alternative is $4,600.

Alternative BD-2; Building Decontamination/Waste Treatment and
Disposal

This alternative includes decontamination of the building to remove
contaminated dust, sludges, RI drums, and waste oil drums and off-
site disposal of the dust, sludges, and waste oil. It is not
anticipated that the walls and the ceiling of the building would
require decontamination. However, a supplemental quantitative
sampling would be conducted during remediation to confirm this.
Confirmatory sampling will also be conducted following remediation.
Hazardous dust would be removed using a dusting, vacuuming and
wiping procedure for off-site treatment and disposal. No cleanup
levels are available for the building. However, contaminant
concentrations would be reduced bel'ow detection levels. Waste oil
drums would be removed by a contractor for off-site disposal. The
hazardous RI drums would be treated on-site along with source
control and groundwater treatment alternatives. The non-hazardous
drums would be consolidated on site for eventual on-site redeposi-
tion. Sludges would be removed and disposed of at an off -site
treatment and disposal facility.

The estimated present worth cost of for this alternative is
$284,000. The estimated time for implementation of this alternative
is seven months.
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SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES

During the detailed evaluation of remedial alternatives, each
alternative is assessed against nine evaluation criteria, namely
overall protection of human health and the environment, compliance
with ARARs, long-term effectiveness and permanence, reduction of
toxicity, mobility or volume (including the statutory preference
for treatment), short-term effectiveness, implementability, cost,
state acceptance and community acceptance.

Each criterion will be briefly addressed with respect to the
alternatives for the remediation of the soil, the groundwater, and
the decontamination of the building.

SOIL

A. Overall Protection of Human Health and the Environment

Alternative SC-5, treatment of soils to remove the volatile organic
contaminants, will result in the elimination of a long-term source
of groundwater contamination and will mitigate the risks to public
health and the environment associated with the presence of those
contaminants in the soil on-site and with their migration.
Alternative SC-5 would effectively mitigate those risks by removing
the most mobile wastes from the soil leaving the treated soil to be
landfilled on-site.

Alternatives SC-3 and SC-4 also would mitigate the risks to public
health and the environment associated with the leaching of contami-
nants into the groundwater and their migration off-site. Under
Alternative SC-1, contaminants would continue to leach from the soil
into the groundwater and continued off-site migration of contami-
nants would occur. Monitoring would be implemented to observe
contaminant migration, but an indeterminate amount of time would
elapse between detection and the implementation of mitigating
measures.

B. Compliance with ARARs

All technologies proposed for use in Alternatives SC-3 through
SC-5 would be designed and implemented to satisfy all action-
specific regulations including all air emission standards. No
federal or New York State regulations specify cleanup levels for
contaminants in the soil. In terms of achieving target levels for
soils for the purpose of removing potential sources of groundwater
contamination, Alternative SC-5, along with Alternatives SC-3 and
SC-4, would be quite effective.

C. Lono-Tenn Effectiveness and Permanence

Alternative SC-5 would effectively treat the volatile organic
compounds in on-site soil, thus reducing the hazards posed by the

30
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contaminated soils and permanently removing the source of groundwa-
ter and surface water contamination. Alternatives SC-3 and -SC-4
also would provide a high degree of effectiveness, since the
contaminated soil would be treated or removed from the site. In.
contrast, under Alternative SC-1, the contaminants would be left
untreated in the soil, and a long-term monitoring program would be
implemented to determine if the contamination was migrating from
the site.
Alternative SC-5 and Alternatives SC-3 and SC-4 would result in
comparable reductions in the toxicity, mobility or volume of the
treated material. Alternative SC-1 would provide no reduction in
toxicity, mobility or volume.

«• Short-Term Effectiveness

All alternatives, with the exception of the no-action alternative,
include activities such as contaminated soil excavation and
transport that could result in potential exposure of residents to
volatilized contaminants and contaminated dust. However, mitiga-
tive measures to reduce the probability of exposure would be
implemented. In addition to excavation, Alternative SC-4 includes
off-site transport of contaminated soils.

Both Alternative SC-5 and Alternative SC-3 provide treatment on-
site, thereby reducing potential risks to residents along transpor-
tation routes. Furthermore, Alternative SC-5 would not result in
the generation of significant quantities of treatment byproducts
(stack emissions, particulates) that would be generated by Alterna-
tive SC-3.

Alternatives SC-3, SC-4 and SC-5 might result in worker exposure to
volatilized contaminants and dermal contact with contaminated soils
during waste excavation and handling. In addition, Alternatives SC-
3 and SC-5 might result in additional low-level emissions exposure
from the on-site treatment unit. The threat to on-site workers,
however, would be mitigated through the use of protective equipment
by the on-site workers, and control of emissions would be accom-
plished by emissions treatment. Additionally, scrubber wastewater
produced by Alternatives SC-4 and SC-5 would be treated on-site or
transported off-site for treatment and disposal.
Alternatives SC-3, SC-4 and. SC-5 could be implemented in about 3,
2.5 and 2 years, respectively, with actual remediation times of 15,
12 and 9 months, respectively.

P. Implementability

All of the alternatives would utilize relatively common construction
equipment and materials. Little construction difficulty would be
encountered with any of the alternatives.
31
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The technologies proposed for use in the alternatives are proven
and reliable in aphieving the specified process efficiencies"and
performance goals. Low temperature thermal extraction, has been
successfully pilot tested and has performed on a full-scale basis
with similar organic contaminants.

G. Cost

The present-worth cost of Alternative SC-5 is $2,772,400. The
lowest cost alternative is Alternative SC-1 at $736,800. The
highest cost alternative is Alternative SC-4 at $17,918,700.
Alternative SC-3 has a present worth cost of $8,322,800.

The amount of additional organic contaminants removed by Alterna-
tives SC-3 and SC-4 above the amount of organic contaminants removed
by Alternative SC-5 is insignificant when compared to the substan-
cial difference in cost between these Alternatives.

Table 21 lists all of the costs for the five soil alternatives for
comparison purposes.

GROUNDWATER

A. Overall Protection of Human Health and the Environment

Alternative GW-4 would provide the highest protection to human
health and the environment among the three treatment alternatives.
It would remove and treat the organic contaminants found in
groundwater and would prevent their migration off-site. The higher
degree of protection associated with Alternative GW-4 in comparison
to Alternative GW-6 is due to the higher certainty for contaminant
treatment associated with the air stripping and carbon adsorption
technologies versus the UV/oxidation treatment technology of
Alternative GW-6.

In comparison to Alternative GW-3, Alternative GW-4 offers a higher
degree of protection as a result of the additional carbon adsorption
treatment of the contaminated groundwater following air stripping.

The limited action alternative would provide protection of the
health of the affected residents. However, it would not ensure
protection of the health of future users of the aojuifers and would
not prevent continued migration of contamination.

B. Compliance with ARARs

Alternative GW-4, as well as Alternative GW-3, would achieve federal
drinking water and state groundwater standards for the organic
contaminants by providing the required contaminant removal during
the treatment stage utilizing air stripping and carbon adsorption.

The ability of Alternative GW-6 to achieve the groundwater standards
for the organic contaminants is of a lower certainty than the

32
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preferred alternative's because of limited experience with -the
UV/oxidation treatment process. ... _ . ,
f
Alternative GW-1 would not comply with state or federal drinking
water standards or criteria or those ARARs required for protection
of the groundwater resources. Alternative GW-2 would achieve
chemical-specific ARARs for drinking water, but would not achieve
any groundwater standards for the contaminated plume.

C. Lona-Tenn Effectiveness and Permanence

Alternative GW-4, GW-3 and GW-6 would effectively reduce the
potential risks associated with the migration of contaminants into
the,groundwater by extracting the contaminated groundwater, treating
it to remove contaminants and returning the treated water to the
aquifer.

Alternative GW-1 does not provide treatment but would attempt to
restrict usage of contaminated groundwater. Alternative GW-2
provides a safe permanent water supply to the affected residents
but would not restore the contaminated aquifer for future use.

D. Reduction in Toxicity, Mobility and Volume

Alternatives GW-4, GW-3 and GW-6 would effectively reduce the
toxicity, mobility, and volume of the organic contaminants in the
groundwater. Alternative GW-4, utilizing liquid phase carbon
adsorption, would provide the greatest reduction in toxicity of all
alternatives under consideration. Alternative GW-2 would reduce the
toxicity, mobility and volume for the individual water supplies of
the affected residents. Alternative GW-1 would not reduce the
toxicity, mobility and volume of contaminants.

E. Short-Term Effectiveness

Alternatives GW-4, GW-3 and GW-6 include activities that could
result in potential exposure of residents and workers to volatilized
contaminants during the installation of the groundwater extraction
and reinjection systems. However, mitigative measures to reduce the
probability of exposure would be implemented.

The implementation of Alternatives GW-1 and GW-2 would result in no
additional risk to the community during implementation.
Alternatives GW-4, GW-3 and GW-6 would require a 30 year remediation
time. EPA projects that it would take Alternative GW-2 well in
excess of 30 years and Alternative GW-1 more than a thousand years
to achieve the cleanup levels.

P. Implementabilitv

All components (extraction, treatment and reinjection) of Alterna-
tive GW-4, as well as of Alternative GW-3, utilize relatively common
construction equipment and materials and could be easily imple-
mented, in addition, the air stripping and carbon adsorption

33
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technologies that^comprise the treatment are proven and reliable in
achieving the specified performance goals and are readily available.

In contrast, the treatment technology for Alternative GW-6 (UV/
oxidation), although successful in pilot runs, has had limited full
scale use to date. Therefore, site-specific pilot scale studies
would be required to confirm its adequacy for the American Thermo-
stat site. In addition, UV/oxidation is currently available from
only two sources nationwide.

All components of Alternatives GW-1 and GW-2 would be easily
implemented.

6. Cost

"lie present worth cost of Alternative GW-4 is $23,044,900. The
lowest cost alternative is Alternative GW-1 at $757,000. The
present worth cost for GW-2 is $8,911,300. For Alternatives GW-3
and GW-6 the present worth cost is $18,821,900 and $21,845,200
respectively.

The costs of the alternatives and their overall effectiveness were
compared to determine whether the costs were proportional to the
effectiveness achieved. The additional treatment provided by the
carbon adsorption system, within the context of consideration of
the other factors discussed above, was deemed to justify the
increased costs that would be incurred by selecting the preferred
alternative.

Table 21 lists all of the costs for the six groundwater alternatives
for comparison purposes.

BUILDING DECONTAMINATION

A. Overall Protection of Human Health and the Environment

Under Alternative BD-2, all hazardous materials would be removed
from the building. Therefore, this alternative would be fully
protective of public health and the environment.

Under Alternative BD-1 hazardous materials would be left in the
building. Human health and the environment would remain protected
as long as building security could be effectively enforced and
building integrity maintained.

B. Compliance with ARARs

Alternative BD-2 would comply with the relevant action-specific
ARARs. No chemical-specific ARARs exist for building contami-
nation. By definition, no action-specific ARARs apply to the no-
action alternative.
34
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C. Long-term Effectiveness and Permanence
0
Alternative BD-2 would remove all hazardous materials from the
building for either off-site disposal or on-site treatment and
disposal, so that long-term exposure risks from.the building are
eliminated. Alternative BD-1 would only maintain the building in
its present condition, so that hazardous materials would remain in
the building. Public protection would rely on maintaining building
security.
Alternative BD-l provides no reduction in toxicity, mobility or
volume of the contaminants. Alternative BD-2 provides for complete
reduction in toxicity, mobility and volume, since all contaminated
material would be removed from the building.

E. Short-term Effectiveness

Since Alternative BD-2 involves removal and transport of the
contaminants from the building, there are some public exposure risks
as well as environmental impacts from potential waste spills
resulting from a possible transport accident during remedial
activities. Implementation of Alternative BD-1 should result in no
additional risks to the community or the environment as long as
building security and integrity could be maintained.

F. Implementabilitv

Both alternatives are readily implementable. Methods and services
for building decontamination under Alternative BD-2 are technically
feasible and readily available. Alternative BD-1 would require
institutional management of the long-term building maintenance
program, whereas Alternative BD-2 would not require any long-term
management.
The present worth costs for Alternatives BD-1 and BD-2 are $4,600
and $284,900, respectively (see Table 21).

State Acceptance

NYSDEC concurs with the preferred soil, groundwater and building
decontamination alternatives.

Community Acceptance

The community has expressed support for the alternatives selected
for remediation of the soil and the groundwater and the decontami-
nation of the building.
35
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THE SELECTED REMEDY

Based upon consideration of the requirements of CERCLA, the detailed'
analysis of the alternatives, and public comments, both EPA and
NYSDEC have determined that Alternative SC-5, Low Temperature
Enhanced Volatilization, for treatment of the contaminated soil,
Alternative GW-4, Air Stripping and Carbon Adsorption, for treatment
of the groundwater, and Alternative BD-2, Decontamination of the AT
Building, is the appropriate remedy for the American Thermostat
site. The major components of the selected remedy are as follows:

- .Approximately 6,500 cubic yards of soil contaminated with VOCs
will be excavated from the southwestern portion of the site in the
former dumping area between the AT building and Route 23. The
lateral extent of the excavation will be more precisely defined by
additional sampling to determine the extent of the area where
contaminant soil concentrations exceed the soil cleanup levels set
to protect the groundwater during the design phase of the remedia-
tion. Soil in the contaminated area will be excavated down to the
water table (approximately 7 feet below the ground surface) .
Fugitive emissions will be controlled during the excavation by such
techniques as water spraying, vapor suppression forms, etc.

- The VOCs in the soil will be treated using a low temperature
enhanced volatilization technology.

Contaminated sediments from the Rath pond will be removed and
will be treated with the contaminated soils. Confirmatory sediment
samples will be collected from the Schmidt and Mueller ponds and
from Tributaries A and B (upgradient and downgradient of the site)
during the remedial design. Analysis will be for TCL metals only.
In addition, should the confirmatory sampling during the design
phase indicate that the sediments in Tributary B immediately
upgradient of the AT site are indeed contaminated with PCE and TCE
above the soil cleanup levels, those sediments in Tributary B will
also be treated with the contaminated soil. It is estimated that
300 cubic yards of contaminated sediments will be removed for
treatment.

- The treated soils and sediments which will still contain some
less mobile organic compounds and metals, will be tested for TCLP
toxicity to determine whether they constitute a RCRA hazardous waste
and will be placed back into the excavation areas from which they
.were removed. Clean top soil will be placed on the fill areas.
These areas will be regraded.

- The treated soils and sediments will be subjected to the TCLP to
determine whether all the RCRA hazardous wastes contained in them
meet the LDR treatment standards (TCLP concentrations). Since the
treated soils and sediments which pass the test will meet the LDR
standards and will no longer contain hazardous wastes above health
based levels, as determined by the risk assessment, they will not
be subject to regulation under Subtitle C of RCRA (including the

36
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land disposal restrictions imposed by the Hazardous and Solid WasteJ
Amendments to RCRA) and may be replaced into the areas .from which^
they were removed.

- In the unlikely event that the treated soils do not pass the TCLP
toxicity test, they will be further treated to meet the TCLP
requirements prior to their placement in the excavated areas.

- Contaminated groundwater will be removed from the unconsolidated
and bedrock aquifers by a system of extraction wells, located over
the entire area of the contaminated plume. It will be treated on-
site for removal of the VOCs using a combination of air stripping
and carbon adsorption technologies, and the treated water will be
reinjected in the ground through a reinjection system. The ground-
water will be treated to drinking water standards before recharge.
The exact number and location of the extraction wells, the pumping
__^*_es and the type of the reinjection system will be specified
during the design phase.

- Contaminated surface water from the Rath pond will be removed
and treated with the groundwater. Treated water will be used to
refill the pond.

The groundwater treatment will continue until federal and state
standards for the organic contaminants have been achieved in the
groundwater throughout the contaminated plume area or until a point
has been reached at which contaminant concentrations in the
groundwater "level off". At that point, the remedy will bdj
reevaluated for its effectiveness. ^

- Hazardous dust would be removed from the building floor by
dusting, vacuuming and wiping.

- The sludges from the drain pits inside the building and 18 waste
oil drums from previous AT operations will be removed and shipped
to an off-site facility for treatment and disposal.

- The drums containing wastes generated during the RI that have
been identified as hazardous will be treated on-site with the soil
and groundwater treatment systems. RI drums that contain solid
matter, other than soil, will be shipped off-site for disposal at
a licensed facility.

- All residuals from the treatment of the soil and of the ground-
water will be shipped to an off-site RCRA hazardous waste facility.

- Air monitoring will be performed prior to, during, and following
construction at the site. Air emissions from the treatment units
during both the soil and groundwater remediation will meet the air
emission ARARs. Environmental monitoring will be required during
the life of the treatment process. In addition, monitoring of the
groundwater at the site will be conducted for a period of 3 years
after completion of the remediation, to ensure that the goals of
remedial action have been met.

37
-------
Remediation Goals'

The purpose of this response action is to reduce the present risk'
to human health and the environment due to the contamination- of the
on-site soil, to restore the groundwater underlying the site and
throughout the contaminated plume to levels consistent with state
and federal ARARs and to ensure protection of the ground and surface
water in the vicinity of the site from the continued release of con-
taminants from soils. Since no federal or state ARARs exist for
soil, the action level for the VOCs in soil was determined through
a site-specific analysis. This analysis used fate and transport
modeling to determine levels to which VOCs in soils should be
reduced in order to ensure no contaminants leach into the ground-
water above MCL levels. Reduction to these levels also would ensure
•*:hat no excessive risk would result from human contact with soil at
the site. Finally, this response action will result in decontami-
nating the AT building so as to make it suitable for future use.

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 require-
ments 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 be 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 selected remedy protects human health and the environment
through the removal and treatment of the organic contaminants in
groundwater, using air stripping and carbon adsorption. In
addition, treatment of the contaminated soils through a low
temperature enhanced volatilization process will remove the most
mobile wastes from the soil, resulting in the elimination of a long-
term source of surface water and 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.
38
-------
Compliance With Applicable or Relevant and Appropriate Requirements
f
The selected remedy of excavation and on-site low temperature
enhanced volatilization of contaminated soils along with air
stripping and carbon adsorption of the groundwater will comply with
all chemical-, action-, and location-specific ARARs.

Cost Effectiveness

The selected remedy is cost effective because it provides overall
effectiveness proportional to its cost; the net present worth value
being $26,102,200. The cost of the soil treatment component of the
selected remedy ($2,772,400) is only 33 percent of the cost of the
excavation and on-site incineration alternative and only 15 percent
of the cost of the alternative involving off-site incineration, and
yet the selected remedy mitigates, as effectively as those alterna-
tives, all the risks posed by the contaminants at the site. The
cost of the groundwater component of the remedy is approximately 5.5
percent higher than the cost for the UV/oxidation alternative and
22 percent higher than the air stripping option, but it offers a
much higher degree of certainty with regard to the effective removal
of all the VOCs 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 American Thermo-
stat site. Of those alternatives that are protective of human
health and the environment and comply with ARARs, EPA and NYSDEC
have determined that this selected remedy best balances the goals
of long-term effectiveness and permanence, reduction in toxicity,
mobility or volume achieved through treatment, short-term effective-
ness, implementability, and cost, also considering the statutory
preference for treatment as a principal element and considering
state and community acceptance. With regard to the most mobile soil
wastes that pose the major risks at the site, the selected remedy
will offer as high a degree of long-term effectiveness and perma-
nence as the other treatment alternatives, involving incineration,
by permanently removing the source of groundwater contamination and
reducing the risk to human health and the environment. The selected
remedy will result in significant reductions in the toxicity of the
contaminated material (comparable to the reductions achieved by
incineration) through thermal destruction of the organic contami-
nants. The selected remedy is as effective as the other remedial
action alternatives and, compared to the off-site incineration
alternative, in the short-term it offers the additional advantage
of on-site treatment thereby reducing the potential risks to
residents along transporta-tion routes. Also, compared to the on-
site incineration, the selected remedy offers the advantage of
reduced stack emissions and release of particulates, thereby
reducing short-term risks to residents. Implementing the selected

39
-------
remedy is the least costly treatment option that is protective of
public health arfd' the environment.

The decision to treat the contaminated soil is consistent with
program requirements that state that highly toxic and mobile'wastes
should be treated to ensure the long-term effectiveness of a remedy.
Since all of the alternatives provide approximately the same long-
term effectiveness, the toxicity, mobility, volume reductions
achieved, and implementability are the major factors that provide
the basis for the selection of the soil portion of the remedy are
short-term effectiveness and cost. The selected remedy can be
implemented with less risk to the area residents and at less cost
than the other remedial action alternatives and, therefore, is
determined to be the most appropriate solution for the contaminated
soils at the American Thermostat site.

The selected remedy for the groundwater offers as high a degree of
long-term effectiveness and permanence as the other treatment
options of air stripping and UV/oxidation, and it reduces the
toxicity, mobility and volume to a greater extent than air stripping
or UV/oxidation through the destruction of organic contaminants.

The selected remedy is as effective in the short-term as air
stripping and UV/oxidation. With regard to implementability, the
components of the selected remedy and of the air stripping alterna-
tive are easily implemented, proven technologies and are readily
available. In contrast, the treatment technology for UV/oxidation,
although successful in pilot runs, has had limited use to date. In
addition, UV/oxidation is currently available from only two sources
nationwide.

The cost of the selected remedy is slightly higher than the other
treatment options (22% higher than the cost of the air stripping
option and only 5.5% higher than the UV oxidation option).

Since all treatment options for the groundwater are reasonably
comparable with respect to long-term effectiveness, short-term
effectiveness, and cost, the major consideration that provides the
basis for the selection of the air-stripping and carbon adsorption
alternative as the remedy for the groundwater is implementability
when compared to the UV/oxidation option, and toxicity reduction
when compared to the air stripping option. The technology for the
selected remedy is proven and readily available, and the carbon
adsorption system when added to the air stripping option ensures
complete removal of contaminants.

Preference for Treatment as a Principal Element

The selected remedy addresses the principal threats posed by the
site through the use of treatment technologies by treating the VOC-
contaminated soils in a low temperature enhanced volatilization unit
and by treating the groundwater by air stripping and carbon adsorp-
tion. Therefore, the statutory preference for remedies that
employ treatment as a principal element is satisfied.

40
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APPENDIX 1

TABLES
-------
TABLE 1
SURFACE SOIL SAMPLE ANALYTICAL SUMMARY
Compound

Volatile (ug/kg)

Methylene Chloride
1,2-Dichloroethene (Total)
Trichloroethene
Tetrachloroethene

PNA (ug/kg)

Phenanthrene
Fluoranthrene
Pyrene
Benzo(a)anthracene
Bis(2-ethylhexyl)phtha1ate
Chrysene
Benzo(b)fluoranthene
Benzo(k)fluoranthene
Benzofajpyrene
Indenofl,2,3-CD)pyrene
Benzo(g,h,i(perylene

pest/PC,B (ug/kg)

BETA-BHC

Inorganics (mg/kg)

Aluminum
Arsenic
Barium
Beryllium
Cadmium
Calcium
Chromium
Cobalt
Copper
Iron
Lead
Cyanide
Magnesium
Manganese
Nickel
Potassium
Selenium
Sodium
Vanadium
Zinc
2/19
2/19
6/19
16/19
3/11
2/11
3/11
2/11
3/11
3/11
3/11
2/11
3/11
1/11
1/11
1/11
20/20
20/20
20/20
2/4
6/20
18/18
20/20
19/19
16/26
20/20
20/20
2/20
20/20
20/20
20/20
9/14
5/20
10/15
20/20
18/20
(1)
Minimum
Detected
Concentration
.i.O
35.0
6.0
3.0
.0
.0
.0
.0
15.0
70.0
51.
41.
58.
11.
22.0
45.0
12.0
140.0
190.0
100.0
7,370.0
3.4
30.0
0.4
0.9
524.0
10.0
5.7
11.0
14,400.0
8.2
0.8
,940.0
171
15.0
308.0
0.4
279.0
10.0
44.0
1,
0
Maximum
Detected
Concentration/
Location
7.0/SS-9
36.0/SS-2
9.300.0/SS-3
2.700.000.0/SS-3
160.0/SS-
160.0/SS-3
270.0/SS-3
140.0/SS-3
.800.0/SS-14
170.0/SS-3
170.0/SS-3
220.0/SS-3
160.0/SS-3
140.0/SS-3
190.0
100.0/SS-4
16.200.0/SS-ll
28.0/SS-15
106.0/SS-I5
0.4/SS-13
36.0/SS-11
28,700.O/SS-5
- 19.0/SS-10
18.0/SS-12
201.0/SS-3
32.400.0/SS-11
87.0/SS-12
1.1
9.360.0/SS-9
786.0/SS-9
38.0/SS-3
1.170.0/SS-3
0.9/SS-9
1.170.0/SS-9
22.0/SS-14
1I8.0/SS-7
Mean
Detected
Concentration1
5.0
35.5
3,084.8
547,096.6
84.6
115.0
129.0
90.5
119.3
73.6
75.3
132.
69.
.5
.6
140.6
100.0
9314.0
7.2
45.7
0.4
8.0
.1
.6
9,884
13
9.2
35.8
19,655.0
24.4
0.9
4.366.0
451
24
688
0
584
16.0
77.6
(1) Frequency = number of detections per number of valid analyses.
-------
TABLE 2

WELL BORING SAMPLE ANALYTICAL SUMMARY: OFF-SITE
Compound

Volatile* (ug/kg)
Hethylene Cholorlde
Acetone
Toluene
Total Xylenes

Innrganiti (ug/kg)
Aluminum
Arsenic
Barium
Beryllium
Calcium
Chromium
Cobalt
Copper
Iron
Lead
Magnesium
Manganese
Nickel
Potassium
Vanadium
Zinc
T'Tira "~ •-••' — . - T. — .- .. J; =..-. — .. ---r

Frequency
3/6
6/6
4/6
2/6
6/6
6/6
1/1
4/4
6/6
6/6
2/2
6/6
6/6
6/6
6/4
6/4
6/4
2/1
5/5
6/6

Minimum
Detected
Concentrarion
7.0
27.0
14.3
4.0
7.270.0
4.1
45.1
1.3
1,610.0
9.8
11.6
18.4
17,300.0
7.3
4,670.0
161.0
23.5
1,100.0
11.2
50.8
Maximum
Detected
Concentration/
Location
57.0/WB-3
290.0/WB-3
44.0/WB-2
4.0/WB-l
11.100.0/WB-3
10.4/WB-3
45.1/WB-l
1.3/WB-2
51.300.0/WB-1A
19.1/HO-l
15.0/WB-3
58.6/WB-2
27,900.0/WB-l
11.6/WB-l
9,050.0/WB-lA
822.0/WB-2
39.1/WB-3
1.130.0/WB-2
16.9/WB-l
80.8/WB-l
- -
Mean
Detected
Concentration
25.3
122.8
29.2
4.0
9.168.3
6.2
45.1
1.3
27.256.6
15.6
13.3
31.4
22,666.6
9.5
6,770.0
566.0
27.4
1,115.0
13.5
66.0
(1) Frequency = number of detections per number of valid analysis.
-------
TABLE ''3

HEllCORING SAMPLE ANALYTICAL SUMMARY; ON-SITE
Compound

Volatile* (ug/kg)
Acetone
Tetrachloroethene

Inorganics (ug/kg)
Aluminum
Arsenic
Barium
Beryllium
Calcium
Chromium
Cobalt
Copper
Iron
Lead
Magnesium
Manganese
Nickel
Potassium
Vanadium
Zinc
Frequency
2/4
2/4
4/4
4/4
1/1
6/4
3/3
4/4
2/2
4/4
4/4
4/4
4/4
4/4
4/4
1/1
3/3
4/4
Minimum
Detected
Concentration
53.0
31.0
7,700.0
7.6
45.7
1.2
1,480.0
12.5
11.0
22.8
20.000.0
9.6
3,040.0
602.0
22.4
1.150.0
11.1
60.1
Maximum
Detected
Concentration/
Location
71.0/WB-5
18.000.0/WB-5
11.400.0/HD-5
12.7/WB-5
45.7/WB-4
1.3/WB-5
37.600.0/WB-5
16.2/WB-4
13.5/WB-5
65.1/WB-4
25.900.0/WB-5
19.4/WB-5
5.710.0/WB-4
912.0/HO-4
2B.O/WB-4
1.150.0/W8-4
17.0/WB-5
81.2/WB-5
Mean
Detected
Concentration
62.0
9.015.5
9,397.5
9.6
45.7
1.2
21.693.3
14.9
12.2
35.7
23.325.0
13.0
3.912.5
751.2
25.6
1.150.0
13.6
.68,2
(1) Frequency = number of detections per number of valid analysis.
-------
TABLE A

BUILDING FOUNDATION BORING SAMPLE ANALYTICAL SUMMARY
Compound

Volallies (ug/kg)

Methylene Chloride
Acetone
Carbon Disulfide
1,1,1-Trichloroethane
Tetrachloroethene
Toluene
Ethylbenzene
Total Xylenes

BNA (ug/kg)

Bts(2-ethy1hexy1)phthalate

Pest/PCB (og/kg)

BETA-BHC
Arochlor 1260

Inorganics (ntg/kg)

Aluminum
Arsenic
Barium
Beryllium
Cadmium
Calcium
Chromium
Cobalt
Copper
Iron
Lead
Magnesium
Manganese
Nickel
Vanadium
Zinc
1/12
6/12
1/9
2/12
6/12
7/12
2/12
3/12
2/3
1/3
1/3
11/11
11/11
5/5
7/7
1/9
9/9
11/11
6/6
8/8
11/11
11/11
10/11
11/11
11/11
9/9
11/11
(1)
Minimum
Detected
47.0
22.0
0.6
0.7
4.0
0.7
1.0
1.0
600.0
6.4
510.0
6,880.0
3.8
46.6
1.2
1.5
1.310.0
11.9
11.5
10. fl
19,200.0
10.2
2.510.0
516.0
19.2
10.8
37.2
Maximum
Detected
Concentration/
Location
47.0/BF-4
840.0/BF-4
0.6/BF-2
1.0/BF-5
390.0/BF-4
74.0/BF-4
3.0/BF-5
13.0/BF-5
1.100.0/BF-5
6.4/BF-5
510.0/BF-5
Mean
Detected
47.0
241.8
0.6
0.8
71.3
26.2
2.0
6.3
850.0
6.4
510.0
13.700.0/BF-5
13.2/BF-4
65.8/BF-5
1.4/BF-4
1.5/BF-4
36.300.0/BF-4
22.7/BF-5
13.9/BF-2
44.7/BF-4
29.500.0/BF-2
30.8/BF-3
4.600.0/BF-5
1.170.0/BF-2
31.3/BF-5
23.9/BF-5
79.1/BF-5
9,921.8
7.8
54.6
1.2
1.5
9.580.0
15.3
12.5
29.5
23.390.9
17.0
3,365.0
781.8
23.9
16.2
59.7
(1) Frequency = number of detections per number of valid analysis.
-------
TABLE 5

GROUNOWATER SAMPLE ANALYTICAL SUMMARY: ON-SITE
Compound

Volatile* (ug/1)

Vinyl Chloride
Chloroethane
1.1-Oichloroethene
1.2-Dlchloroethene (Total)
Chloroform
1,2-Oichloroethane
1,1,l-Trichloroethane
Trichloroethene
Tetrachloroethene
Toluene
1,I,2,2-Tetrachloroethane

BKA. (ug/1)

N-Nltrosodiphenylamlne

Inorganics (ug/1)

Aluminum
Antimony
Arsenic
Barium
Beryl 1 ium
Cadmium
Calcium
Chromium
Cobalt
Copper
Iron
Lead
Magnesium
Manganese
Mercury
Nickel
Potassium
Sodium
Vanadium
Zinc
Frequency
2/15
1/15
5/15
7/15
2/15
2/15
1/15
10/15
15/15
2/14
3/15
5/7
15/15
1/13
2/3
3/13
3/12
2/13
12/12
12/14
3/8
10/11
10/10
15/15
9/9
15/15
1/15
6/11
3/7
10/10
2/5
15/15
(1)
Minimum
Detected
Concentration
19.0
6.0
0.0
1.0
0.9
4.0
1.500.0
0.9
4.0
2.0
26.0
2.0
557.0
119.0
109.0
257.0
5.9
6.7
5,960.0
11.0
51.2
36.0
24.200.0
27.2
6.930.0
171.0
0.6
53.4
6.980.0
18.900.0
107.0
294.0
Maximum
Detected
Concentration/
Location
Mean
Detected
Concentration
150.0/BF-4
6.0/WB-5
2.0/WB-4
9.0/1-29
6.0/BF-4
5.0/WB-4
1.500.0/R-14
440.0/BF-4
31.000.0/R-14
3.0/WB-4
100.0/1-29
. 84.5
6.0
0.6
5.0
3.4
4.5
1,500.0
230.0
7,712.8
2.5
57.3
14.0
5.6
326.000.0/R-14
I19.0/R-14
245.0/R-14
2.490.0/R-14
20.2/R-14
32.2/R-M
106.000.0/BF-4
521.0/R-14
641.0/R-14
629.0/R-14
658.000.0/R-14
1.610.0/R-14
146.000.0/R-M
6.120.0/R-14
0.6/R-14
1.080.0/R-14
30.400. O/R-14
142.000.0/MW-4
458.0/R-14
4.960.0/R-14
51.686.4
' 119.0
177.0
1,605.6
15.2
19.4
36.060.0
117.0
440.0
180.3
173,780.0
303.4
41.794.4
1.607.3
0.6
398.8
18.593.3
96.460.0
282.5
1.206.5
(1) Frequency = number of detections per number of valid analysis.
-------
TABLE 6

GROUNDHATER SAMPLE ANALYTICAL SUMMARY: OFF-SITE
Compound Frequency

Volatile* (ug/1)

Chloromethane 1/29
Methylene Chloride 3/16
1,1-01chloroethene 4/19
1,2-Dichloroethene (Total) 5/29
Chloroform 3/29
1,2-Oichloroethane 5/29
Carbon Tetrachloride 1/29
Trichloroethene 11/28
2-Hexanone 2/26
Tetrachloroethene 18/29
Toluene 3/27
1,1,2,2-Tetrachloroethane 1/29

Inprganics (ug/1)

Aluminum 19/21
Antimony 1/24
Arsenic 5/11
Barium 7/9
Beryllium 4/23
Cadmium 7/24
Calcium 25/25
Chromium 11/24
Cobalt 3/23
Copper 10/21
Iron 25/25
Lead 27/27
Magnesium 20/20
Manganese 28/29
Mercury 1/29
Nickel 3/20
Potassium 8/12
Sodium 26/26
Vanadium 4/26
Zinc 28/26
(1)
Minimum
Detected
Concentration
Concentration
Maximum
Detected
Concentration/
Location
Mean
Detected
Concentration
3.
2.
2.0
3.0
0.6
0.0
0.9
.0
.0
0.0
4.0
0.0
2.0
4.0
165.0
68.9
10.2
115.0
5.2
5.1
5,750.0
9.3
90.8
32.0
300.0
10.6
5,450.0
30.0
0.2
250.0
838.0
7,370.0
50
1
24.7
2.0/WB-1A
4.0/R-26
0.2/R-19
2.4/R-6
220.0/R-ll
4.0/WB-3
2.0/R-16
85.0/R-6
10.0/WB-1A
1,800.0/R-ll
6.0/R-26
4.0/R-19
163,000.
68.
60.
1,080.
7.
23.
507.000.
511.
179.
2,870.
343,000.
420.
130.000.
10,900.
0.
469.
45.600.
175.000.
329.
2.020.
0/WB-1A
9/WB-3
4/WB-3
O/WB-2
8/WB-3A
4/R-31
O/WB-2
O/WB-2
O/WB-3
O/R-11
O/WB-2
O/R-26
O/WB-2
O/WB-2
2/WB-1A
O/WB-2
0/WB-1A
O/MW-5
O/WB-2
O/R-19
2.0
3.3
0.1
0.6
82.3
3.4
2.0
15.7
7.0
374,
4,
4.0
26,342.6
68.
36.
481,
6.7
77
10
,629
105
142.6
656.7
94,502.0
137.7
23.121
1,340.6
0
369
.824
56,206.5
231.7
623.7
(1) Frequency = number of detections per number of valid analysis.
-------
TABLE 7
SURFACE WATER SAMPLE ANALYTICAL SUMMARY: ON-SITE
Compound

Volatile* (ug/1)
Vinyl Chloride
Methylene Chloride
Acetone
1,1-Dlchloroethene
1,2-Dichloroethene (Total)
1,2-Dlchloroethane
THchloroethene
1,1,2-Trichloroethane
Tetrachloroethene
Toluene

BJA. (ug/1)
Benzole Acid

Inorganics (ug/1)
Aluminum
Calcium
Copper
Iron
Magnesium
Sodium
Zinc
Frequency
2/5
1/5
1/5
2/5
) 2/5
1/5
4/5
1/5
1/5
1/5
Minimum
Detected
Concentration
5.0
210.0
4.0
0.7
270.0
3.0
2.0
3.0
0.8
1.0
Maximum
Detected
Concentration/
Location
7.0/SW-8
210.0
4.0
2.0
640.0//SW-8
3.0
320.0/SW-26
3.0
48.000.0/SW-8
l.O/SH-30
Mean
Detected
Concentration
6.0
210.0
4.0
1.3
455.0
3.0
127.2
3.0
9.937.9
1.0
1/1
2/3
5/5
2/4
2/2
1/1
5/5
2/3
4.0
483.0
6,160.0
54.7
703.0
8.470.0
41.000.0
638.0
4.0/SW-26
563.0/SW-30
71.100.0/SW-26
77.5/SW-28
1.360.0/SW-30
8.470.0/SW-29
145.000.0/SW-28
3.760.0/SW-28
4.0
523.0
36.844.0
66.1
1.031.5
8,470.0
90.940.0
2.199.0
(1) Frequency = number of detections per number of valid analyses.
-------
TABLE 8

SURFACE HATER SAMPLE ANALYTICAL SUMMARY: OFF-SITE
Compound . Frequency

Volatiles (ug/1)

Vinyl Chloride 4/17
Methylene Chloride 2/14
Carbon Disulfide 1/17
1.l-Oichloroethene 3/17
1.2-Dichloroethene (Total) 4/17
Trichloroethene 5/17
Tetrachloroethene 5/17

BMA (ug/1)

Phenanthrene • 1/1
Anthracene 1/1
Fluoranthrene 1/1
Pyrene 1/1
Benzo(a)anthracene 1/1
Clirysene 1/1
Di-n-octyl Phthalate 1/1
Benzo(b)fluoranthene 1/1
Benzo(k)f1uoranthene 1/1
Benzo(a)pyrene 1/1
IndenoU,2.3-CD)pyrene 1/1
Benzo(G,H,I)perylene 1/1

Inorganics (ug/1)

Aluminum 5/10
Barium 3/5
Cadmium 2/17
Calcium 17/7
Chromium 1/17
Copper 2/14
Iron 7/10
Lead 3/15
Magnesium 11/11
Manganese 10/12
Mercury 1/15
Potassium 6/7
Silver 2/17
Sodium 17/17
Zinc 4/15
(1)
Minimum
Detected
Concentration
0.3
5.0
15.0
0.1
7.0
0.0
3.0
13.0
3.0
1S.O
13.0
6.0
5.0
1.0
3.0
4.0
4.0
2.0
4.0
21.0
8.0
6.7
18.900.0
11.0
3.0
101.0
2.3
3,150.0
18.3
0.3
900.0
5.8
4.000.0
21.0
Maximum
Detected
Concentration/
Location
31.0/SW-21
6.0/SH-18
15.0/SW-27
0.4/SW-20
510.0/SW-21
200.0/SW-21
1.000.0/SH-20
13.0/SW-27
3.0/SW-27
18.0/SW-27
13.0/SW-27
6.0/SW-27
5.0/SH-27
l.O/SW-27
3.0/SW-27
4.0/SW-27
4.O/SW-27
2.0/SW-27
4.0/SW-27
Mean
Detected
Concentration
13.4
5.5
15.0
0.2
220.2
80.8
472.6
13.0
3.0
18.0
13.0
6.0
5.0
1.0
3.0
4.0
4.0
2.0
4.0
1.060.0/SW-22
26.0/SW-22
8.7/SW-19
80.600.0/SW-27
11.0/SW-22
7.0/SW-22
1.630.0/SW-22
7.3/SW-27
10,200. O/SW-27
407.0/SW-1B
0.3/SW-22
5.920.0/SW-25
18.0/SW-18
77. 100. O/SW-27
60.8/SW-23
508.8
14.0
7.7
39.094.1
11.0
5.0
427.5
4.9
5,629.0
116.8
0.3
2,698.3
11.9
26, HO. 5
33.9
(1) Frequency = number of detections per number of
analyses.
-------
TABLE 9
SEDIMENT SAMPLE ANALYTICAL SUMMARY
Compound

Volatile* (ug/kg)

Vinyl Chloride
Hethylene Chloride
Acetone
1,2-Dichloroethene (Total)
2-Butanone
Trichloroethene
Tetrachloroethene

BNA (ug/kg)

4-Methylphenol
Phenanthrene
Di-n-butylphthalate
Fluoranthrene
Pyrene
Benzo(a)anthracene
Chrysene
Benzo(b)f1uoranthene
Benzo(k)f1uoranthene
Benzojajpyrene

Inorganics (mg/kg)

Aluminum
Antimony
Arsenic
Barium
Beryllium
Cadmium
Calcium
Chromium
Cobalt
Copper
Iron
Lead
Magnesium
Manganese
Mercury
Nickel
Potassium •
Selenium
Silver
Sodium
Vanadium
Zinc
frequency
1/9
1/9
3/7
4/9
2/9
3/9
3/9
1/7
3/7
1/7
1/7
1/7
2/7
2/7
2/7
2/7
2/7
11/11
1/10
11/11
10/10
7/11
4/11
9/9
11/11
4/5
10/10
11/11
9/9
11/11
11/11
2/11
10/11
4/5
1/6
2/11
5/5
11/11
11/11
(1)
Minimum
Detected
Concentration
37.0
26.0
21.0
3.0
6.0
4.0
12.0
180.0
43.0
31.0
230.0
220.0
35.0
53.0
46.0
54.0
43.0
,260.0
27.0
1.9
49.0
0.5
2.2
.330.0
9.5
8.1
16.0
15.000.0
12.0
.930.0
90.0
3.9
12.0
227.0
2
1,
1.
Maximum
Detected
Concentration/
Location
37.0/SW-20
26.0/SW-6
91.0/SH-7
530.0/SW-20
13.0/SW-20
32.0/SW-20
53.0/SW-22
180.0/SH-20
340.0/SW-6
31.0/SH-20
230.0/SW-6
220.0/SW-6
50.0/SW-20
88.0/SW-20
79.0/SW-20
76.0/SW-20
69.0/SH-20
Mean
Detected
Concentration
37.0
26.0
52.0
175.7
9.5
20.6
26.6
180.0
147.6
31.0
230.0
220.0
42.5
70.5
62.5
65.0
56.0
8
16.0
14.5
10.0
42.0
21.400.0/SW-8
27.0/SW-18
36.1/SW-5
120.0/SW-19
2.7/SW-8
3.4/SW-20
14.000.0/SW-23
30.8/SH-23
12.0/SW-18
144.0/SW-8
45.000.0/SW-8
114.0/SW-20
7.130.0/SW-8
3.150.0/SW-B
12.0/SW-I9
88.7/SW-8
60I.O/SW-22
2.8/SW-23
100.0/SW-I8
637.0/SW-20
32.7/SH-8
1.530.0/SW-8
12,452.7
27.0
11.0
77.7
1.4
2.9
4,576.6
18.9
9.5
51.3
24.672.7
54.2
3.652.7
812.4
7.9
32.1
405.5
2.8
58.0
371.1
17.2
234.5
(1) Frequency = number of detections per number of valid analyses.
-------
TABLE 10

SLUDGE SAMPLE ANALYTICAL SUMMARY
Compound

Volatile* (mg/kg)
1,2-Dlchloroethene (Total)
Trichloroethene
Tetrachloroethene

BNA (mg/kg)
D1~n-Buty1 phthalate
Butyl Benzyl Phthalate
Bis(2-Ethylhexyl)Phthalate
Dl-n-Octyl Phthalate

Pest/PCB (mg/kg)
Arochlor 1254
Minimum .
... Detected
Frequency''' Concentration
3/5
1/5
5/5
3/5
5/5
4/5
1/5
4/5
6.8
5.6
1.0
Maximum
Detected
Concentration/
Location
1,000.0/SL-l
5.6/SL-l
28,0/SL-l
Mean
Detected
Concentration
352.6
5.6
10.1
21.0
2.0
5.0
11.0
44.0/SL-1
650.0/SL-1
240.0/SL-1
11.0/SL-1
36.0
305.4
143.7
11.0
7.8
22.0
14.9
Inorganics (mg/kg)
Aluminum
Barium
Cadmium
Calcium
Chromium
Copper
Iron
Lead
Cyanide
Magnesium
Manganese
Mercury
Nickel
Zinc
5/5
4/5
4/5
5/5
5/5
5/5
5/5
5/5
1/5
5/5
5/5
5/5
5/5
5/5
8,430.0
289.0
19.0
4,620.0
29.0
4,100.0
14,800.0
422.0
2.0
2,860.0
110.0
1.6
140.0
2,690.0
24.400.0/SL-3
3,150.0/SL-l
160..0/SL-1
45.700.0/SL-3
764.0/SL-l
32,700.0/SL-l
72,600.0/SL-l
1,880.0/SL-l
2.0
13,900.0/SL-l '
555.0/SL-3
4.8/SL-2
3,020.0/SL-l
12,800.0/SL-l
17,186.0
1,492.2
82.0
18,610.0
306.4
13,922.0
39,880.0
1,111.8
2.0
9,342.0
306.6
2.3
1,219.0
7,304.0
(1) Frequency • number of detections per number of valid analyses.
-------
TABLE 11

DRUM SAMPLE ANALYTICAL SUMMARY
Cpmpoupd

Volatile* (ug/1)
Trichloroethene

BNA (ug/1)
Phenanthrene

Pest/PCB (ug/1)
Chlordane

Inorganics. (ug/1)
Aluminum
Antimony
Arsenic
Calcium
Chromium
Copper
Iron
Lead
Mercury
Nickel
Selenium
Minimum Maximum
' Detected Detected
Frequency*'' Concentration Concentration
2/8
1/6
1/6
1/8
7/8
7/8
2/8
2/8
2/8
3/8
1/8
8/8
7/8
7/8
210.0
6.9
20.0
230.0
6.9
20.0
Mean
Detected
Concentration
220.0
6.9
20.0
540.0
12.0
2.0
140.0
2.0
5.0
386.0
100.0 .
0.0
40.0
1.0
3,540.0
12.0
2.0
1.190.0
2.0
53.0
6.520.0
100.0
2.8
40.0
1.0
3.540.0
12.0
2.0
1.165.0
2.0
29.0
2.688.6
100.0
0.4
40.0
1.0
(1) Frequency = number of detections per number of valid analyses.
-------
EXHIBIT 12

AMERICAN THERMOSTAT SITE
SUMMARY CF INDICATOR CHEMICALS IN AREA MATRICES
Surface/
Subsurface Surface
Grouncwater Soils Water Sediments
VQLATILES
Tetrachloroethylene
Trichloroethylene

X
X

X
X
-
X
X
Chloroform X
1,2 Dichloroethane X
1,1-Dichloroethene X
1,1,2,2-Tetrachloroethane X
Vinyl Chloride X
INORGANICS
Arsenic
Csdiriur*
Chromium*
Lead*
X
X
X
X
BASE NEUTRAL/ACID EXTRACTABLES
Bis(2-ethylhexylJPhthalate
N-Nitrosodiphenylamine X
X: Indicates compound was detected above site and relevant background
levels and has been selected as an indicator for the medium.
-: Indicates compound was not selected as an indicator for the medium.
*: Indicates noncarcinogenic indicator chemical. All remaining contaminants
listed above are potential carcinogens.
-------
TABLE 13
• v

AMERICAN THERMOSTAT SITE

EXPOSURE ASSUMPTIONS FOR DIRECT CONTACT WITtj
SURFACE WATER AND SEDIMENTS '
Parameter
Most
Probable
Case
Realistic
Worst
Case
Age During Exposure

Duration of exposure

Frequency of exposure
(events per year)

Average Body Weight

Sediments

Sediment Ingestion Rate

Gastrointestinal Adsorption

Sediment Adherence Rate
Surface area
exposed
mg/cm2

Dermal Adsorption Rate
6-15 yrs

5 yrs

36 days/yr

35 kga

25 mg/dy

50%

0.5 mg/cm2

0.6%
6-15 yrs

9 yrs

60 days/yr

35 kga

100 mg/dey

100%

1.0

0.12%
Surface Water

Amount Accidently Ingested

Surface Area Exposed
On-Site Drainage Areas
Schmidt/Roth Ponds

Hours Exposed
100 ml
1200 cm2
7700 cm2
150 ml
4890 cm2
7700 cm2
SOURCES:
1 Anderson, et al., 1985
2 USEPA Exposure Assessment Manual. 1988

NOTE: Average and upper bound surface water evaluations
assume whole body exposures assuming average and upper 90%ile
body surface areas (for children). Average sediment exposure
evaluations assume exposure to hands and feet only; worst-case
evaluations assume exposures to hands, legs and feet.
-------
TABLE 14
AMERICAN THERMOSTAT SITE

ParassJer.
Age During Exposure
. Duration of Exposure
Frequency'
Average Body Weight2
Soli Ingestion Rate3
Ingestfon 81oavail ability4
Dermal Contact Rate
Soil Adherence Rate
Surface Area Exposed Exposed
Dermal Absorption Factor5
Respiratory Volume (wVhr)
Inhalation Absorption Factor
Average Exposure
6-15 yrs
5 yrs •
72 events/yr
35 kg
100 ing/event
SOX
752.5 nig/event
0.5 mg/cm2
1505 en2
0.6X
1.5 irVhr
25X
fi-15 yrs
9 yrs
.ISO events/yr
27 kg
100 mg/event
inor.
5500 mg/event
1.0 mg/cm2
5500 cm2
1.2X
5.7 «rVhr
IflOX
USEPA. 1985
tISEPA. 1989
Polger and Schlatter, 1980
Schaum. 1985
USEPA. 1985
Yang et al.. !986a, 1986b
USEPA, 1988
USEPA. 1988
'Frequencies given for average exposure scenarios assume a child visits the
site 2 days/week for 9 months of the year. Assumed maximum values are approximately
two times greater.
2Mean body weights for assumed age distributions. Source: Development of Statistical
Distributions or Ranges of Standard Factors Used in Exposure Assessments (USEPA, 1985).
3$oll Ingestion rates, assumed to be 100 mg/day for all age groups, were taken from
recently promulgated USEPA guidance (1989).
^Absorption factors are based on studies of TCOD (rlioxin) absorption from soil and fly ash (Potfjer and Schlatter, 1980).
^Dermal absorption factors cited above also Include a dermal bioavallability factor of 15*
per Polger and Schlatter (1980).
-------
TABLE 15
AMERICAN THERMOSTAT SITE
ASSUMPTIONS USED TO ESTIMATE EXPQSUR£SjrQ_SURFACEANf) SUBSURFACE SOUS (0-1')
DIRECT CONTACT MID INHALATION PATHWAYS
FUTURE INDUSTRIAL, U55 SCENARIOS: AtlULT WORKERS
Parameter
Age During Exposure
Duration
Frequency'
Average Body Weight
Soli Ingest I on Rate2
Ingest I on BioavaUabillty3
Dermal Contact Rate
Soli Adherence Rate
Surface Area Exposed
Dermal Absorption Factor^
Respiratory Volume
Inhalation Absorption Factors
HVCI aye c.*pu3iirc
Best Estimate
Adult
10 yrs
230 d/yr
70 kg
100 mg/day
SOX
10BO mg/event
0.5 mg/cm2
2160 cm2
0.6X
1.3 m3/hr
25X
Maxim/uncase
Adul t
40 yrs
230 dys/yr
70 kg
100 mg/day
100%
8700 mg/event
1.0 mg/cm2
8700 cm2
1.2X
7.1 m3/hr
100X
Source
USEPA. 1985
USEPA. 1089
Polger & Schlatter. 1980

Schaum, 1985
USEPA. 1985
Yang et al.. 1984a, 1986b
USEPA. 1988
USEPA. llflB
'Frequencies for both average and maximum exposure scenarios assume an adult works
on-site In the absence of remediation 5 days/week for 11.5 months (accounts for 2
week vacation).
2Sol1 Ingest Ion rates, assumed to be 100 mg/day for all age groups, were taken from
recently promulgated USEPA guidance (1989).
^Absorption factors are based on studies of TCOO (dioxin) absorption from soil and fly ash (Poiger and Schlatter, 1980).
^Dermal absorption factors cited above Include a dermal bioavailability factor of 15X
per Polger and Schlatter (1980).
-------
TABLE 16
AMERICAN THERMOSTAT SITE
SURFACE SOIL VOLATILIZATION PATHWAYS: EXPOSURE POINT CONCENTRATIONS
EMISSION RATE CALCULATIONS FOR SURFACE SOILS
EMISSION RATE EQUATION}
PARAMETER DEFINITIONS!
C
0
CS
A
»
M
d
I • D*C»«A«
4.7
4.7
4.7
4.7
4.7
4.7
VINO
SPEED
•Viec
4.6
4.6
4.6
4.6
4.6
4.6
C
GROUND LEVEL
CONCENTRATION
g/«'3
5.74E-09
7.7IE-11
2.86E-06
6.00E-11
6.44E-06
7.97E-08
GROUND LEVEL CONCENTRATION EQUATION: C • E\(Oy*Ol*3.14*US)
PARAMETER DEFINITIONS:
C • concentration of substance In g/M*3 (assumed 100m downwind of the site)
E • Mission rate of compound from soil (g/sec)
Oy • dispersion coefficient In the lateral direction (m)
Ot • dispersion coefficient In the vertical direction (m)
US • wind speed. 4.7 in/sec
P< • 5.14
d • effective depth of soil cover: 15 cm (0.5 ft)
(Assumes Stability Class D]
lAssims Stability Class D)
-------
EXHIBIT 17
AMERICAN THERMOSTAT SITE
CANCER POTENCY FACTORS AND WEIGHT OF EVIDENCE .CLASSIFICATIONS:

V.
-At«»lNU;S.iNiS

CANCER POTENCY FACTOR
(mg/kg/cay)
CHEMICAL
ARSENIC
CADMIUM
CHROMIUM
(HEXAVALENT)
N-NITROSOD IPHENYLAMINE
i,2 DICKLOROETEANE
1,1 DICHLOROETHYLENE
1,1,2,2 TETRACHLORO-
ETHANE
TETRACKLORO-
ETHYLENE
TRICHLORO-
ETHYLENE
ORAL
1.8S+OQ
NA

NA
4.9E-03
9.1E-02 .
5.8S-01
2.0E-01

5.1E-02

. 1.1E-02
INHALATION
1 .5E+01
6.1E+00

4.1E+01
NA
9.1E-02
1.16E-K50
2.0E-01

4.6E-03
WEIGHT OF
EVIDENCE1
A
Bl

A
B2 .
B2
C
C

SOURCE'
CAG
CAG

CAG
CAG
CAG
KEA
CAG

CAG

CAG
Cancer potency factor for each exposure route as defined by IRIS (EPA,
1989). EPA Weight of Evidence classifications are defined as follows:

Group A - Human Carcinogen. Sufficient evidence from epidemiologic
studies to support a causal association between exposure and
cancer.

Group Bl - Probable Human Carcinogen. Limited evidence of
carcinogenicity in humans from epidemiologic studies.

Group B2 - Probable Human Carcinogen. Sufficient evidence of
carcinogenicity in animals, inadequate evidence of
carcinogencity in humans.

Group C - Possible Human Carcinogen. Limited evidence of
carcinogenicity in animals.
Source: HEA
CAG
Health Effects Assessment Document
Carcinogen Assessment Group
NOTE: For those compounds where inhalation criteria are not available, the
oral criteria will be used as the cancer potency factor in evaluating
potential risk posed by those compounds.
-------
EXHIBIT 18
AMERICAN THERMOSTAT SITE
TOXICITY CRITERIA USED FOR NONCARCINOGENIC CHEMIC AL S
CHEMICAL

''CADMIUM (WATER)
CADMIUM (FOOD)
ARSENIC
MERCURY (INORGANIC)
CHROMIUM (HEXAVALENT)
CHLOROFORM
TETRACHLOROETHYLENE
BIS(2-ETHYL-HEXYL)
PHTHALATE
CHROMIUM
(TRIVALENT)
LEAD
REFERENCE DOSE
(mq/kg/day^

5.0E-04
l.OE-03
l.OE-03
2.0E-03
5.0E-03
l.OE-02
l.OE-02

2.0E-02

l.OE+02
1.1E-03
USEPA
SOURCE

RfD
RfD
RfD
HEA
RfD
RfD
RfD

RfD

RfD
MCL
NOTES:
1) RfD VALUES PERTAIN TO CHRONIC INTAKE.

2) SOURCES ARE EITHER USEPA REFERENCE DOSE WORK GROUP (RfD)
OR USEPA HEALTH EFFECTS ASSESSMENT GROUP (HEA)

3) CHEMICALS IN BOLDFACE ALSO EXHIBIT CARCINOGENIC TOXICITY
-------
TABLE 19
AMERICAN THERMOSTAT SITE
PROPOSED GROUNDWATER ACTION LEVELS
CURRENT AND EUTIIRE SITE
On-Slte Concentrations

Carcinogenic
Parameter
Tetrachloroethene
Trichloroethene
Vinyl Chloride
Arsenic
1,1,2,2-Tetrachloro-
ethane
1 ,2-Dichloroethane
1 ,l-Dich1oroethane
N-Ni trosod i pheny 1 ami ne
Chloroform

Geometric
Mean
uq/1
548.185
25.6
7.42
5.5

5.27
2.75
1.63
5.4
2.3

Off-Site
USES:
CARCINOGENS AMD NONCARCINOGENS
Concentrations
Cancer
Geometric
Maximum
iid/1
24000
440
150.000
9.900

100.000
5
2
14
2.5

1
On-Slte Concentrations

Noncarcinogenic
Parameter
Lead
Chromium (VI)
Cadmium

Geometric
Mean
uo/1
83.24
20.391
2.83

Maximum
ug/1
170
90.4
52.2
Mean
ug/1
23.73
3.18
3.75
8.72

2.48
2.62
1.38
ND
3.00

Off-Site

Geometric
Mean
ug/1
95.78
13.94
4.07
Maximum
ua/1
310000
240'
5.0
245.0

2.5
4
2.5
5
200

Concentrations

Maximum
uo/1
1610
521
23.4
Potency
-1
mg/kq/day
5.10E-02
1.10E-02
2.00E-01
1.80E+00

2.00E-01
9.10E-02
5.80E-01
4.90E-03
6.10E-03

Cancer
Potency
-1
mg/kq/dav
1.14E-03
5.00E-03
5.00E-04
10-6 Risk
Action Level
uo/1
0.69
3.18
0.18
0.02

0.18
0.38
0.06
7.14
5.74

10-6 Risk
Action Level
uq/1
39.9
175.0
17.5

"Recommeded"
Action
Level
Ground-
water
Cone.
ua/1 Ml
5.0
5.0
2.0
25.0

5.0
5.0
5.0
50.0
100.0
"Recommeded"
Action
Level

Ground-
water
Cone.
uq/1 Ml
25
50
10

Carcinogenic Contaminants
At GW Concentration:
Action Level Ratios
On-Site Off-Site
Geom Geom
Mean Max Mean Max
Source ua/1 uq/K ug/1 uo/1
NYS MCL(l) 109.6 4800.6 4.7 62000.0
NYS MCL(l) 5.1 80.0 0.6 18.0
NYS MCL(1) 3.7 75.0 1.9 2.5
NYS MCLM) 1.1 2.0 1.7 49.0

NYS MCL(1) 1.1 20.0 0.5 0.5
NYS MCL(l) 0.6 1.0 0.5 0.8
NYS MCLM) 0.3 0.4 0.3 0.5
NYS MCLM) 0.1 0.3 ND 0.1
NYS MCL(l) 0.02 0.03 0.03 2.2
Carcinogenic Contaminants
At GW Concentration:
Action Level Ratios
On-Site Off-Site

Geom Geom
Mean Max Mean Max
Source uo/1 ug/1 un/1 un/1
NYS MCL(2) 3.3 6.8 3.8 66.4
NYS MCL(2) 0.4 1.8 0.3 10.4
NYS MCL(2) 0.3 0.7 0.4 3.2
(1) Source: NYSOOH Bureau of Public Water Supply and Protection Regulations for Standards Limiting Organic Chemical Containation in Drinking Water, November
23, 1988 (10 NYCRR 5).
(2) Source: NYSDEC-NYS Ambient Water Quality Standards and Guidance Values. April 1987.
-------
TABLE 20

AMERICAN THERMOS TAT. SITE
---• « *--r»ftn | CMC I (

1 !»*»! V*T-T-_« =
CURRENT AND
niRECT CON
FUTURE SITE USES:
TACT WITH SOILS

Recommended Soil Action Levels: PPM
Carcinogenic
Parameter
Tetrachloroethylene
Trirhlnroethvlene
On-Slte
Geometric
Mean
ma/ka
2.406
0.009
Surface Soil
Mod Ian
rcg/kq
4.650
0.003
Concentration
Upper
Quartile
ing/ Kq
1200.0
7.0
Maximum
inn/ kg
2700.0
9.3
Cancer
Potency
-1
ma/kq/day
5.10E-02
1.10E-02
Current
Best
Estimate
Exposures
mg/kg
893.5
4142.4
Use Exposures
Upper
Bound
Exposure
mg/kg
84.9
393.5
CTJT O
Future
Best
Estimate
Exposure
mg/kg
270.0
1251.6
?ni28.5
Use Exposures
Upper
Bound
., Exposure
ma/ka
18.6
85.5
1390.5
B1$(2-ethylhexyD-
phthalate
0.021
0.183
0.4
0.4
6.84E-04
66616.9
-------
TABLE 21

COST ESTIMATE SUMMARY OF ALTERNATIVES
BOIL
Alternative
SC-1
SC-3
SC-4
SC-5
- No Action
*
- On-Site Incineration
- Off-Site Incineration
- Low Temperature
Enhanced Volatilization
$
$ 8,
$17,
$ 2,
Capital
Cost
26,500
322,800
918,700
772,400
Annual o & M
$

44,400
0
0
0
Total Present Worth
5% Discount Rate.
$
$ 8
$17
$ 2
736,800
,322,800
,918,700
,772,400
QROUNDWATER ALTERNATIVES
GW-1 - No Action
GW-2 - Limited Action
GW-3 - Air Stripping
GW-4 - Air Stripping/
Carbon Adsorption
GW-6 - UV Oxidation
BUILDING DECONTAMINATION ALT.
BD-1
BD-2
- No Action
- Decontamination
$
$
$ 2,
$ 2,
$ 3,
$
22,100
234,800
635,200
995,200
263,500
0
284,900
$
$
$1,
$1,
$1,
$
$
46,000
577,900
053,000
304,300
208,800
300
0
$
$ B
$18
$23
$21
$
$
757,000
,911,300
,821,900
,044,900
,845,200
4,600
284,900
-------
APPENDIX 2

FIGURES
-------
100
700
U.S. ENVIRONMENTAL PROTECTION
AGENCY
AMERICAN THERMOSTAT SITE
FIGURE t

AMEKICAN TMCRMOStAT
Slit PLAN
!•»
-------
cuivtni.' I
ABANDONED I '
wrtL HMD a
IN VAULT
100
0 ' 100

a?
SCALE IN FEET
200
U.S. ENVIRONMENTAL PROTECTION

AGENCY

AMERICAN THERMOSTAT SITE
FIGURE 1

AMERICAN TiltRMOSTAT

Silt TLAN
loll
ERASCO SFRVICE'S iNconponAjED
-------
SEPTICMFOHMER 3 UNIT
CESSPOOL
SYSTEM!
* COOt ANT
WATER
DISCHARGE
» TU SUriHACE
\SWALE
APPBOXIMATE
LIMITS OF
SEPTIC FIELD
r PVC
DISCHARGE
FOH AIR
S1IIIPP1NQ
UNI IS
SEPTIC FIELD
OVERFLOW
DISCHARQE
TO SWALE
8'STEEL PIPE
HOOF DRAIN
DISCHARGE
TO SURFACE
SWALE
US ENVIRONMF.N1AL PROTECTION
AGENCY
AMERICAN THERMOSTAT SITE
FIGURE 2
«

SUBSURFACE STRUCTURES
FIASCO SERVICES INCH
-------
APPROXIMATE
LIMITS OF
SEPTIC FIELD
"I
5!
SEPTIC FIELD OVERFLOW
DISCHARGE TO SWALE
fi"PVC PIPE
SEPTIC FIELD OVERFLOW
DISCHARGE 6"STEEL PIPE
APPROXIMATE LIMITS OF
ARMORY SEPTIC FIELD
NVS:
I ROUTE 23
CONCRETE VAULTS
100
100
200
SCALE IN FEE I
U.S. ENVIRONMENTAL PROTECTION
AGENCY
AMERICAN THERMOSTAT SITE

FIGURE 2 .

SUBSURFACE STRUCTURES'

a OF 2
-------
U.S. ENVIRONMENTAL PROTECTION
AGENCV
•UllOINd FOUNDATION TEST BOHINO LOCATIONS
Will tORINO IOCA1IONS
AMERICAN THERMOSTAT SITE
FMURE 3

SOIlt INVESTIGATIONS

EITEHT Or BUBSUMACe SOIL CONTAMINATION
IN OH-SITC ANI1 OFF-8IIE WtU tORINdS

TED
VOC-TOTAL VOIAIILE OROANIC CONCENTRATiON. pp
rc»-Ui«Ac>iiOBoei»f ME CONCENIRAIION. nn'i
PIN -OEPIH BEIOW SURFACE. FT.
u -UNDETECTED
EPASCO SERVICES INC
-------
181IMA1ID LIUIT 0' VCHATILt ORGANIC CDN1AUINA1ION
IN SURFACE AND SUBSURFACE SOIL
U.S. ENVIRONMENTAL PROTECTION
AGENCY
VOC-tOtAl VOtAtltt OnQANIC CONCCNtfl*no«. ppn
fCI-ItlHACIIlOHOEIIICIIE CONCEN1 RAMON, ppm
• DEHH (CLOW SURFACE. FT.
• UNO! UCttO
AMERICAN THERMOSTAT SITE

FIQURE .'It
SHEET I OF * ,
SOU. INVESTOATIOM EXTENT OF
SUnFACE AND SUBSURFACE SOIL
CONTAMINATION
IRASCO SERVICES INCORPORATED
-------
U.S. ENVIRONMENTAL PROTECTION
AGENCV
AMERICAN THERMOSTAT SITE
FIQURE
SHEET 2 OF 2

SOIL INVESTIGATIONS
FOASCO SERVICES I
-------
WB-04 '.
UJI ••
AMER)CAN
TitcnyosTAT
U.S. ENVIRONMENTAL PROTECTION
MW0

WB f
BF
••*»••••
CONSOUOATEO MOMTOniNd WELLS

UNCON90UDATED MOMTORINQ WELLS-INSTALLED
IN TEST BORINOS
UNCONSOUDATED MOMTORINO WELL-INSTALLED IN
BUILOINd FOUNDATION TEST OOntNO.
EXTENT OF PCE CONTAMINATION
l>5ppb)DETECTEO IN TIC UNCOH3OLIDAED
AQUIFER SOURCE EBASCO fHELIMNAAY ni DATA.
400
11 PCE CONCENTRATION DETECTED IN UQ/I.

u UNDETECTED
• MW-02
400
5?C
SCALS IN FEE r
BOO
AMERICAN THERMOSTAT SITE
. FOURE 5

EXTENT OF VOLATILE OROAMC
CONTAMNATION IN THE
UNCONSOLtMTED AOUFER

FIIASCO sEnvices INCORPORATED
-------
• MW-OI
OH-2
OH-1
/ R-3
n-8.
tTBO-3301
n-ia •!•• ...
•I50-I2U R-*°
• i MW-03 0 R-20 \

' ' * i i "*••••_.
AMERICAN
THERMOSTAT
I-JB

'«300-89ni
U.S. ENVmONMENfAL PROTECTION
AGENCY
• EXISTIN RESIDENTIAL WELLS AND MOMTOniNQ WELLS.
SAMPLED DURING REMEDIAL INVESTIGATION

O EXtSTINQ RESIDENTIAL WELLS NOT INCLUDED IN REMEDIAL
INVESTIGATION
400
EXTENT OF PCE CONTAMINATION OSppb) DETECTED IN THE
BEDROCK ACUFER. SOURCE: EBASCO PRELIMINAnY Rl
DATA AND IISTORCAL DATA.
• MW-02
0 <00

SCALE INFtf f
800
AMERICAN THERMOSTAT SITE
FIGURE 6

EXTENT OF VOLATILE ORGANIC
CONTAMINATION IN TIC '
UEOHOCK AQUIFER.
-------
TO 8W-I (5U.BUI
I AT BHIOQEI
SW-20V
\\ SW-ZI
U.S. ENVIRONMENTAL PROUCTION
AGENCY
SURFACE WATER SAMPLING LOCATION
SURFACE WATER SAMPLING LOCATION
AT PIPE OR MAN-MADE STRUCTURE
AMERICAN THERMOSTAT SITE
0 400

SCALE IN FEF.T
VOC-SURFACE WATER
VOC-SEtMMENT
SURFACE WATEB/SEDIMENT

CONTAMINATION
VOC • TOTAL VOLATILE OROAMC CONCENTRATION, ppb

U - UNDETECTED
FtiAsnn scnvicES INCOIVOHATED
-------
DW-1
TCE-1S
B/N/A-2
Cfl-19
Cr-HO
PB-13TO
AMERICAN THERMOSTAT
PLANT
DR-003
DR-003A
TBANS 1.2-OCE-1000
TCE-S.6
PCE-2S
B/N/A-B60
Cd-180
Cr-764
Pb-isao
WOOD FRAME
SHED
DR-7, 8, 10. 12
TCE-t.1
B/N/A-10
Cr-2«
Pb>422
AIR STRIPPING UNITS
PUMPHOUSE—*£7
ENVIRONMENTAL PROTECTION
AGENCY
OUST WIPE SAMPLE LOCATIONS

DRUM SAMPLE LOCATIONS
AMERICAN THERMOSTAT SITE
SLUDGE SAMPLE LOCATIONS
TRANS 1.2-DCE-TRANS-1.2-0!CHLOROETHENE CONCENTRATION, ppm
TCE-TRICHLOROETHENE CONCENTRATION, ppm
PCE-TETHACHLOROETHENE CONCENTRATION, pom
•/N/A - TOTAL BASE/NEUTRAL/AOD EX TRACT ABLE ORGANIC
CONCENTRATION, ppm
Cd - CADMIUM CONCENTRATION, ppm
Cr - CHROMIUM CONCENTRATION, ppm
Pb - LEAD CONCENTRATION, ppm
EXISTING FACILITIES INVEST.
SAMPLE LOCATIONS
EBASCO SERVICES INCQRPORATED
-------
APPENDIX 3 - ADMINISTRATIVE RECORD INDEX
-------
APPENDIX 4 - NYSDEC LETTER OF CONCURRENCE
-------
hew York State Department of Environmental Conservation
Wolf Road, Albany, New YorK 12233 -7010
Thomas C. Jorltng
Corrimisslonar
Mr. Constantine Sidamon-Eristoff
Regional Administrator
U.S. Environmental Protection Agency
Region II
26 Federal Plaza
New York, NY 10278

Dear Mr. Sidamon-Eristoff:
JUH 2-8-1990
Re: American Thermostat
NYSDEC Id. No. 420006

I am pleased to advise you that the New York State Department of
Environmental Conservation concurs with the remedial alternatives
specified in the Record of Decision for the American Thermostat site.

We look forward to participating in the design of the remedies, -
and urge you to commence at the earliest date.
0. Sullivan
Deputy Commissioner
-------
APPENDIX 5-RESPONSIVENESS SUMMARY
-------
FINAL RESPONSIVENESS SUMMARY

AMERICAN THERMOSTAT SITE
SOUTH CAIRO, NEW YORK

A public comment period for interested parties to comment on the
Remedial Investigation/Feasibility Study (RI/FS) and the Proposed
Plan for source control at the American Thermostat site concluded
on June 11, 1990.
U.S. Environmental Protection Agency (EPA) held a public
meeting on May 23, 1990 at 7:30 p.m. at the Town of Catskill
Offices, Catskill, New York. At the meeting, EPA provided a
general overview of the Superfund process, a site history of the
American Thermostat Site, the results of the RI/FS, and a
presentation of the Proposed Plan. At this public meeting, EPA
responded to the questions and comments of the interested
citizens present. A summary of the major questions and comments
received during the public meeting and EPA's responses to them
are contained within this Responsiveness Summary.

This Responsiveness Summary provides a summary of citizens'
comments and concerns receive 1 during the public comment period
and EPA's responses to those concerns. All comments summarized
in this document will be considered in EPA's final selection of
the remedial alternatives for cleanup of the site. This
Responsiveness Summary is organized into five sections. These
five sections are described briefly below:

I. SITE HISTORY AND REMEDIAL ALTERNATIVES OVERVIEW

This section briefly describes the background of the
American Thermostat Site and outlines the proposed
remedial alternatives for the site.

II. BACKGROUND ON COMMUNITY INVOLVEMENT AND CONCERNS

This section provides a brief history of community
interest and concerns regarding the American Thermostat
Site.

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

This section summarizes the oral comments presented to
EPA at the May 23, 1990 public meeting and provides
EPA's responses to these comments.
-------
IV. APPENDICES

There are three appendices attached to this document.
They are as follows:

Appendix A: Proposed Plan for the American
Thermostat Site

Appendix B: Sign-In Sheets from the Public
Meeting Held on May 23, 1990 at the
Town of Catskill Offices, Catskill,
New York; and,

Appendix C: A List of Information Repositories
that Contain Technical and
Informational Documents Pertaining to
the American Thermostat Site.

I. SITE HISTORY AND REMEDIAL ACTION OVERVIEW

From 1954 to 1985, the primary activity at the site, was the
assembly, by American Thermostat Corporation, of thermostats for
small appliances. During plant operations, a series of chemicals
were used within the manufacturing pro-ess to operate and clean
the plant machinery. These known chemicals are machine oils,
lubricants and organic solvents including trichloroethene (TCE)
and tetrachloroethene (PCE).

During the 1960s and 1970s, waste TCE and PCE sludges were poured
down the drains inside the building and dumped outside on the
plant grounds for dust control. The drains were connected to the
septic systems, which discharged directly to a tributary of
Catskill Creek.

In March 1981, two American Thermostat employees were observed
dumping solvents in the southwest corner of the plant property.
These observations were reported to the New York State Department
of Environmental Conservation (NYSDEC) which promptly began
investigations into the company's waste handling practices.

During April and May 1981, water samples were collected from
several privately owned wells in the vicinity of the American
Thermostat site by the New York State Department of Health
(NYSDOH). Analyses of these well water samples indicated the
presence of TCE and PCE. The analyses of five of the sampled
wells, those belonging to Rath (now Hook), Lais, Rivenburg,
Briggs, and J. Schmidt (formerly Nesensohn), indicated
concentrations of PCE in excess of the maximum contaminant level
of 0.05 mg/1 of organic chemicals as established by the NYSDOH.
TCE was detected in four of the five wells with only one sample
indicating a concentration in excess of the established maximum
contaminant level (0.05 mg/1). The affected residents were
-------
advised by the NYSDOH not to use their well water for cooking or
drinking purposes. Several law suits were filed by the plant's
neighbors in late 1981.

As a result of volatile organic contamination in several nearby
residential wells, the American Thermostat Corporation began
supplying bottled water to local residents in April 1982. By
November 1982, American Thermostat Corporation had installed
carbon filters on their own well and the affected wells. The
nearest neighbors, the Raths, were connected to American
Thermostat Corporation's well water supply system.

In February 1983, New York State entered into an interim Consent
Order with American Thermostat and Amro Realty Corporation
(property owner) in which the companies agreed to clean up the
site and its surroundings, to supply bottled water for cooking
and drinking purposes and to install, monitor, and maintain
carbon filter systems for the five affected homes listed above.
The order also stipulated that two groups of bordering private
wells had to be monitored to determine whether any contamination
had spread beyond the original affected area. American
Thermostat and Amro Realty Corporation did not fully comply with
the Consent Order and did not remedy the contamination at the
site, but only temporarily provided the affected residences with
clean water.

In May 1985, the American Thermostat Corporation ceased
operations at the American Thermostat site. At the request of
NYSDEC, the EPA began an immediate action response at the
American Thermostat site in June 1985. The action response was
designed to mitigate the threat to public health by providing the
affected residences with potable water supplies. Aspects of the
initial response included a sampling program to determine the
extent of contamination at the site and to evaluate the
effectiveness of the existing carbon filtration systems. In
addition, the plan included the installation of carbon filtration
systems at two additional residences and maintenance of an
existing filtration system.

In April 1986, NYSDEC requested that EPA assume responsibility
for the operation and maintenance of the carbon filters that had
been previously installed, and the installation and operation of
airlift stripping systems at two existing wells. The stripping
systems have treated, to date, over 7 million gallons of
contaminated groundwater. PCE concentrations have been reduced,
in the Rath well, from a high of 131,000 to 25,000 parts per
billion (ppb) and, in the American Thermostat well, from 3,200 to
400 ppb.

A Focused Feasibility Study (FFS) for Alternate Water Supply was
issued in November 1982 as the first operable unit for the
American Thermostat site. The purpose of the FFS was to develop,
-------
screen and evaluate various alternatives* for an alternative'
supply for the affected and potentially affected residences at
the American Thermostat site.

In January 1988, a Record of Decision (ROD) was signed, selecting
the extension of the Village of Catskill's water supply to the
affected and potentially affected residences.

Following the signing of the ROD, the Village of Catskill
questioned the ability of its water system to handle the
additional demand associated with adding the affected and
potentially affected residences to the system. In response, EPA
prepared a technical assessment of the Village of Catskill's
water supply system. The assessment, which was finalized in June
1988, indicated that the Village's water supply had sufficient
capacity to accommodate the demand associated with including the
affected and potentially affected residences. Further work on
the alternate water supply selected in the ROD was suspended
while negotiations between EPA and the Village of Catskill
continue. Several meetings, from February to May 1990, between
EPA, NYSDEC, NYSDOH, and the Town and the Village of Catskill
have resulted in the resolution of the major issues regarding the
alternate water supply. The Town of Catskill and the Village of
Catskill passed resolutions memorializing their decisions on the
alternate water supply on May 1 and May 8, 1990, respectively.
As a result, EPA has initiated the initial aspects of the design
of the alternate water supply.

In January 1988, EPA initiated a Remedial Investigation and
Feasibility Study (RI/FS) to determine the nature and extent of
the contamination at and emanating from the American Thermostat
site and to evaluate remedial alternatives. The findings of the
Remedial Investigations are summarized below.

• Soils at the American Thermostat site are contaminated
with volatile organics. The extent of soil
contamination is limited to the southwestern portion of
the site.

• Groundwater is contaminated with volatile organics both
in the unconsolidated (shallow) and in the bedrock
(deep) aquifers. The extent of the volatile organics
contamination for the shallow and deep aquifers is
estimated at approximately 26 acres and 53 acres,
respectively, in a general northwestern direction from
the site.

• Surface water is contaminated with volatile organics
on-site and in the adjacent Rath property.

• Building surfaces and sludges in drain pits within the
American Thermostat plant are contaminated with low
-------
levels of volatile organic, PCS, pesticide and metal
compounds.

The remedial objectives can be summarized as follows:

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

• Restore groundwater in the affected area to levels
consistent with state and federal water quality
standards; and,

• Decontaminate the American Thermostat building for
future use.

Based on the results of the RI/FS, the following preferred remedy
to address the contamination in the soil, groundwater and in the
building at the site is presented.

Alternative 8C-5t Excavation/Low Temperature Enhanced
Volatilization/On-Site Redeposition

This alternative would include the excavation and on-site
treatment, using low temperature enhanced volatilization, of
6,740 cubic yards of contaminated soil. The excavated soil would
be fed into a mobile thermal treatment unit brought to the site,
where hot air injected at a temperature above the boiling points
of the organic contaminants of concern would allow the moisture
and the organic contaminants to be volatilized into gases and
escape from the soil. The organic vapors extracted from the soil
would then be thermally treated in an afterburner operated to
ensure complete destruction of the volatile organics. The off-
gas would be treated in a scrubber for particulate removal and
acidic gas absorption. The disturbed areas would be revegetated.
Under this alctjrnativs, groundwater would bs extracted from both
the unconsolidated and bedrock aquifers and would be pumped
through an air stripper and carbon absorbers located at the site.
Contaminated groundwater would enter the air stripper which would
be designed to strip out the volatile organic compounds (VOCs).
The air and VOC mixture exiting the air stripper would then be
treated by a vapor phase carbon adsorption unit for the removal
of the stripped VOCs. The clean air would be emitted to the
atmosphere. The treated groundwater would be directed to a
reinjection system. Also, the spent carbon in the carbon
adsorption unit, would be removed for off-site regeneration or
incineration, thus destroying all organic contaminants.
Environmental monitoring would continue throughout the life of
-------
the treatment process.

Alternative BD-2t Building Decontamination/Waste Treatment and
Disposal

Under this alternative, hazardous dust would be removed using
dusting, vacuuming and wiping procedures for off-site
treatment/disposal. The waste oil drums would be removed for
off-site treatment/disposal.

Sludges would be removed and disposed of at an off-site
treatment/disposal facility.

Selection of an Alternative

EPA's preference for the three remedial alternatives above for
the American Thermostat site, is based on the requirements of the
Comprehensive Environmental Compensation and Liability Act
(CERCLA) and Superfund Amendments and Reauthorization Act (SARA)
regulations. These regulations require that a selected site
remedy be protective of human health and the environment, cost-
effective, and in accordance with other statutory requirements.
Current EPA policy also emphasizes the utilization of permanent
solutions incorporating on-site remediation of hazardous waste
contamination whenever possible. Final selection of a remedy
will be documented in the ROD only after consideration of all
comments received by the EPA during the public comment period.

II. BACKGROUND ON COMMUNITY INVOLVEMENT AND CONCERNS

The American Thermostat site emerged as a community issue when,
following NYSDEC and NYSDOH analysis of residential well water
samples in April and May 1981, residents were informed of the
presence of TCE and PCE in five wells. The affected residents
were advised by NYSDOH *?.-/t to use their water for cooking or
drinking purposes. It was at this point, in late 1981, that
several lawsuits were filed against American Thermostat by some
of the plant's residential neighbors.

In 1982, upon commencing the American Thermostat investigation,
the EPA implemented a community relations program to inform local
residents about the site and related remedial activities and to
obtain their input. Community concern has been at a relatively
high level since 1981.

As a result of the EPA's community relations activities, five
major community concerns were identified:

• Human health risks from exposure to contaminated
groundwater;
-------
• Maintenance of the carbon filtration systems installed
in residential water supply systems;

• Potential contamination in Catskill Creek;

• The economic impact of the American Thermostat Site
on residential property values; and

• A perceived lack of progress in getting the site
cleaned up.

III. SUMMARY OF MAJOR QUESTIONS AND COMMENTS RECEIVED DURING THE
PUBLIC COMMENT PERIOD AND EPA'S RESPONSES TO THESE COMMENTS

Comments raised during the public comment period on the source
control RI/FS and Proposed Plan for the American Thermostat site
are summarized below. The public comment period concluded on
June 11, 1990, The comments received are organized into five
(5) categories:

• Time frame for Cleanup Actions;

• Logistics of Waterline Connection;

• Health Risks;

• Future Use of American Thermostat site; and,

• Other Comments.

TIME FRAME FOR CLEANUP ACTIONS

Comment: A resident inquired into the present status of the
ongoing cleanup at the site. . : ;.-

EFA Response: In 1986, two air strippers, installed at the site
to begin the remediation of the groundwater contamination, have
decreased the contamination in those wells at the source. The
Rath well has gone from higher than 130,000 parts per billion
(ppb) to 24,000 ppb. The well at the American Thermostat site
itself has been reduced from 3,500 ppb to 400 ppb.

In December, 1989, EPA installed a new system of seven wells
along the property line between the Rath well and the American
Thermostat site. The purpose of these wells is to extract water
from another area of contamination and also to reinject into the
ground the water that has been extracted and has been treated by
the air strippers, so as to accelerate the removal and treatment
of contaminants leaching from the soil .into the groundwater.
-------
In addition, during the December 1989, veil installation, a
system was installed that extracts vapors from the soil and
treats them to reduce vapor contamination.

Commentt A resident asked for an estimated timeframe for the
total cleanup of the site.

EPA Response: EPA anticipates signing the ROD, after considering
all comments received, by the end of June. Following the signing
of the ROD, EPA must notify the Potentially Responsible Party
(ies) (PRPs) - the parties(s) potentially responsible for the
contamination - to notify them about EPA's decision and to ask
them for a good faith offer to take financial responsibility for
the cleanup activities. If EPA does not receive a good faith
offer from the PRP, then EPA will fund the design of the chosen
remediation. It is anticipated that the design phase will take
approximately one year. Once the system is designed, EPA intends
to fund the construction phase. EPA stated that there are two
basic cleanup targets - the soil and the groundwater. The soil
is much easier to deal with than the groundwater. From the point
in time that EPA begins the treatment of the soil, EPA believes
that the soil will be cleaned up within a year.

With respect to the groundwater, the situation is considerably
more complicated, due to the subsurface geology present at the
site. The geological structure beneath the site and the
surrounding area is fractured bedrock. It is so named because
the subsurface rock has hundreds of thousands of cracks in it.
This presents enormous difficulties in developing scientific
models to determine a cleanup design.

Given the geology of the site, it is difficult to predict the
duration of the groundwater cleanup. Continued monitoring will
provide EPA the opportunity to develop estimates as the activity
progresses.

Comment: A resident asked when the £ner:N-an Thermostat building
itself would be decontaminated.

EPA Response: Building decontamination will be one of the first
remedial activities undertaken, following the signing of the ROD
and remedial design. It is estimated that the time required to
plan and implement the decontamination of the building will be,
approximately, one year.

LOGISTICS OP WATERLINE CONNECTION

Comment: A resident whose well was not contaminated, but who is
"potentially affected", asked if he would have to bear the futurj
cost of water line connection if he refused connection now, but

8
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later experienced well contamination.
9
EPA Response: Residents within the proposed district that refuse ,
to connect to the water line would be assuming the potential risk
of bearing the cost of establishing a water line connection at a
later date, should the well become contaminated and the contract
for hook-ups, at that time, is no longer in place. In addition, a
representative from the New York State Department of Health
(NYSDOH) indicated that if the water line connection was refused,
NYSDOH's monitoring would also cease. NYSDOH has been monitoring
the well two times a year, at a cost of approximately $200 per
test.

Comment: A resident asked if the wells of houses not presently
in the zone of contamination later become contaminated, would
they receive no charge water line connection.

EPA Response: Currently, EPA believes that wells not presently
contaminated will remain safe. However, if new wells, outside
the proposed district, did become contaminated, EPA would then
have to negotiate with the Village of Catskill to extend the
water line connection to those homes. This is the same
negotiation process EPA entered into to extend the original water
line connection to the affected wells. Those negotiations will
result in the creation of a water district for approximately 43
homes between Puffer Road and the borderline of the Town of Cairo
and the Town of Catskill. During the negotiations, EPA discussed
the remote possibility of contamination migration. It was
decided then that, if it became necessary, EPA would renegotiate
the terms for enlarging the newly created water district.

Comment: A resident asked if his road will get fire hydrants,
along with the installation of the water line.

EPA Response: EPA has examined the possibility of fire hydrants
and is willing to take this matter into further consideration.

Comment: A resident stated that he thought the system is unfair.
He complained that after bearing the expense of digging and
maintaining his own well, he should not have to pay for water
(following the water line connection).

EPA Response: EPA, sharing the citizens7 concerns about the cost
of their water bills following connection to the water line, made
a concerted effort, during negotiations with the owner of the
water supply system, to ensure that the cost to the citizens
remains at a minimum. In addition, EPA will look into a
suggestion by a citizen that the provision of fire protection
will result in a financial benefit to the residents, stemming
from reduced fire insurance rates. This savings, if achievable,
may counteract the cost of water usage.
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PEM.TH RISKS
• i\
Comment: A resident asked about the status of the drums that are
stored at the American Thermostat site inside the building. The
resident stated that some of the drums appeared to be bulging.
The resident also said that some of the drums contained spent
carbon from the presently operating carbon adsorption filter.
She expressed concern that the carbon night corrode the drums and
leak out.

EPA Response: The drums that appear to be bulging are designed
with a convex cover to maximize the drum capacity. These drums
were recently inspected and are in safe condition. The drums
containing carbon on-site are of a plastic material and contain
fresh carbon, not spent carbon. However, even if these plastic
containers held spent carbon, they would maintain their
integrity. .

Comment: A resident asked if there was lead contamination in the
well water.

EPA Response: Well water sampling conducted by NYSDOH has found
no evidence of lead contamination. The issue of lead
contamination arose earlier because of inaccurate readings by
EPA's contractor due to the suspension of fine particles in the
water samples taken from the bottoms of the wells. NYSDOH takes
its water sample from the water taps within the affected homes
ant? these NYSDOH tests have shown no evidence of lead
contamination. Additionally, repeated sampling of groundwater '
failed to show any lead. NYSDOH results at the affected wells is
further verified by water samples taken at all nearby
restaurants, hotels and motels.

Comment: A resident inquired into the level of security that
will be in place at the American Thermostat site once the
remediation activity accelerates.

EPA Response: The area of soil contamination will be fenced
during the remedial action. In addition, a security guard will
be hired to guard the site.

FUTURE USE OP THE AMERICAN THERMOSTAT SITE

Comment: A resident asked if the American Thermostat building
could be occupied and used before the soil and groundwater are
completely remediated.

EPA Response: The building would not be able to be used prior to
the completion of the remediation of the soil. However, there is
the possibility that, prior to a complete remediation of the
groundwater contamination, the facility could be utilized for a

10
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commercial purpose. However, the new owner or operator would
have to tolerate the presence of a continually operating water
treatment unit. EPA understands the importance that this
facility has played in local economics in the past and will
explore the possibility of releasing portions of the site for use
prior to total site remediation.

Comment: A resident asked what purposes the water could be used
for in the future at the American Thermostat site.

rrA Response: No entity may make use of the water in its
existing state. However, if an entity processed and treated
their own water, they may use it for whatever otherwise purposes
they see fit.

Comment: A resident asked that, since the American Thermostat
site is in arrears for nonpayment of property taxes, will it be
auctioned off.

EPA Response: According to the CERCLA, ownership of a Superfund
site makes the owner a PRP. Therefore, if someone purchased the
property at an auction, they could become potentially liable for
the cleanup.

OTHER COMMENTS

Comment: A resident asked what was the total estimated cost of
the American Thermostat site cleanup.

EPA Response: EPA responded that the total cost for the cleanup
of the building, the soil, and the groundwater was $26,000,000.
Most of this amount would be required for the groundwater
cleanup. This figure does not include the cost of the remedial
actions that have taken place thus far or the cost of installing
the water line, which is estimated to be $4,000,000.
11
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APPENDIX A

PROPOSED REMEDIAL ACTION PLAN FOR AMERICAN THERMOSTAT SITE

SOUTH CAIRO, NEW YORK
-------
PROPOSED PL&M
FOR
AXERXCAV THERMO8TXT BITE
SOUTH CAIRO, HEW YORK
PREPARED BY

U.S. raVXROKKZNTAL PROTSCTXOH XQEHCY

KAY IttO
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INTRODUCTION

This Proposed Plan describes the remedial alternatives considered
for the American Thermostat (AT) site and identifies the U.S.
Environmental Protection Agency's (EPA's) and the New York State
Department of Environmental Conservation's (NYSDEC's) preferred
remedial alternative and the rationale for this preference.

SITE LOCATION

The AT site covers approximately 8 acres within a rural residential
area in the Town of South Cairo, Greene County, New York. The area
is bounded on the northeast and southwest by Routes 23B and 23,
respectively (See Figure 1). Private homes are hear the eastern
and western boundaries. Water in the area is supplied by private
wells.

SITE HISTORY

From 1954 to 1985, the primary activity at the site was the
assembly of thermostats for small appliances. In the plant
operations, a series of chemicals including machine oils,
lubricants and organic solvents such as tetrachloroethene (PCE) and
trichloroethene (TCE) were used within the manufacturing process
to operate and clean the plant machinery. During the 1960s and
1970s, waste PCE and TCE sludges were poured down drains inside the
building septic systems and dumped outside on the plant ground for
dust control. In March 1981, two AT employees were observed
dumping solvents on plant property. This led to investigations
into the company's waste handling practices by NYSDEC and the New
York State Attorney General's Office.
•
During April and May 1981, water samples were collected from
several residential wells in the vicinity of the AT site by the New
York State Department of Health (NYSDOH) and NYSDEC. Analysis of
the water samples indicated the presence of TCE and PCE in five
wells. The affected residents were advised by NYSDOH not to use
their water for cooking or drinking purposes. Several law suits
were filed by the plant's neighbors in late 1981.

In February 1983, New York State entered into an interim consent
order with AT and Amro Realty Corporation (property owner) in which
the companies agreed to clean up the site and its surroundings, to
supply bottled water to the five affected residences for cooking
and drinking purposes and to install, monitor, and maintain carbon
filter systems for these residences. The order also stipulated |
-------
that two groups of bordering private wells had to be monitored to
determine whether any contamination had spread beyond the original
affected area.

In May 1985, AT ceased operations. Since June 1985, EPA has been
sampling wells in the area and has been maintaining the previously
installed carbon filtration units. In addition, EPA installed two
new carbons units on contaminated private wells and installed air
stripping systems on two highly contaminated wells.

In April 1986, NYSDEC requested that EPA assume responsibility for
the operation and maintenance costs of the carbon filters that had
been previously installed, and the installation and operation of
airlift stripping systems at two existing wells. The stripping
systems have treated to date over 7 millions gallons of contami-
nated groundwater. PCE concentrations have been reduced, in the
Rath well, from a high of 131,000 to 25,000 parts per billion (ppb)
and, in the AT well, from 3,200 to 400 ppb.

A Focused Feasibility Study (FFS) for Alternate Water Supply was
issued in November 1987 as the first operable unit for the AT site.
The purpose of the FFS was to develop, screen and evaluate various
alternatives for an alternative water supply system for the
affected area and potentially affected residence... at the AT site.

In January 1988, a Record of Decision (ROD) was signed, selecting
the extension of the Village of Catskill's water supply to the
affected and potentially affected residences.

Following the signing of the ROD, the Village of Catskill
questioned the ability of its water system to handle the additional
demand associated with adding the affected and potentially affected
residences to the system. In response, EPA prepared a technical
assessment of the Village of Catskill's water supply system. The
assessment, which was finalized in June 1988, indicated that the
Village's water supply had sufficient capacity to accommodate the
demand associated with including the affected and potentially
affected residences. Further work on the alternate water supply
selected in the ROD was suspended while negotiations between EPA
and the Village of Catskill continue. Recent meetings, from
February to May 1990, between EPA, NYSDEC, NYSDOH, and the Town and
the Village of Catskill have resulted in the resolution of the
major issues regarding the alternate water supply. As a result,
EPA intends to initiate the design of the alternate water supply
this summer.

In January 1988, EPA initiated a remedial investigation and
feasibility study (RI/FS) to determine the nature and extent of
the contamination at and emanating from the AT site and to evaluate
remedial alternatives.
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Volatile organic contamination (mainly PCE and TCE) in the soil is
concentrated at only one location in the southwest corner of the
site including the old leaching field area. High contaminant
levels are detected at the surface to about 7 feet below ground
surface. The extent of contaminated soils in this -area is
estimated at approximately 26,000 square feet at a depth of 7 feet,
or approximately 6,740 cubic yards, based on PCE concentration
exceeding 1.0 milligram/Kilogram (mg/kg).

Groundwater was found to be contaminated with volatile organics
from the site. The volatile organic contamination within the
bedrock aquifer is significant with respect to federal and state
maximum contaminant levels (MCLs). The volatile organic
••"ortamination plume extends approximately 53 acres from the AT
site, in a general north-westerly direction as shown in Figure l
(developed on the basis of a PCE concentration exceeding 5
micrograms/liter (ug/1) (MCL)). The volume of the volatile organic
contamination in the bedrock aquifer is approximated at 1.3 x 10
gallons. The maximum detected bedrock PCE concentration of 31,000
ug/1 was found in the Rath's Well, R-14.

In the case of the shallow groundwater aquifer above the bedrock,
the contamination plume extends approximately 26 acres throughout
the project site in a general northwesterly direction. Within the
contamination plume, the entire unconsolidated aquifer, of an
average 50 feet in depth, is contaminated with PCE exceeding 5
ug/1. The volume of the contamination in the unconsolidated
aquifer is estimated at 2.9 x 106 gallons.

The natural drainage area south of the AT plant, the leach field
overflow pipe, the surface water upstream of Tributary A and the
Rath Pond are contaminated with volatile organic compounds (PCE,
TCE and 1,2-dichloroethene). Volatile organic contamination was
not detected in Catskill Creek or in springs flowing from the
surface downgradient from the site.

The building floor surface and the drain pit sludge are
contaminated with low levels of TCE, PCE and 1,2-dichloroethene,
base/neutral extractables (Polyaromatic hydrocarbons), pesticides,
polychoriuated biphenyls (PCBs) and toxic metals (arsenic,
chromium, lead and mercury).

A total of eighteen 55-gallon drums containing waste oil generated
from the AT operations are currently stored within the AT plant.
The materials contained within these drums are not considered
hazardous based on the New York State Identification and Listing
of Hazardous Wastes.

The baseline public health evaluation in the RI report evaluated
11 exposure pathways to define cumulative risks from carcinogenic
and noncarcinogenic chemicals detected during the AT field
investigation. Six risk evaluation scenarios assumed current-uses,
-------
including: 1) ingestion of treated residential well water; 2)
ingestion of untreated residential groundwater; 3) inhalation of
volatilized organics while showering (treated and untreated
groundwater); 4) direct contact with on-site soils (assuming young
adult receptors); 5) inhalation of volatilized organics from on-
site surface soils (children) and 6) direct contact with on-site
and off-site surface water and sediments. Five scenarios were
evaluated for future risks, assuming industrial development of the
*.T site. These included: 1) ingestion of on-site groundwater; 2)
ingestion of off-site groundwater; 3) inhalation of volatilized
organics while showering (on-site and off-site groundwater); 4)
direct contact with on-site soils (assuming adult worker recep-
tors) ; and 5) inhalation of volatilized organics from on-site
surface soils (adults). Potential risks associated with future
surface water and sediment exposures were assumed to be the same
as for current use.

The current-use risks associated with ingestion of treated
residential well water are within EPA's range of acceptable
risks. That range is 10"4 to 10"6. ' However, risks associated
with exposures to untreated residential well water are in the
higher limit of that range, indicating the need to maintain
existing treatment measures. In general, both worst-case and most
probable exposure assumptions for current-use exposures to soils,
sediments and surface water indicate risks which are within the EPA
range of acceptable risk.

Future-use risks calculated for exposures to contaminated ground-
water under and adjacent to the AT site indicated risks which
exceed EPA guidelines for groundwater ingestion. Future (indus-
trial use) carcinogenic and noncarcinogenic risks, are within the
USEPA range of acceptable risk. However, the upper bound carcino-
genic risk (1.5 x 10"4) for soil contact/ingest ion is at the higher
limit of this range, indicating the need for "hot-spot" treatment
of on-site soils co reduce potential contaminant exposures.

PURPOSE OF THE PROPOSED PLAN

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.
Excesslifetime cancer risks are probabilities that are
generally expressed in scientific notation (e.g., IxlO"6) . An
excess lifetime cancer risk of IxlO"6 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.
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Changes to the preferred alternative or a change from the pre-
ferred alternative to another alternative may be made if public
comments or additional data indicates that such a change will
result in a more appropriate solution. The final decision re-
garding the selected remedy will be made after EPA has taken into
consideration all comments from both NYSDEC and the public. We are
soliciting public comment on all of the alternatives considered in
the detailed analysis phase of the RI/FS because EPA and NYSDEC may
select a remedy other than the preferred 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/FS
report. The Proposed Plan, highlights key information from the
RI/FS report but it is not a substitute for that report. Copies
of the RI/FS report and supporting documentation are available at
the NYSDEC Albany office, the EPA Region II office, the Town of
Catskill offices, the Cairo Town Hall, and the Village of Catskill
offices. Addresses for these repositories are listed below:
Town of Catskill Offices
439 Main Street
Catskill, N.Y. 12414

Village of Catskill Offices
422 Main Street
Catskill, N.Y. 12414
Cairo Town Hall
Main Street
Cairo, N.Y. 12413

New York State Department of
Environmental Conservation
50 Wolf Road
Albany, N.Y. 12233
-U.S. Environmental Protection Agency
Emergency and Remedial Response
26 Federal Plaza, Room 29-102
New York, N.Y. 10278
SUMMARY OF REMEDIAL ALTERNATIVES

The Comprehensive Environmental Response, Compensation and
Liability Act (CERCIJV}., roramonly known as Superfund, requires that
each selected site remedy be protective of human health and the
environment, comply with other statutory laws, be cost effective,
and utilize permanent solutions and alternative treatment tech-
nologies and resource recovery alternatives to the maximum extent
practicable. In addition, treatment as a principal element for
reduction of toxicity, mobility, or volume of the hazardous
substances, is preferred.

The findings of the RI are summarized as follows:

Soils at the AT site are contaminated with volatile organics.
The extent of soil contamination is limited to the southwestern
portion of the site.
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Groundwater is contaminated with volatile organics both in the
unconsolidated (shallow) and in the bedrock (deep) aquifers. The
extent of the volatile organics contamination for the shallow and
deep aquifers is estimated at approximately 26 acres and 53 acres,
respectively, in a general northwestern direction from the site.

- Surface water is contaminated with volatile organics on-site
and in the adjacent Rath property.

- Building surfaces and sludges in drain pits within the AT plant
are contaminated with low levels of volatile organic, PCB,
•*• icj.de and metal compounds.

The remedial response objectives can be summarized as follows:

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

- Restore groundwater in the affected area to levels consistent
with state and federal water quality standards; and

Decontaminate the AT building for future use.

Accordingly, the FS evaluates, in detail, four alternatives for
addressing the contaminated soils that contribute to groundwater
contamination at the AT site. A fifth alternative, Alternative SC-
2, capping of the contaminated soil, was preliminarily evaluated
in the FS and was eliminated from further consideration as it was
determined that it would not prevent the migration of the volatile
organics to the groundwater and to the air. In addition, five
remedial alternatives for addressing the contamination in the
groundwater were evaluated. A sixth alternative, Alternative GW-
5, treatment of the groundwater via activated carbon adsorption,
was preliminarily evaluated in the FS and was. eliminated from
further consideration since it was determined that it would be less
effective in removing the groundwater contaminants and more costly
than the combined air stripping/carbon adsorption alternatives.
Finally, two alternatives are evaluated for the decontamination of
the AT building.

These alternatives are:

SOIL ALTERNATIVES

Alternative SC-lt Ko Action

Remedial action would not be taken, other than long-term monitor-
ing. This alternative is used as the baseline for comparison of
other alternatives.
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Alternative SC-3; Excavation/On-Site Incineration/On-Site
Redeposition

This alternative would include the excavation and on-site treatment
by incineration of 6,740 cubic yards of contaminated soil. The
soil would be used as backfill and the disturbed areas would be
regraded and revegetated.

Alternative SC-4; Excavation/Off-site Incineration/Backfill
With Clean Soil

This alternative would include the excavation and off-site thermal
treatment of 6,740 cubic yards of contaminated soil. The exca-
vated material would be placed in dump trailers or drummed, covered
and transported to a licensed thermal treatment facility. The
facility would be responsible for disposing the treated soil. The
excavated area would be backfilled with clean fill, regraded, and
revegetated.

Alternative SC-5; Excavation/Lov Temperature Enhanced
Volatilization/On-Site Redeposition

GROUNDWATER ALTERNATIVES

All groundwater alternatives, with the exception of Alternative GW-
1, assume that the operation and maintenance of the existing
individual treatment systems (5 carbon filters and 2 air strippers)
will continue until either the implementation of the alternate
water supply selected in the 1988 ROD, or the cleanup of the
aquifer by means of a particular groundwater alternate.
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8

Alternative GW-1: Ko Further Action

The No-Further Action Alternative was not considered to be
protective of human health and the environment and it was not
evaluated as a viable alternative for implementation. This
alternative was used only as a baseline for comparison to the
remaining alternatives being analyzed.

Under this alternative, the existing individual treatment systems
operated and maintained by EPA would be terminated. This
alternative would consist of restricting the use of contaminated
groundwater by deed restrictions and other institutional controls.
A long-term monitoring program and distribution of fact sheets that
would explain the monitoring results and would include warnings and
recommendations for water usage would be established.

Alternative GW-2; Limited Action

This alternative would consist of the continuous operation and
maintenance of the existing individual treatment systems and the
installation of approximately 25 new carbon filters for the
residences potentially affected within the next 30 years. A long-
term monitoring program would be established.

Alternative GW-3; Pumpinq/Pretreatment/Air Stripping/
Reinfection

Groundwater would be extracted from both the unconsolidated and
bedrock aquifers and would be pumped through a series of air
strippers (2 air strippers). The treated water would be reinjected
into the ground.

Environmental monitoring would be required during the life of the
treatment process. In addition, monitoring of the groundwater at
the site would be conducted for a period of 3 years after
completion of the remediation, to ensure that the goals of the
remedial action have been met.

Alternative GW-4; Pmnpinfr/Pretreatment/Air Stripping/
Carbon Adsorption/Reinfection

Groundwater would be extracted from both the unconsolidated and
bedrock aquifers and would be pumped through an air stripper and
carbon absorbers located at the site. Contaminated groundwater
would enter the air stripper which would be designed to strip out
the volatile organic contaminants (VOCs). The air and VOC mixture
exiting the air stripper would then be treated by a vapor phase
carbon adsorption unit for the removal of the stripped VOCs. The
clean air would be emitted to the atmosphere. The treated
groundwater would be directed to a reinjection system. Also, the
spent carbon in the carbon adsorption unit, would be removed for
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off-site regeneration or incineration, thus destroying all organic
contaminants.

Environmental monitoring would be required during the life of the
treatment process. Groundwater monitoring would be the same as in
Alternative GW-3.

Reinfection

Groundwater would be extracted from both the unconsolidated and
bedrock aquifers and would be treated using UV light and an oxidant
such as hydrogen peroxide. The treated water would be reinjected
into the ground. Monitoring would be the same as in Alternative
GW-3.

All alternatives described above would include pre-construction,
construction, and post-construction air monitoring.

BUILDING DECONTAMINATION ALTERNATIVES

Alternative BD-1; No Action

Remedial action would not be taken other than a long-term building
security and maintenance program. Fact sheets would be distributed
in order to increase public awareness.

Alternative BD-2; Building Decontamination/Waste Treatment and
Disposal

Hazardous dust would be removed using dusting, vacuuming and wiping
procedures, for off-site treatment/disposal. The waste oil drums
would be removed for off-site treatment/disposal.

Sludges would be removed and disposed of at an off-site treatment/
disposal facility.

PREFERRED ALTERNATIVE

Based upon an evaluation of the various alternatives, EPA and
NYSDEC recommend Alternative SC-5, Low Temperature Enhanced
Volatilization, for treatment of the contaminated soil, Alternative
GW-4, Air Stripping and Carbon Adsorption, for treatment of the
groundwater, and Alternative BD-2, Decontamination of the AT
Building, to remediate the contamination at the AT site.

RATIONALE FOR SELECTION

During the detailed evaluation of remedial alternatives, each
alternative is assessed against nine evaluation criteria, namely
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10

overall protection of human health and the environment, compliance
with Applicable or Relevant and Appropriate Requirements (ARARs),
long-term effectiveness and permanence, reduction of toxicity,
mobility or volume (including the statutory preference for
treatment) , short-term effectiveness, implementability, cost, state
acceptance and community acceptance.

Each criterion will be briefly addressed, in order, with respect
to the preferred alternatives for soil, groundwater and building
decontamination alternatives.
GLOSSARY OF EVALUATION CRITERIA

- Overall protection of human
health and the environment
addresses whether or not a
remedy provides adequate
protection and describes how
risks posed through each path-
way are eliminated, reduced or
controlled ^hrough treatment
engineering controls or
institutional controls.

Compliance with ARARs
addresses whether or not a
remedy will meet all of the
applicable or relevant and
appropriate requirements of
other Federal and State
environmental statutes and/or
provide grounds for invoking
a waiver.

- Long-term effectiveness and
permanence refers to the mag-
nitude of residual risk and
maintain reliable protection
of human health and the envi-
ronment over time once clean-
up goals have been met.

- Reduction of toxicity,
mobility, or volume through
treatment is the anticipated
performance the treatment
technologies that may be
employed in a remedy.
- Short-term effectiveness
the remedy achieves protection,
as well as the remedy's
potential to create adverse
impacts on human health and the
environment that may result
during the construction and
implementation period.

- Implementability is the
technical and administrative
feasibility of a remedy.

- Cost includes capital and
operation and maintenance costs.

- State acceptance indicates
whether, based on its review of
the RI/FS and Proposed Plan, the
State concurs with, opposes, or
has no comment on the preferred
alternative.

- Community acceptance will be
assessed in the ROD following
a review of the public comments
received on the RI/FS report and
the Proposed Plan. .
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11
verall Protect
The preferred alternative, Alternative SC-5, treatment of soils to
remove the volatile organic contaminants, will result in the
elimination of a long-term source of groundwater contamination and
will mitigate the risks to public health and the environment
associated with the presence of those contaminants in the soil on-
site and with their migration. The preferred alternative would
effectively mitigate those risks by removing the most mobile wastes
from the soil leaving the treated soil to be landfilled on-site.

Alternatives SC-3 and SC-4 also would mitigate the risks to public
health and the environment associated with the leaching of
contaminants into the groundwater and their migration off-site.
Under Alternative SC-1, contaminants would continue to leach from
the soil into the groundwater and continued off-site migration of
contaminants would occur. Monitoring would be implemented to
observe contaminant migration, but an indeterminate amount of time
would elapse between detection and the implementation of mitigating
measures.

B. Compliance with ARARs

All technologies proposed for use in Alternatives SC-3 through
SC-5 would be designed and implemented to satisfy all action-
specific regulations including all air emission standards. No
federal or New York State regulations specify cleanup levels for
contaminants in the soil. In terms of achieving target levels for
soils for the purpose of removing potential sources of groundwater
contamination, the preferred alternative, Alternative SC-5, along
with Alternatives SC-3 and SC-4, would be quite effective.

C. Long-Term Effectiveness and Permanence

The preferred alternative, Alternative SC-5, would effectively
treat the volatile organic compounds on-site soil, thus reducing
the hazards posed by in the contaminated soils and permanently
removing the source of groundwater and surface water contamination.
Alternatives SC-3 and SC-4 also would provide a high degree of
effectiveness, since the contaminated soil would be treated or
removed from the site. In contrast, under Alternative SC-1, the
contaminants would be left untreated in the soil and a long-term
monitoring program would be implemented to determine if the
contamination was migrating from the site.
The preferred alternative, Alternative SC-5, and Alternatives SC-
3 and SC-4, would result in comparable reductions in the toxicity,
mobility or volume of the treated material.
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12

Alternative SC-1 would provide no reduction in toxicity, mobility
or volume.

E. Short-Term Effectiveness

All alternatives, with the exception of the no-action alternative,
include activities such as contaminated soil excavation and
transport that could result in potential exposure of residents to
volatilized contaminants and contaminated dust. However, mitiga-
tive measures to reduce the probability of exposure would be
ir.pleraented. In addition to excavation, Alternative SC-4 includes
off-site transport of contaminated soils.

Ai the preferred alternative, Alternative SC-5, and Alternative
SC-3 provide treatment on-site, thereby reducing potential risks
to residents along transportation routes. Furthermore, the
preferred alternative, Alternative SC-5, will not result in the
generation of significant quantities of treatment byproducts (stack
emissions, particulates) that would be generated by Alternative SC-
3.

Alternatives SC-3, SC-4 and SC-5 might result in worker exposure
to volatilized contaminants and dermal contact with contaminated
soils during waste excavation and handling. In addition, Alter-
natives SC-3 and SC-5 might result in additional low-level emis-
sions exposure from the on-site treatment unit. The threat to on-
site workers, however, would be mitigated through the use of pro-
tective equipment by the on-site workers and control of emissions
would be accomplished by emissions treatment. Additionally,
scrubber wastewater produced by Alternatives SC-4 and SC-5 will be
treated on-site or transported off-site for treatment and disposal.

Alternatives SC-3, SC-4 and SC-5 could be implemented in about 3,
2.5 and 2 years, respectively, with actual remediation times of 15,
12 and 9 months, respectively.

F. Implementability

All of the alternatives would utilize relatively common
construction equipment and materials. Little construction
difficulty would be encountered with any of the alternatives.

The technologies proposed for use in the alternatives are proven
and reliable in achieving the specified process efficiencies and
performance goals. Low temperature thermal extraction, the
preferred alternative, has been successfully pilot tested and has
performed on a full-scale basis with similar organic contaminants.

G. Cost

The present-worth cost of the preferred alternative, Alternative
SC-5, is $2,772,400. The lowest cost alternative is Alternative
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13

SC-1 at $736,800. The highest cost alternative is Alternative SC-
4 at $17,918,700. Alternative SC-3 has a present worth-cost of
$8,322,800.

The incremental removal of organic contaminants through
incineration (Alternatives SC-3 and SC-4) above the removal that
would be achieved by the preferred alternative, Alternative SC-5,
are minimal compared to the difference in costs between the.
incineration options and the preferred alternative.

Table 1 lists all of the costs for the five soil alternatives for
comparison purposes.

GROPNDWATER

A. Overall Protection of Human Health and the Environment

The preferred alternative, Alternative GW-4, would provide the
highest protection to human health and the environment among the
three treatment alternatives; it would remove and treat the organic
contaminants found in groundwater and would prevent their migration
cii-site. The higher degree of protection associated with Alterna-
tive GW-4 in comparison to Alternative GW-6 is due to the higher
certainty for contaminant treatment associated with the air ,
stripping and carbon adsorption technologies versus the
UV/oxidation treatment technology of Alternative GW-6.
i

In comparison to Alternative GW-3, Alternative GW-4 offers a higher
degree of protection as a result of the additional carbon
adsorption treatment of the contaminated groundwater following air
stripping.

The limited action alternative would provide protection of the
health of the affected residents. However, it would not ensure
protection of the health of future users of the aquifers and would
not prevent continued migration of contamination.

B. Compliance with ARARs

The preferred alternative, Alternative GW-4, as well as Alternative
GW-3, would achieve federal and state groundwater quality standards
for the organic contaminants by providing the required contaminant
removal during the treatment stage utilizing air stripping and
carbon adsorption.

The ability of Alternative GW-6 to achieve the groundwater quality
standards for the organic contaminants is of a lower certainty than
the preferred alternative's because of limited experience with the
XJV/oxidation treatment process.

Alternative GW-i would not comply with state or federal drinking
water standards or criteria or those ARARs required for protection
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14

of the groundwater' resources. Alternative GW-2 would achieve
chemical-specific ARARs for drinking water, but would not achieve
any groundwater quality standards.

C. LopQ-Term Effectiveness and Permanence

The preferred alternative, Alternative GW-4, and Alternatives
GW-3 and GW-6 would effectively reduce the potential risks
associated with the migration of contaminants into the groundwater

by extracting the contaminated groundwater, treating it to remove
contaminants and returning the treated water to the aquifer.

Alternative GW-1 does not provide treatment but will restrict
usage of contaminated groundwater. Alternative GW-2 provides
a safe permanent water supply to the affected residents but will
not restore the contaminated aquifer for future use.

D. Reduction ia Toxicity. Mobility and Volume

The preferred alternative, Alternative GW-4, and Alternatives
GW-3 and GW-6 would effectively reduce the toxicity, mobility,
and volume of the organic contaminants in the groundwater.
Alternative GW-4 would provide the greatest reduction in toxicity
of all alternatives under consideration. Alternative GW-2 would
reduce the toxicity, mobility and volume for the individual water
supplies of the affected residents. Alternati\e GW-1 would not
reduce the toxicity, mobility and volume of contaminants.

E. Short-Term Effectiveness

The preferred alternative, Alternative GW-4, and Alternatives
GW-3 and GW-6 include activities that could result in potential
exposure of residents and workers to volatilized contaminants
during the installation of the groundwater extraction and
reinjection systems. However, mitigative measures to reduce the
probability of exposure would be implemented.

The implementation of Alternatives GW-1 and GW-2 would result in
no additional risk to the community during implementation.

The preferred alternative, Alternative GW-4, and Alternatives GW-
3 and GW-6 would require a 30 year remediation time. EPA projects
that it would take Alternative GW-2 well in excess of 30 years and
Alternative GW-1 more than a thousand years to achieve the cleanup
levels.

F. Implementability

All components (extraction, treatment and reinjection) of the
preferred alternative, Alternative GW-4, as well as of Alternative
GW-3 utilize relatively common construction equipment and materials
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15
and could be easily implemented. In addition, the air stripping
and carbon adsorption technologies that comprise the treatment are
proven and reliable in achieving the specified performance goals
and are readily available.

In contrast, the treatment technology for Alternative GW-6 (UV/
oxidation) , although successful in pilot runs, has had limited full
scale use to date. Therefore, site-specific pilot scale studies
would be required to confirm its adequacy for the American
Thermostat site. In addition, UV/oxidation is currently available
only two sources nationwide.
All components of Alternatives GW-1 and GW-2 would be easily
implemented.

G. Cost

The present worth cost of the preferred alternative, Alternative
GW-4, is $23,044,900. The lowest cost alternative is Alternative
GW-1 at $757,000. The present worth cost for GW-2 is $8,911,300.
For Alternatives GW-3 and GW-6 the present worth cost is
$18,821,900 and $21,845,200 respectively.

Table I lists all of the costs for the six groundwater alternatives
for comparison purposes.

BUILDING DECONTAMINATION

A. Overall Protection of Human Health and the Environment

Under the preferred alternative, Alternative BD-2, all hazardous
materials would be removed from the building. Therefore, the
preferred alternative would be fully protective of public health
and the environment.

Under Alternative BD-1, hazardous materials would be left in the
building. Human health and the environment would remain protected
as long as building security could be effectively enforced and
building integrity maintained.

B. Compliance vith ARARs

Alternative BD-2 would comply with the relevant action-specific
ARARs. No chemical-specific ARARs exist for building contami-
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16

nation. By definition, no action-specific ARARs apply to the "no-
action" alternative.

C. Long-term Effectiveness and Permanence

The preferred alternative, Alternative BD-2, would remove all
hazardous materials from the building for either off-site disposal
or on-site treatment and disposal so that long-term exposure risks
from the building are eliminated. Alternative BD-1 would only
maintain the building in its present condition so that hazardous
materials would remain in the building. Public protection would
rely on maintaining building security.

D. Reduction in Toxieitv. Mobility and Volume

Alternative BD-1 provides no reduction in toxicity, mobility or
volume of the contaminants. Alternative BD-2 provides for complete
reduction in toxicity, mobility and volume since all contaminated
material would be removed from the building.

E. Short-term Effectiveness

Since the preferred alternative, Alternative BD-2, involves removal
and transport of the contaminants from the building, there are some
public exposure risks as well as environmental impacts from
potential waste spills resulting from a possible transport accident
during remedial activities. Implementation of Alternative BD-1
should result in no additional risks to the community or the
environment as long as building security and integrity can be
maintained.

F. Implementability

G. Cost

The present worth costs for Alternatives BD-1 and BD-2 are $4,600
and $284,900 respectively (see table 1).

State Acceptance

NYSDEC concurs with the preferred soil, groundwater and building
decontamination alternatives.
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17

Community Acceptance

Community acceptance of the preferred alternatives will be assessed
in the ROD following a review of the public comments received on
the RI/FS report and the Proposed Plan.

CONCLUSION

EPA believes that the preferred alternatives described above are
fully protective of human health and the environment, meet all the
ARARs, offer the best balance among the evaluation criteria
discussed above and satisfy the statutory preference for treatment
as a principal element in remedy selection.

COMMUNITY ROLE IN 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 June 11, 1990. 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.
Public meeting will be held during the comment period at the Town
of Catskill Offices, Catskill, New York on May 23, 1990 at 7:30
p.m., to allow EPA to present the conclusions of the RI/FS, to
further elaborate on the reasons for recommending the preferred
remedy and to receive public comments. Written and verbal comments
will be documented in the Responsiveness Summary section of the
subsequent ROD, the document which formalizes the selection of the
remedy.

All written comments should be addressed to:

Christos D. Tsiamis
Project Manager
U.S. Environmental Protection
Agency
26 Federal Plaza, Room 29-102
New York, N.Y. 10278

It is important to note that the remedy described above is the
preferred remedy for the site. The final selection will be
documented in the ROD only after consideration of all comments on
each of the remedial alternatives addressed in the Proposed Plan
and the RI/FS report.
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18
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19

TABLE 1

COST ESTIMATE SUMMARY OF ALTERNATIVES
SOIL
Alternative
sc-1
SC-3
SC-4
SC-5
- No Action
- On-Site Incineration
- Off-Site Incineration
- Low Temperature
Enhanced Volatilization
$
$ 8
$17
$ 2
Capital
Cost
26,
,322,
,918,
,772,
500
800
700
400
Annual
$ 44
•

O & M
,400
0
0
0
Total Present Worth,
5% Discount Rate
$
$ 8
$17
$ 2
736,800
,322,
,918,
,772,
800
700
400
GROUNDWATER ALTERNATIVES
GW-1
GW-2
GW-3
GW-4
GW-6
- No Action
- Limited Action
- Air Stripping
- Air Stripping/
Carbon Adsorption
- UV Oxidation
$
$
$ 2
$ 2
$ 3
22,
234,
,635,
,995,
,263,
100
800
200
200
500
$ 46
$ 577
$1,053
$1,304
$1,208
,000
,900
,000
,300
,800
$
$ 8
$18
$23
$21
757,
,911,
,821,
,044,
,845,
000
300
900
900
200
BUILDING DECONTAMINATION ALT.
BD-1
BD-2
- No Action
- Decontamination
$
284,
0
900
$
$
300
0
$
$
4,
284,
600
900
-------
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-------
APPENDIX B

SIGN-IN SHEETS FROM THE PUBLIC MEETING

TOWN OF CATSKILL OFFICES

CATSKILL, NEW YORK

MAY 23, 1990
-------
'""••V,
\ UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION II
26 rEDERAL PLAZA
NEW YORK NEW YORK 10278
AMERICAN THERMOSTAT 0UFERTUND BITE MEETING

8XOH-XM CEBCT

FLEASB BB fURE TO PRIMT YOUR XXXZ AJTO ADDRESS CLEARLY SO TEAT WE
CAM ADD YOU TO OUR MAXLXNQ LIST I

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-------
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REGION II
26 FEDERAL PLAZA

NEW YORK. NEW YORK 10278
AXERZCAV THERMOSTAT SUFERTUHD 8ZTE MEBTZNO
PLEXBB BE SURE TO PRIMT YOUR HXKB XXD ADDRESS CLEARLY SO TEAT WE
CAN ADD YOU TO OUR KAZLZMO LIST I

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-------
APPENDIX C

INFORMATION REPOSITORIES FOR THE

AMERICAN THERMOSTAT SUPERFUND SITE
-------
EPA has established information repositories for the American
Thermostat Superfund site. The locations of these informaation
repositories are listed below:

1. Town of Catskill Offices
439 Main Street
Catskill, New York 12414

2. Village of Catskill Offices
422 Main Street
Catskill, New York 12414

3. Cairo Town Hall
Main Street
Cairo, New York 12413

4. New York State Department of Environmental Conservation
50 Wolf Road
Albany, New York 12233

5. U.S. Environmental Protection Agency
Emergency and Remedial Response
26 Federal Plaza, Room 29-102
New York, New York 10278
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