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

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).  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

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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

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     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

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 to a mobile
thermal treatment unit brought  to the  site, where hot air injected
at a temperature above  the  boiling points of the organic contami-
nants of concern would allow the moisture and the organic contami-

                                 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

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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.
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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.
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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

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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.

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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

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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

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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

-------
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.

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                                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
-
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.

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                          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.

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                                                            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).

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                                                           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).

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                                                                                  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)

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                                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

NA


4.6E-03
WEIGHT OF
EVIDENCE1
A
Bl

A
B2 .
B2
C
C

B2


B2

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.

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                          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

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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.

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                                                                         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

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                                          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

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APPENDIX 2




  FIGURES

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

                                             AMEKICAN TMCRMOStAT
                                                   Slit PLAN
                                                                  !•»

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            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

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     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

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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

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                                                                                                                                        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

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    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

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 U.S. ENVIRONMENTAL PROTECTION
           AGENCV
  AMERICAN THERMOSTAT SITE
         FIQURE
       SHEET 2 OF 2

     SOIL INVESTIGATIONS
FOASCO SERVICES I

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                                                                                                                    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

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                                                       • 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.

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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

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                       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

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APPENDIX 3 - ADMINISTRATIVE  RECORD INDEX

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APPENDIX 4 - NYSDEC LETTER OF CONCURRENCE

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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

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APPENDIX 5-RESPONSIVENESS SUMMARY

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                   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.

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     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

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          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

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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;

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     •    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.

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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

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           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.

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  |

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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,

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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

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
to 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 treated soil would be tested in  accordance  with the Toxicity
Characteristic Leaching Procedure  (TCLP)  to determine whether it
constitutes  a  Resource,  Conservation  and  Recovery Act   (RCRA)
hazardous waste and, provided that it passes the test, it would be
used as backfill material for  the  excavated area.   The disturbed
areas would be revegetated.

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.

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  under  the  preferred
alternative above the costs of other alternatives.

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

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 does not require any long-term
management.

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

HAKE                              ADDRESS
            A / 5                  "  "  "
                                      "  too.  Lee^€.. AJT
                                                       A) ./  /
                                              ?//w^^/jy.
7*
                            7i
           A  k.-

-------
.*'••"">,
     *)   UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
                               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

 NAIJE     •      i   ^-^                 ADDRESS
           <                      vA .*  ^ *^a t 10 '£ .  Lg^d^

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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

-------