United States         Office of
        Environmental Protection   Emergency and
        Agency           Remedial Response
EPA/ROD/R02-91/134
March 1991
EPA   Superfund
        Record of Decision
        C&J Disposal, NY
                                       Printed on Recycled Paper

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50272-101
 REPORT DOCUMENTATION
        PAGE
                        1. REPORT NO.
                           EPA/ROD/R02-91/134
                                                                   3. Recipient1* Accession No.
 4. Title and Subtitle
   SUPERFUND RECORD OF DECISION
   C&J Disposal, NY
   First  Remedial Action - Final
                                                                     5. Report Date
                                                                             03/29/91
 7. Author(s)
                                                                   8. Performing Organization Rept No.
 9. Performing Organization Name and Addreu
                                                                     10. ProjecVTask/Work Unit No.
                                                                     11. Contract* C) or Gr«nt(G) No.

                                                                     (C)

                                                                     (G)
 12. Sponsoring Organization Name and Address
   U.S.  Environmental Protection Agency
   401  M Street,  S.W.
   Washington, D.C.   20460
                                                                    IX Type of Report & Period Covered

                                                                              800/000
                                                                     14.
 IS. Supplementary Notea
 16. Abatract (Limit: 200 worda)
   The C&J Disposal site  is a former  industrial  waste disposal area in  the Town of  Eaton,
   Madison County,  New York.   Land  use in the area  is rural  and residential.  Surface
   drainage flows toward  a  small pond located in a  wetland area 100 feet  from the disposal
   area,  and ultimately drains into Woodman Pond.   Located 3,000 feet to  the south  of  the
   site,  Woodman  Pond serves  as a backup drinking water source for the  nearby Village  of
   Hamilton.  Currently,  twelve area  residences  use ground water as a source of drinking
   water.  In 1976, C&J Leasing dumped paint sludge,  liquid  industrial  wastes, and  75  to
   100 drums into an onsite disposal  trench.  The trench was subsequently covered with
   fill,  burying  the wastes and drums.  In 1989,  C&J Leasing conducted  an unauthorized
   site excavation, which left two  large holes and  three stockpiles of  soil and waste
   material in  the trench,  as well  as scattered  crushed drums, cans, and  plastic scrap
   material.  It  is believed that many buried drums were removed offsite  during this
   excavation.  EPA believes  that onsite contaminants are primarily adsorbed or bound  in
   the 1,250 cubic yards  of waste material and soil and are  not presently migrating into
   the ground water.  This  Record of  Decision  (ROD)  addresses onsite contaminated soil and
   debris, and  provides a final remedy for the site.   The primary contaminants of concern

    (See Attached  Page)
                                          NY
17. Document Analyeia a. Descriptor*
  Record  of Decision  - C&J Disposal,
  First Remedial Action - Final
  Contaminated Media:   soil, debris
  Key Contaminants:   VOCs (benzene, toluene,  TCE, xylenes),  other  organics  (PAHs,
  . ..  „„  _  , ..,       phenols), metals  (lead)
  b. Identiflers/Open-Ended Terms    c
    c. COSATI Reid/Group
  18. Availability Statement
                                                     19. Security Claas (This Report)
                                                               None
                                                      20. Security Claaa (Thia Page)
                                                           	 None
21. No. of Pages
       108
                                                                                 22. Price
 (See ANSI-Z39.18)
                                       See Instruction* on Reverse
                                                                               OPTIONAL FORM 272 (4-77)
                                                                               (Formerly NTIS-35)
                                                                               Department of Commerce

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EPA/ROD/R02-91/134
C&J Disposal,  NY
First Remedial Action - Final

  stract (Continued)

affecting the soil and debris are VOCs including benzene, toluene, TCE, and xylenes;
other organics including PAHs and phenols; and metals including lead.

The selected remedial action for this site includes dewatering the trench and treating
the water before recharge, if necessary; excavating approximately 1,250 cubic yards of
contaminated soil and debris from the disposal trench, followed by offsite treatment or
disposal; transporting drummed wastes generated during the field investigation to an
offsite RCRA facility for treatment and/or disposal; backfilling the trench;
revegetating the site; and monitoring ground water for one year.  If all or a portion
of the soil and debris is classified as RCRA hazardous wastes and require incineration
to meet land disposal restriction  (LDR) regulations, and the wastes are managed prior
to May 8, 1992, the soil and debris will be disposed of offsite without treatment under
a National Capacity Variance.  If the wastes require treatment other than incineration
under LDR regulations, the necessary treatment will be conducted offsite under a
Treatability Variance.  That portion of the soil and debris not classified as a RCRA
hazardous waste will be disposed of in a RCRA Subtitle-D facility.  After May 8, 1992,
this ROD provides for a contingency remedy, which includes offsite thermal treatment of
organic wastes, and treatment and disposal of inorganic wastes in accordance with LDR
requirements.  The estimated present worth cost for this remedial action, assuming
offsite disposal without treatment, is $672,400, which includes an annual O&M cost of
$86,000.

 ERFORMANCE STANDARDS OR GOALS:  Removal of contaminated soil and debris will ensure
 hat Federal and State regulations for ground and surface waters are not exceeded.
Cleanup criteria will be based on background levels found in offsite and native soil
samples.  There were no chemical-specific ARARs provided for soil.

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                            ROD FACT SE2ET
  SITE

  Nane:

  L-ccation:

  EPA Region:

  E3S Score  (date)

  N?L Rank (date) :
  C & J Disposal

  Tcvn of Eaton, New York; Madison County

  II

  42.94

  657
  ROD

  Date Signed:

  Ksnedv:
  Capital Cost:

  O & M:

  Present Worth:
  3/Z9/9/
  Selected Remedy:   Removal and Off-Site
  Treatment/Disposal

  Contingency Remedy:   Removal and Off-Site
  Thermal Treatment

  $    586,400

  $     86,000

  $    672,400
  LEAD

  EPA Remedial

  Primary Contact:

  Secondary Contact:

  PRPs:
  F3P Contact:
 Jack O'Dell  (212-264-1263)

 Douglas  Fischer (212-264-9792)

 Occidental Chemical  Corp.  (Occidental
 Petroleum)
 C&J  Leasing
 Birge Company
 Charles  Picariello  -
 Geneso  (aka James) Picariello

 Duane, Morris  & Heckscher  (Occidental
 Chemical)
Tyre:


Heditra:

Origin:
Organics  (phthalates, phenols, VOCs), metals
(lead)

Soil

Bulk liquid/sludge dumping in 1976 and
earlier

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              RECORD OF DECISION

             C  & J  DISPOSAL SITE
                TOWN OF EATON
           MADISON COUNTY, NEW  YORK
               PREPARED BY THE

UNITED STATES  ENVIRONMENTAL PROTECTION  AGENCY

                  REGION II

               NEW YORK,  NEW YORK

                  MARCH 1991

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              Declaration  for the Record of Decision

Site Name and Location

C&J Disposal Site
Town of Eaton, Madison County,  New York

Statement of Basis and Purpose

This decision document presents the  selected  remedial action for
the C&J Disposal site (the "Site"),  located in the Town of Eaton,
Madison 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  Reauthorization Act  of  1986 (SARA)
and, to  the extent practicable,  the National Oil and Hazardous
Substances  Pollution  Contingency Plan.   This decision document
explains the factual and legal basis for selecting the remedy for
the Site.

The State  of New York concurs with  the selected  remedy  and the
contingency  remedy.    The information  supporting this remedial
action decision is contained in the administrative record for the
Site.   The administrative record index is attached.

Assessment of the Site

Actual or  threatened releases of  hazardous substances  from the
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  final action for the Site.  The selected
remedy  will  address  the  contaminated soil  and  debris in the
disposal trench at the Site.

The remedy includes:

          Excavation of approximately 1,250 cubic  yards of contam-
          inated soil and debris from the disposal  trench, followed
          by transportation to a permitted, Resource Conservation
          and Recovery Act (RCRA)-compliant waste management
          facility for treatment/disposal.

          Transportation of the drums containing wastes generated
          during  the  field investigation  to a  permitted,  RCRA-
          compliant  waste  management  facility  for  treatment/
          disposal.

          Temporary dewatering of the disposal trench prior to
          excavation, and treatment of the water, if necessary,
          prior to recharge.

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          Backfilling of the trench with clean fill and returning
          the Site to a vegetated state.

          Quarterly monitoring of  the  groundwater underlying the
          Site and downgradient residential wells for one year.

Because  of  the  variety  of contaminants  at  the Site  (various
organics and lead), their uncertain volumes and distribution, and
possible treatment requirements, an exact disposal regime will have
to be determined in the remedial design (RD)  phase. Testing of the
excavated  soil  and  debris  during  the  RD  will  be by  Toxicity
Characteristic Leaching  Procedure  (TCLP)  analysis.  If  all  or a
portion of the soil  and  debris  is  classified as a RCRA hazardous
waste, for the contaminants that would  require thermal destruction
as a  treatment under  the RCRA  Land Disposal Requirements. (LDRs),
the waste  may  be disposed of,  without  treatment,  in a permitted
RCRA-compliant minimum technology hazardous waste landfill.  This
can be done before May 8, 1992 under a National Capacity Variance
for Third-Third  wastes.  Disposal after May 8, 1992 would require
treatment in accordance with LDRs.   If the soil and debris, after
testing, is  found to  contain wastes  which,  under LDRs, require a
•form  of treatment  other than  thermal treatment,  the necessary
treatment will  be conducted at a  permitted,  RCRA-compliant off-
site  facility  (on-site treatment is  not practical)  prior to off-
site  disposal.   This  can  be  done through  a  soil  and  debris
Treatability  Variance up  until the time  that  final treatment
standards are  promulgated  for  soil  and debris.   Conversely, that
portion of the soil and debris not classified as hazardous by the
TCLP  analysis can be disposed of in a RCRA Subtitle-D  facility.

For  estimation  purposes  and to account for  different  disposal
regimes, the present worth cost for this alternative presumes  that
all of the contaminated  soil is  RCRA hazardous-waste and will be
disposed of  at a land disposal  facility without treatment, under
a National Capacity  Variance.   This  cost is intermediate between
the possible lower costs afforded  by Subtitle-D disposal and the
additional costs for any required waste treatment.

In the unlikely event that this alternative  can not be  implemented
before the RCRA  LDR deadline of May 8,  1992,  the portion of the
waste that has been  classified  as  an organic RCRA characteristic
waste would  be  thermally treated  at an off-site  facility.   Any
residue from the thermal treatment would be  treated further,  if
necessary, to comply with disposal regulations.  Any portion of the
waste classified as  hazardous  on the  basis of inorganics  (i.e.,
lead) alone, would be  treated  and  disposed  of in accordance with
LDR requirements.  This contingency remedy would  involve the same
on-site remediation activities as the selected remedy.

Declaration of Statutory Determinations

The selected remedy  and  the contingency remedy are protective of

                                ii

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human health and the environment, and comply with federal and
state requirements that are legally applicable or relevant and
Appropriate to the remedial action, and are cost-effective.  The
selected remedy and the contingency remedy utilize permanent
solutions and alternative treatment (or resource recovery)
technologies to the maximum extent practicable.  The statutory
preference for remedies that employ treatment as a principal
element will not be satisfied for those scenarios where treatment
is not required under LDRs.  However, even under those scenarios,
the selected remedy will be protective of public health and the
environment.

Because the selected remedy and the contingency remedy will not
result in hazardous substances remaining on-site above health-
based levels, the five-year review will not apply to this action.
  Regional Administrator

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               DECISION SUMMARY

             C & J DISPOSAL SITE
                TOWN OF EATON
          MADISON COUNTY, NEW YORK
UNITED STATE  ENVIRONMENTAL PROTECTION  AGENCY

                  REGION  II

             NEW YORK,  NEW  YORK

                  MARCH 1991

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                         TABLE OP CONTENTS
SITE NAME/  LOCATION AND DESCRIPTION	  1
SITE HISTORY	  2
ENFORCEMENT ACTIVITIES	  3
HIGHLIGHTS  OP  COMMUNITY PARTICIPATION	  3
SCOPE AND ROLE OP RESPONSE ACTION	  4
SUMMARY OF  SITE CHARACTERISTICS	  4
SUMMARY OF  SITE RISKS	  5
DESCRIPTION OP ALTERNATIVES	  8
SUMMARY OP  COMPARATIVE ANALYSIS OP ALTERNATIVES	11
THE SELECTED REMEDY	15
STATUTORY DETERMINATIONS	16
DOCUMENTATION  OP SIGNIFICANT CHANGES	19
                            ATTACHMENTS

                  APPENDIX 1 - FIGURES
                  APPENDIX 2 - TABLES
                  APPENDIX 3 - ADMINISTRATIVE RECORD  INDEX
                  APPENDIX 4 - NYSDEC LETTER OF CONCURRENCE
                  APPENDIX 5 - RESPONSIVENESS SUMMARY

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SITE NAME, LOCATION AND DESCRIPTION

The Site is located  in the Town of Eaton, Madison County, New York.
It is  near the intersection of  Routes  12B and 46,  north  of the
Village of  Hamilton.   The  Site  includes  a  rectangular disposal
trench which measures approximately 140 feet  by  40 feet.   Access
to the Site can be gained by entering a New York State Department
of Transportation  (NYSDOT)  storage area  at the  intersection  of
Routes 12B  and  46,  and following a former  New York,  Ontario and
Western  Railroad railbed  approximately  800  feet  to  the  south
(figure 1).

The disposal trench is  situated between the  former  railroad bed to
the east  and an active  agricultural  field  (classified AA-Prime
Farmland)  to  the west.  Mature  trees and  heavy  undergrowth are
found to the north and a small pond is found to the south (figure
2) .   The  Site  is   also  'at the  intersection  of  three adjoining
properties.  These  are owned by  C&J Leasing,  New York State (the
former railbed area) and Joan and Howard Mosher (the agricultural
field).

A small pond which lies to the south,  approximately 100 feet from
the disposal trench, ultimately drains to  Woodman Pond  (3,000 feet
to the south) which serves  as  a  backup  drinking  water source for
the Village  of Hamilton.   There are  thirteen residences  in the
vicinity  (within  1,800   feet)   and   downgradient  of   the  Site.
Currently, twelve residences are actively utilizing private wells
as their source of drinking water (figure 2).

The  small  pond is part  of  a  New  York State  Department  of
Environmental  Conservation  (NYSDEC)-designated  wetland  (HA-2),
which  is  a Class I wetland  (the highest New York State wetland
designation).  A second state-designated wetland (HA-1, Class II)
is located  approximately 1,800 feet west  of the  Site.  These two
wetland areas comprise the  ecologically  significant habitat area
known as "Fiddler's Green."

The Site is situated in a glacially scoured valley floor in which
recent  deposits  and  unconsolidated  glacial  deposits  overlie
bedrock.  The area  forms  the drainage  basin  of the  Chenango River,
which is a major tributary to the larger Susquehanna River Basin.
The localized surface drainage pattern at the Site is toward the
small pond and wetland.   The Site is not located within a 500-year
flood plain area as designated  by the  Federal Emergency Management
Agency, but is within a flood-prone area as identified by Cornell
University and the U.S. Soil Conservation Service  (Madison County
Planning Department, 1988).

The Town of Eaton is a rural, central New York community.  The 1980
population of the Town was 5,182 with an average rural density of
55 persons/square mile  (mi2) outside of incorporated villages  (U.S.
Census, 1980; Madison County Department of Planning,  1988).  The
neighboring  Town of  Hamilton  is  similarly  rural with a  total
population  (1980)   of  6,027,   and average  rural  density   of  39

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persons/mi2  outside of incorporated villages  (U.S.  Census,  1980;
Madison  County  Department  of   Planning,  1988) .    The  closest
population center  in  the  vicinity of the site  is  the  Village of
Hamilton (population 3,725),  located approximately 1.5 miles to the
southeast.

SITE HISTORY

In March 1976, C&J  Leasing,  located  in  Paterson,  New Jersey,  was
observed dumping what appeared to be paint sludges and other liquid
industrial waste materials in a trench on or adjacent to land owned
by C&J Leasing.   Inspections were subsequently conducted by the New
York State Department of  Health  (NYSDOH), NYSDEC and the Village
of Hamilton Engineer.  During a March 22,  1976 inspection conducted
by NYSDEC and the Village Engineer, approximately 75 to 100 drums
were observed  lying in a  stagnant  pool  of  liquid wastes  in  the
previously described trench.  The trench was subsequently covered
with fill, reportedly by C&J Leasing, apparently burying the drums
observed in March 1976.

Sampling was conducted  at the  Site by NYSDEC in  1985  and  by  the
Environmental   Protection  Agency's   (EPA's)    contractor,   NUS
Corporation, in  1986.   Surficial soil samples  obtained  from  the
Site  revealed  the  presence of  phenolic compounds,  phthalates,
various volatile organic  compounds  (VOCs),  polynuclear  aromatic
hydrocarbons (PAHs)  and lead.    Bis  (2-ethylhexyl)  phthalate  was
detected in the  sediments of the adjacent pond.   A final  Hazard
Ranking System score was derived  for the Site  based  on the findings
of the Preliminary Assessment and Site Inspection (PA/SI)  prepared
for EPA by NUS Corporation in 1986.

Private residences  in the vicinity of the Site use groundwater as
their drinking water source.  NUS Corporation  sampled taps from two
private wells  downgradient. of  the Site  during  its 1986  sampling
effort, but did not detect any contaminants.   Additional sampling
by NYSDOH in 1988 of four  private wells downgradient from the Site
did not reveal any contamination with  volatile  organic compounds
or priority pollutant metals.

The Site was placed on  the Superfund National Priorities List in
March 1989.

In April 1989, prior  to the start of remedial investigation  (RI)
field  activities,  the  Site  was  subject  to  an  unauthorized
excavation by  the principals of C&J Leasing,  leaving  two large
holes and three stockpiles of soil and waste material  in the trench
area.   A  few partially crushed  55-gallon drums,  a  number of 5-
gallon cans  (some crushed) and  scraps of plastic  waste material
were found scattered around the Site. The drums  and cans contained
waste residue  identical to the  waste  observed  on the Site.   In
April  1989,  or  earlier,  drums  that were believed to have been
buried may  have been removed and taken  off-site.   An extensive

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follow-up  investigation  has  failed to determine  where  the drums
were taken.

RI field investigations began in October  1989 and upon completion,
the Site was secured with temporary fencing and covers on the waste
piles.   In  December 1990,  site  security  was upgraded  with the
installation of more substantial fencing both around the disposal
trench and with  gates and fencing across the  access road to the
Site.  In  addition,  to improve safety and to reduce surface water
ponding in the trench, the external soil pile was moved back into
the trench.  Drums  from  the  RI  field sampling were placed within
the enclosed trench area.  The trench  was covered with a synthetic
liner to prevent sediment runoff and wind-borne contaminants from
leaving the Site (figure 2).

ENFORCEMENT ACTIVITIES

Notice letters were  sent on July 15,  1988 to the C&J Leasing Co.,
the  Birge  Company,  Charles  Picariello  and  Geneso  (aka James)
'Picariello  identifying  them  as potentially  responsible parties
(PRPs).  The notice letters also notified each  PRP of an impending
RI and feasibility  study (RI/FS)  ta be  conducted at the Site and
invited each PRP to  either perform the RI/FS or finance it.

None  of  the PRPs agreed to  perform or  finance the  RI/FS.   As  a
result,  EPA sought  access  to the  Site  in order to conduct the
necessary  activities.    After C&J  Leasing  Co. refused  to grant
access  to  its _property  at   the  Site,   EPA  issued  a  unilateral
administrative order on  May  5,  1989 to  gain access.  In  response
to an unauthorized  excavation of the  Site in April  1989,  a second
unilateral order was issued,  also on May 5,  1989, directing Charles
Picariello and  C&J  Leasing  Co.,  to  "refrain  from  disposing of,
moving, placing, or handling the previously excavated materials or
any other  materials  of any type at the Site."

On  the  basis  of evidence  linking contaminants  at the  Site to
"Firestone Plastics" of  West Caldwell,   New  Jersey,  EPA issued  a
notice  letter  to   Bridgestone/Firestone  on  November  16,   1990.
Occidental Petroleum  Corporation  purchased  the  West   Caldwell
facility  from  Firestone  in  1980, and was also  issued  a notice
letter as  Firestone's corporate successor in interest with regard
to the West  Caldwell  facility.

HIGHLIGHTS OF COMMUNITY  PARTICIPATION

The RI/FS  report and the Proposed Plan for the Site  were  released
to the public for comment on January 25,  1991.  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, New York, at  the Hamilton  Village Library in Hamilton,
New York,  and at NYSDEC's offices in Albany, New York.  A public
comment period on these documents was originally held from January

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25, 1991 through February  25,  1991.   Following a  request from a
PRP, however, the comment period was  extended  to  March 12,  1991.
In  addition,  a  public meeting was held at the Hamilton Central
School in the Town  of Hamilton, New York on February 13, 1991.  At
this meeting, representatives  from  EPA and NYSDEC discussed the
problems  at  the   site,  the  alternatives  considered,  and  the
preferred alternative  and  answered  questions.   Responses to the
comments received during the public comment period  are included in
the Responsiveness  Summary, which is appended to this ROD.

SCOPE AND ROLE OF RESPONSE ACTION

This response applies a comprehensive approach and therefore only
one operable unit is required to remediate the Site.

The purpose of this  response  is  to  address the principal threats
posed by the conditions at the Site by:

     Eliminating the potential for direct human or animal contact
     with the contaminated soil and debris at the Site.

-    Preventing the migration of contaminants from the Site through
     surface water runoff to the pond, wetlands and agricultural
     field adjacent to the Site, and ensuring the protection of the
     groundwater from the continuous release of contaminants from
     site soils.

SUMMARY OF SITE CHARACTERISTICS

The RI conducted by EPA during 1989 and 1990 indicated that, with
the exception of some low levels  of contamination  in the sediments
of the adjacent pond, the contaminants at  the Site  are confined to
the waste disposal trench,  (Figure 2).   No significant levels of
contaminants were found in surface soils at various distances from
the trench.   The total volume  of waste material and contaminated
soil and debris in  the disposal trench is  estimated at 1,250 cubic
yards  (i.e.,  contained in  the area of 140 feet by 40 feet and to
a depth of 6 feet).  The waste is non-uniformly distributed and is
comprised  of soil  mixed with  a plastic-like residue  and/or a
similar  synthetic  matter,   crushed drums  and  plastic  bags  (drum
liners) contaminated with the same or  similar plastic residue, and
some wood debris.  The plastic occurs  as large  clumps, layers, and
as  small, highly distributed fragments.  The primary contaminants
in  the  trench  area  are  various  phthalates  (bis(2-ethylhexyl)
phthalate, di-n-octylphthalate, di-n-butylphthalate, etc.), phenols
(4-methylphenol, etc.)  and volatile  organic compounds  (VOCs) ,
(benzene,  ethylbenzene,  toluene, xylenes,  4-methyl-2-pentanone,
etc.).   Lead, which  was detected above background levels in only
one sample during extensive RI sampling, was found  at significantly
elevated  levels  during more  limited  testing  by  NUS Corporation
(1986) and EPA  (post-RI,  1990).   It  is not possible to attribute
the above chemicals found at the Site to any specific RCRA "listed"

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hazardous  wastes.    A  wide  variety  of  polynuclear  aromatic
hydrocarbons  (PAHs)  found  in  the  disposal trench and surrounding
surface  soils  are attributable to the old  railroad  bed and are,
therefore, considered background.  The maximum detected concentra-
tions of soil contaminants at the Site are shown in Table 1 .'

While some of  the waste  materials are  in direct contact with the
shallow  groundwater,  the contaminants are  presently  adsorbed or
bound in the  waste material and/or  are  adsorbed to the soils and
are not  migrating to the groundwater  from the trench.  Extensive
chemical analysis of the eight local  residential  wells (serving
twelve  residences)  during  the RI  further  confirmed  the  prior
results, i.e., that  no contaminants from the Site had migrated to
these wells.  Seven grouncwater monitoring wells  (four shallow and
three deep), installed during the RI in and around the Site, also
indicated  no  migration  of  contaminants  from  the  trench  to  the
groundwater.

Testing  of   the  water  in  the   adjacent   pond   indicated  no
contamination  from  the  Site.   Low levels  of  bis(2-ethylhexyl)
"phthalate  and  lead  found  in  the  sediments  in  the  pond  are
apparently attributable  to overland sediment transport by surface
water runoff.

The RI/FS report  provides greater detail of the.nature and  extent
of contaminants  found at the Site.

The potential for direct human exposure, as well as the potential
for future contaminant migration to  groundwater  and surface  water,
exists at the Site.  Presently,  there are no permanent controls in
place to prevent  contaminant migration from the site.

SUMMARY O7 SITE  RISKS

EPA conducted a  risk assessment of the "no-action" alternative to
evaluate the  potential  risks  to human  health and the environment
associated with the Site in its current state.  The  risk assessment
focused on the soil contaminants which  are likely to pose the most
significant  risks  to  human  health and  the environment   (i.e.,
chemicals  of  concern).    The  chemicals  of concern  and  their
concentrations in site media are  shown in Table 2.

EPA's risk assessment  identified  two  potential  exposure pathways
by which the public may be exposed to contaminant releases from the
Site under current land-use conditions.

     - dermal contact with surface materials

     - incidental ingestion of surface materials.

The potentially  exposed  population  assessed was residents  living
near the Site and using the  Site for  recreational purposes. The

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receptor was assumed to be a local resident (70 Kilogram (kg)  who
jogs through the Site an average  of once a month, over a period of
9 years.   Exposure  is  only assumed to occur half the  year,  as
frozen ground,  snow cover and outerwear preclude contact during the
winter  months.    Exposures were  based  on  reasonable  maximum
concentrations, calculated as the 95th percentile upper confidence
limit of the geometric mean.

Under  current   EPA guidelines,  the  likelihood  of  carcinogenic
(cancer causing)  and noncarcinogenic effects due  to  exposure to
site chemicals  are considered separately.  It was assumed that the
toxic  effects  of  the  site-related  chemicals would be  additive.
Thus,  carcinogenic  and  noncarcinogenic  risks  associated  with
exposures to individual  indicator compounds were summed to indicate
the  potential   risks   associated  with   mixtures   of  potential
carcinogens and noncarcinogens, respectively.

Noncarcinogenic  risks  were  assessed using  a  hazard index  (HI)
approach, based  on a comparison of  expected  contaminant intakes
and  safe  levels  of  intake  (reference doses).   Reference  doses
(RfDs) have been developed by EPA for indicating the potential for
adverse health effects.  -RfDs,  which  are expressed  in  units of
milligram per kilogram per day  (mg/kg-day), are estimates of daily
exposure  levels  for  humans which are  thought to  be  safe  over a
lifetime  (including sensitive individuals).  Estimated intakes of
chemicals from  environmental media  (e.g.,  the amount of a chemical
ingested  from  contaminated  soil)  are compared  with  the RfD to
derive the hazard  quotient  for the  contaminant in  the particular
media.  The HI  is  obtained by adding the hazard quotients for all
compounds across all media.
                                  •
A HI  greater than 1.0  indicates that potential exists  for non-
carcinogenic health  effects  to occur as a result of site-related
exposures.  The  HI provides a  useful reference point for gauging
the potential significance of multiple contaminant exposures within
a single  medium  or across media.  The  reference  doses and HI for
the chemicals  of concern at the Site for dermal contact and
incidental ingestion are  presented  in  Table  3.   A  summary of the
non-carcinogenic risks associated with these  chemicals is found in
Table 4.
    a
It  can be  seen from Table 4  that  the  HI  for  non-carcinogenic
effects from dermal  contact is  4 and, therefore,  indicates that
non-carcinogenic  effects  may  occur  from  the  exposure  routes
evaluated in the risk assessment.

Potential  carcinogenic  risks  were  evaluated using  the  cancer
potency factors developed by the  EPA for the chemicals of concern.
Cancer  potency  factors  (CPFs)   have  been  developed  by  EPA's
Carcinogenic Risk  Assessment Verification Endeavor for estimating
excess  lifetime  cancer  risks  associated   with  exposure  to
potentially carcinogenic  chemicals.  CPFs, which are expressed in

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units of (ng/kg-day)'',  are multiplied by the estimated intake of a
potential  carcinogen,  in  mg/kg-day,  to  generate  an upper-bound
estimate  of  the  excess   lifetime  cancer risk associated  with
exposure to  the compound  at the  intake  level.  The term "upper
bound" reflects the conservative estimate of the risks calculated
from the CPF.   Use of  this approach makes the underestimation of
the risk highly  unlikely.   The  CPFs for  the  chemicals of concern
for dermal contact and incidental  ingestion are  presented in Table
5.   A summary of the  cancer risks associated with these chemicals
is found on Table  6.

For knovn or suspected carcinogens,  the EPA considers excess upper
bound individual lifetime cancer risks of between 10" to  10* to be
acceptable.   This level  indicates  that an  individual  has  not
greater than  a  one in  ten thousand  to one in a million chance of
developing  cancer  as  a  result  of  site^related  exposure to  a
carcinogen over a 70-year period under specific  exposure conditions
at the Site.  The cumulative upper  bound  risk  at the Site is 2 x
10".   Hence,  the risks  for carcinogens at the Site are at the high
end of the acceptable EPA  risk range of lO^1 to 10*.

While the  RI  did  not  provide any  analysis of future risks due to
the  migration of  contaminants  from  the  trench,  three exposure
pathways,  which  are  now  minimal  or  incomplete   could  become
significant  in  the future.  These  included:  1)  the transport of
contaminants through surface water runoff to the pond and wetlands;
2)  the wind-borne transport of  fugitive  dust to downgradient
receptors  (pond & wetlands, local  residences, etc.) and  3)  the
.release of contaminants to  the groundwater and migration to local
downgradient wells used for drinking water.   In this latter case,
changes  in soil  chemistry brought  on  by adjacent agricultural
activities (fertilizer, lime or pesticide application) or natural
phenomenon (bio-degradation of the waste material matrix, or algae
or mold blooms, in the trench pits,  etc.) might cause the release
of contaminants into the groundwater.

Uncertainties

The procedures and inputs used to  assess risks  in this evaluation,
as in all  such assessments, are subject to a wide variety of
uncertainties.    In general,  the  main   sources of uncertainty
include:
                                                               •
-  environmental  chemistry  sampling and analysis
-  environmental  parameter  measurement
-  fate and transport modeling
-  exposure parameter estimation
   toxicological  data

Uncertainty  in environmental sampling  arises  in   part  from the
potentially uneven distribution  of chemicals  in the  media sampled.
Consequently, there  is significant  uncertainty  as  to the actual

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levels present.  Environmental chemistry  analysis  error can stem
from  several  sources  including  the  errors  inherent  in  the
analytical methods  and characteristics of the matrix being sampled.
Uncertainties in the exposure assessment are related to estimates
of how often an individual would actually come in contact with the
chemicals of concern, the period of time over which such exposure
would occur, and in the models used to estimate the concentrations
of  the   chemicals  of  concern   at   the  point   of   exposure.
Uncertainties  in toxicological  data occur  in  extrapolating both
from animals to humans and from high to low doses of exposure, as
well  as  from  the  difficulties in  assessing the  toxicity  of  a
mixture of chemicals. These  uncertainties are addressed by making
conservative assumptions concerning risk  and  exposure  parameters
throughout  the assessment.    As  a result,  the risk  assessment
provides upper bound estimates of the risks to populations near the
Site,  and is highly unlikely  to underestimate actual risks related
to the Site.

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

DESCRIPTION OF ALTERNATIVES

A  total  of  six  alternatives  were  evaluated  in  detail  for
remediating the Site.  These alternatives are as follows:

Alternative 1;  No Action

Capital Costs:  $0
Operation and Maintenance (O & M)  Cost:  $50,000/yr
Present Worth Cost:  $528,500
Time to Implement:    1 month

The Superfund program requires  that  the  "no-action" alternative be
considered  as  a  baseline  for comparison with other alternatives.
Under this  alternative, no remedial  action  to control  the source
of contamination would take place.  However, long-term monitoring
of  the  Site would  be necessary.    The monitoring  program would
consist of  sampling  seven existing  on-site  monitoring  wells on a
quarterly basis for  30 years.

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  may be
implemented to remove or treat the wastes.

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alternative 2: Liaited Action

Capital Cost:  $30,000
O & M Cost:  $50,000/yr
Present Worth Cost:  $558,500
Time to Implement:  6-9 months

This alternative  would be similar to the  no-action  alternative,
but would add land-use restrictions and  permanent securing of the
Site.  This  alternative could affect all three  land  parcels with
deed  restrictions  and possibly   require  the  relocation  of  a
telephone  fiber-optic  cable  under the  former  railroad bed.   By
erecting  a permanent  fence  around the Site,  the potential  for
physical  contact  with  the contaminated  soil and  debris would be
limited. The impact of the deed restrictions and site security on
the  productivity  of  the  agricultural  field  would  have to  be
assessed.

As with the no-action alternative,  quarterly groundwater monitoring
for 30 years, as  well  as  five year reviews,  would be instituted.
If  justified by  the  five-year  review,  remedial  actions  nay  be
implemented to remove or treat the wastes.

Alternative 3; Containment

Capital Cost:  $85,000
O & M Cost:  $56,000/yr
Present Worth Cost:  $712,500
Time to Implement:  12 months (includes  design)

This alternative  would  involve  filling  and regrading the  trench,
removing the monitoring well in the disposal trench,  installing a
multimedia cap to prevent rain infiltration, permanently lowering
the  water  table  to  eliminate  the possibility  of  contaminant
migration  (via the groundwater) , and discharging groundwater from
the dewatering operation,  to the adjacent pond.   This alternative
would also require deed restrictions.

The multimedia capping system would consist of an upper vegetative
layer, a  drainage layer,  and a synthetic  membrane.   Because the
contaminated  soil and  debris  is presently  in  contact with the
groundwater, the water table  would have  to  be lowered permanently.
This could be accomplished by operating pumping wells  near  the four
corners  of  the  trench  to  produce the   necessary  water  table
drawdown.  Hydrologic modeling has determined that pumping a total
of 100 gallons per minute would be required to maintain the water
table approximately three feet  below the waste.   The groundwater
would be piped and discharged to the adjacent pond and wetlands in
accordance with appropriate state and federal regulations.

Long-term groundwater monitoring would be performed and five year

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reviews would also be implemented as part of this remedy.

Alternative 4: Removal and Off-Site Treatment/Disposal

Capital Cost:  $586,400
O & M Cost:  $86/000/yr
Present Worth Cost:  $672,400
Time to Implement:  6-9 months (includes design)

This alternative would involve the excavation of the contaminated
soil and  debris from the  disposal trench, followed  by off-site
transportation  and  treatment/disposal  at  a  permitted,  RCRA-
compliant facility.

Under  this  alternative  a  temporary dewatering  trench  would  be
installed to lower the water  table in  the disposal trench before
the excavation of the waste.   Excavation would be anticipated to
extend to a depth of six feet throughout the trench area and result
in the removal of approximately 1,250 cubic yards  of soil and waste
material.  The monitoring well in the center of the disposal trench
would be  removed.  Confirmatory  sampling and laboratory analysis
of remaining soils in-situ  would  be performed  to verify that site-
specific  cleanup  criteria  were met.   Cleanup criteria   for the
chemicals of concern would be based on background levels found in
off-site soil samples obtained from the abandoned  r'ailroad bed and
native soil samples adjacent to the Site.  Upon confirmation that
the contaminants of concern had been removed, the excavations would
be backfilled with clean fill  and vegetated.  All monitoring wells
and eight residential wells in the vicinity of the Site would be
sampled on a quarterly basis for a period of one year following the
completion of site remediation.   If site contaminants are detected
in the groundwater,  monitoring would be  continued and  if levels
contravene  drinking  water standards,  corrective action  will  be
instituted.        '

Because  of  the  variety  of   contaminants at  the  Site   (various
organics and lead), their uncertain volumes and distribution, and
possible treatment requirements,  an exact disposal regime will have
to be determined in the  RD phase.  Testing of the excavated soil
and debris  during  the RD will be by TCLP  analysis.   If all or a
portion of  the soil and  debris  is classified as  a RCRA hazardous
waste, for the contaminants that  would  require thermal destruction
as a treatment under the RCRA LDRs, the waste may be disposed of,
without treatment,  in a permitted RCRA-compliant minimum technology
hazardous waste landfill.   This  can  be done before  May 8, 1992
under  a  National  Capacity  Variance   for  Third-Third  wastes.
Disposal  after May 8,  1992 would require treatment in accordance
with LDRs.   If the soil and  debris,  after testing,  is found to
contain wastes which,  under LDRs,  require a form of treatment other
than thermal treatment, the necessary treatment will be conducted
at a permitted, RCRA-compliant off-site facility (on-site treatment
is not practical)  prior to off-site disposal.   This  can be done

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through a soil and debris Treatability Variance up until the time
that final treatment standards are promulgated for  soil and debris.
Conversely, that portion of the soil and debris not classified as
hazardous  by  the  TCLP analysis  can  be  disposed of  in a  RCRA
Subtitle-D facility.

For  estimation  purposes  and  to  account  for  different  disposal
regimes, the present worth cost for this alternative presumes  that
all of the contaminated soil is RCRA  hazardous waste  and will be
disposed of at a  land  disposal  facility without treatment,  under
a National Capacity Variance.  This cost  is  intermediate between
the possible lower costs  afforded  by  Subtitle-D disposal and the
additional costs for any required waste treatment.

Alternative S  - Reaoval and Off-Site Thermal  Treatment

Capital Cost:   $1,133,500
O & M Cost:  $36,-000/yr
Present Worth  Cost:  $1,219,500
Tize to Implement:  6-9 months (includes design)

This  alternative  involves   excavating  the   soil   and  debris
(approximately  1,250  cubic yards)  from  the  disposal trench as
described in Alternative 4 and transporting the material off-site
for  thermal treatment.   Thermal  treatment involves  the thermal
destruction of  the  contaminants,  and  is principally  used  in
destroying  organic waste.   The  resulting ash/residue  would be
treated,  if necessary,  and disposed  of  in  a  permitted  RCRA-
conpliant  off-site Treatment,  Storage,  and   Disposal  facility.
There are several  thermal  treatment options  available (i.e., low
temperature, incineration, etc.).   Also, as in Alternative 4, the
contaminated soil and debris would be disposed of on the basis of
TCLP analysis.  Portions of the waste not classified as hazardous
could be disposed of  at a  Subtitle-D facility.  Any portion of the
waste classified  as  hazardous  on the basis of inorganics (i.e.,
lead) alone, would be  treated and disposed of in accordance with
LDR requirements.

As  described  in  Alternative 4,  any  alternative involving the
removal of the soil and debris  from the trench would incorporate
confirmatory  sampling  of  the  trench  upon   completion  of  the
excavation work.   Cleanup criteria would  be  based  on background
levels found in upgradient soil samples obtained from the abandoned
railroad bed and a  native soils sample.  Upon confirmation that the
contaminants had been removed,  the excavation would be backfilled
with clean fill and vegetated.  All monitoring wells  on site and
the nearby residential wells would be  sampled  on a quarterly basis
for a period of one year.

The  estimated  present worth  cost of  this alternative  does not
include the off-site  treatment of  the ash/residue/soil which would
vary  with  the  type  of  thermal   treatment   performed.    (i.e.,

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stabilization/solidification at  an  estimated cost  of $130/cubic
yard).

Alternative 6 - In-Situ Vitrification

Capital Cost:  $1,030,000
0 & M Cost:  $46,000/yr
Present Worth Cost:  $1,551,800
Time to Implement:  6-9 months (includes design)

This  alternative  involves  on-site  treatment  by  melting  the
contaminated soil and debris with heat generated from an electrical
current.   Four  electrodes  would  be  implanted into  the  soil  in a
square pattern, spaced 30  feet apart.   A  mixture of graphite and
glass grit would be placed on the surface to provide a conductive
path for the electric current.  Resistance in the soil would cause
the temperature to rise to  near 2,000 degrees centigrade resulting
in   the   destruction   of   the   organic  contaminants   and   the
encapsulation of any remaining material in a  glass-like mass.  This
process would require temporary dewatering of the  Site, which would
be  accomplished  by  excavating  a  temporary  dewatering  trench
adjacent to the Site as described in  Alternative 4.  A treatability
study would be required to determine the effectiveness of in-situ
vitrification with the Site's soils  and to  determine if clean-up
levels could be  achieved.   As a result of  the process,  a 25-45%
reduction in volume would occur and  clean  fill would be brought in
to fill and revegetate the Site.

Because the material would be left in place, groundwater monitoring
would be  required for  a period  of  30 years to  confirm that the
contaminants of concern are not migrating  from the vitrified mass.
This alternative would also require  five-year reviews.

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 Applicable or Relevant and Appropriate Requirements  (ARARs),
long-term  effectiveness  and permanence,  reduction  of  toxicity,
mobility,  or volume, short-term  effectiveness,  implementability,
cost, state acceptance, and community acceptance.

Each criterion will be  briefly addressed below with  respect to the
alternatives for the  remediation  of  the  Site.  The results of this
analysis are summarized in Table 7.

A.  Overall Protectiveness of Human  Health and the Environment

Alternative  1  would  not  be protective of  human health  and the
environment.   Alternatives 4  and 5, by contrast,  would be fully
protective  of  human   health  and   the  environment  because  the

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contaminants   would   be  completely  removed   from  the   Site.
Alternative 2 would provide  some measure of protection fron direct
contact with contaminants through permanent  fencing  of  the Site,
but would  not  prevent contaminants  from migrating from  the Site
through surface water runoff,  air transport or release  into the
groundwater and migration to downgradient drinking water sources.
Alternative 3 would prevent  surface contaminant migration from the
Site  and  could   minimize   contaminant   migration   through  the
groundwater,  but would require permanent dewatering of the disposal
trench and discharge of untreated groundwater to the pond and
wetlands.   This could  result  in adverse  environmental  impacts.
Alternative 6 would 'reduce the chance of  contaminant migration to
other  environmental  media  by  destroying  most  of  the  organic
contaminants of concern.  Any contaminants not destroyed would be
encapsulated in  a  glass-like mass that  would be  insoluble and,
therefore, not be likely  to  leach contaminants.    Subsequent
covering of the Site with clean fill would eliminate the potential
for physical  contact with the vitrified  mass.

B.  Compliance with ARARs

Waste constituents are present  in the soils at the  Site but are
not currently present  in the groundwater or surface water.   There
are no chemical ARARs  for soils,  but there are  federal  and state
regulations for groundwater and surface  water.   Alternatives 4, 5
and 6 would eliminate the potential  for  cross-media impacts which
could result in exceedances  of  these ARARs,  whereas Alternatives
1 and 2 would  likely  not aeet ARARs  in the event  of  a release of
contaminants from the Site.   Permanent dewatering of the disposal
trench under Alternative 3 would not be  expected to result in the
exceedance of  ARARs  for groundwater, but could exceed discharge
limits for solids, turbidity, etc. into  the  wetlands.   Temporary
dewatering of  the  disposal  trench under Alternatives 4, 5 and 6
would  also   have   to   comply   with  surface  water  discharge
requirements.

Concerning location-specific ARARs,   Alternatives  2  through 6 may
involve remedial activity at or within the  perimeter of a 100 feet
buffer zone  of  the pond/wetlands.    These  activities  would  be
performed  consistent  with   accepted practices   to  protect  the
wetlands.   The excavation of soil and waste  under Alternatives 4
and 5 would occur just outside of the 100 feet buffer zone.

Alternatives 4,  5, and 6  would  involve  action-specific  ARARs.
Alternatives 4  and  5 would be subject to New York State and federal
regulations  regarding  transportation  and  off-site  treatment/
disposal of wastes.    Also,  in the case  of Alternatives 4  and 5,
the variety  of contaminants at  the  Site  will require a specific
disposal regime.  This will be done as ARAR determinations are made
regarding disposal under RCRA LDRs.   Alternatives 4 and 5 involve
the excavation  of  contaminated  soils on-site,  and  would require
compliance with fugitive dust,  VOC emissions regulations, as well

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as  RCRA   Dilution   Prohibition   regulations   regarding   waste
segregation.   In  the case of Alternative  5  (thermal treatment),
compliance with air  emission standards would be  required  at the
off-site treatment facility.   In the case of Alternative  6, on-
site treatment would be subject to ARARs for air emissions during
the vitrification process.  Treatment of off-
gases may be required to  meet the requirements  of New York State
Regulations for Prevention and Control of Air  Contamination and Air
Pollution and must comply with New York  State Air Guide—1 for the
Control of Toxic Ambient Air Emissions.

C.  Long-Term Effectiveness and Permanence

Alternative 1 would involve no controls and,  therefore,  would not
be effective in permanently preventing exposure to contaminants on-
site or eliminating the potential for contaminants migrating off-
site.   Alternative  2 could  be  effective  in  preventing  direct
exposure  over  the  long-term,  but  would not   be  effective  in
protecting  against migration  of  contaminants  off-site and the
resulting  exposure.   Alternative 3  would be  effective  against
contaminants migrating  from the  Site,  but potential groundwater
contamination may adversely  impact on the pond/wetlands.  Also, the
installation of a  permanent  dewatering  system could have  a long-
term impact on the agricultural  field.   Alternatives 4 and 5 would
be fully effective and  provide  permanent remediation by removing
the wastes from the Site.  Alternative 6 would be highly effective
in protecting against on-site exposure  and off-site migration.

D.  Reduction in Toxicity. Mobility or  Volume

Alternatives  1 and  2 would  provide no  reduction  in  toxicity,
mobility or  volume.   Alternative 3 would  provide  a reduction in
mobility of  the  wastes,  but no reduction  in toxicity or  volume.
Under  Alternatives  4  and  5,    contaminants  would  be  removed
completely.   However,  land disposal  (Alternative 4)  would not
reduce toxicity  and  volume of  the waste,  but  would control and
manage the mobility of the contaminants (as the material would be
treated or placed  in  a  secure facility).   In the case of  thermal
treatment  (Alternative  5) ,   an  overall  reduction  in volume and
toxicity  would be achieved,  as  well  as elimination  of  waste
mobility.     Treatment   (stabilization/solidification)   of  the
subsequent ash/residue/soil, prior to disposal  in an appropriate
landfill, would control  and  manage the mobility of any remaining
contaminants.   Under Alternative  6,  the  organic contaminants of
concern would be destroyed or encapsulated. The  nobility potential
of any residual contaminants would be greatly  reduced or eliminated
by  encapsulation  in  the vitrified  mass.    As   a   result  of the
vitrification process, the  total  volume of contaminated soil and
debris would be reduced by 25-45%.

E.  Short-Term Effectiveness
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Alternative 1 would  be ineffective in protecting  against  direct
on-site exposure  to  contaminants  and in protecting  against  off-
site  migration  of  contaminants.    Alternative  2  would  readily
protect against  direct exposure on-site,  but  would not  address
short-term migration of wastes off-site.  Alternative 3 would have
a  minimal  adverse  environmental   impact  during  capping   and
installation of  the  dewatering  system.   However,  the  impact  of
pumping untreated groundwater into the pond/wetlands could  be  a
significant short-term  concern.   Alternatives  4  and 5 would  be
expected  to  have minimal  adverse  environmental  impacts  during
excavation  and   temporary  dewatering  operations.    Appropriate
measures would be taken during excavation to prevent transport of
fugitive dust and exposure of workers  and  downgradient  receptors
to volatile organic  compounds.  Alternative  6 would be expected to
have  minimal  adverse  environmental  impacts  during  dewatering,
construction,  and operation.  The remaining remediation activities
under alternative 6  would take place  in the  trench area and in the
adjacent  land  between  the trench  and Route  12B and would  have
minimal adverse effect.

F.  Implementability
• .
Alternative 1 would  be  easily implementable,  as only groundwater
monitoring is  involved.   Alternatives 1,  2,  3 and  6 would  each
require  groundwater monitoring  for  30 years  and  beyond,  and
Alternatives 4 and  5 would require monitoring  for  only one  year
each.  Under Alternatives  2 and 3  permanent securing of the Site
would  be  easily  implementable  but  final  agreement  on  deed
restrictions could be  lengthy.   Alternative 3  would be the  most
difficult to implement.  The installation of a permanent dewatering
system could have and adverse impact on the adjacent agricultural
property, this requiring compensation,  and groundwater  discharge
to  the  pond/wetlands  would  require a  New York  State  Pollution
Discharge Elimination System permit and state and federal approval
to  discharge  into  wetlands.   Alternatives 4  and 5 use  proven
technologies,   established   administrative   procedures,    have
sufficient facilities available  for disposal and, therefore, would
be  easily implemented.    Alternative  6 would  be  implementable
provided  treatability  studies demonstrate  adequate effectiveness
of this technology for the Site.   Administrative activities would
include  securing  electricity  for  the  process,  obtaining  and
coordinating  subcontractor activities,  and  providing  adequate
safety for the Site during remediation.

G.  Cost

Estimated present worth costs range from a  low of $528,500 for no
action with groundwater monitoring (Alternative 1)  to  a  high of
$1,551,800 for in-situ vitrification (Alternative 6).

H.  State Acceptance
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NYSDEC concurs  with  the  selected remedy,  Removal and  Off-Site
Treatment/Disposal  (Alternative   4)  and  also  concurs  with  the
contingency  remedy,  Removal  and   Off-Site   Thermal  Treatment
(Alternative 5),  if the selected remedy cannot be implemented.

I.  Community Acceptance

The community has expressed strong support for  the selected remedy,
Alternative 4 and  also  for Alternative 5 the  contingency remedy,
both of which  involve removal of the  waste from the site.   The
Village of Hamilton,  whose citizens  are  in the closest  proximity
to the Site, passed a Resolution endorsing the selected remedy.
A similar resolution was passed by both the County of Madison and
the Town of Eaton.

The community  comments  and  concerns received during the  public
comment period are identified and addressed in the Responsiveness
Summary,  which is attached as Appendix 5  of this document.

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 4, Removal and Off-
Site Treatment/Disposal, is  the  appropriate remedy for  the Site.
The major components of the selected remedy are as follows:

-  Approximately  1,250 cubic  yards of contaminated soil and debris
will be excavated  from the trench and transported to a permitted,
RCRA-compliant facility for treatment/disposal.

- The  drums containing wastes generated  during  the RI will be
transported  to  a  permitted,  RCRA-compliant  waste  management
facility for treatment/disposal.

-  The  water table in  the  disposal  trench  will  be lowered to
facilitate removal  of the  soil and waste.  This will be done by
installing a dewatering trench along  the  west  side of the disposal
trench and pumping continuously.    The  discharge  water will be
pumped (and  treated,  if necessary)  to an upgradient infiltration
trench or pit for recharge  to the groundwater.   This would be done
in accordance with state and local discharge requirements.

- The monitoring well in the  center of the  disposal trench will be
removed to facilitate the excavation.

-  Confirmatory  analysis will be performed after  excavation to
verify the complete removal of contaminants. Cleanup criteria will
be based on  background  levels found  in off-site samples obtained
from both  the former  railroad bed and native  soil  samples.  Upon
confirmation that  the  contaminated  soil   and  debris  have  been
removed,  the excavation will  be backfilled  with clean  fill and the

                                16

-------
Site will be revegetated.

-  The six  monitoring  wells  at  the  Site  and the  eight  local
residential wells will be tested on a quarterly basis for a period
of one year following completion of  site  remediation.    If  site
contaminants are detected in the  groundwater,  monitoring  will  be
continued  and  if  levels  contravene  drinking  water  standards,
corrective action will be instituted.

- A wetlands assessment,  500-year  floodplain assessment,  Stage  1A
cultural  resources   survey,  and  consultation  with   the  Soil
Conservation Service concerning potential  impacts  to ecologically
significant agricultural lands,  will  be  undertaken,  as  necessary,
during the remedial design phase.

Because  of the  variety  of contaminants  at  the  Site  (various
organics and lead), their uncertain volumes and distribution, and
possible treatment  requirements, an exact disposal regime will have
to be determined in the  RD  phase.  Testing  of  the  excavated  soil
and debris during  the RD will  be  by  TCLP analysis.  If all  or a
portion of the soil and  debris is  classified as a  RCRA hazardous
waste, for the contaminants  that would require thermal destruction
as a treatment under the RCRA LDRs, the  waste may  be disposed of,
without treatment,  in  a permitted RCRA-compliant minimum technology
hazardous waste  landfill.   This can  be done before May  8,  1992
under  a  National  Capacity  Variance  for  Third-Third  wastes.
Disposal after May 8,  1992  would  require treatment in  accordance
with  LDRs.   If the soil  and debris,  after testing, is  found  to
contain wastes which,  under  LDRs,  require a  form of treatment other
than thermal treatment, the necessary treatment will be conducted
at a permitted, RCRA-compliant off-site facility (on-site treatment
is not practical)  prior to  off-site  disposal.   This can  be  done
through a soil and debris Treatability Variance up until the time
that final treatment standards are promulgated for soil and debris.
Conversely, that portion of the soil  and debris not classified  as
hazardous  by  the  TCLP  analysis  can  be disposed  of  in  a  RCRA
Subtitle-D facility.

For estimation  purposes  and  to  account  for different  disposal
regimes,  the present worth cost for this alternative presumes  that
all of the contaminated  soil is RCRA  hazardous waste and will  be
disposed of at a land disposal  facility without treatment, under
a National Capacity Variance.  This cost is intermediate between
the possible lower costs afforded  by  Subtitle-D disposal  and the
additional costs for any required waste  treatment.

In the unlikely event  that the selected remedy, Alternative 4, can
not be implemented  before the RCRA LDR deadline  of May 8, 1992, the
contingency remedy, Alternative  5, would  be implemented  in  its
place for the portion of the waste classified  as  hazardous based
on organics.  Any portion of the waste based on inorganics (i.e.,
lead)  alone would  be  treated  according  to  LDRs.    Alternative 5

                               17

-------
involves the same on-site  remediation  activities  as  the selected
remedy.

Renediation Levels

The purpose of this response action is to reduce the present risk
to human health and the  environment  due  to  the contaminated soil
and debris in the disposal  trench at  the Site.  The excavation and
removal of contaminated waste material and soils will reduce both
the carcinogenic  risk and non-carcinogenic hazard to acceptable
levels and will restore the Site to a fully useful state.

This response action will also ensure protection of the groundwater
used for drinking water by the twelve residences in the immediate
vicinity of  the Site and  will  ensure protection of  the surface
water which drains into the adjacent pond and wetlands.  The pond
ultimately drains into Woodman Pond, a back-up potable water supply
for the nearby Village of Hamilton.

STATUTORY DETERMINATIONS

Under  its  legal  authorities,  EPA's  primary   responsibility  at
Superfund  sites is to  undertake  remedial  actions  that achieve
protection  of  human  health  and  the  environment.    In addition,
Section  121  of  CERCLA  establishes   several  other  statutory
requirements and preferences.   These specify  that when complete,
the  selected remedial  action  for  this  site  must   comply  with
applicable  or  relevant  and  appropriate  environmental standards
established under federal  and state environmental laws unless a
statutory waiver is justified.   The  selected  remedy  also must 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
waste as their principal element.  The following sections discuss
hov the  selected remedy and the  contingency  remedy  meet these
CERCIA Section 121 requirements.

Protection of Human Health and the Environment

The selected remedy and the contingency remedy will protect human
health and the environment  by complete  removal of the contaminants
of  concern  from  the  Site.    This  will  reduce  the  current
carcinogenic risk of  2x10^ to much lower levels  and will reduce
the non-carcinogenic  hazard  of  4 to an  acceptable level of less
than one.

Conplete removal of contaminants from the Site will also remove a
substantial threat  to local drinking  water supplies  and  to the
back-up drinking water supply for the Village of Hamilton, as well
as  eliminating  the continuing  threat to  the  adjacent  pond and

                                18

-------
wetlands.   No unacceptable  short-tern  risks will  be caused  by
implementation of the selected remedy or the contingency remedy.

Compliance with Applicable or Relevant and Appropriate Requirements

The selected remedy, removal and off-site treatment/disposal,  and
the contingency  remedy,  removal and  off-site thermal treatment,
will comply  with all  chemical-,  action-,  and  location-specific
ARARs for remediation of the Site.   Although there are no chemical-
specific ARARs for soils,  there are federal and  state regulations
for  groundwater  and  surf-ace  water.    The  complete  removal  of
contaminants  will  prevent  a  release  of  contaminants  to  the
groundwater  or surface water and assure  compliance with  these
regulations.  The selected remedy and the contingency remedy will
comply  with  location-specific ARARs  concerning activity  in  the
vicinity of wetlands, and with action-specific ARARs i.e.,   state
and  federal   regulations  regarding  transportation  of  hazardous
wastes and their treatment/disposal (RCRA).

Cost-Effectiveness

The selected  remedy  provides overall  effectiveness  proportionate
to its cost,  and  is the most cost-effective of the six alternatives
developed  for the  Site.    While  not as  cost-effective as  the
selected remedy,  the contingency  remedy is  cost-effective.   The
selected remedy and the contingency remedy achieve risk reduction
rapidly, are  easy  to implement and with  the  complete removal of
contaminants  from  the  Site,  eliminate  long term monitoring  and
review.
                         0
Utilization  of  Permanent   Solutions  and  Alternative  Treatment
Technologies to the Maximum Extent Practicable

EPA and  New  York State have  determined that  the  selected remedy
and the  contingency  remedy  represent  the  maximum  extent to which
permanent solutions and treatment technologies can be utilized in
a cost-effective manner for the Site.

The selected  remedy  and  the contingency remedy will  result in a
permanent   reduction  in   toxicity,  mobility   and  volume   of
contaminants at the Site, greater  than the containment and in-situ
vitrification  alternatives  and  equal  to  the removal and off-site
thermal   treatment   alternative   (contingency   remedy).     The
contingency  remedy  affords greater  reduction  in  volume,  but at
greater  cost,  and even greater  costs  if  disposal  of the residues
is  considered.   The selected remedy and the contingency remedy
achieve protection of human  health and the environment  in a shorter
time period and  are  more easily implemented than  the containment
and in-situ vitrification alternatives.

Preference for Treatment as a Principal  Element
                                19

-------
The selected remedy addresses  the  principal  threats posed by the
Site through land disposal, although, depending on the results of
the  TCLP testing,  a  portion  or  all  of the  waste may  require
substantial  treatment  (e.g.,  solidifcation/stabilization,  soil
washing, etc.).  The contingency  remedy may require post-treatment
of the  ash/residue.   The statutory  preference  for remedies that
employ treatment as a principal element will not be satisfied for
those scenarios where treatment  is not  required under LDRs. How-
ever, even  under those  scenarios,  the  selected remedy  will  be
protective of public health and the environmemt.

DOCUMENTATION OF SIGNIFICANT CHANGES

There are no significant changes  from  the  preferred alternative
presented in the Proposed Plan.
                                20

-------
FIGURES

-------
s--   \   ?M
                                              VILLAGE  OF HAMILTON
2000"
                      200
-------
FIGURE 2
           C.&JD/SPOSAL  S/TC
                SAMPLE. LOCATION MAP
              EATON d)>  MADISON Co.
                                                           nmnmin
                                                          RESIDENTIAL
                                                      SAMPLING LOCATIONS
                                                             C & J DISPOSAL SITE
                                                             Disposal Trench

                                                              feet by 40  feet)
SOURCE: NYSDF.C/
NUS CORPORATION
                                       WEHI1AN • NEW YOflK, INC.

-------
TABLES

-------
                             TABLE 1
                        CSJ  DISPOSAL SITE
         CONTAMINANTS - KA3IMUM DETECTED CONCENTRATIONS IN SOIL


                                            Concentration
     Contaminant                               (uo/kq)	

     bis (2-ethylhexyl)  phthalate            29,000,000

     di-n-octyl phthalate                       220,000

     di-n-butyl phthalate              .         110,000

     butyl  benzyl phthalate                      19,000

     4-nethylphenol                              17,000

     2,4-dinethyl phenol                            210

     benzene                                      5,900

     ethylbenzene                              190,000

     toluene                                   650,000

     xylenes                                   560,000

     4-aethyl~2-pentanone                      1,100,000

     2-butanone                                250,000

     1,2-dichloroethane                           8,400

     trichloroethene                              3,000

     lead                                           637*
* mg/kg

-------
                                                  Table 2
                                        C&J DISPOSAL SITI!!
               SUMMARY Of PARAMETERS FOR SELECTION OP CHEMICALS OF CONCERN
Parameter
Benzene
Toluene
Etliylbciuenc
Total Xylcnes
4-Methylphcnol
2.4-Dimethylphcnol
di-n-Dulylphthalate
Dutylheniylphthalate
bis (2-Ethylhexyl)phthalate
di-n-Octylphthalate
Maximum
Concentration
d'y'M
Watte Piles
5900 t
650000 OJ
190000 J
5f>0000 J
17000 J
210 J
110000
19000 J
29000000 DJ
220000 J
Detection limit
(l'9/ku)
15000
15000
15000
15000
24000
420
24000
24000
2400000
24000
frequency of
Detection
1/5
1/5
1/5
1/5
4/5
2/5
4/5
5/5
5/5
3/5
Maximum
Concentration
(t'U'M
Surface Soils*
U
U
U
U
U
U
120 J
U
150000 D
U
Detection l.linlt
(iMl'M






430

11000

Ficquenry of
Detection
0/10
0/10
0/10
0/10
0/10
0/10
1/10
0/10
2/10
0/10
* Does nol include samples SS 01 and SS 02, which are upgradient of the site.

Dafa Qu.i/iYi'ers:
  0 - Analyte found in associated blank as well as sample
  J - Value is estimated
  D - Compound identified at a secondary dilution factor
  U - Compound was not delected

-------
                           Table 3
             ORAL  CHRONIC REFERENCE  DOSES
Parameter
Benzene
Butylberuylphthalate
di-n-Butylphthalate
2.4-Dimethylphenol
Ethylbenzene
bis (2-Ethylhexyf)phtha!ate
4-Methylphenol (p-cresol)
di-n-Ottylphthalate
Toluene
Xylenes (total)

RfD
0.0007
0.2
0.1
(O.ooca)* 0.02
0.1
0.02
0.05
0.1
0.3
2

Notes:
  HQ
  Exposure
  RfD
Hazard Quotient  = E*posure/'R'D
Average daily intake (mg/kg/day)
Reference dose for chronic intake (mg/Vg/day)
                RfD used in  dermal risk  calculation  only

-------
                                       Table 4
                               C&J DISPOSAL SITE
                   SUMMARY OF MULTIPATIIWAY CHRONIC HAZARDS
Parameter
Ron/cne
Dulylben/ylplitlialatc
(Ji-n-llulyl|>lillialate
2,4 Dimetliylphcnol
Elliylbun/enc
bii(2-[lliyllioxyl)ph»lialatc
4-Mctliylplicnol (p crcsol)

-------
                          Taile 5
         ORAi  CARCINOGENIC  POTENCY  FACTORS
Parameter
Benzene
Butylben/ylphtholale
di-n-Gulylphthalate
2.4-DimelhyfphenoI
Ethylbenzene
bis (2-EthylhexyQphihalate
4-Melliylphenol (p-cresol)
di-n-Octylphiholote
Toluene
Xylenes (total)

CPF
0.029
-
-
-
-
0.014
-
-
-
-

Notes:
  Risk
  Exposure
  C?F
Exposure xCPF
Average daily intake (mg/kg/day)
Cardnogenic Potency factor (mg/kg/day):'

-------
                    Table 6
           C&JDISPOSALSITIC
SUMMARY OF MULTIPATHWAY CARCINOGENIC RISKS
Parameter
nerwene
nutylhonzylphthalnte

-------
               TaLble 7
            C&JDISPOSALSITE
COMPARATIVE ANALYSIS OF REMEDIAL ALTERNATIVES
AJternative
1. No Action
2. Limited
Action
3. Containment
4. Removal
and Off-She
Treatment/'
Disposal .
5. Removal
and Off-Si:e
Thermal
Treatment
6. In Situ
Vitrification
Protection
of Human
Hearth and
Environment
None
Moderate
Moderate
High
High
Potentially
High
Compliance
with
ARAKs
No
No
No
Yes
Yes
Potentially
Yes
Reduction
in Toxicity.
Mobility or
Volume
No
No
Mobility
Toxicity
Mobility
Toxicity
Mobility
Volume
Toxicity
Mobility
Volume
Short-Term
Effectiveness
None
Moderate
Moderate
High
High
Moderate
Long-Term
Effectiveness/
Permanence
None
Moderate
Moderate
High
High
Moderate to
High
Implement-
ability
High
High
Low to
Moderate
High
High
Moderate
to High
Cost
(S)
528,500
558,500
712.500
672.400
1.219,500
1,551,800

-------
APPENDIX 3 - ADMINISTRATIVE RECORD INDEX

-------
G3/".5/r"                              !-cex :coj-er.: Vjrc«r Crcer                                                Page:  1
                                      C 4 J IIS^SAL Cc
       .: lurrxr: C.O-OO'.-OOC'.  To CC01                                                 Oa:e: 01/29/27
Titlt: C.ttze.-  fcr-areir^  t"e  Sits Inspection iepcrt and  :.u.e :j.a:ars Jariing  Systea documents fer
       t-< sits)
   >.t.Sc.-: F;rt3^,  ?ersr  S.:   Wi;: Ccrpcrat icn
iecipter.:: Ketsirj, Oti.-j:  'JS H-i
 A-.ticr.e-: C.~ -001-COC2
..... .. [[[ A.
Ooc--ne-.: «U3>;-:  C:3-OC', -OCZc  To OU3                  ?ar-r.t: CJD-CO', -CC01           Ca:e: 01/29/37
Ti;:-: Fir*!  :.-af:  Site Ins^fction Repcrt and hazard Rarjrin;  Sys tea Model  CSJ  Oispcsal  Site, Haailtcn
     Ty?:: tZ.:CR7
   X'-t-1-^.-: JUrtor.,  Peter S.:   »,'S Ccrpcra:ion
i e-: ' p i er : : ncr« :  US  L: A
            ±>!.-:  C:0-CC1-0'.— To 01C3                                                 Date: 10/03/15

Title: Preliminary
     Type:
   JLrthcr:  ncne:   US E=A
Recipier.t:  ncne:   none
 A: tachec:  C.T5-001-OU9   C.'0-OOI-OISO   CJO-001-0151    CO-CX31-0153    CJO-C01-0157   C-'0-001-0133   CJO-001-0159
            C.D-OO1-0161

Docjtsr.l  fcj=bcr:  C-T>-C01-C%9 To 01i9                   Parer.t:  C.'3-001-01Ci          Date: 10/2i/25

Title:  0*e3c detailing tan'. ing and  investigation trip  to  four  HTS  Region 7. sites,  including CiJ
        Disposal  site, on October 1-3, 1985)
      Type:
 Csrcitian  HISSIVj ATTAC:-*Z:'4T

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    ,15/91
Index Document K^rber Cruer
C I J DISPOSAL Docuaents
                         Page: 2
 Docxrent Ku*>er:  CJO-001-0150 To 0150                  Parent:  CJD-C01-01U          Date:  C2/12/36

-Title: (Letter responding to Request for Infonaation for the CiJ  Disposal  site, Site ID K-«t±er  727CCX)

      Type: COMESPOCEXCE
 Condition: HISSHTC ATTACHHEXT
    Airthor: Goddard, Charles H.:  KY Dept of Environraental Conservation
 Recipient: Rathbooe, John:  Village of Haailton - Municipal  Utilitits  Cemission


 Docuaent Hu*«r:  C,T)-001-0151 To 0152                  Parent:  CJO-C01-0'4i          Dats:    /   /

 Title: (Photographs taken at CiJ Disposal site)

      Type: GRAPHIC
    Author: none:   none
 Secipiesit: none:   none


          Mi«ber:  CJD-001-0153 To 0156                  Parent:  CJD-001-014A          Date:  10/07/82

 Title: Organic* Analysis Data Sheet (for soil samples)

      Type: DATA
    Author: none:  EXSCO
 Recipient: none:  US EPA


 Docuaent Bv«t*r: CJO-001-0157 To 0157                  Parent:  CJD-001-0144          Date:  C5/01/86

 Title:  (Meao  recaonending action to review a barrel reooval  project at CSJ Disposal site)

      Type: COR££SPOO€XCE
    Author: Deiick, Walter:  US EPA
 Recipient: Kelly. Kevin:  US EPA
  Docuoent Kuxxr: CJD-001-0153 To 0153

  Title:  (Kevo i u HT» iiling a barrel reaoval progr

      Type: CORK£SPOND€XC£
  Condition: MISSING ATTAOflCXT
     Author: Goddard. Oarles «.:  US EPA
  Recipient: King, David:  US EPA
                  Parent: C-T)-C01-014A
              at the CSJ Disposal site)
Date: C5/15/S6

-------
02/15/V.
                                      Index Oocvsaesi: KLrr*r C.—er
                                      C  t  J 3IS2CSAI Doc--nents
                                                                                                               Page:  3
Cocu=eflt Muroer: CJD-C01-0159 To 0160
                                                       Parent: C.;-CO'.-31C:
                                                                                     Ca:e: C6/29/S7
Title: (Heno forwarding attached registry  charge  s>.«t. prcpcsi.-.s that CiJ Disposal site t« rec'.assi f ie.arl« W.:  US  EPA
Hr::piem: Cress, Larr-/:  US £?*
Coc-jaer.t HLrc«r: CJD-001-OT61 To 0162
                                                       Fzrent: C.'3-CO:- j'.~
                                                                                     Oa:e:   /  /
Title: tractive Hazardous Waste Disposal  Repcrt  (f:r CiJ Disposal sit;)

     Type: RE?CST
   Author: none:  US £?A
Recipient: none:  US E?A
Oo
-------
   15/71
Index Dm-rant Xtcber Crcer
C I J DISPOSAL Docuaems
         Kircer:  CJD-001-0187 To 0361                   Parer.t:  CJ3-001-01SS          Date: Oi/01/2?

Title: Saecling and Analysis Plan (SAP) for RI/FS CiJ Disposal  Site Eaton, New Tort

     Type: PLAH
   ALTthor: Buidobro, Patio:  Ebasco Services
Recipient: none:   US EPA


Docaent tusixr:  CJD-001-0362 To 0363                                               Date: C3/C9/i?

Title: (Letter forwarding copies of the RI/FS Work Plan)

     Type: CORK£S?OBENC£
   Ai-lhor: Sachdev, Oev R.:  Ebasco Services
Recipient: Alvi,  N. Shahe-r:  US EPA
 Attached: CJD-001-0364

               :  CJO-001-036i To 0462                  Parent:  CJO-001-OI62          Da:e: 03/C9/i9

      : Rl/FS Work Plan

     type: PVOi
   Author: Buidobro, Pablo:  Ebasco Services
Recipient: none:   US EPA


Doc^ent *uaber: CJD-001-0463 To 0606                                               Date: 01/01/91

Title: Volu*e  1: Remedial  Investisation

      Type: REPORT
   Author: Savino, Anthony:  Ebasco Services
Recipient: none:  none
         lluaber: CJD-001-0607 To

 Title:  (Remedial Investisation Report) Voluae 1A: Appendix; Appendices A -  H

      Type: REPORT
   Author: Savino. Anthony:  Ebasco Services
 Recipient: none:  none
                                                Date:  01/01/71

-------
C3/15/7*                              Index Ocor>ent Kurber u. ^c                                               Pegs: 5
                                      C 1 J OISrCSAL Ooc--r«ms
Coc--«r.t Hu±*r: C-ID-C01-1W7 To 1424                                                Date:  01/01/91

Title: (Seoe-diat Investigation Report) Volirae  13:  Appendix; Appendices H - K

     Type: REPCST
   Author:' Savino, Anthony:  Ebasco Services
Recipient: none:  rone


Dcxr-ner.t Kurccr: c:3-001-Ki5 To 1427                                                Da:e:  C9/13/90

Title: CLetter px-«entir^ MTSEC and t.k.e  M.T.  State  Oepartnent cf Health's eonrvents  on the  Draft
       RI Repcrt)
     Type:
   Author: Schick, Robert V. :  IfT Oept  of  Environmental Conservation
Recipient: Sir^eraan, Joel:  US E?A
Coc-j«r.t Hvri>;r: C.-D-C01-U22 To  1422                                                Date:  02/20/E?

Title: (Letter regarding consent  for  iccevs  to property  in orcer to perfona sampling  activities)

     Type: CC*A£S?O*OENC£
   Avthor: Picariello, Claries:   C  (  J  Leasing Coopany,  Inc.
Recipient: Schlagel. Joel:  US EPA
 Attached: CJD-001-U29

Oociaent Musber: CJD-001-U29 To  U30                 Parent:  U>-Q01-U23'          Date:  11/02/28

Title: (Letter requesting  access  to site parcels to perfora Rl  activities, with  attached consent
       fora)

     Type: CZR2ES7QNDEMCS
   Author:  Schlagel.  Joel:  US EPA
Recipient: Picariello, Diaries:   C  I  J  Leasing Canpeny,  Inc.


Docuaent Uixcer: CJO-001-U31 To  1521                                                Date:  01/01/91

Title: Voline 2: Feasibility Study

     Type: REPORT
   Author: Savino,  Anthony:  Ebasco Services
Recipient: none:  US EPA
 Attached: C,T>-001-1522    C,1)-001-1531

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                                      Index Doc-jaent Number Croer                                              Page: 6
                                      C i J DISPOSAL Docusents
Coer-ner.t Munber: CJO-001-1522 To 1530                  Parent: CJD-C01-1431          Dste: 01/01/91

Title: Sixer-fund Proposed Plan - C I J Disposal Site, Towi of Eaton, Ksdison Ccinry. Kev Ycrt

     Type: PtAX
   Author: none:  US EPA
Eec:pier.t: none:  none


Docxoent luK-er: CJD-001-1531 To 1531                  Parent: CJD-001-1431          Date: 02/19/91

Title: (Letter stating support for Alternative 4 or Alternative 5)

     Type: COttESPOKDENCS
   A^hc-r: tuiper, Robert H.:  Rod i son County Board of Sirervisors
Bec-pier-.t: O'Dell. Jack:  US EPA
   --nent *j±xr: CJD-001-1532  To 1532                                              . Care: 01/30/91

    e: CXeao regarding New York State DOH coaxnent  and  review  of Prcposed Reraedial Action Plan (PRAP)
       for C & J Disposal site)

     Type: CCRRESPCMDEHCE
   Author: Block, Arthur:  US  Dept  of Health  t Hunan Services
Recipient: O'Dell, Jack:  US EPA
         KLBber:  CJD-001-1533  To 1534                                               Date: 01/24/91

 Title:  (Letter  regarding  CiJ Disposal site,  Eaton (T),  Kadison Cou-ity  site No. 7-27-OC4, Prcposed
        Eeaedial Action Plan (giving HTSOEC concjrrence  with  PHAP  and offering cements on Record of
        Decision)

     Type: CORAESPCICEJJCE
    *i.thor: Sulliven,  Eduard 0.:   KT Dept of  Environmental  Conservation
 Rec-:?ier.t: Tsiaais, Ciristos:  US EPA

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G/"3/~                              I.-cex Iccuaer.t KLRC*.- Crier                                               Page:  7
                                      C 4 J OISPCCAL C3C--r>er>:s
         v-™-*-- CJC-30Vi533  To 1537                                                ta:j: 11/30/90

Title: (Letter prcv-::ir«; i  -turits on the Draft Feasibility Stucy review by HTSTEC end IfTSSCH)

     Type: C3UI SOC EXC;
   JL.-r-.cc: Sc^.ick, irc^r-: W.:   IfT De-pt of E/^viroreiental  Conservation
itcipier.:: Sir»;?raar, Jo»l:  US tr*
                 CJC-OO1- 1535 To 1541                                                Dz:»: 11/27/90

Title: C^-s» disctjssins  feasibility SV-cry praje^:: review ne»tin? held on November 20, 1590.  List
       oi ztterrie^s jrt-
         : S^vino, *j".t±>onr:   rba^cs Services
         : O'^ell. Jaci:  US  L?A
       -.t rjtxser: CX-001-15«i2 To 15-42                                                Date: 10/U/S3
Title: (Letter respcndin;  to Septeaser 13. 19S2 letter revesting current and fct-jre action of C
       I J Disposal site and providing tpcUte of status of activities at the site)
     Type:
Canditicn: HISSIHG ATTAC3CXT
   A^-^or: BA^onn, Kelvin:   US E?A
£ec-pient: Lir-in. 6di-y A.:   BY Dept of Health
Do- rant fc-ccj-r: CJC-001-15i3 To 1544                                                Date: 09/13/SS

Title: (Utter dis=jssins  questions ttat haft arisen pertaining to the status vx! prosr-ss of the
       *ite  irrvest: jatior/reoetiiation, reojesting copies of reports and an updated starts of the site)
     Type:
   /L.-t*»r: Litwin, Gary A.:   KT Oept ef Health
Ze=:pierrt: K«an. Ciroline:   US E?A

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    S/91                             Index Docjaent Kunber Order                                               Pace: 8
                                     C S J DISPCSAL Doc-jaents
      r.t Kvrccr: (UTJ-OOI-IS-S To 15^3                                                Date: 07/C4/90

Title: Sespcrs* to Succleoental Request for  Information

     Type: CORifSPOCOCE
   Author: V«ton, Alan F.:  Occidental Cheaical
Recipient: Miles, Jan:  US EPA
 Attached: C.-D-001-15-i9

Docjaer.t MLiaber: CJD-001-l5i9 To 1W9                  Parent: CJO-001-1545          Date: 01/OS/8*

T::le: (Letter discussing disposal of solid  uzste dcring  19SO, sutnitted with S^ppleaental Rerpcrsse)

     Type: CCRJl£;?C»a;£)iC2
   Ai.thor: Ailing, E.3.:  ncne
Bj^ipier.:: none:  KJ Sweau of Uaste Managejaer.t
       -.t H«CE
Condition: MISSIKG ATTAO9CXT
   Author: Roaen. Oiristine M.:  Bridgestone/Fir«stone,  Inc.
E-cipient: Beausejour. Kafalie:  US  EPA
      r.t lumber: CJO-001-1532 To  1552                                                Date: 06/04/90

Title:  (Letter  resarding  extension  of  tiae  to  respond to  Request for Information)

      Type:  COMES?Oe>O
-------
03/15/rl                              IrtUi Ccxr-raer.: Wuroer Crier                                               Pa==- 9
                                      c i J DISPOSAL Doc-.r«nts
Ccojaer.t rjne.-: CJD-3G1- '.535  To 15:6                                                Date: 06/14/90

Title: (Seipors-i ts  —A's  April  26,  199C,  tetter recuestir-; infc.^at icn concerning t!-.e sale of  a
       fcraer 5.*-aoes:3Te/r irestor*,  Inc.  facility)


Conditicn: )«tS::
-------
  715/91
Index Docuaer.t Kiccer Crcer
C t J DISPOSAL Dcoxjer.ts
                                                                                                             Pace:  10
Oocuaent Berber: CJt>-001-'571 To 1533                                                Date:  CS/TO/S9

Title: Request for Inforsaticr. Pursuant to Section 1C4 of dCUA and Section 3CG7 of  RC5A

     Type: CORRESPONDEHC
   Author: Luftig, Stephen D.:  US EPA
Recipient: Hevin, J.J.:  Bridgestorie/Firestone, Ire.


Docuaent MLrfcer: CJD-001-15S1 To 1528                                                Date:  07/25/S9

Title: (Response to 104
-------
                                      Iroex Docvner.t  i\ccxr Cr-^er                                               Page: 11
                                      C £  J DISPCSAi  Ccc-.-cer.ts
Oocuaer: luaoer: C.'0-00'.-'!6i4 To 16*1                  ri.-er.:: CJD-C01 -16C3          Ca:e:  C6/22/S9

Title: (Litter fcraarsing arswtrs to question  3 of  the Issues: fcr Infcr=aticn Letter)

     Type: COttf SPOKE E«C£
   AutJyy: Picariello, Charles:  C I J Leasing Conpiny.  Inc.
Rec-pier.t: Kiles, Jca.n:  US £?A
                : C.'0-001-U'.2 To 16%                                                Date:  01/Z:/S9

Ti:le: (Lerrtr  asting t>.«t E?A be grantee  acrti-s  t: p^rt-ls  127-1-Z5 a.-d 137-1-27, on  the  C S  J  Disjxsa!
       site, to perform 81 activities)
     Type:
   Aire>cr: Schta^el, Joel:  US E?A.
 ecipier.t: Pitariello, Ovirles:  C I J Leasing Cootiny,  Inc.
      r.t tvaoer: CJO-001-14'5 To 16".9                                                Date:  Oi/Zi/90

Title: SLppleaental Bequest for Irrfcrnation; C t  J Oispc&al Site

     Type: CSX£S?OCaC£
   Author: luftig, Stephen 0.:  US E?A
Recipient: Aurott, Secr^e V.:  8ridsestor«/F irestore,  Ire.
t>ocL«ent iLKier: CJO-001-1620 To 1629                                                Date: CK/ti/90

Title: Jequest for Information P-jrsuant  to Section  104 cf CiCLA and Section 3C07 of RC^, C  J  J
       Oispcsal Site, Eaton, lev Tort

     Type: CRR£S?affiE*CZ
   AirC-«r: Laftig, Stephen D.:  US E?A
Recipier.t: none:  Occibertal C-.
              r: CJD-001-1630 To 1630                                                Date: 01/29/90

Title: (tetter respording to a &*ce=t*r 21. 19€9  letter requestir.g infcrsation on the presence of
       federally listed endangered or threatened  icecies in the vicir.ity cf the site)

     Type: COlRfSPOCEUCE
   Aurrxx-: Cocin, Lecrard P.:  US Fish t Uilclife Service
Recipient: Sar^rore, Robert W.:  US E7A

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    |/91                             Index Dooxaent Nixfcer Order                                              Page:  12
                                     C i J DISPOSAL Docuaents
Document Huaber: CJD-001-1631 To 1631                                               Date:  12/21/89

Title: (Letter requesting a written stateoer.t indicating whether any endangered or threatened species
       Ulich are listed or proposed to be listed Bay be present in the project  area)

     Type: CORR£SPO*E*C£
Ccodition: MISSIHG ATTACHMENT
   Author: Hargrove, Robert U.:  US EPA
Recipient: Corin, Leonard P.:  US Fish & Wildlife Service
Doc-jnent Kuaber: CJD-001-1632 To 1633                  -                              Date:  05/05/89

Title: (Letter confirming a Kay 5, 19E9 telephone conversation and forwarding two Adrainistrative
       Orders issued by EPA pursuant to CEICLA, incomplete Administrative Crd«r attached)

     Type: CORRESPONDENCE
   ALthcr: Simon. Paul:  US EPA
Recipient: Picariello. Charles:  C C J Leasing Conparr/, Inc.
        c: CJD-001-163i   CJD-001-1639

Docuaent Kurber: CJD-001-1634 To 1638                  Parent: CJD-001-1632          Date:  C6/05/89

Title: Achinistrative Order (Index Mo. II CE2CLA-90216)

     Type: LEGAL DOCUMENT
   Author: Musrynski. Williaa J.:  US EPA
Recipient: none:  none


Docuaent Huit«r: CJD-001-1639 To 1643                  Parent: CJD-001-1632          Date:  05/05/89

Title: Achinistrative Order directing compliance with Request for Access (Index Ho.  II  CEJZCLA-90213)

     Type: LEGAL DOOJHEMT
   Author: Huszynski. Uillian J.:  US EPA
Recipient: none:  none

-------
OS/15/71                              Iroeji locjaer.t K-j»er C.-aer                                                Page:  13
                                      C I J 3IS?C£Ja Oco-nents
Docuaerit Ktrber: C,-0-001-16ii  To  16ii                                                Cate: 10/13/S9

Title: (letter fonarding  the  Conmniry Zelatiora Plan for the  C i J  Oispcsal  site)

     Type: CRAESPOCEXCH
   /Urthcr: £ack.dev, Oev a.:  Ebasco Services
Bec-pier.t: Alvi. X. 3;»ie
-------
                                      Irrie* Docvraent  Hurber Croer
                                      C I J DISPOSAL  Docuaer.ts
                                                                                                                Page:  14
Poc-jae-.t r-COb.-: CJ>XI1-',£73 73 *.i~                   Parsr.t:  C,t)-C01-1672          Date: 03/07/90

"Title:  (Letter  rj^a.— :ns ~A irrf &.-==:; oral visit  Ksdis^i Ciu-iry H^C-Heus release discussing the terch
        15,  19SC aeeti.ig with BEO a::acr.eO

     Type:  CXII3>>C€>iC;
   Airt-Sor:  Tcrt.s,  S-»v-r. J.:  Kac:.»cn Cou-.ry  Planning De^.-tae-.t
Recipient:  So-i^jaur,  fctalie:  US E?A


Doejae-.t K-JSCC-: CX-XI1-1676 7o ".£77                   Pa.-ir.t:  CJO-C01-16r2          Date: 02/13/91

Title:  Resiluf'o-.  iecarcirg D •; s?c-s ; t i cri of the CiJ  Dispc&a'. Sits

     Type:  UES«1 CXX^>EVI
   A^Sor:  too.-,  FTIC'.  C.:  VUl^;; of taailtoo.  Hew Ycrk
t ±c ; p i er. t :  ix^*e :   rw


       it K-ory-r: CX- 001-1673 To 1i73                   Par-it:  CJD-001-1672          Date: OZ/M/^I

Title:  CXe^spsper  «r:icle er.i::lec:) E?A slates rtnp site cltarxp  hearing at KCS

     Type:  CA:i^a^'J»CCKC£
   Author:  SterrBLT^.  Sus^n terry:  CSeranso Valley News
tecipient:  nons:   none


DociBent fcjnber: CJXXT1-167? To laW                   Par-it:  CJD-C01-1672          Date: 02/03/91

Title:  (₯e*spE?er  Article er.t:tlec':) E?A s^ecs cleanus at Eaton chemical site

     Type:  CDttSSOCOfCH
    Aithcr:  We'.r=h. ^ria T.:  Syrar-s* Gerald  Aaericin
tecipierrt:  nor»s:   rcne
         anr»i-; CX-OC1-16c'. To  '.6£1                   Fs.-ent: C:D-C01-1672

Title: C^svsfsper trtic'.e ertitlec:)  E7A secures deep sits
      Type: C3.T
    Author: none:  d^rango Yaile-j'  Mews
 tecipierrt: ncne:  rone
                                                                                       Date: 02/01/91

-------
                                            Cocuaer.t l^co-r Crier                                               Pa-e. 15
                                      C 1 J OI^CSAl Docuaert;
Co&aer.t Munoer:  C-"0-OC1-:6£2  To 16c3                                                Date: 0'./29/9',

Title: (Mevs  !eleas«  -  EPA  Proposes Zeaedy fcr SLcerfund Si:e in Eaten,  «-* Tc.-i)
     Type:
   Ai^-Sor: Harris,  Tvetts:   LS L=A
Zdipier.t: none:   none
          : C-'D-001 -16SA   CJO-'X'. -',
Cocujer.t ""-r»r-  c-,"0 • 00 1 - 1 t£A  Ta Idoi                  Parer.t:  C.'3-CC'. - '.632          Da:s: 0'./7?/T'

Title: (Mevsp^per article  entitled:) SJ^erfind site in Eatsr. plotis t?.4ri clei--xs>
     Type:
   AiTLSo<-: Welych,  Raria  T.:   S-JTSCLS* Hera 1 2 Aaerican
iecipier.t: none:  none
       -.t r_nc*r:  CJO-001-1625  To 16d7                  Parer.t:  CJ3-C01-1632          Date:

Title: (Kevspaper article  entitled:) EPA results of reoedial invest isatioryf eisibi I i ty st-jdy slated
       for  release

     Type:  CRKfSPOCEKCE
   Author:  Sterrturg.  Scsan Henry^  Oierango Valley ievs
Recipient:  none:   none
      r.t tu»er:  CJO-001-16S8 To 1623                  .                              Date: 12/01/90

Title: Fact  She-st -  EPA Sl^xrhjnd Action at fonaer Waste  Disposal  Site in Eatai, Mev Tcrk

     Type: C3M1SPOCE3MZ
   AutSor: none:   US EPA
tecipier.t: none:   none


Doc^Hent Nicber:  C."0-001-16£9 To 16?2                                                Date: 12/01/S9

Title: Fact  Sheet -  EPA Conducting Investigation of C t J Disposal Site

     Type: COUESPOCEKC
   Author: none:   US EPA
lecipierrt: none:   none

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T3/1
715/71
Index Doc-jnent Nirber Crier
C 4 J DISPOSAL Doc-jaents
                                                                                                              Page:  16
 Doc^nert  Ifcxcer: CJ)-001-1693  To  1693                                               Date:  10/77/S9

 Title:  (Keagpaaer  article  entitled:)  EPA Begins Study of C 4 J  Disposal  DLrp Si:e

      Type:  G3U£S?OCEHCS
    Ai.TT-.cr:  Stemourg,  Susan  Henry:   Cher^nso Valley Kevs
 Recipient:  ncne:   none


 EtocjKT.t  BLiiaer: CJD-001-1694  To  1697                                               Date:  C£/01/£?

 Title:  Fact She-t  -  EPA Conducting  Investigation of C 4 J Disposal  Site

      Type:  O3tt£S?CM3EHCE
    Ai-rvor:  none:   US EPA
 » ;< : p i —rt:  none:   none
 Attached:  CJD-001-1698   CJD-001-1700

      nt  Eucer: CJD-001-1698  To  1699                  Parent:  C.'D-C01-16?i          Date:  05/19/E7

 Title:  (Se^spaper  article  entitled:)  Hazardous tixp disging incer  investigaticn

      Type:  CCRRESPONDEHCE
    AirAor:  Clese,  Gene: Chenango Valley Hews
 Eecipienx:  none:   none


 Poejrrt  Bjber: CJO-001-1700  To  1700                  Parent:  CJO-001-1694          Date:  05/05/t?

 Title:  (*e«specer  article  entitled:) Unidentified cocpany digs  v^>  Tcwi of Eaten hazardous

      Type:  ORJtESPOKDEKCc
    Ai-tSor:  Sterrtxjrg, Susan Henry:   Dienanso Valley Xews
 Secipierrt:  none:   none
               r: CJD-001-1701 To 1701
 DOTM»TC
 Title: CS««spaoer article entitled:) Haailton Site Added to Tcxic Cleanup List

      Type: CCRi=S?OKDEMC£
    Author: Weibexahl, Susan:  Utica Observer Dispatch
 Recipiers: none:  none
                                                                                   Date: C6/2Z'£3

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02/15/91                              Inotx Docuaent Ku±>er Croer                                             Pare: 17
                                     C i J DISPOSAL
Dociant Ktcfcer: C.D-001-1702 To 1702                                   .            Oa:::

Title: (Mevspaper article entitled:) HaiiltonDuap Targeted
     Type:
Condition: ILLEGIBLE
   Author: (Illegible). Jonathan 3.:  Syraei* Herald - Jounal  •  Kici sen/Met. -3
Recipient: none:  none
Docuaent Xurber: CJO-001-17U3 To 1703                                               C^ts:  1Z/25/90

Title: (Hevspaper article entitled:) E?A Sejls Suspected Wute >J=p Site

     Type: G»RESPOM5EHC£
   ALTtSo*-: Ovjffy, Lori:  The Post - Standard
iiecipient: none:  none


Doejaent Xucfcer: CJD-001-17W To 1704                                               D2:s:  Q3/7:/70

Title: (Letter of regret that EPA repr«s«ntitivea were net afcl« to attend Karch 15,  1990 oe~»:ing
       to discuss the status of the site)
     Type:
   Author: Sinseraan, Joel:  US EPA
Recipient: Turtle, Steven J.:  Kadi son Couiry Planning Oeparraer.t
       t Kurber; CJD-001-1705 To  1716                                                Da:e:  01/22/29

Title: 
-------
4 - NY £ DEC LITTIR  CF CONCURRENCE

-------
New York State Department of Environmental Conservation
50 Wolf P.oac. Albanv. New Yo.'X 12233
                                                                            Thomas C Jorllng
                                                                            Commissioner
                                                                7 i93i
     i-srcir.cy a_~.i Rirreiial  r.esr
     Unit£-i Sis.t6£ Er.vir~.vr.5r.ta"-
     Recicr. I"
     2€ Fedoral ?lar&
     \\i-.\ 'i-.r'x., Ne- Vcr>.  102 "S
              Disrcsoi  S_t*,  Ea-on, Xddistr. Ccuntv,  Site So.  "7-27-CCA

     T'r.e fir.al cr^ft P.eccrc of Incision (?.^D) for  the  CiJ disposal Si-e  received by
     the N^w YcrV. State Cepartr.ent of E.-vircr.-r.ental  Cor.ser.-aticn (NY322C) on  March
     27, 1351. hes teen reviewed.  T>-.e K":SDEC ccr.curs  with th* selected  P.eaeiy as
     presented in th» crsft ROD.  Ihis r»--edy calls  for axcavation ar.d rt^oval cf
    "the c = r.t£_iir.ated soil ar.d re.T.=-ral tc pertittsa  waste lanagernent facility for
     treat-~«nt/cispcsal.

     If yc-j hive any questions ccr.cerr.ir.c this ratter, please contact
     Mr. Michael J. C'Tcole,  Jr., ?.E. at (513)  457-5881.

                                             S-r.cerely,
                                                      cnrr.issicr.sr

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APPENDIX  5-P-ZSPOSSIVZKZSS

-------
                       Responsiveness  Summary
                         CSJ DISPOSAL SITE
              TCVN C? EATON, MADISCN COUNTY, NEW YORK

This Responsiveness Summary is organized into the following sections:

   I. Responsiveness  Summary   Overview.     This  section   briefly
      describes the purpose of  the Responsiveness Summary.

  II. Background on Community Involvement and Concerns.  This section
      provides  a  brief  history cf community interest and  concerns
      regarding the CSJ Disposal sire.

 III. Summary of  Major  Questions and Comments  Received During  the
      Public Comment Period and  the Environmental Protection  Agency's
      (EPA's) Responses.  This section summarizes comments submitted
      to  E?A at the  public nesting  and curing the  public  comment
      period and provides  EPA "s responses to these comments.

Attached to this Responsiveness  Summary are -he  following appendices:
Appendix  A  includes the  legal  notice announcing the  start, of  the
public comment pericd  and  the agenda, for the public meeting;  Appendix
E includes the Fropcsed Flan;  Appendix C includes the  public meeting
sign-in sheet; and Appendix D contains correspondence  received by  EPA
during the public consent  period.

I.  RESPONSIVENESS SUMMARY OVERVIEW

EPA held a public comnent period from  January 24, 1991  through March
12,  1991  for  interested  parties  to  comment  on   EPA's  remedial
investigation and  feasibility  study  and Proposed Plan  for  remedial
action for the CiJ Disposal Superfund  Site  in Eaton, Madison County,
New York.

EPA  held a  public meeting  on  February 13,  1991  at  the  Hamilton
Central School,  Hamilton,  New York to  describe  the remedial  alterna-
tives  and  to  present  EPA's  preferred   remedial  alternative   to
remediate the C&J Disposal site.

The purpose  cf  this  Responsiveness  Summary is  to provide a  summary
of citizens' comments and  concerns associated with the  site  and  the
preferred remedy  that were raised during  the public cozcent period
and EPA's responses to  those  concerns.   All comments  summarized  in
this document will ce considered  in EPA's selection of  the  remedial
alternative  for cleanup of the  si.e.

II.  BACKGROUND ON COMMUNITY INYOLVZMENT AMD CONCERNS

Past community  involvement specific to  the  C & J Disposal  site  has
net been  extensive.  While officials and a  few  citizens cf  Hamilton
and Eaten Townships have been monitoring developments at the  site,  no
organized citizens groups are kr.cvr. to be actively involved  with  the
site.   In June  19£c,  local newspapers released  articles  concerning
the  results  of a  site  investigation  funded by  EPA.   The  articles

-------
r.czed  the  potential  threat  of  contamination  to  the Village  of
Hamilton vater supply and tc nearby private wells.  At that time, the
Village vas using Woodman Pond as an interim municipal water supply.
Due to the concern expressed by residents and officials, the Village
ceased  use  of Woodman Fond  as a primary water  supply  beginning in
September 19S3.

Ccmmunity groups have  been  established on both the local and county
levels  in  response  to other environmental'  issues  in the area.   The
Natural Resources Conservation Council was formed in Eaton Township
•tc  address  such issues as development  of  a solid waste program and
protection of local  water resources.  The Madison County Environmen-
tal  Management  Council  vas  also  established in  response to  the
proposed siting of  a hazardous waste treatment and storage facility
by  the  New  York  State  Department  of Environmental  Conservation
 (.VYS3ZC) .  The  council now  serves in an advisory capacity en issues
including  water resources  and solid  waste.   County residents  and
officials  were  also  active  in seeking  to close a  county landfill
shovn  tc be  contaminating  local groundwater.   NYSDEC  subsequently
closed  the facility.

A Community Relations  Plan for the  C&J Disposal site was completed
by  E?A  in  October  19S9.   Input received  at that time indicated the
fcllcwing  site-related  issues to  be  of  community  concern:    the
schedule for site cleanup; the nature and extent  of surface water and
groundvater contamination; and methods for disseminating site-related
infcrma-ion to  the  pub-lie.

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

PUBLIC  MEETING

Issues  and  questions raised  at  the  public meeting  for the  C&J
Disposal  site  are  summarized below  and  are  organized  into  the
fcllcwing areas:

A.      Cleanup  Fundinc/Fotentiallv Responsible Party  (PRP) Responsi-
        bility"
E.      Remedial Alternative  Selection Process
C.      Grcundwater  Contamination/Other Community Impacts
C.      Cleanup  Schedule
E.      Other  Concerns

The public  meeting  for the C&J Dispcsal  site began  at  7:30 p.m.  on
February  13,  1991  with presentations by  EPA,  and was followed  by a
question  and  answer session.  Approximately  15  residents  and  local
officials attended  the meeting.

Ccncerr.s expressed  at  the public meeting are as  follows:

-------
        LEAJ—P Ft^DISG/r?.? ?-IS POSSIBILITY

                                                      (GxyChem)  was


EPA r-ESPONSZ:  Cn the basis cf evidence linking  contaminants  at the
Site to "Firestone Plastics"', I?.-, issued a notice  letter  to Bridge-
stcr.e/Firestcne  en  No-vernier If,  1990.   As  Bridgestcr.e/Firestcr.e ' s
cert crate successor, OxvChet was  also civen notice en  November 16,
1993.   It vas later learned -ha- CxyChem would represent both itself
and  Bridgestcne/Firestrr.e  en  the   basis   of   an  indemnification
C.	 = — :
CCXXZ>ns :  A citizen asked  if CiJ Leasing was responsible for cleanup
costs at the site.   Another citizen asked whether  the  principals  cf
CiJ leasing cr  the corpcratirn  itself are responsible for the cleanup
costs.  If the latter  is the case, what  is  to  prevent  the  fim fron
redistributing its  assets  cr declaring bankruptcy  in order to avoid
payi.-.c the cleanup  costs.

EPA P-ESPONSE:   N'ctice leiters were sent on  July 15,  19 = 3 to the CSJ
Leaning Co., the  Eirge Ccrrany,  ar.i Charles and Geneso  (aka  Janes)
Ficirieilo  (the principals cf  CiJ Leasing Co.) identifying  the-  as
?.= ?=.   The notice  letters also  notified each PP.? cf  an  i-pencing
Penedie.1 Investigation and Feasibility Study (RI/FS)  to be  conducted
at  the  Site and  invited  sich PP.?  to either •  perf cm  the RI/FS  cr
finance it.  None  of the  PP^s agreed to perform cr finance the RI/FS.
As was noted,  en  the basis of evidence  linking contaminants  at the
Site to Firestcne  Plastics, OxyChen became a FRP.

The  PRPs  are  responsible  fcr either  undertaking  or  financing the
investigatory and cleanup efforts.  EPA intends to attempt to recover
the costs which it has already incurred.  In addition,  negotiations
with the PRPs regarding either funding cr undertaking the cleanup of
the  site  will begin after   a  re-edial  alternative  is  formally
selected.   If  the PRPs do net make  a good  faith  offer, the  agency
will  perform  the  work and will  attempt to recover  the costs  at a
later date.  While companies can certainly redistribute their assets
cr declare bankruptcy in  an attempt to avoid paying for investigatory
and cleanup costs  at Superfur.d sites,  EPA will  use the  court system,
if necessary,  to  seek  recovery cf its costs.
  ._h~r:  A local official asked if GxyChem is aware cf its responsi-
bility  at  the site  and  if it has allocated  any  ncney fcr  the  C&J
Disposal site remediation  project.

EPA RESPONSE:   As ncted in the previous response,  EPA  has informed
CxyChem  that  it has been  identified  as  a  PR? fcr  the  C&J Disposal
site.   EPA has  no  knowledge  cf CxyChem allocating  any  funds  for
site-related cleanup costs.

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B.     REMEDIAL ALTERNATIVE SELECTION PROCESS

COMMENT:   A  citizen  asked  if  certain  remedial  alternatives are
permanently eliminated  from  consideration  because they do not meet
all of EPA's evaluation criteria.

EPA RESPONSE:  EPA  and NYSDEC have identified Alternative 4 as the
preferred alternative for remediating the C&J Disposal  site since  it
best  satisfies the balance  cf  all  cf  the  evaluation criteria.
However, cne cf the other alternatives which have  been  developed and
evaluated  could  be selected  after  careful  consideration  of all
comments received by EPA.

COMMENT:  A citizen asked if the  PRPs are able to select a remedial
alternative ether  than the preferred alternative  if such a remedy
would be less costly to implement.

EPA RESPONSE:  If credible technical  evidence  for selecting  another
alternative is presented,  EPA. is bound  to consider the comment and
evaluate  it  using   the  established criteria.   A  PRP suggestion  of
another alternative based solely en the costs involved is not  a  sound
basis for EPA  to alter its decision regarding selection of  a  final
remedy.  EPA factors all nir.e  cf  its  evaluation criteria, including
cost, intc the alternative selection process.

COMHENT:   A citizen expressed concern  that  a  situation where EPA
technical experts prefer a  remedy  different frcm cne suggested by PRP
experts cculd occur and asked who  would arbitrate such a dispute.

EPA RESPONSE:  The  EPA Region II Administrator will assess  all the
relevant input and  make the final  decision.

C.      GROUNDWATER  CONTAMINATION/OTEER COMMUNITY IMPACTS

COMMENT:  A citizen asked how  direct  contact  between waste material
and grcuncwater  in the disposal  trench  could not have resulted  in
groundwater contamination.

EPA RESPONSE:  The  waste in the disposal trench is  primarily composed
cf  plastic  materials which  appear to be relatively  stable.  High
levels  cf phthalates  in the  waste material which have leached into
surrounding soils are likely  bended to organic matter in the soil and
have limited water  solubility in that form,  and thereby have  minimal
potential for migration through groundwater.   Leachate  from contami-
nated soils that may have been  in contact with drums removed in the
unauthorized  1SS9  excavation has  not been  detected in groundwater
samples either.  However, these  conditions could potentially change
and would be monitored  over time  under any cf  the remedial alterna-
tives not involving removal of the contaminated wastes.

COMMENT:  A citizen asked why  permanent  lowering cf  the water  table
by  operating  pumping wells is  included  under Alternative 3  if the

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grcuj-.dwater  is  not  currently  contaminated and  may not  be in  the
future.  The citizen also asked  if installation  of  a protective  cap
without  employing pumping  wells would  be  a  ncre  cost  effective
remedy.

EPA P-ESPONSS:  Installing a protective cap without installing pumping
wells  would  obviously be  less costly than  implementation of both
technologies.  However,  since the leachability of the contaminants in
the  soil  and  waste material  ever  time  cannot  be   conclusively
characterized, prudent engineering practices dictate against simple
installation  cf a protective  cap without  implementing  supporting
r^redial measures such as cewaterir.g.

CCXXINT:  A  citizen  asked about  the  rationale behind establishing a
quarterly monitoring well and  residential well sampling program  for
cr.e  year  following  the  completion  cf  site   remediation  (under
Alternatives 4 and 5).

I --. RESPONSE:   An initial round cf monitoring well and residential
v -1 sampling would provide some  baseline data on  groundwater quality
t; wh-ich  pre-remediaticn and  subsequent quarterly  sampling  results
c--r. be  compared.   These  subsequent sampling results would  ser/e  as
cr-.firmatcry  data  to verify that  groundwater  contamination is  not
occurring curing the  pcst-ccnstructicn period.  The one-year duration
cf  the  sampling  program would  certainly  be  extended if  results
indicate groundwater contamination is, in fact,  occurring.

COOCENT:   A citizen asked  where  the   thermal  treatment  facility
described in Alternative 5 would be  located.

EPA  RESPONSE:  '  If  Alternative 5  were  ultimately  selected  for
implementation, an off-site Treatment,  Storage  and Disposal facility
for handling the excavated waste .material would  be  selected through
a competitive bidding process.

CCXHZNT:  A  citizen  asked when the public would be informed of  the
route that trucks transporting waste off-site would take.

EPA RESPONSE:  It is  likely that a  public meeting wculd be scheduled
prior to the  implementation cf  site construction activities, at  which
time waste transport routes and other issues impacting  the community
would be discussed.

D.      CLEANUP  SCHEDULE

COCKZNT-:  A  citizen  asked if  negotiations between EPA  and  the PRPs
regarding cleanup cost recovery  could adversely  impact the schedule
for  implementing  Alternative  4  as it  is described in  the  proposed
plan.

EPA RESPONSE:  EPA intends to select  a remedy for the site by the  end
cf  March 1991.   A  notice  letter will  be  sent to the PRPs soon

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afterward, giving them the opportunity to make  a  good faith offer  to
finance or perform the design and construction  of the remedy that  is
selected  in the  RCD.   If  the  FRFs cake a good  faith offer,  it  is
a-r.ricipated that a settlement  could be reached a few months  later.
If the FRFs do not make  a coed faith offer,  EPA will undertake the
re-edial work itself.

COXXZNT:  A citizen asked  for  assurances that the cleanup  action  at
rl-e site will ta>:e place  in a timely fashion  regardless  of  who bears
rr.e financial responsibility for it.

EPA F.ESPONSS:    EFA's  objective under Alternative 4 is to complete
remedial  action,  which   involves  the  actual   waste   removal and
disposal, by May 1592.

E.     OTEER CONCERNS

COXXZNT:   A  local official  informed  EFA that  the Hamilton  Village
Corliss ion  and  the   Heard  of Trustees  have   adopted  resolutions
endorsing Alternative 4  -  Removal  and  Off-Site Treatment/Disposal -
frr the  cleanup  of contamination  associated with the C&J Disposal
si~e.    The official  also  expressed appreciation for EPA's  efforts
regarding the C&J Disposal site.

EPA RESPONSE:  EPA acknowledges and appreciates the  support.

CO.yXENT:   A  citizen  asked if  C&J  Leasing's  activities  at the site
constituted criminal cr  civil  violations.

EPA RESPONSE:  C&J Leasing's waste disposal  activities at the site
vere in violation of New York  State civil law.

COXXENT:   A citizen asked if a Technical Assistance Grant (TAG)  is
available  to  eligible community groups  interested  in the C&J site
cleanup.

EPA RESPONSE:  An interested community group  whose membership may  be
affected by contamination at the C&J site can apply  for  a TAG. This
errant provides funds to  local  communities for the purpose  of hiring
technical consultants to aid in the interpretation and understanding
of site-related technical  data.

COXXENT:   A citizen asked for the C&J  site's  NFL  ranking  and its
hazard ranking system (HRS)  score.
EPA RESPONSE:  The C&J Disposal site  is listed as No. 651 on the NPL.
The site's KRS score  is 42. S4.
VRITTEN COMMENTS

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Issues and questions raised in letters- (see appendix D for copies of
the letters) and their responses are summarized below:
  MXZirr:  A resident expressed ccncerr. regarding the potential threat
tc the drinking water  from the sire and the diminished  value of his
property due to its  proximity tc the CaJ Disposal site.

EP.-. F_ISjCKSI:  Samples collected  from  private  wells  located downgra-
dier.t from the site  in 1S35,  1SE3,  1S3S,  and 1SSO did not reveal any
cc-.tam:Lr.aticr. and  the  likely removal  of contaminants from  the  site
       alievia.ce any such ccr.cerns.
   CyZ^.T: The  Beard cf the Tcvr. c:  Eaten  ar.d the Ccunty  of  Madison
prcviied endcrseranis cf Alterr.at ive 4.

Er?. FJISPONSE:  Kc  response necessary.
CC>{MZ?rr:   Eased  up  -.  its reviev c: the Proposed Plan  and  the  RI/7S
report, CxyChem prc.csed two options for more limited remedial action
plins at the  C&J Disposal site.  CxyChem relieves  both  options  are
more ocst-effective as well as protective cf human  health based upon
their reassessment cf risks.

Option 1  includes adding  a waste separation  step.   This  step  is
designed  to  reduce  the  quantity cf  material  requiring  off-site
disposal by separating the plastic material and hazardous waste soils
from the- r.cn-hazarcous soils found within  the  trench at  the  site.
Waste  characterization  analyses  would  be  employed  to  determine
hazardous versus  non-hazardous  waste volumes.

Option  2,  OxyChem's Suggested  Alternative,  includes  the  following
components:

Grade the site using imported ccnmcn clean fill  to  achieve a minimum
12 inches cf  fill ever the  waste  at a minimum grade of 1 percent
Cover fill with  6-inches  of tcpsoil.

Grcu_ndvater monitoring fcr volatile organic compounds (VOCs) and BNAs
at four dcvngracient wells  semi-annually.

The present worth cost cf  this  alternative  is $SS,700.
Ecth options  presented by CxyChem are predicated upon  the  following
assumptions:

           The waste  found in the trench has  been  in  place approxi-
           mately 15 years  and  no impact on groundwater quality with
           regard to organic compounds  was  detected.  As  such,  the
           potential  for contaminant migration fron the waste is not
           expected  new  or in the future.
           The  VOCs  and  ENA compounds  detected   within  the  soil
           samples  show  affinity for the soils.

                                  7

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           The health risk assessment in the R_/rS has been overesti-
           mated.     OxyChem's   reassessment   indicates,  that  the
           incremental cancer risk is 2  x 10" net 2 x  10J as presented
           in the RI/FS.  The principal  reason  for the difference in
           the cancer risks estimated is due in  OxyChem's opinion, to
           incorrect exposure assumptions used in the RI/FS.
           With  either option,  these  site conditions  ana reduced
           risks suggest that crcur.cwc.ter ncnizoring at  quarterly or
           semi-annual frequencies will  be sufficient to monitor the
           effectiveness of these alternative remedial plans.


EPA RESPONSE:  Neither option proposed adequately  satisfies  the nine
evaluation criteria employed in the detailed evaluation of  alterna-
tives and the risk assessment dees nc~ overestimate  the incremental
cancer risk at this site.   Alternative 4  is  mere protective  of human
health and the  environment and beiter  eliminates the potential for
future exposures and  pollutant  releases and  tetter satisfies the
statutory requirements of CERCLA Section 121.


OPTION 1  - MODIFICATION TO  ALTERNATIVE  4 BY  INCLUSION OF A WASTE
SEPARATION STEP

Overall Protection of Human Health and the Environment

This option cculd be protective of human health and  the environment
if  the  plastic  waste and  contaminated soils  could,   in  fact,  be
completely separated  and completely removed.   The  non-homogeneous
nature and lack of structural integrity  of the  waste material limits
the potential of OxyChem's option to be  as  protective as Alternative
4 which calls  for  complete excavation  and removal of all waste and
soil and replacement with virgin soils.

Compliance with  Applicable or Relevant and  Appropriate  Requirements
(ARARS)

Temporary impacts to nearby wetlands are more of  a potential concern
with this  option,  as  presumably,  its  implementation would involve
excavation, a screening operation, and the  staging  of screened soil
piles fcr several weeks until Toxicity Contaminant Leaching  Procedure
(~CL?) ,   VCC,  and  ENA  analytical  results  are obtained'for waste
segregation purposes.   This ncre expensive operation would require
mere  intrusion  into  the wetland iruffer  zone and  for a longer time
period compared to Alternative  4.   Although  these  impacts can be
mitigated, i.e., by appropriate  erosion  and sedimentation  controls,
as well as fugitive and emissions controls,, cr by conducting all or
a portion  of the remediation under a temporary  roof,  the  need fcr
these mitigative measures  will  increase the cost proposed  for this
option.

Cleanup levels  at  which the soil could be backfilled would have to

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be developed before the analytical  data  were  received  so  as  to  avoid
maintenance cf staged piles cf soil Icngar than necessary.

Even if the soils are net deemed  hazardous  waste  en  the basis of  the
TCI?,  The r.cr.-hazardcus soils may be classified  as  industrial  waste
by the  J.'YSZEC.    Placing these wastes  back  into the trench  could
cc.-.stitute  disposal cf  industrial wastes,  and  as  such,  must  be
performed consistent with 6  NYC?-". Part 360 regulations. There are no
previsions for addressing this requirement in this OxyChem cption.

It should  be  pointed cut that Alternative 4  does not preclude  the
ccirse separation cf wastes and scils during  the  initial/single step
cf exoavat ir.g the disposal  tre.-.ch.  However,  the  lack cf structural
integrity  cf  the  waste curing  a  subsequent,  discreet, notarized
separation step could result  in substantial distribution cf  smaller
contaminated  fragments  into  ur.ccr.taminated  or  lesser contaminated
soils.    The  RC7A  Dilution  Prohibition  (40  CFR  263.3)   clearly
prohibits  this  activity,  thus   ruling  cut a   highly   mechanized
separation step.

Therefore, this alternative would not con fern to ARA?.s as  well as  the
selected alternative.

Lc.-.g.-Term Effectiveness and Permanence

The long-tern effectiveness and pemaner.ee of this  option will be a
function of how  effective  the waste  segregaticn process   is.   It is
anticipated that this  separation  -process will  not  be   completely
effective cue to  the ncn-hcr.cgeneous  nature  cf the waste materials
and its  lack of  structural  integrity.   Therefore,  a   far  greater
potential  exists  for leaving  soce residual  waste  in place,  using
OxyChem's Option 1.  Whether the waste left on-site is  residual  waste
frcn a screening operation or whether it is waste fron a  15-year  old
placement, does not preclude that conditions at the site could change
in the near future,  and release  contaminations to  the groundwater.
The complete  removal cf contaminants as  proposed in Alternative  4
insures long-term effectiveness and permanence.

Reduction cf Toxicity, Mobility,  and Voluzie through Treatment

As with Alternative 4,  the OxyChem option would remove  the soil/waste
material in the trench area, thereby  reducing the potential  toxicity
and mobility  cf  the in-place  contaminants;  however,  not as effec-
tively for  the  reasons  noted  above.   The volume  of waste requiring
dispcsal  wculd  te  less,  but  land  dispcsal  cf  the  hazardous  waste
fraction  would  not reduce  its overall  toxicity unless   preceded by
treatment,  which  was   net  considered  by  OxyChen.   The  residual
ncn-hazardcus contaminated soils  left in place, however, would not be
treated.  Therefore, this cption is not better than Alternative  4.

Short-Tern Effectiveness

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This CxyChem  option is not  as  effective on a  short-term basis as
Alternative 4  because of the  need  for greater materials handling and
staging requirements.  The potential for  both adverse  impacts to the
environment, due to greater potential for larger encroachment within
the wetland buffer zone,  as  well as greater  worker exposure,  make
this option less effective.

Implementability

The RI/FS  analytical data,  although  adequate to  characterize the
extent of site contamination, were not designed to characterize the-
distribution  or  physical  characteristics of the  plastic waste and
contaminated  soil.   As  such,  the  existing  data are not adequate to
permit  OxyChem's   proposed   segregation  step  without  extensive
additional testing during the excavation process.  From the test pits
installed during the RI, the  plastic waste  pieces observed ranged in
size from tiny fragments to  large clumps.  OxyChem has assumed that
some type  screening operation would result  in removal  of  all the
plastic waste and  that  a  significant portion  of the soils would be
acceptable as backfill.   This may not  be feasible as further  waste
characterization would be required.  Further, the existing data also
do  not suggest  that  the soil  in the  trench  is uncontaininated.
CxyChem has nade no distinct provision to  segregate  contaminated soil
iron non-contaminated  soil in the field,  only  the obvious plastic
waste.

The time  to  implement  this  option would  be  longer  than that for
Alternative 4 because  the acceptable  levels  of  contamination tha.t
could  be  backfilled would have  to  be  established  and  additional
characterization of the .waste would have  to be  done to determine the
feasibility of a screening operation,  e.g.,  types and sizes of rotary
screens to be used.

Cost

CxyChem has based its cost analysis for this option on an  assumption
that two-thirds of  the volume excavated  could be backfilled.   There
is no basis for this assumption,  and in  fact,  the  actual  volume may
be less if  upon excavation segregation methods are less  effective.
No testing costs are included for waste  characterization purposes nor
dees the cost account  for the  possible need  to comply with 6  NYCRR
Part 360 requirements fcr those materials left  in place as backfill.
In addition,  no backup  was  provided  fcr  the  $20,000 estimate for
waste segregation.  As  such, it is questionable if this alternative
is as  cost-effective as proposed. Furthermore,  while the proposed
costs  fcr  Alternative  4  were conservative  (based on  a hazardous
disposal of  all 1,250  cubic yards),  such separation  of waste and
soils  during  excavation could reduce  costs further and  lesser the
difference between  Alternative 4  and  OxyChem's Option 1.
                                 10

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State and Community Acceptance

Ecth ir^SDIC and the public have indicated accepzar.ee cf Alternative
4 in its current structure.
In  summary,  Cpticr.  1 is  net  considered as  feasible a  remedy  as
Alternative  4.    This option  dees  not  comparably meet  cr  exceed
Alternative 4 when evaluated against the criteria noted above.

OPTION 2 - SUGGESTED  R2XZDIAL ALTERATIVE

Overall Protection of Eumam Health and the Environment

It should be noted that  both Option 1 , and mere particularly  Option
2, are predicated cr.  CxyChem's assumption that the waste material has
teen stable ever  the past  15  years  and that it will continue to  be
stable.  This  is  net a  sound  assumption.   While the lac>: cf  ground
water contaminants found as a result of the fev tests conducted since
1SS3 provide  some very  short-term  comfort  (presently),  it doesn't
-ear. that the  waste  is  stable  (the  waste has changed  significantly
from its 1976 description)  and it doesn't mean that conditions that
cculd trigger  a  large scale release could not occur.   In fact, the
longer the waste remains en-site,  the  creazer the  chances are  that a
release will  occur.   Therefore,  with Option 2,  the  potential for
future contaminant migration would not be eliminated.

The graded,  vegetated soil cap would reduce  infiltration through the
waste,  but  not nearly  to  the extent  that  a  low permeability cap
designed in accordance with 6 NYCRR Part  360 requirements .  Also,  a
cap alone would not  prevent direct contact cf contaminated  soils  or
waste materials with  grour.dwatsr .  Therefore,  waste/soil constituents
could in the future be entrained  in  the leachate  from  the trench and
the waste would still be in contact with the water table.

Also, the decreased groundwater monitoring prcpcsed by  Oxychem would
significantly increase the  risxs that  any future  contaminant  nigra-
tior. might not be adequately assessed,  either in magnitude  or in time
and, therefore, dcwncradient receptors are net adequately protected.
Therefore,  this  alternative  is  not   considered  as  protective  as
Alternative 4.

Compliance with A£ARs

Ever,  if the  waste  is  considered  non-hazardous,  6 N'YCPJR  Part 360
closure requirements would probably be applicable.  The soil cover
proposed  would not  meet the  requirements  cf an impermeable cap.
Therefore, this  alternative would net ccmclv with A?_-_?.s as well  as
Alternative 4.

Lcng-Term Effectiveness  and Permanence

Because the  potential for future migration exists, especially with

                               •  11

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waste/soil in contact with the water table',  this  option would not be
effective in  being protective and meeting  ARARs in the long-term.
The only way to verify the long-term effectiveness  and permanence of
this  option  would  be to  monitor  groundwater,   cap  integrity,. and
possibly  surface  water,   for  an  extended  period  of  tine  (i.e.,
30 years).

Reduction of Toxicity, Mobility, and Volune through Treatment

This option does little to reduce toxicity, mobility, or volume' of in
place wastes.   The soil cap would minimize, tut not eliminate, the
potential for  contaminant transport  as  the  waste would still  be in
contact with the water table and subject to potential leaching cue to
rainfall infiltration.   No volune  reduction or treatment to reduce
tcxicity  is  provided for.   Alternative  4  is  more  effective  in
reducing  the  potential  for future contaminant  migration  from the
site.   Alternative 4 does  reduce  toxicity  and  volume,  on site,  in
contrast to  OxyChem's option,  as  it calls  for  the disposal of the
waste  materials  in  a  secure  facility off-site.    This   disposal
activity may be  preceded  by treatment if required,  in light c~ land
disposal restrictions.

Sbort-Term Effectiveness

This  OxyChem  option would be as effective on a  shcrt-term basis as
Alternative 4.

Implementability

This OxyChem option would not be implementable since the proposed cap
dees not meet 6 NYCRR Part 360  requirements.  The reliability of this
cption  for  contaminant  containment  is  also questionable  as the
proposed cap does litzle to control rainfall infiltration or prevent
groundwater from being  in contact  with the  in place wastes.

Cost

This  option  as  presented  by  OxyChem,  does  not  achieve  the same
remedial response goal as Alternative 4.  As such, this limitation is
reflected  in  the lower cost estimate provided  by OxyChem for this
alternative.  Upgrading the cap to satisfy 6 NYCRR Part  360  require-
ments, an ARAR, would increase  the  cost for this option considerably.
As  part  of  the RI/FS process,  a more protective containment option
than  that proposed by OxyChem  was  evaluated which  included  capping.
Ey  comparison  this  option had a present worth value of $712,500.

State and Community Acceptance

As  with  Option 1,  this cption  represents  a  significant  modification
to  the  Proposed Plan which has  already received NYSDEC and public
approval.  Further consideration of this cption would delay  implemen-
tation of a remedy at this site.

                                 12

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In summary, although  more  cost-effective  as presented, the OxyChem
Succested Alternative fails to meet many of  the previously described
criteria.  This alternative is net  as protective of human health and
environment as Alternative 4.   It dees  not comply with  ARARs, nor is
it effective or permanent on a long-term basis.  Lastly, this option
is not implemer.table and if  implemented would do little to reduce the
toxicity, mobility, cr volume of the in place wastes.

RISK ASSESSMENT

The Superfund program has been designed to  protect human health and
the  environment  from  current  and future  potential  threats  frcm
uncontrolled releases of hazardous  substances frcm sites.  To achieve
this purpose,  the  U.S.  Environmental  Protection Agency's Office of
Emergency and Remedial Response (OERR)  has developed  guidance en the
human health  evaluation  process.   The  Risk  Assessment Guidance for
Sucerfunc  (RAGS)  (EPA/54 6/1-89)is  the guidance document EPA adheres
to in developing the human  health  risk assessment conducted as part
of the remedial investigation/feasibility study (RI/FS) process.

The baseline risk assessment process as outlined in the RAGS consists
of the following components:

           data  collection and  evaluation

           exposure  assessment

           toxicity  assessment

           risk  characterization.

The exposure  assessment  component  c: the  RAGS provides the specific
equations  and parameter values  for common  Superfund site exposure
pathways.    It outlines  the  revised  National  Contingency Plan's
reasonable  maximum exposure  (RXE)  concept  under  both current and
future land-use conditions.     The RXE  is defined  as the highest
exposure that could reasonably te  expected  to occur  at a site.  The
guidance clearly outlines several  of the  assumptions that should be
considered in calculating the  RXE.  Furthermore,  the guidance defines
the  concentration  value used  to calculated the RXE as  S5th upper
confidence limit (UCL)  en the arithmetic mean concentration contacted
over the exposure period, rather than  the  mean  itself.  The guidance
goes  en  to say -that "'if there  is  great  variability  in measured or
r.cdeled concentration values - such as when  too few samples are taken
or when  model inputs  are uncertain -  the upper confidence limit on
the  average concentration  will  be high,  and  conceivably  could be
above the  maximum detected cr modeled value.   In -these cases, the
r.aximum detected cr modeled value should be used to estimate exposure
concentrations.  This could be regarded by  some as too conservative
an estimate,  tut  given the uncertainty in the data  in these situa-
tions, this approach is  regarded as reasonable."

                                 13

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The risk assessment completed for the C & J Disposal site, by EPA's
contractor, Wehran Engineering (Wehran),  did adhere to the exposure
assumptions stated in the  RAGS.   Furthermore,  the RME was based on
concentration values  that were  either the  95  UCL or  the maximum
detected  concentration.    Wehran  only used  the  maximum detected
concentration when  the 95 UCL exceeded the  maximum.    This  is in
agreement with the RAGS.  OxyChein's contention that average concen-
trations be used is not supported in the RAGS.

In addition,  EPA believes  that the risks quantitated for the site, by
Wehran are an underestimation  of potential site risks because  only
one  current  recreational scenario  was  assessed.   The scenario
assessed assumed an adult jogger ran by or through the site a total
of  6  times  over a  9  year  period.  In EPA's  opinion,  a current
recreational scenario  could  have estimated the  risks  for a jogger
who ran  a total of  at  least 100  tines  over  a  30  year exposure
duration.   The  exposure duration  value  (30 years) is  in the  RAGS
guidance and represents the national upper-bound time  (90th percen-
tile)  at one residence.   In calculating the RME,  Region  II uses  this
number.

Furthermore, future land-use  scenarios were not assessed by Wehran
It would not have been unreasonable to  quantitate the risks posed by
a  future  on-site residential scenario.   Future land-use  scenarios
assume no site remediation.

In  conclusion,  OxyChem's claim  that  the  "assumptions  used  in the
RI/FS  soil  exposure scenario  were overly conservative"  is  not in
accordance with  the RAGS document.  Several of the exposure assump-
tions used were  not as conservative as  those  commonly used in EPA
Region II.  Furthermore, other future  land-use scenarios  could  have
been considered  and the  risks calculated with those pathways would
have been  greater than the  current land-use risks.   EPA believes
that, while more conservative modeling could have been performed by
Wehran, the risk assessment was sufficient  to characterize the risks
present at the site, at a minimum,  and  Alternative  4, which involves
removal and  off-site  disposal,  would  also be fully appropriate for
more conservative modeling.
                                 14

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                            Appendix A
the legal nc~ice announcing the start cf the puilic cczi^snt period
               and the agenda for the public nesting

-------
                 THE UNITED STATES
      ENVIRQN'MSS'TAL PIGTKTnON AOENC'
            PROPOSES  C!.F»>:l!P REMEDY
     AND SCHEDULES A f wBLIC MEY7INC FCS
      THE C At j D1SPQSAJ. SVPERF'JND SITS Vi
      EATON, MADi5O* CO'JNTY, NSW YO»»:
      :-.  ,,.
s?tr-«r fc- Ihc C & J
cvbiic  m^»dnc \r>  d
**«ib"Uy Stud/ (R'.'Fi) o.nd the rropc^etf Pld" for :nc
p*ync  e^ tUe rem*di«tio:v
                   c§!(> fcr th-e
   l. vs«tt* fm»t«nVr., and cft'-jit? tresimer.vtfljpova' for i
C A- J Oltpojal S'Jtssrfvnc >it« '.i Ea:on, Vi*^i)9n Cov^tf.
ll.Y. TK« eoi!  <>/ clea-'jc  prcj^t  Is  appro*  .-ratc:y
4672. -OO. Supti-fwircJ  i> the friera:  ?rcg:«m  is
           wast? s'les.
E?A hn t^Sodv'ed a p-jb"c fr^-'Jr-t ?•: d'j:yj? 1^ f .idings
c? tts r.«mKl;fti lrtvc?t!a»:;cn.T*i:it::iry S:y^v  (^i/1'S). o^
                               •tSeC&Ji
             .   . .      .-!!! b«he?dat ?:>
d§y, Frbrvary  '3. 19*! »', th? ttarr-,.iton Cer.lral ?:ch
'•'•'c:'. K*f*.d'lc'< A-'t, Mamli-.c". NY. THe Propoic^ P:j.-. dc-
iCr>b*> tne r*rr.rt'al alieTurtvo cor.jldf*d '6'  Ih'i C &  j
i-tc  TK* rele»:c 01 t'n* rVcpcie-d riant »r;^ vKe >ched^lto

titioi  fcjpoi.iibill'iei  v»r»d«f jcetlon I'7(8)  of  th'j com-

L'nbili.jy A."ct tCeRCl/0 of 19*0.    '              "'    •
of th« tix
                                        dufir.g \h
                                        .°A fcvicv.
                    Tve(hol frf c.
 p«rmancr>t sccu'lng C- th> site; 3; fi.'llrj 1,15! rtzarulri2 Cf
 tr-C d.ipoti't Irerch (tiie contaminant source), ip^ia'l^no1*'
 o' a  rfc!er?:vc cap. to p-*\-c^; d:tit"t*.-ii;t of th; coi>-
           area »rd p«rrrv4rtnt l«rtve/in| c( l.w.C w^tCf table
           '  '            r,- ef CCn5irr.irv*nt  mijratl^n v'.J
                         cr« cf 1^30 cubic  y»rii c- co^-
           toll jind w««tt matpo«ur^i ^nti line dUpeu! sf the
 rrv»:eri«l in 3 p«:n>ilitd facility; 5) o.cavaVon cf jcil'wju'.e
 rrvaJe'ial ?» In Alternative 4 and •j'ar^B^rtation cf the mrttr-
 rial ofT.»l'.« for |He'rp.|! trestmp.it; 6.' On-S!!*  trtatmcnl b">'
 fr^Hing the *«:Lw«»;e fna:e*i»i »»ith neat generatetJ from
 an electrical  c>'"*"L Bas^d upv a" cvoiuaticn c! UHT/B
 various alle-rm^vti, E?A 'i 'eco^rrxr^irs A!tcm«tr-e .--'c.
 4 a* ?ht prefe'rei alic'n»tJ%«. Irvolvinf ei;«v«»:on.off-iiie
 t-'arnpcrtalion.  *nd  trc^br-tni'^iipo^il  p!  Ihi  tC
 wa»tt materiali.
 EPA w«tcom«t ix.'bl!c com.-rven: on tS«j ArJmini)ira'.Ii't Re-
 COftJ «nd *:! J(tef.n.M.v«-i kii.nlir^d tbCVX. SPA YV-
    flrit-.Sue  renpfrcy »i";cr  ih»  owb'ic  comrrwnt
       of  £nvlrcr>rr.«n|,-;|  crnyi'.atlc^.  I
 ft--ay «e!*e: an option oiK«- Uvei the
            '
in \?
  orj
 cxxxirrerititio^ ef tne prc'-fll fir.dins* Ij p.TM'iied i
 Aijmir.ijtfjtive Rccere Fii«. which C,cnW = f\J Rl'rS  R?
 *-xJ lS» PrCPOStd PUn. TKr»e COCUTTrenU a?C BvaileJt

 pubiic  review »( «K« H.ami^c'iTutlic UOfa'y.  7 Bro.i^
 '^V^'-f ^^^.'Hofl. N.Y. T.K^ svfc!;r. ir.^y CC-THT.«.-.I in T^^tc;^
 at iKe public rrMfl.^a ind-or tufc.r>ri >Yfi:ten 
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    t  UNITED STATES EN V:=r CNVENT AL PROTECTION AGENCY
                       CC-S «. >vrr: --^s?^.
                               W YCSK 10272
                      AGENDA
                 C & J Cispcsal SuDerfund Site
                   l-;amiltcn Central Schccl

                 l-amiltcn,  sevv >crK
                  rehruarv 13,
I.  Wslcone &  Introduction
I_
Overview of Superf'.
Process  at the
C & J Disposal
Sucerfund Site
Yvette Karris
Cc^riunity Relations  Coordinator
U.S. E?A, Region  2

Jcel Singernan
Acting Chief
NY/Caribbean Superfunc  Branch
U.S. EPA, Region  2
III.  Site Background
     History
Raymond M.  Kapp
Senior Environmental  Scientist
Wehran Envirotech
(Consultants to EPA)
IV.   Presentation of
     Results of the
     Remedial Investigation
     & Feasibility Study
     (RI/FS)
V.   Presentation of  EPA's
     Preferred Alternative
VI.  Concluding Remarks
VII. Questions & Answers
 Jack O'Dell
 Project Manager
 Western New York Superfund
 Section
 U. S. EPA,  Region 2

 Joel Singer~an
 Yvette Karris

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   Appendix B
the Proposed  Plan

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Superfund Proposed  Plan

                                    C&J   Disposal  Site

                                         Town  of  Eaton,
                             Madison  County,   New  York
EPA
Recion 2
January. 1S91
PURPOSE OF PROPOSED PLAN

This Proposed Plan describes the remedial alternatives
considered for the C&J Disposal Superfund site located
in the  Town of Eaton, Madison County, New York, and
iden'.ifes the preferred remedial alternative  with the
rationale fcr this preference.  The Proposed Flan was
developed by the U.S. Environmental Protection Agency
(EFA; with support from the New York State Department
of Environmental Conservation (NYSDEC). EPA is issuing
the  Proposed Plan as part of  its  public  participation
responsibilities under Section 117(3) of the  Comprehen-
sive Environmental Response, Compensation, and Liability
Act  (CERCLA) of 1980, 42 USC Section  9617 (a), as
amended, and Section 200.430(0 of the National Contin-
gency  Plan (NCP). The attematrves summarized here are
described in the Remedial  Investigation  and Feasibility
Study  (FU.TS) Report, which should be consumed for a
more detailed description of all the attematrves.

This Proposed Plan is being provided as a supplement
to the RJ/FS report to inform the  public of EPA's and
NYSDEC's  preferred remedy and to  solicit public com-
ments pertaining to  all the remedial attematrves evalu-
ated, as well as the preferred alternative.

Chances to the preferred remedy or  a change from the
preferred remedy to another remecty may  be made if
public comments or additional data indicate that such a
chance will result in a more appropriate remedial action.
The finaJ decision regarding the selected remedy will be
made  after EPA has taken  into consideration all public
ccmmsnts.  We are soliciting public  comment on all of
the ajtemsives considered in the detailed analysis phase
of the RLTS because EPA and  NYSDEC may select a
remedy other than the preferred remedy.

Tne detailed information  and data used in determining
the  nature  and  extent of the contamination on-site and
in the development of remedial alternatives is contained
         in the Rl/FS report.  Tne Proposed  Pla~. nic.'.iiC'is re/
         information from the  Rl/FS report, but it is net a sucs1.;-
         tute for that report.

         Copies of the Rl/FS report. Proposed Flan, a'.c s-ccc".-
         ing documentation a/e available at the foi.'cv.-ir.g repcs to-
         nes:

         - Hamilton Village Public Library
          13 Broad Street
          Hamilton. N.Y.  133-J5

         - New York State Department of
           Environmental Conservation
          50 Wort Road, Room 222
          AJbany, N.Y.  12233-7010

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

         COMMUNfTY ROLE IN SELECTION PROCESS

         EPA and NYSDEC rely on public input to ensure that the
         concerns of the community are considered in se'ecting
         an erfectrve remedy for each Superfund site. To tr:s en a
         the Rl/FS report has been made available to the public
         for a public comment period which concludes on Febru-
         ary 22. 1991.

         Pursuant to Section 117(3) of CERCLA, a public meeting
         will be held during the  public comment period a: the
         Hamilton Central School, West Kendrick Avenue. Hamil-
         ton, N.Y. on February 13, 1991. at 7:30 p.m. to present
         the conclusions of the Rl/FS, to further elaborate en the
         reasons  for  recommending  the  preferred  remedial
         alternative,  and to receive public comments.

         Written and oral comments will be' documented in the
         Responsiveness Summary section of the Record of

-------
   ~s:on (ROD),  the  document  which formaJizes  the
   •ertJon of the remedy.
A3 wTiaen comment should be addressed to:

Jecx O'DefL Project Manager
Western New York Superfund Section I
U.S. Environmental Protection Agency
25 Feoersi Plaza, Room 29-102
   x York, New York 10278
SITE BACKGROUND
Tne C&J Disposal she is located in the Town of Eaton,
Mac'son County, New York.  It is near the intersection of
Ro--.es  123 and 46 just north of the Village of Hamilton.
The s.ie includes a rectangular disposal trench which
measLres  140 feet by 40 feet.  The trench is  situated
berr.'.s-e.n a former railroad bed and an active agricultural
fieJc.  The site  is also at the intersection  of three land
pa-ceis, one of which is owned by C&J  Leasing.  A small
po". on the C&J property, lies to the south and  is within
 ; X '.=—'. of  the disposal trench.  The pond,  with an
acf.= :en: wetland to the west, ultimately drains to Wood-
   -~ For.d which  serves as a backup drinking water
   L-:e  fcr the Village  of Hamilton.  There are  thirteen
res'.c-ervces in the vicinity (within 1800 feet) and downgra-
die~ ct the site.  Currently, twelve residences are utiliz-
ing private wells as their source of drinking water (see
DuTL-g the mid-1 970's, the trench v/as reportedly used for
the disposal of solid and liquid industrial waste materials.
In March 1976, C&J Leasing  of Paterson.  New  Jersey
v/as observed  dumping what appeared to  be paint
slucces and other liquid industrial waste materials in the
trercn.  Inspections were subsequently conducted by the
New  York   State  Department  of  Health   (NYSDOH),
NYSTEC. and the Village of Hamilton Engineer.  During
inspections  conducted  by  NYSDEC  and   the  Village
Enc'reer, approximately 75 to 100 drums were  observed
layL-jc in £ stagnant  pool of liquid wastes in the  previous-
ly oescrroed trench.    The  trench  was subsequently
ccvered with soil, reportedly by C&J Leasing, apparently
burying the  drums.

Sarpung was conducted at the site by  NYSDEC  in 1985
and by EPA's contractor,  NUS Corporation,  in 1986.
Surfcia! soil samples obtained from the site  revealed the
presence of phenolic  compounds, phthalates,  various
voiatle organic compounds (VOCs), pofynuclear aromatic
    Ccca-sons (FAHs),  and  lead.   Bis  (2-ethylhexyl)
    a'are was detected in  sediments from the adjacent
    --

The sie was placed on the Superfund National Priorities
Lis: (NFL) in March  1989.
During the 1986 sampfing, NUS also  sampled drinking
water from two private wells downgradient of the site but
did not detect any contaminants. Additional testing by
NYSDOH in September 1988 of four private wells do-.vn-
gradient from the site did not reveal  any contamination.

In  April 1989, prior to the start  of Remedial Investigation
(Rl) field  activities,  the  site was subject to an  unautho-
rized excavation  by the principals of C&J Leasing.  As a
result, two stockpiles of soil  and waste material v/ere
accumulated within the trench  and one  stockpile 'of  soil
and waste material v/as accumulated outside the trench.
Most  of the drums believed  to be buried earlier had
apparently been  excavated and disposed of off-site.  EPA
is  continuing to investigate this  matter.

The  Rl conducted  by EPA during 1989 and 1990 indi-
cated that the primary contaminants in  the trensh area
and external soil and waste pile  were non-halogenated
VOC's (benzene,  ethylbenzene,  toluene,  xylenes, 4-
methyl-2-pentanone.  etc.). various   phthalates  (bis(2-
ethylexyOphthalate,di-n-octylphthalate,di-n-butylphthalate,
etc.) and  phenols  (4-methylphenol,  etc.).  Lead, which
was  not  detected above background levels during
extensive Rl sampling was found at elevated levels during
more limited testing by NUS (1986) and USEPA  (post Rl).
All of these  contaminants are presently  adsorbed or
bound in the waste material and/or are adsorbed to the
soils and have not  migrated to the groundwater. from the
trench. Extensive chemical testing of the twelve residen-
tial wells during the fil further confirmed the prior results.
i.e., that no contaminants from the site had migrated to
these wells.  Seven monitoring wells, installed during the
Rl  in and around the site, also  indicated no migration of
contaminants  from  the  trench  to  the  groundwater.
Testing of the pond water indicated  no contamination
from the  site.  Low levels of bis  (2-ethylhexyl) phthalate
found in sediments from the adjacent pond are attributed
to  overland sediment transport by surface water runoff.

At  present, the site is secured with temporary fencing.
To provide increased safety, the external  soil  pile v/as
moved back into the trench.  Finally,  all soil and waste
material piles have been covered with protective covers
to  prevent contaminated soil transport.

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SUMMARY OF SfTE RISKS

A baseline hearth risk assessment  was performed as a
part of the Rl to evaluate trie carcinogenic risks and non-
carcinogenic chronic lifetime effects associated with the
C&J Disposal site; assuming that no remediation occurs.
This risk assessment was based on the impact of the ten
chemicals ol concern, Le. benzene, butyl benzyl phthal-
ate,  di-n-butyl  phthalate. 2,4-dimethyl  phenol, ethyk
benzene, bis(2-€thylhexyi) pttthaJate, 4-methylphenol. di-
n-ocryl phthalate, toluene, and total xylenes.

Because  the  s.te is no; permanentry  secured and  is
subject to trespassing,  it is  assumed  that  individuals
ccu'.d come in direct contact with contaminated soils and
wastes found at the surface. Therefore, human exposure
pathways include dermaJ contact and incidentaJ ingesticn
of  surface materials.  The maximum exposure carcino-
genic risk and non-carcir.ogenic hazard were calculated
for these  exposures.  The carcinogenic risk was esti-
mated at 2 x  10^ and is at the high end of the accept-
able range of  10"4!? 10"*?  EPA considers risks in the
ra.-^ge of  lO^to I0"6to be acceptable.   This risk range
can be interpreted to mean than an individual may have
a one in  ten thousand to a one in  one million increased
chance  of developing  cancer  as  result of  site-related
exposure to a carcinogen over a 70-year lifetime under
the specific exposure conditions at the  site.

The  non-carcinogenic Haza/d Index (HI) for the same
maximum exposure  was estimated  to be 4.  An  exceed-
ance  of unity, that is 1.0, in the HI indicates that condi-
tions existing at the  site  are not adequately protective of
human hearth.

The low levels of bis (2 ethylhexyf)  phthaJate detected in
the pond sediments are apparently attributable to the
site. However,  the pond is privately owned and currently
not known to be used extensively for fishing or wading.
Furthermore,  compared  with the  NYSDEC  Fish  and
Wildlife Sediment Criteria Guidance values, the contami-
nant concentrations are  tow and the impacts  on humans
or wildlife under current  conditions are negligible. While
exposure derived from sediment pathways (direct contact
and  bioaccumulation)   may  currentry  be  considered
minimal, the potential movement of contaminants from the
site to the pond under current circumstances represents
a threat.

Exposure pathways  presently considered to be incom-
plete include the wind-borne transport  of fugitive dust
and the migration of contaminants through groundwater.
In the former case, temporary cover measures  and  the
presence of  natural vegetation significantly  limit dust
generation to downgraclent receptors.  In the latter case,
the absence  of contaminants in the groundwater at  the
site,  as  well as  in  the  downgradient  residential wells
sampled from 1986-19SO. indicate that no significant risk
cf exposure to  humans from groundwater consumption
exists at the present time.  However, the soil contamina-
tion may pose significant indirect risk by being a potent-
ial source  of future groundwater contamination.   EPA
policies and  regulations allow  remedial actions to be
taken whenever cross-media impacts result in exceeden-
ce of cne or more Maximum Contaminant Levels (MCLs).
Even  though  there  is no  current  evidence  cf  MCL
exce-edence,  changes  in soil chemistry brought on by
either agricultural activities (fertilizer, lime,  or pesticide
application) or natural phenomena (bio-degradation of the
waste material  matrix,  or algae or mold blooms in the
trench pits, etc.) might cause the release of contaminants
into tr.e groundwa'.er.   Consequently, soil remediation is
warranted to  remove this continuous  source of contami-
nation to  the groundwater to ensure  compliance v.itn
Federal and  State groundwater standards.   In  both
groundwater  migration  or  air transport, there  are no
permanent measures  in place to prevent  releases of
waste constituents through these pathways.  Actual cr
threr-ned releases of hazardous substances from this
srte. rf not addressed by the preferred alternative or one
cf the other alternatives, may present a current or future
threat to  public health, welfare,  or the environment.

SUMMARY OF  REMEDIAL ALTERNATIVES

CERCLA  requires that the  selected  site  remedy be
protective of human health and the environment, be cos;
effective, comply with  other  statutory  laws, and  utilize
penr-anent solutions and alternative treatment technolo-
gies and resource recovery alternatives to the maximum
extent practicable.  In  addition, the statute includes  a
preference for the use of treatment as a principal element
for the reduction of toxicity.  mobility, or volume of the
haza/dous substances.

The remedial response objectives for the C&J Disposal
site are:

-  E::minate the potential for direct human or animal
contact with the contaminated soil and waste.

-  Prevent the migration of  contaminants from  the site
through surface' water runoff and ensure protection of
the groundwater and surface water from the continuous
release of contaminants from soils.

Accordingly,  the feasibility  study (FS)  report evaluates.
six remedial  alternatives,  in  detail, for addressing the
contamination associated with the C&J Disposal site.

These alternatives are:

ALTERNATIVE  1- No Action with Monitoring

Capital Costs:  SO
Operation and  Maintenance (O & M) Cost:  S50,000/yr

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Preset Worth Cost:  3528,500
Tirr>e :o Implement:  1 month
I
  is  Superfund  program  requires  that the  'no-action*
atte-rr-alive be considered  as a baseiine for comparison
with  ctn^r aJtematives. Under this alternative, no
rerr/e-iiaJ action to control the  source  of contamination
wccii take place.  However, long-term  monitoring of the
site would be necessary.  The monitoring program would
ccns'st  of  sampling  seven  on-site existng  monitoring
weC-s on a qua/terry basis for 30 years.

Because this attemat'rve would result in  contaminants
remaning on-site, CERCLA  requires  that the  site  be
rev>?
-------
Tnird Land Disposal Restrictions (LDRs) if remediation is
taxen at the site before May 3.  1S92.  Conversely. if me
waste is net cLassrfied as  a FC.-A hazardous waste on
the basis  cf TCL?  ar.aiysis fcr the  contaminants  cf
ccncem,  it could be disposed  c! in a permitted landfill
accepting industrial waste.  Lastly, if me waste, cr portion
of the waste, fails the TCLP analysis  due to other constit-
uents not identified as contaminants cf  concern (e.g.,
teac). that waste would be restricted from land  disposal
unless pretreated (e.g., stabilization/solidification).  Costs
in this case could  be  an  additional  $160,000 (based on
stabilization Si Si30/cutic yard).  The pretreated waste
would  have to  meet TCLP requirements  to  permit land
cispcsaJ  and pcss-.'ory  require  a treatabiiiry  variar.ce to
ALTH=.NA7'.VE 5 -  Ferr.cva!  and Off-Site Thermal Tre;:-
Cacr.a! Costs:  $1.133,500
04M Costs:  $36,000
Present Worth Costs:  $1,219,500
Time to Implement:  6-9 months

This cte.T.atrve involves excavating the soil/waste material
(approximately  12£'0 cubic yards)  from the disposal
trer.ch as described  in Alternative 4 and transporting the
material crl-srte  for thermal treatment.  Thermal treatment
involves the thermal destruction of the contaminants, and
is principally used in destroying organic waste.   The
resulting ash/residue would be treated, 'rt necessary and
disposed of in an off-site Treatment, Storage and Dispos-
al (TSD) facility.   There  are  several thermal treatment
options available (i.e.. low temperature, incineration, etc.).
The above  costs are based on incineration.   This cost
does no; include the off-site treatment of the remaining
astx'residue.'soil, for  any of the thermal treatments.

As described in Alternative 4, any  alternative involving the
removal  of the soil/waste material from the trench would
incorporate confirmatory  sampling  of the trench  upon
completion  of  the excavation work.  Cleanup criteria
would be based  on background levels found in upcra-
d~tent soil samples obtained from the abandoned railroad
bed and a  native  soils sample.  Upon confirmation that
the  contaminants of concern had been removed, the
excavation would  be backfilled with clean fill and vege-
tated. All monitoring  wells  on site and the nearby residen-
tial wells would be  sampled on  a  quarterly  basis fcr a
period of one year.

ALTERNATIVE  6 - In-Situ  Vitrification

Capital Costs:  $1,030.000
O &  W Costs:  S-iS.OOO/yr
Present Worth  Costs:  $1,551,800
Time to  Implement:  6-3  months"
This alternative involves cn-srte treatment by melting the
soil/waste material with heat generated from an electrical
current. Four electrodes would be implanted into the soil
in a square pattern, spaced 30 feet apart.  A mixture of ±
graphite and glass grit would  be placed on the surface
to provide a conductive  path for the electric  cjrrer.t.
Resistance in the soil would cause  the temperature to
rise to near 2.000° C  resulting in the destruction of  the
organic contaminants and the encapsulation  cf any
remaining material in a glass-like  mass.  This p-ocess
would  require temporary  dewatering  of  the site, which
would  be  accomplished   by  excavating a  temporary
dewatering trench adjacent to the site as described in
Alternative  4.

Because the material would be left in place, crcur.-.-.atsr
monitoring would be required for a period of 30 years 10
corrfirm that the contaminants  of concern are net migrat-
ing from the vitrified mass.  This alternative wc-jid also
require five-year reviews.

PREFERRED ALTERNATIVE

Eased upon an evaluation of the  various alternatives.
E?A recommends Alternative 4 as the  proposea rerr.edy
for the site.  This alternative consists  of remove c;  the
contaminated soil and off-srte  treatment/dispose!

The preferred  alternative  achieves  risk  reduct.-cr. me-
quickly and  at substantially  less cost  than  the oth
options.  Therefore, the preferred alternative wii! prcv;u-
the  best balance of  trade-offs among alternatives v;:tn
respect to the  evaluation  criteria. EPA believes that the
preferred  alternative will be protective of human health
and the  environment,  will comply  with Applicable  or
Relevant and Appropriate  Requirements (ARARs;. will be
cost effective,  and  will utilize permanent solutions and
alternative treatment technologies to the maximum extent
practicable.  This  remedy  is  also consistent  with  the
statutory preference for the use of a remedy that involves
treatment as a principal element.

In the unlikely  event that  Alternative 4 cannot be imple-
mented  before the RCRA Land  Disposal  Restrictions
deadline of May 8, 1992. Alternative 5 would ce imple-
mented in its place for the portion of the waste that  has
been classified as a RCRA characteristic waste.  Arterna-
•tive 5 involves the same on-site remediation activities and
also has NYSDEC concurrence.

RATIONALE FOR SELECTION

During the detailed evaluation of remedial alternatives.
each  alternative is assessed against  nine  evaluation
criteria, namely short-term effectiveness: long-term effec
tiveness and permanence; reduction of  toxicity.
or  volume;  implementability;  cost;  compliance  w
ARARs;  overall  protection of human hearth  and  in
mobili^M
:e  wfl
ind the

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 environment; and state and community acceptance.

     evaluation criteria are explained below.

 o  Overall protection of human  hearth and the environ-
 ment  addresses whether  or not  a remedy  provides
 adequate  protection and  describes how risks  posed
 through each exposure pathway (based on a reasonable
 maximum exposure scenario) are eliminated, reduced, or
 controlled  through treatment, engineering controls, or
 institutional controls.

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

 o  Long-term effectiveness and permanence refers to the
 ability  of a  remedy  to maintain  reliable protection of
 human health and  the environment  over  time, once
 cleanup goals have  been met.  It  also addresses the
 magnitude  and  effectiveness of the  measures  that  may
 be  required to manage  the risk posed by  treatment
 residuals and/or untreated wastes.

B   Reduction  of  toxicrty,  mobility,  or volume through
^eatment is the anticipated performance of the treatment
 technologies, with respect to these parameters, a remedy
 may employ.

 o  Short-term effectiveness addresses the period  of time
 needed to  achieve protection and any- adverse impacts
 on  human  health  and the environment that may be
 posed during the construction and implementation period
 until deanup goals are achieved.

 o   Imolementabilitv  is the  technical and administrative
 feasibility of a remedy, including the  availability of materi-
 als and services needed.

 o   Cost  includes estimated capital and  operation and
 maintenance costs,  and the net present  worth costs.

 o   State  acceptance  indicates  whether, based on its
 review of the RI/FS report and Proposed Plan,  the State
 concurs  with,  opposes,  or has  no comment on the
 selected remedy at  the present time.

 o  Communrty acceptance will be assessed in  the ROD,
 and refers  to the public's general response to the alter-
 natives described in the Proposed  Plan  and the RI/FS
 report

WK comparative analysis of the six remedial aHematives for
 the C&J Disposal site based upon the evaluation criteria
 noted above, follows:
Overall Protectiveness of Human Health and Environment

Alternative 1 would not be protective of human health
and the environment, but is included for comparison with
the other alternatives. Alternatives 4 and 5, by contrast.
woukl  be fully  protective  of  human  health  and  the
environment because the  contaminants are complete!-/
removed from the site.  Alternative 2 would provide some
measure of protection from direct contact with contami-
nants through permanent  fencing of the site, but does
not prevent  contaminants  from migrating from  the  site
through surface water runoff, air transport or release into
the groundwater and migration to downgradient  drinking
water sources.  Alternative 3 would prevent contaminant
migration  from  the site, but would require permanent
dewatering of the  disposal trench  and  discharge  o!
untreated  groundwater to the pond and wetlands.  This
coukj result  in adverse environmental impacts.  Alterna-
tive 6 would reduce the chance of  contaminant migra-
tion to other environmental media by destroying most c!
the organic contaminants of concern. Any contaminants
not destroyed would be  encapsulated  in a glass-like
mass that  would be insoluble and, therefore, not likely tc
teach contaminants.  Subsequent  covering of  the  si:e
with  clean fill would eliminate  the potential for  physical
contact with the vitrified mass.

Compliance  with ARARs

Waste constituents are  present in the soils at the site but
are not currently  present in the  groundwater  or surface
water. There are no chemical ARARs for soils, but there
are federal and state  regulations for  groundwater and
surface water.  Alternatives 4, 5, and 6 v/ould meet these
ARARs, whereas Alternatives 1  and  2 v/ould likely  no;
meet ARARs in the event  of a release of contaminants
from the site.   Alternative 3 would not  be expected to
exceed ARARs for  groundwater, but could exceed  dis-
charge limits for solids, turbidity, etc. into the  wetlands.

Concerning   location-specific  ARARs,   Alternatives  2
through 6 may involve remedial  activity at or within the
perimeter  of a 100 feet  buffer zone of the pond/wetlands.
These  activities  would be  performed  consistent with
accepted  practices to protect the v/etlands. The excava-
tion  of soil and waste under Alternatives  4 and  5 v/ould
occur just outside of the 100 feet buffer zone.

Alternatives  4, 5. and  6 involve action-specific ARARs.
Off-site disposal  (Alternatives  4 and  5) would  be
subject to  New York  State  and  federal  regulations
regarding transportation  and  disposal.    Due  to  the
presence  of lead in the waste, disposal at a Resource
Conservation and Recovery Act (RCRA) permitted facility
is assumed.  Current RCRA Land  Disposal Restrictions
would allow the disposal of the excavated soil  and waste
in a land-based  unit until May  8,  1992  (Alternative  4).

-------
i r>e final ct~.a.'ac:=n2H*jcn of wastes and the apprcpriate-
r.ess  of  a  Testability  Variance  under LDRs would  be
determined ty TCLP testing.  In the case cf Alternative 5
(tnermaJ  treatment) compfiance  with ajr emission stan-
dards would be required at the off-site treatment faciirry.
In  the case cf Alternative 6. en-site treatment would be
sublet to ARARs for air emissions during the vitrification
process.  Treatment cf  off-gases may be  required to
meet the requirements  of New York State Regulations for
Fre.-errtion and  Conuo^  cf  Air  Contamination  and  Air
FoSction and must compty with New York Slate Air Guide
- 1 for the Control of Toxic Ambient Air Emissions.

Lore-Term E"ecti"/eness and ^enraner.ce

Aiematrve 1 would involve no controls and,  therefore, is
rex effective  in  permanently preventing  exposure to
contaminants  on-site  ex- eliminating  the  potential  for
contaminants  migrating off-site.   Alternative 2 could be •
elective in  preventing  direct exposure over the long-
term,  but would  not be effective in protecting  against
migration of  contaminants   off-site  and  the resulting
exposure.   Alternative  3  would  be  effective  against
contaminants  migrating from  the  site,  but potential
grccrxJwarer contamination may  adversely impact on the
pocd/wetlands.   Also,  the  installation of a  permanent
de^atering system could have a  long-term impact on the
agricultural field.   Alternatives 4 and  5 would  be  fulty
elective and  would  provide  permanent  remediation.
AJtemative 6  would be  highly   effective  in protecting
against on-site exposure and off-site migration.

Reduction in Toxiciry. Mobility, or Volume

Alemaiives 1  and  2  would provide no  reduction  in
taxJc.ty. mobility, or volume.   Alternative 3 would  provide
a  reduction in mobility of wastes, but no reduction in
tcobcrty or volume.  Under Alternatives 4 and  5. corrtami-
rtsrss would  be  removed completely.   However,  land
disposal (Alternative 4)  would  not  reduce  toxicity  and
volume of the waste, but would  control and manage the
mobility  of the contaminants (as the  material would be
pfeced  in  a  secure facility).  In the case  of  thermal
tres^nent (Alternative 5). an  overaJI reduction in volume
and toxJcrty would be  achieved, as  well as eliminating
waste mobility.  Treatment (stabilization/solidification) of
the subsequent ash/residue/ soil, prior to disposal in an
appropriate landfill, would  control   and  manage  the
mociDry  of any remaining contaminants.  Under  Alterna-
tive 6. the organic contaminants of concern would be
destroyed or encapsulated.  The mobility pctentia. cf any
residual contaminants would  be greatly  reduced  or
e*rr,inated by encapsulation in the vitrified mass.  As  a
result of the  vitrification process, the total volume of
sod "waste would be reduced by 25-457o.
Short-Term Effectiveness

Alternative  1  would be  ineffective in protecting  against
direct  on-srte exposure to  contaminants and  off-site
migration of  contaminants.  Alternative  2 would readily
protect against direct exposure on-site, but  would not
address short-term migration of wastes off-site.  Alterna-
tive  3 would have  a  minimal  adverse  environmental
impact during capping and installation of the dewatering
system.   However, the impact of pumping  untreated
groundwater  into the  pond/wetlands could be a signifi-
cant short-term concern. Alternatives 4  and 5 would be
expected to have minimal adverse environmental impacts
during excavation and temporary  dewatenng operations.
Appropriate measures will be taken during excavation  to
prevent transport of fugitive  dust and  exposure  o!
workers and  downgradient  receptors to  VOCs.  Alterna-
tive  6 would be  expected  to  have minimal  adverse
environmental impacts  during dewatering. construction
and operation. The remaining remediation activities would
take place in the trench area and  in the adjacent  land
between the  trench and Route  125 and would  have
minimal adverse effect.

Imolementabilrrv

Alternative  1   would be easily implementabie as  only
groundwater  monitoring is involved.  Alternatives 1,  2.  3
and 6 would  require groundwater  monitoring for 30 years
each, and Alternatives 4 and 5 would require monitoring
for only one  year each.   Under Alternatives 2  and  3
permanent securing of  the site would  be easily imple-
mentabie but final agreement on  deed restrictions could
be lengthy.   Alternative  3 would  be the most difficult  to
implement.  The  installation of a  permanent dewatering
system would have  a 30 year impact  on the adjacent
agricultural property and groundwater discharge to the
pond/wetlands would require a New York State Pollution
Discharge  Elimination  System  permit  and  state  and
federal approval to discharge into wetlands.  Alternatives
4 and 5 use proven technologies,  established administra-
tive procedures, have  sufficient  facilities  available for
disposals  and therefore  these  alternatives  are easily
implemented.  Alternative  6  would  be implementable
provided  treatability  studies  demonstrate   adequate
effectiveness for the site.  Administrative activities would
include securing electricrty for the process, obtaining and
coordinating   subcontractor  activities   and  providing
adequate  safety for the  site during remediation.

Cost

Present worth costs range from a  low of  5528,500 for No-
Action with Groundwater Monitoring (Alternative 1)  to a
high of Si,55",800 for In-Situ Vitrification (Alternative  6}.^

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  !_,„ A~.eotance

         concurs with the preferred alternative.

..Community Acceptance

 Community acceptance of the preferred alternative will be
 assessed in  the ROD following  a review of the public
'comments  received  on the RI/FS report and  the Pro-
 posed Plan.

 CONCLUSION

 EPA believes that the preferred remedy described above
 is fully protective of human health and the environment,
 meets aJl the ARARs, offers the best balance among the
 evaluation  criteria  discussed above,  and satisfies  the
 statutory preference  of treatment as a principal  element
 in remedy selection.

 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 any  of the  remedial  alternatives
 addressad in the RI/FS report and the Proposed Plan.

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     Appendix C
iblic  nset-inc sicrs —in sheet.

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                                             REGION II
                                             ILIC MEETING
                                                FOR
                                  C  &  J Disposal Buperfund Site
                                   Hamilton, New York

                                         February  13,1991
                                         MEETING ATTENDEES
     NAME
  <1( ' /^(f/c't /'•
/LJ/V^/Si/i/;
/>£
         STREET
                         /', /-.
                                           (Please Print)
CITY
                                   1   /
                                     JL) V ^
                          /i.
                                            M
ZIP
                                  A//V 1C 2
PHONE
  '
                                                  //,-
                MAILI:
REPRESENTING    LIST
                                                                         A/1? >
                                                                          \\v

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                      UNITED STATES  ENVIRONMENTAL PROTECTION AGENCY
                                         REGION II
                                      PUBLIC  MEETING
                                            FOR
                              C K  J  Disposal Buperfund  Oito
                               Hamilton, New  York

                                     February 13,1991
                                     MEETING ATTENDEES
                                       (Please  Print)
                                                       ., i '••                            MAII
NAME              BTREET          ( CITY  (       ZIP     '  PHONE       REPREBENTINO     LIST
 \. v.x\        ''...v \(^         ';'*.;.».'» 1 V..v  \  iV/l.   .'(.(Q
                                                                                   ,
        \

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                     UNITED STAT^KNVFRONMENTAL  PROTECTION  AGENCY
                                ^^   REGION  II
                                     PUBLIC MEETING
                                           FOR
                             C & J  DiDposal Buporfund  Oite
                              Hamilton,  New York

                                    February 13,1991
                                    MEETING ATTENDEEO


                                     (Please Print)


NAME             STREET           CITY        ZIP       PHONE      REPRESENTING    LI

                                        _    ///    _

                                        ._   MV     >:
            ti^V

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                   Appendix D
;ncer.ce  received ty EPA curing the public ccrTuaent  period

-------
                                                 •   .    ,   ~.-.   .,
                                               :-;arilt,cr. ,  lie'.v Ycrz
                                               !-'arch.  ~   1-91
      V.  .^ = -L -!. .  ."". - ~. ~ — — ; —  J1


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                                               Arcean  5.  Rocrar.
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-------
(Q&
ROBEK7 H. KUlPErl                                                      CNDY L URTZ

                                   ^                            CIS) ^2201
                          (Q&u/nfy ^cav-d of 
-------
                            RE c OZi L" T ~ •""• \


           INFORMING THZ ENYIRCN.VENTAL PROTECTION AGENCY  THE
           HOARD OF THZ TOWN C7 EATCN, NY, POSITION RELATIVE TO THE
           CLEAN-UP OF THE CSJ LEASING HAZARDOUS WASTE  SITE IN THE
           TOWN  OF EATON, NY.


     VTEEREAS,  Inspections at the site by the New York  State Department of
Health ar.d Village of Eaniltcr. Engineer revealed approximately 75 to 100
druns cf liquid wastes arc

     KEZEEAS,  the site, ccr.tair.s a snail pond, which is  adjacent to wetlands
that ultimately drain tc Kcc-cr.ar, Pcr.d which serves as  a  backup drinking
water source  for the Village cf llar.ilten and

     *TEZ?Z_SS,  sair.plir.es frcra the site by the New York  State Department of
Envircr.rj5r.tai  Conservation ar.c FPA's contractor, NUS Corporation revealed
presence cf phenolic ccrpcurcs, phthalates, various volatile organic
ccrrcurds, pclynuclear arcnatic hydrocarbons and lead.   Arse Bis  (2-ethylhexyl)
rhthal=te  detected in sedirerts frcr. the adjacent pond and

     KETFIAS,  the site vas clacec  cr. the Superfunc National Driorities
   r- ir. ."arch  1989 ar.c

     KEEP.EAS,  further study by NUS Corporation indicated concentrations
low, the potential nover-ent of ccr.taninates from the site to the pond under
curreri circuristances represents a threat and

     KHZ PEAS,  CERCLA requires that the selected site rer.edy be protective
cf hunar- health and the envircnr.ent, comply with other statutory laws, and
utilize permanent solutions,

     srcw,  THEREFORE, EE IT RESOLVED, the Board of the  TCV.T. of Eaton endorses
as a nlnlrur.  solution ALTERNATIVE  4  - Removal and Off-Site Treatnent/Disposal
as set fcrrh  in the Superfur.c Prcpcsec Plan, C&J Disposal Site, dated
January, 1991,  EPA-Regior. 2.
      3. J=-e: E.  Episcopo, icvn C:erk. Trvn of Eaton, certify that the above resolution
   vas -J.2- passed at the M^rch 11,  1991 reeting of the Town of Eaton Board.  Councilman
   Ra- Simons aoved the resoluticr  be accepted and Councilman Johr. Pearsall seconded
   the ncricn and  the follevins vote resulted:  Supervisor Anthony Zazzara-aye;
   Co —ri_n£n John Pearsal 1-aye ; Ccucci ir^sr Ray Simmons-aye ; Councilnian Thomas Ciarrocchi-aye.
                                                    >.->-  -/  ^

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February 27, 1991
Mr. Jack O'DeU, Project Manager
Western New York Superrund Section I
U.S. Environmental Protection Agency"
26 Federal Plaza - Room 29-102
New York, New York
1027S

Dear Mr. O'Dell

Re:    C&J Disposal Site
       Review of PFLAP and RJ/FS

       Occidental Chemical Corporation (OxvChem) wishes to make the following
comments on the following documents  related to the C
-------
    OxyChem
    February 27, 1991
    Page 2 of 2


    Review of the Remedial Investigation and Feasibility Study (RI/FS) indicates that the
    health risk has been overestimated by the risk assessment included in the RJ/FS (Chapter 6).
    The incremental cancer risk posed by the conditions at the Site has been reassessed and
    found to be on the order of 2£-07 not 2E-04 as presented in the RI/FS. The principal reason
    for the difference in cancer risks estimated was due to incorrect exposure scenarios used in
    the RI/FS.

    Based on a reassessment of the risk, and identified site conditions, OxyChem believes that a
    more limited remedial plan can be implemented to protect human health.  OxyChem's
    suggested remedial plan is:

          Soil Cap           -  grade site using imported common clean fill to achieve a
                               minimum 12-inches of fill over the waste at a minimum
                               grade of 1%
                               cover fill with 6-inches of topsoil
                               vegetate topsoil

          Croundwater      -  VOCs and BN'As at 4 downgradient wells (MW-02D &
          Monitoring           S and MW-03D 
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                                                            February 27,1991
                                                          Reference No. 3S7S
                              ATTACHMENT 1
             OXYCHEM COMMENTS ON USEPA PROPOSED PLAN
                           FOR C&J DISPOSAL SITE
              (January 1991) AND C&J DISPOSAL SITE REMEDIAL
           INVESTIGATION AND FEASIBILITY STUDY (January 1991)

A)    L'SEPA Proposed Remedial Action Plan

      The following comments are presented on the USEPA's Proposed Plan.

Disposal

      As discussed in Section B of this Attachment, the risk, as estimated by USEPA,
      is due to the one high level concentration of DEHP in a subsurface sample,
      (the other DEHP soil concentrations are lower by approximately a factor of
      100), and the analytical results are indicative of phthalate content in a plastic
      rather than a soil with phthalate compounds present.  OxyChem
      recommends that the PRAP include the option to separate plastic material
      and hazardous waste soils  from the non-hazardous waste in order to reduce
      the volume of waste requiring disposal.  The plastics and hazardous waste
      soil would be appropriately disposed of and the remaining non-hazardous
      waste soils would be placed back in the trench.  Suitability of the soil for
      placement into the  trench would be determined  by analyzing the soils, after
      plastic removal, for YOCs,  BN'As and by employing TCLP procedures on
      selected soil samples. The space created by the removal of the plastic and
      unsuitable soils would be backfilled with dean imported soil.

      If this approach of separating and  disposing of only the plastic and unsuitable
      soils at an off-site location were implemented, it is estimated that a cost
      savings of approximately 5200,000 for disposal would be realized  (See Table 1 -
      OxyChem Revised  PRAP - Waste Separation).  This alternative assumes that
      approximately 1/3 of the material  would require off-site disposal as a
      hazardous waste and 2/3 of the material would be reused as backfill. If the
      materials separated for off-site disposal are not hazardous materials, the cost
      of  disposal and transportation for  both the EPA and OxyChem Revised
      PRAP's would be greatly reduced making waste  separation (plastic and
      unsuitable soils) less advantageous.  The estimated cost of waste  separation is
      520,000.

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                                                            February 27,1991
                                                          Reference No. 3878
                                     -2-
Monitoring
      Analysis for VOCs and BXAs is appropriate for the site.  However the
      frequency of monitoring and number of locations can be reduced. Reduction
      of monitoring frequency and locations is supported by the following:

      i)     The waste has been in-place for approximately fifteen years and no
            impact on groundwater quality with regard to organic chemical
            compounds was detected during the RI/FS ie. no organic compounds
            above contract required detection limits were detected in the
            groundwater, including groundwater analyses from the well placed
            within the waste (MW-04S).

      ii)    The organic compounds detected within soil samples, including both
            VOCs and BXAs, show affinity for the soils.

      Therefore, since no organic compounds, including  the more soluble and
      mobile VOCs, were detected in the groundwater after approximately fifteen
      years of waste placement, it is not expected that these compounds would now
      start to migrate in the groundwater.  Thus, the nature of the chemicals and of
      the site hydrogeologic characteristics indicate that monitoring of the four
      downgradient wells, MW-02D & S and MW-03D & S at quarterly intervals for
      one year would be sufficient to determine if groundwater containing
      site-related chemistry is migrating from the site. The locations of these wells
      is such that if chemistry is detected at these locations, ample time would still
      be available to determine other remedial actions, required if any, and to
      implement them before local domestic water supply wells were impacted.

Cost Review

      The items which are overestimated in the RI/FS are:

      i)     groundwaier monitoring (reduced level of monitoring will suffice);
            and
      ii)    oversite/coordination.

      The following items were underestimated:

      i)     Soil excavation; and
      ii)    Disposal Costs.

-------
                                                             February 27,1991
                                                           Reference No. 3S7S
      Ln addition, a numerical error was detected for placement of 2000 cubic yards
      of dean fill ie. 2000 x S20 = 540,000 not 530,000. A comparison of estimated
      costs for the PRAP using the original and revised plans are listed on Table 1.
B)    RI/FS Ri^k Assessment

      Assumptions used in the RI/FS soil exposure scenario were overly
      conservative resulting in an incremental cancer risk and a total chronic
      hazard index that are too high.  Therefore, the risk has been reassessed (see
      Appendix A) using more appropriate exposure scenarios.

Review of RI/FS Risk Assessment Assumptions

1)    Dermal Exposure

      The dermal exposure is over-stated. In the RJ/FS assessment, it was assumed
      that S600 cm-, representing approximately one-half of the total body surface,
      would be  soiled.  A more appropriate assumption would be to assume that
      the person is clothed and that the areas soiled would be the feet, lower legs,
      hands and lower arms. The surficial area soiled would be 1590 cm-.

      In addition, the RI/FS assumes that 100% of the chemical contained in or on
      the soil particles is absorbed through the skin in the 1-hour exposure period.
      This is unrealistic considering  that almost all the carcinogenic risk and
      chronic hazard are due to DEHP which has a high affinity for  adsorption to
      soil (Koc = 7244).  More appropriate assumptions would be that 15% of the
      chemical on the soil particles is actually in contact with the skin and that 47c
      of this chemical is adsorbed in the exposure period.  Therefore, a more
      appropriate adsorption factor would be 0.6% (Hawley, 1985).

      Another factor compounding the high risks calculated in the RI/FS was the
      use of maximum concentrations. This is especially important of DEHP
      recognizing that almost all  the risk is due to this one compound. Using the
      maximum concentration for DEHP is overly conservative since it is from a
      subsurface sample which was described as a "discrete waste sample, in which
      volatile organic compounds (VOCs) were detected", and contact with
      subsurface soils is highly unlikely for the casual passer-through.  Further, the
      RI/FS  states "the high phthalate levels detected analytically are derived from
      the laboratory extraction process and may not represent the degree of
      phthalate  leachability  under ambient conditions".  The phthalate

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                                                            February 27,1991
                                                          Reference No. 3878
                                     -4-

      concentration detected in this sample (29,000 mg/kg) is indicative of phthlate
      content in a plastic rather than a soil with phthalate compounds present.

      A more reasonable assumption would be to use average concentrations.

Rgassessement of Risk

      Tne risk reassessment was performed using OxyChem's exposure scenarios
      presented above with the average of detects for soil concentrations (CS).

      The risk reassessment estimated an incremental cancer risk of 2E-07 and a
      hazard index of 6E-03.

      Specifics  of the risk reassessment are presented in Appendix A.

Need for Remediation Based on the Risk Reassessment

      The estimated risk levels presented above and  on Table A-l of Appendix A
      are low level. These low levels of risk  allow consideration of a more limited
      remedial alternative.


C    OXYCHEM SUGGESTED ALTERNATIVE

      Based upon review of the RI/FS, the USEPA Proposed Plan and the OxyChem
      risk reassessment, the following remedial alternative is suggested by
      OxyChem.

i)     Cap and  Monitor

      Soil Cap           -   grade site using imported common clean fill to  achieve
                           a minimum 12-inches of fill over the waste at.a
                           minimum grade of 1%
                        -   cover fill with 6-inches of topsoil
                           vegetate the topsoil

      Groundwater      -   VOC's and BN'A's at 4 downgradient wells
      Monitoring          quarterly (+1 blank, 1 duplicate, 1 MS/MSD) for the
                           first year, annually thereafter for the next four years.
                        -   at the end of the five years, perform an assessment to
                           determine  continuing monitoring requirements, if
                           any.

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                                                       February 27,1991
                                                     Reference N'o. 3S78
                                -5-
Since all the estimated health risks are due to surficial soil contact and
inhalation, capping of the site to sever these exposure pathways is
appropriate. The existing pit, if any, would be filled with dean imported fill
and the site graded to a minimum 1% slope while ensuring a minimum of
twelve inches of dean fill over any waste.  This would be overlain by six
inches of vegetated topsoil. Since the groundwater pathway has not been
deemed to represent  a complete exposure pathway in the RI/FS , monitoring
of the four dowr.gradient wells, MV/-02D &. S and N1W-03D &S, quarterly for
one year, then annually for the next four years would be sufficient to detect
groundwater migration, if any, and, if detected, would allow ample time to
evaluate and implement  additional remedial  actions before  the migration
would  impact  local domestic well  supplies.  After the five years of
groundwater quality monitoring, an assessment would be performed to
determine continuing monitoring requirements, if any.

Tne estimated  present worth cost for this alternative is 590,000 (see Table 1).

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                                            TABLE 1

                          PROPOSED ALTERNATIVE COST ESTIMATES
A) Temporary Dewatering of Site

B) Excavation of Soil/Waste
   from Trench
   Waste Separation

C) 2000 cubic yards clean fill g<20/yd

   Soil Cap/Fence

D) Disposal Costs
   (Hazardous)

E) Transportation

   Analytical Costs

C) Oversite/Coordiaation

H) Groundwater Monitoring
   First Year
   Analytical Costs
   Labor & Expenses (following years)

   Following Years
   Analytical Costs
   Labor & Expenses (following years)

Total Capital
Annual O
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                                                             February 27, 1991
                                                           Reference No. 3S7S
                                 APPENTJDCA

                              C&J DISPOSAL SITE
                           REASSESSMENT OF RISK
The follcnvir.g risk reassessment was performed using more realistic and
appropriate exposure scenario and chemical concentrations than those used in the
R1/F5. The risk reassessment has been performed using OxyChem's exposure
scenario combined with soil concentrations (CS) which axe the average of detects.

Table A-l presents the results of the risk reassessment using the exposure scenario
presented in Table A-2.  The exposure scenario is presented (see Table A-2) to allow
comparison with the scenario used in the RI/FS.

From Table A-l, it is apparent that DEHP presents the greatest percentage of the total
risk from exposure to surface soil, representing in excess of 90^ for both excess
cancer risk and Hazard Index.  This evaluation indicates that the high concentration
of DEHP at one sub-surface soil sample was responsible for a significant part of the
total risk attributed  to the site surface soils. It is important to note that this was not a
surface soil and therefore direct exposure to the soil from the sample location is
highly unlikely. Therefore, use of the  maximum concentration  from this
subsurface soil is overly conservative.
Conclusion

If more appropriate assumptions are applied to the exposure scenario and average
soil concentrations are used, the estimated risks related to exposure to surface soil
would fall within an acceptable range and the present conditions could be
considered protective of public health.
Extent of Remediation Required

The principal compounds detected at the site are VOCs, PAHs and phthalates.
Because of the risk reassessment and the low solubility and high KQC values of
PAH's and phthlates, particularly DEHP, migration as solutes in groundwater is not
expected for these compounds. This is supported by the fact that the above
compounds, including VOCs, have not been detected in the well immediately below
the waste fifteen years after disposal. The VOCs detected at the  the site are more
soluble and mobile than the PAH's and phthalates. However, these compounds  do

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                                                             February 27,1991
                                                           Reference No. 3878
                                      -2-

not contribute significantly to the estimated health risks.  Therefore, a more limited
remedial action can be considered.
Reassessment of Risk

The risk reassessment was performed using OxyChem's exposure scenario presented
above with the soil concentrations which are the average of detects. The risk
reassessment estimated incremental cancer risks and hazard indices of 2E-07 and
6E-03 respectively.

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                                                                  ' A
TABLE  A-2
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                     A'.T:  .".fi r:..v  IlrlSVLi v  •;•::•.""•;:": - • .   TA.'.IT.  .".I.

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Mcyor
     U£//:iTi K. Pike
Er.^ir.t er
    Jihn P.ztkbone
Cliri-T rea-jrer
    Pzxi C. Kogut
    VILLAGE  OF HAMILTON
          Municipal  Office
     P.O  Box  119-3 Broad  Siree:
      ha.T.;.':on. New YO.-'K 12345
            :3-5,  82-:-: 1-
Trustees
    Lawrence J. Baker
    H'illard Fuller
    Jane M.  Erb
    Daniel P. Bergen
                c:   t:
1     1    F-    I    C   Q   "T    I   O
                 C£^Ti"Y  tnat t^e  at tac^e^  is a  t^-ue.  coclete  aic  acca"a*. e
                a  •• f -. : 1«.: : c - arcpte^  c /  t ~ e  <.': 1 . 
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         RESOLUTION REGARD ING DISPOSITION OF THE CiJ DISPOSE SITE

    UHEREflS  the  Municipal  Utilities  Commission  of  the  Village  of
Hamilton,  tne Trustees of the Villas? of Hat:lton,  the New YorU State
Department of Health have identified  an  area  north  of tne Village of
Hamilton  in whicn unknown industrial  waste  materials  were deposited,
and

    WHERESS this area, subsequently known as the "C4J Disposal Site",
is  located  immediately tc  the  north  of  Wcac-mai  Pond, an  alternate
source of potable water fc'  the Village of Hamilton,  ana

    WHEREflS  these  agencies  ar.c  the  New  Yor* State Departtent  of
Environmental  Conservation  and   tne  United   States  Environmental
Protection Agency  have invest;gatec  the  disposal  site to  determine
the extent of env:ronmental  daia^e,  ans

    WHEREfiS  the  United  States  Environmental  Protection  Agency  has
determined  that  there  are  seve-al  a] t e-r.at: ves  tc  cons:der  in
remediating the situation at the "L&J Dispose^ Site,'  arc

    WHEREAS  the  United  States  Environmental  Protection  figency  has
scheduled a public  hearing  at the hatilton  Central  School at  7:30 pe
on Wednesoay,  13 February  l9^»:  tc ciscusv  t-.e  findings and proposes
alternative remediation strate;:es,

    NOW  THEREFORE   BE  IT   RESOLVED,  that  the  municipal  Utilities
Commission and the  Board of Trustees  of  the Village  of Kami]ton find
acceptable only  one  alternative tc resolve  the  environmental  damage
found at the 'C4J Disposal  Site': complete  removal  of all sources of
contamination anc all  contaminated  sc:l  and other material  fror  the
site,  to   be  transported  to  and deposited  in  or   destroyed  at  a
disposal  site  approved  by   the  New  York   State   Department   of
Environmental  Conservation  ar.c  the  Unitec   States  Environmental
Protection flgency.

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