United States
          Environmental Protection
          Agency
              Office of
              Emergency and
              Remedial Response
EPA/ROD/R02-91/146
June 1991
&EPA
Superfund
Record of Decision
          Applied Environmental
          Services, NY

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50272-101
REPORT DOCUMENTATION 1. REPORT NO. 2.
PAGE EPA/ROD/R02-91/146
4. TNeandSUriHe
SUPERFUND RECORD OF DECISION
Applied Environmental Services, NY
First Remedial Action - Final
7. Auttior(i)
8. Performing Organization Name and Addreaa
12. Sponsoring Organization Name and AddreM
U.S. Environmental Protection Agency
401 M Street, S.W.
Washington, D.C. 20460
3. ReclpienTa Acceaalon No.
S. Report Date
06/24/91
6.
8. Performing Organization Rapt No.
10. Pro|ectflaak/Work UnK No.
1 1. CootractJC) or Grant(G) No.
(C)
(0)
13. Type of Report ft Period Covered
800/000
14.
 15. Supplementary Note*
 16. Abstract (Limit: 200 worda)
   The 3.2-acre Applied Environmental  Services site is a former petroleum,  gasoline, and
   solvent chemical  facility in Glenwood  Landing,  Nassau County, New  York.   The site is
   surrounded by  industrial, commercial,  and residential properties.   A tidal wetlands
   area of Hempstead Harbor is located to the west of the site.  From 1939 to 1972,
   Texaco Oil Company and, subsequently,  Phillips  Petroleum used the  site for bulk
   storage of petroleum products.  From 1974 to 1980, Mattiace Petrochemical Company
   leased part of the property, and  stored and distributed chemical solvents onsite.
   Numerous  spills and releases have occurred onsite, including a  tank truck spill in
   1978,  which released 3,000 gallons  of  toluene that soaked into  the sandy soil and
   spilled into the  adjacent harbor.   From 1980 to 1984, a new tenant,  Applied
   Environmental  Services, blended various chemical waste materials onsite and operated
   a hazardous waste storage facility  at  the site.  EPA and State  investigations in 1984
   identified VOCs,  metals, and organics  in soil,  sediment, ground water, surface water,
   and air.  Consequently, in 1984,  the current site owner, Shore  Realty,  was required
   to remove 255  of  the 410 drums containing hazardous waste that  were stored on the
   property.  In  1986 due to the imminent danger posed by the site, the State removed

   (See Attached  Page)
                                                          NY
17. Document Analyala a. Deacriptora
  Record of Decision - Applied Environmental  Services,
  First Remedial  Action - Final
  Contaminated Media:   soil, sediment, gw,  sw,  air
  Key Contaminants:  VOCs '(TCE, toluene,  xylenes),  other organics  (PCBs,  PAHs), metals
                     (arsenic, chromium,  lead),  oils
  b. Mentlflera/Open-EndMtTerma
   e. COSATI Reid/Group
18. Availability Statement
1$. Security Class (This Report)
None
20. Security Claaa (Thia Page)
None
21. No.ofPagea
86
22. Price
(See ANSI-23S.18)
                                     Sw Instructions on Rcmrae
                                                                            OPTIONAL FORM 272 (4-77)
                                                                            (Formerly KT1S-35)
                                                                            Dcpti tiiiunt of Convnsfco

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EPA/ROD/R02-91/146
Applied Environmental Services, NY
First Remedial Action - Final

Abstract (Continued)

approximately 700,000 gallons of hazardous waste including PCBs from the facility.  This
Record of Decision  (ROD) addresses contamination of soil, ground water, sediment, surface
water, and air as a final remedy.  The primary contaminants of concern affecting the
soil, sediment, ground water, surface water, and air are VOCs including TCE, toluene, and
xylenes; other organics including PCBs and PAHs; metals including arsenic, chromium, and
lead; and oils.

The selected remedial action for this site includes treating contaminated soil using
in-situ vacuum extraction; onsite pumping and treatment of contaminated ground water
using air stripping, followed by reinjecting the treated ground water along with
nutrients and a chemical source of oxygen to promote in-situ aerobic biodegradation of
contaminants in ground water and soil; treating air emissions from the vacuum extraction
and air stripping processes by catalytic oxidation prior to release to the atmosphere;
and monitoring soil, sediment, ground water, surface water, and air.  The estimated
present worth cost  for this remedial action is $4,507,000, which includes an annual O&M
cost of $970,000 for 4 years.

PERFORMANCE STANDARDS OR GOALS:  Soil clean-up goals are based on risk-based criteria.
Ground water clean-up goals are based on State standards.  Chemical-specific goals for
ground water include arsenic 25 ug/1, chromium 50 ug/1, lead 25 ug/1, TCE 5 ug/1,
toluene 5 ug/1, and xylenes 15 ug/1.  For all other media, clean-up goals are based on
applicable standards for sediment, surface water, and air.

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                          ROD FACT SHEET
SITE

Name:
Location/State:
EPA Region:
HRS Score  (date)
NPL Rank (date):

ROD

Date Signed:

Selected Remedy

Soils:

Groundwater:

Capital Cost:
O & M:
Present Worth:

LEAD
Applied Environmental Services
Glenwood Landing, Nassau County, New York
II

454 (10/84)
June 24, 1991



Soil Vapor Extraction

Pump and Treat, plus bioremediation

$  2,390,000
$    970,000
$  4,507,000
Enforcement, New York State Dept. of Environmental Conservation
Primary Contact (phone):  Andrew English  (518-457-3395)
Secondary Contact  (phone):  Melvin Hauptman  (212-264-2647)
WASTE

Type:


Medium:
Origin:
Ethylbenzene, toluene, xylene, chlorinated
volatile organics

Soil, groundwater
Pollution originated as a result of improper
storage and handling of hazardous wastes at
this location.

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                  RECORD OF DECISION




            APPLIED ENVIRONMENTAL SERVICES SITE






                     ALSO KNOWN AS




                    SHORE REALTY SITE






                NASSAU COUNTY, NEW YORK




                    ID NUMBER 130006
                      PREPARED BY




NEW YORK STATE DEPARTMENT OF ENVIRONMENTAL CONSERVATION




     UNITED STATES ENVIRONMENTAL PROTECTION AGENCY




                       JUNE 1991

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                    DECLARATION FOR THE RECORD OF DECISION
SITE NAME AND LOCATION

Applied Environmental Services Site
Also Known As: Shore Realty Site
Glenwood Landing
Nassau County, New York
New York State Site Code:  130006

STATEMENT OF BASIS AND PURPOSE

This decision document presents the selected remedial action for the Applied '
Environmental Services Site (also known as the Shore Realty Site) located in
Glenwood Landing, Nassau County, New York, which was chosen in accordance
with the New York State Environmental Conservation Law (ECL), and consistent
with the Comprehensive Environmental Response, Compensation, and Liability
Act of 1980 (CERCLA), as amended by the Superfund Amendments and
Reauthorization Act of 1986 (SARA) and the National Oil and Hazardous
Substances Pollution Contingency Plan ("NCP").  This decision document
summarizes the factual and legal basis for selecting the remedy for this
site.

Exhibit A identifies the documents that comprise the Administrative Record
for the site.  The documents in the Administrative Record are the basis for
the proposed remedial action.

ASSESSMENT OF THE SITE

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

DESCRIPTION OF THE SELECTED REMEDY

The selected remedy addresses the principle threats posed by the site by
removing the source contaminants from the soils and groundwater.

The major elements of the selected remedy include:

     o    active venting, by vacuum extraction, of contaminated unsaturated
          soils;

     o    collection of contaminated groundwater from a series of shallow
          groundwater extraction wells;

     o    treatment of the collected groundwater by air-stripping;

     o    reinjection of treated groundwater along with nutrients and a
          chemical source of oxygen to stimulate the growth of indigenous
          bacteria capable of degrading contaminants in the groundwater and
          saturated soils; and

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     o    treatment (e.g. catalytic oxidation) of contaminant laden vapors
          from the vacuum extraction and air-stripping processes before
          release to the atmosphere.

DECLARATION               ~

•i'ne selected remedy is protective of human health and the environment,
complies with State and Federal requirements that are legally applicable or
relevant and appropriate to the remedial action, and is cost effective.-  This
remedy utilizes permanent solutions and alternative treatment or resource
recovery technologies, to the maximum extent practicable, and satisfies the
statutory preference for remedies that employ treatment that reduces
toxicity, mobility, or volume as a principal element.

Because this remedy may not allow for unlimited use and unrestricted exposurife
within five years after commencement of remedial action, a five year policy
review will be conducted.  This Level I evaluation will be conducted within
five years after the commencement of remedial action to ensure that the
remedy continues to provide adequate protection of human health and the
environment.
                                          O
     Date                                 Edward 0. Sullivan
                                         Deputy Commissioner
                                  Office of Environmental Remediation
                              New York State Department of Environmental
                                             Conservation
      Date                          Constantiife SfaamonT&rJ&toff    /
                                       Regional Admini^rptor     ^J
                               United Stages Environmental Protection
                                        *     Agency
                                      ii

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                              TABLE OF CONTENTS                       PAGE




I.        Site Location and Description	  1

II.       Site History and Enforcement Status	  1

III.      Highlights of Community Participation	  3

IV.       Scope and Role of Response Action	  4

V.        Summary of Site Characteristics	' 4
                                                                            ',
VI.       Summary of Site Risks	  7

VII.      Description of the Remedial Alternatives	  9

VIII.     Summary of the Comparative Analysis of the Alternatives	 16

IX.       Selected Remedy	 21

X.        Statutory Determinations	 23


                                  Figures

     1.,   Site Location Map
     2.   Site Plan
     3.   Location of Sampling Points
     4.   Soil Horizons
     5.   Conceptual Design of Proposed Alternative


                                    Tables

     1.   Summary of Site Conditions
     2.   Cancer Risks and Hazard Indices - Residential Scenario
     3.   Initial Screening of Technologies and Process Options
     4.   Listing of Potential ARARs & TBCs
     5.   Listing of Potential New York State ARARs/SCGs & TBCs
     6.   Sample Locations and .Concentrations Detected in Groundwater Above
            Groundwater ARARs
     7.   Evaluation of Final Alternatives
                                  Exhibits
     A.   Administrative Record
     B.   Registry Excerpt
     C.   Project Milestones
     D.   Responsiveness Summary
                                      111

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                              RECORD OF DECISION
                     APPLIED ENVIRONMENTAL SERVICES SITE
                       AKA SHORE REALTY SITE (#130006)

I.  SITE LOCATION AND DESCRIPTION

The Applied Environmental Services (AES)  site, also known as the Shore Realty
site,  is  located at  One Shore  Road,  Glenwood Landing,  Nassau County,  New
York.   The  site  is  listed  in  the  New  York  State  Registry of  Inactive
Hazardous Waste  Sites as site  number  130006 (see Exhibit  B).   The  site is
part of  a small  peninsula on  the  east  shore of Hempstead Harbor  directly
north of Mott's Cove.  Mudflats around the  site,  designed as tidal wetlands,
are periodically  exposed by falling tides.   Figure 1 shows the  location of
the site with respect to Hempstead Harbor.

This 3.2  acre  site  is surrounded by industrial,  commercial, and residential
areas.   Directly north of the site is a  fuel oil  terminal.   Farther north is
a LILCO power  station including  fuel oil  storage tanks.   To  the east  is a
boat yard.  The nearest residence is approximately 600 feet to the northeast.
Figure 2 is a site plan showing approximate borders and the layout of surface
structures (tanks, buildings,  loading,  platform,  etc.).

There are no drinking water supply wells  within one mile of the site.  Twelve
non-pvblic  groundwater  wells  within  one   mile   of  the  site   are used  for
industrial,  irrigation,  and  observation purposes.   The principal  aquifers
beneath  the site  include  the   Upper  Glacial,  Port  Washington,  and  Lloyd
aquifers.     These  aquifers  are used   to   varying  degrees  as  sources  of
groundwater.  The Magothy  aquifer,  often used on Long  Island as  a source of
drinking water, is not present  under the site.   Groundwater beneath the site
discharges to Hempstead Harbor to the west  and south.

II. SITE HISTORY AND ENFORCEMENT STATUS

A summary of the  major events affecting the environmental  conditions at the
site is included as Exhibit C.

The Shore Realty  property was  first used  for the bulk  storage of petroleum
products in 1939 by Texaco  Oil  Company.  Texaco  reportedly sold the property
to Phillips Petroleum in 1964.   Phillips used the property to store gasoline
and fuel oil in above-ground tanks until 1972.  In 1974 Circle Terminal Corp.
leased the facility from Phillips.  At some point in the same year, a part of
the  facility  was   also  leased  to  the   Mattiace  Petrochemical  Company
(Mattiace),  which used  it  for  the  storage  and  distribution of  chemical
solvents.   Numerous spills of organic chemicals are reported to have occurred
during the period of Mattiace's occupancy.   In 1978, an overturned tank truck
released approximately 3000 gallons of  toluene  onto the western  portion of
the site.  Undetermined  amounts soaked  into the  sandy  soil and spilled into
Hempstead Harbor.

In October 1980, Mattiace received 34 citations  regarding the  poor condition
of the storage tanks and safety violations.   Mattiace was also ordered by the
New York State Department of Transportation  and United States  Coast Guard to
initiate a clean up of the property but failed to comply with the orders.
                                                               Page 1 of 25

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     In July  1980 Phillips  sold the  property to Messrs.  Joseph Saleh  and
Amnon  Bartur.    The  new  owners, in  turn,  leased  the  property to  Applied
Environmental Services (AES) later that same year.   AES operated the  facility
for the blending  of  various chemical waste materials that have  a heat value
to  provide alternate  fuel  sources.    It  also  operated  a  hazardous  waste
storage facility.  A series of monitoring wells,  a recovery trench (which was
installed  while  the  Site  was still  occupied by Mattiace),  and a  floating
liquid chemical  recovery  pump were installed  at  the Site while  occupied by
AES.   The  trench  is  reported to have recovered approximately  500 gallons of
liquid chemicals per month during 1981-82.

     Shore Realty  Corp.  purchased the  Site in October  1983.    Shore  Realty
then evicted AES  in  January  1984.   New York State filed  suit against Shore
Realty and its owner  in  February 1984.    As  a  result  of that  suit,  Shore
Realty and its owner were ordered by  the  court to  undertake  certain  remedial
actions  at  the  Site.    Subsequent  to  that  order,  numerous  third-party.
defendants, including  the prior landowners,  prior  on-site operators,  and a
number of  companies  that  allegedly sent  chemicals  to the Site while  it  was
operated by AES,  were  brought into the case by  Shore Realty.   Between June
and  September  1984,  Shore  Realty   removed  255  of  410  drums  containing
hazardous  wastes  which  were  stored  on  the  property.    Shore  Realty  then
refused to remove the  remaining drums  and additional  wastes in tanks  and
containers at the site.

     In October  1984,  the District Court  granted  an earlier  request  by  the
New York State  Attorney General ordering  Shore  Realty to remove all  of  the
remaining hazardous wastes from the site,  an order affirmed by the U.S. Court
of Appeals.  Shore was held in contempt of court  for failing to carry out the
remediation of the site and fined $l,000/day until the cleanup was completed.
This decision was  appealed  and upheld but remanded to the District  Court to
recompute the fine and determine Shore's financial condition.

     In May  1985,  the Commissioner  of  the  New  York  State  Department  of
Environmental Conservation  (NYSDEC)   determined  that  the  site  presented an
imminent  danger  of   further  irreversible  and  irreparable   damage  to  the
environment.    As  a  result,  the NYSDEC  hired  a  contractor  to remove  the
hazardous  wastes  stored in  tanks  and  containers  at the  site.    The  NYSDEC
completed  the  removal  of approximately  700,000  gallons of  hazardous  wastes
from the site  at  a cost of over $3.1 million by the end  of September 1986.
More  than  half  of  this  amount  was  used  for  the  disposal  of  wastes
contaminated with polychlorinated biphenyls  (PCBs).

     After being  nominated  to the  federal National Priorities List  (NPL) in
October 1984,  the site was  incorporated  into the list  in June  1986.   This
step formalized the involvement of the United States Environmental Protection
Agency (USEPA) in the process of investigating and remediating the site.

     In  February  1987  a  number  of  companies  that allegedly  sent  waste
chemicals to the site, now  referred  to  as the Common Defense Group,  retained
a consultant  (Roux Associates,  Inc.)  to  perform the  Remedial Investigation
and Feasibility Study  (RI/FS) for  the site.  An RI/FS work  plan was created
to  specify  the  steps needed  to   define   the  nature  and   extent  of  the
contamination  at  the  site  and  evaluate  the   feasible  alternatives  for
remediating the site.  The  results of the RI are  summarized  below in Section
V  (Summary of  Site  Characteristics)  and  the  conclusions  of  the  FS  are

                                                               Page 2 of 25

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described  in  Section VIII   (Summary  of  the  Comparative  Analysis  of  the
Alternatives).   Before  the  work plan  was finalized,  a public  information
meeting was held near the site to describe the methods and goals of the RI/FS
and  solicit  public comment.    The  requirement  to  perform the  RI/FS  was
incorporated into a court ordered stipulation signed September 16,  1987.

     Investigations at the  site began in October  1987.   The first  draft of
the  RI report  was submitted in February  1988.   A public notice of  the
availability  of  the   draft   report  was  issued  in  March  1988.     Due  to
deficiencies  in  the report,  it was rejected  in May 1988.  A revised report
was submitted in August 1988 and was also rejected.   A major problem with the
report was that  many  of  the  analyses  of samples from the site  were  found to
be unreliable  due to laboratory problems.   The need  to repeat much  of  the
sampling  and  analysis  work,  along  with  the  assessment  that  additional.
information was  needed,  led  to the  development of  a supplementary  RI work
plan.  After extensive negotiations,  the supplementary work plan was approved
in October 1989.

     Field  work  began  in November  1989  and  the  supplemental  report  was
submitted in  April  1990.   A  revised report that combined both  phases of the.
RI was submitted  in August 1990.  The first draft of  the FS was submitted in
September  1990.    The  reports  were  rejected  in  November  of   1990  and
resubmitted in February, March, and April 1991.  The April  1991 reports were
accepted for the purposes of  preparing the Proposed  Remedial Action Plan and
for public inspection.

III. HIGHLIGHTS OF COMMUNITY PARTICIPATION

     Concurrent  with  the investigations and  remedial measures performed at
the site, there has been significant community involvement and input into the
project.    Between  1984  and  1987,   regular  meetings  were  held  between
interested citizens and  federal, state, county,  and  local officials as often
as once per month.

     Before  the work  plan for  the  Remedial  Investigation and  Feasibility
Study  (RI/FS)  was finalized,  a public meeting  was  held at  the nearby North
Shore  High  School  (August 12,  1987).   Six  local  information   repositories
were established and  the  transcript  from the  meeting  was  placed  into  the
repositories.  A citizen participation  workplan was  developed  by  the NYSDEC
in early 1988.   As  part  of the  plan, a public contact list  was  developed and
used   to   disseminate   fact   sheets,   meeting  announcements,  and  other
information.   The    Citizen  Participation  Plan has been  placed   into  the
document repositories.   A  news   release,  public notice,  and  fact  sheet were
issued to announce the plan and summarize developments to that date.

     When the first draft of  the Remedial  Investigation Report  was submitted
in February  1988,  a news release and public  notice were issued, and a fact
sheet,  briefly  describing  the draft  report,  was also  distributed.   Upon the
receipt  of  the  first draft  of  the  Feasibility  Study  in September  1990,
another news  release, meeting notice, and fact sheet were  issued.   A public
meeting was held on September 18, 1990 to describe  the revised  RI  Report and
the FS and again solicit comments.   The  RI/FS reports were also placed  in the
repositories.
                                                               Page 3 of 25

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     A  notice  of the availability of  the  final drafts of  the  RI/FS Reports
and the Proposed Remedial Action Plan (PRAP) was published on April 17, 1991.
Additional methods used to encourage public participation included publishing
a  series  of announcements  in local newspapers, mailing  notices and  a fact
sheet  to the  project  contact list,  mailing  notices  to  residents  in  the
vicinity of  the  site,  obtaining assistance from the  local  school board,  and
other methods.   The   reports, the Proposed Remedial  Action Plan (PRAP),  and
the Administrative Record for the  project  were placed into the repositories.
A  formal  public  meeting was  held  on  May  15,  1991 to present  the  PRAP  and
seek public  comment.    A responsiveness  summary has been prepared containing-
responses  of  the  NYSDEC and EPA  to comments  received  during the  public
meeting and  comment period (Exhibit D).

IV.  SCOPE AND ROLE OF RESPONSE ACTION
                 -  	          —                                             -.r

     The  remedial  action selected  in this  decision document  addresses  the
entire  site  and  the  areas immediately  surrounding  the site.  As discussed in
more detail  in Section V below, the primary  media contaminated include site
soils  and  groundwater.    Surface water (Hempstead  Harbor),  surface water
sediments,  and ambient air  above  the mudflats  have  been  contaminated as  a
result of contaminants migrating with site groundwater or through site soils.

     By directly removing contaminants  from  the soils and groundwater,  the
response  action  will remove  the  source of  contaminants from  the  remaining
indirectly contaminated media.  The  remediation  of the  site will be complete
after the response action has been implemented.

V.   SUMMARY OF SITE CHARACTERISTICS

     For ease  of reference.  Table  1 summarizes the  main  characteristics of
the Shore Realty Site.


                     Summary of Field Investigations

     The following paragraphs summarize the components and conclusions of the
field investigations  performed at the site.   For  more  detailed information
regarding   the  individual   investigations  or   for  additional   regional
information,  refer  to  the  Remedial  Investigation  Report  listed   in  the
Administrative Record (Exhibit A).

     After the removal  of hazardous wastes from tanks and  containers  at  the
site in 1985-86, it  was necessary to determine the nature  and  extent  of  the
subsurface (i.e.  soil and groundwater), sediment, and air contamination.  The
Remedial Investigation  (RI) designed to  accomplish these  goals was completed
in two phases.

     The first phase  was  carried  out from October  1987  through January 1988
and  included  the  following tasks:  (1)   a  reconnaissance  program;  (2)
installation of nine groundwater monitoring wells;  (3)  sampling and analysis
of groundwater from  15 monitoring wells;  (4) collection and analysis of 30
soil samples;  (5)  collection and analysis  of  eight sediment  samples;  (6)
performance  of  a site-wide  soil  gas  survey;  and  (7)  an  assessment  of  the
hydrogeologic conditions at  the site.
                                                               Page 4 of 25

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     Figure 3 shows the location of sampling points during both phases of the
RI.   The  second  phase  of  the  RI  included  (1)  the installation  of  two
additional  groundwater  monitoring  wells • to  evaluate  deeper  groundwater
conditions;  (2)  sampling and  analysis  of  groundwater  from  16  monitoring
wells;  (3)  collection and analysis  of  32 soil  samples;  (4)  collection  and
analysis of  17 sediment  samples;   (5) collection and  analysis  of five  air
samples; and (6) updating the hydrogeologic assessment.

     The contaminants found  at the  site  can  be grouped  into the  general
categories of  volatile organics,  semi-volatile organics,  and metals.   The
contaminants that are present in the  highest concentrations are  the volatile
compounds ethylbenzene, toluene,  and xylenes (ETX).   PCBs were detected  in
only  one  unconfirmed   sediment  sample  at  99   parts-per-billion   (ppb).
Pesticides were not found at the site.   The  distribution  of the contaminants
is best described  by addressing the  individual media of  soil,  groundwater,
sediments, and air.   The following discussion  gives  representative examples
of the.findings.

                                Soils

     Soils at the site can be divided into  four "horizons," A  through D (see
Figure 4).   The A-horizon includes soils  from five feet above the water table
to the  ground surface.  Toluene and xylenes  were found at low  concentrations
(39  ppb  and  38  ppb respectively).    Metals   were   also  detected  at  low
concentrations, the highest being zinc at 224 ppb and lead at 47.4 ppb.

     The B-horizon,  the  most  contaminated soil  layer,  includes  soils  five
feet above to  three  feet  below the water table.   ETX was  found in 18 of  27
samples  at  concentrations   (sum   of  the  three)  up   to  10,700,000  ppb
(approximately  one   percent).      Chlorinated  volatile   organics   (e.g.
trichloroethahe and its degradation products) were found in six of 29 samples
at  concentrations  up  to an  estimate of  20,000  ppb  (methylene  chloride).
Polycyclic  aromatic   hydrocarbons   (PAHs,  e.g.   naphthalene)   were found  at
concentrations up to 13,000 ppb (2-methylnaphthalene).  Phthalates were found
in four of the five valid samples  at  concentrations up to 12,000 ppb (bis(2-
ethylhexyl)phthlate).   Metals  are  evenly distributed  across  this layer  at
concentrations somewhat higher  than in the A-horizon  (e.g.  highest levels of
lead and zinc at  87.6 ppb  and  786 ppb,  respectively).   The presence  of
additional volatile  organics  may have been  masked by high detection limits
caused by the very high concentrations of ETX.

     The C-horizon includes soils  between  three and 15 feet below the water
table.    The  concentrations of  ETX are lower than those in  the B-horizon but
are  significant  (e.g. xylenes  up to 39,000 ppb).   Methylene  chloride was
found in two samples  at 6 ppb and 370 ppb.   PAHs and phthalates were found in
two samples at concentrations of 130  and  1600 ppb respectively.   Metals were
not detected.

     Five  soil  samples  were  taken  in  the  D-horizon  which  includes  soils
greater than 15 feet  below the  water  table. .  Concentrations of ETX compounds
are  below   100  ppb  except  for one  location  with  xylenes  at  2,200  ppb.
Tetrachloroethene was detected  at  one location  at an  estimated concentration
of 4 ppb.

     Horizontally,  the  areas  of  highest soils  contamination  are  along the

                                                               Page 5 of 25

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western portion of the site (access road and bulkhead) and under the elevated
tank farm.

                             Groundwater
     Similarly to soils, groundwater contamination  can be  described in terms
of three levels; water table  (WT-series),  shallow  (SW-series),  and deep (DW-
series).   Although  somewhat  influenced  by the tides, groundwater generally
moves from east -to west across the site and discharges into Hempstead Harbor.
The sandy soil, along with  the presence  of an  elevated and bermed tank farm,
combine to form a groundwater mound in the center of the  site.   The impacts
of the mound and the harbor on the direction of  groundwater flow lessen with
depth.  The hydraulic conductivity and groundwater  velocity are estimated tp
be 0.02 cm/sec and 0.55 m/day, respectively.                                r

     The WT-series  wells along  the western portion  of  the site  show heavy
contamination, particularly with ETX compounds (maximum is toluene at 350,000
ppb).    Chemicals   floating  on  the  water table   captured by  these  wells
contribute to  these high values.   Other non-chlorinated,  chlorinated, semi-
volatile,  and metal  contaminants  are  present  in  this  level.    The  high
concentrations of ETX may mask the presence of additional contaminants.   WT-
series  wells  along  the   eastern  portion  of  the  site  are  relatively
uncontaminated although  some  exceedances of groundwater standards have been
found (e.g. tetrachloroethene at 49 ppb).

     The SW-series  wells,   screened at  the interface of  the  C  and  D  soil
horizons,  show  low-level  contamination  by  chlorinated  volatile  organic
compounds (e.g. tetrachloroethene  at 22 ppb).    The data indicate that there
may be  an  off-site  source  of contamination,  however, there are  no adequate
off-site,  upgradient,  wells  to  confirm  or disprove this.    The DW-series
wells,   screened   approximately   52   feet  below   the   water   table,   are
uncontaminated.

                     Sediments and  Surface  Waters

     The analyses   of  sediment  samples  taken from  the  tidal mudflats  in
Hempstead  Harbor   and   Mott's   Cove   show  contamination  by  semi-volatile
compounds and  metals  (e.g.  benzo(b)fluoranthene, bis(2-ethylhexyl) phthlate,
lead)  at individual  concentrations  generally  less  than  1,000  ppb.    The
vertical distribution of  the contaminants and  the  low   concentrations  of
volatile contaminants suggest that the  main  source of  contamination  is the
discharge of  shallow groundwater onto the mudflats during low  tide.   There
are  no  ARARs  for   the  sediments,   but  some of  the  PAHs  and  metals  exceed
guidance values established by the NYSDEC.  The  distribution of contaminants
indicates  that  there  may  be   off-site   sources  contributing  to  the  PAH
contamination in the sediments.

     Surface  water   contamination   exceeding  New  York  State  water  quality
standards is evident in the surface sheen visible adjacent to the site.

                                 Air

     Since  it  is  known  that  groundwater contaminated with volatile organic
compounds discharges  onto  the  mudflats,  air' samples were taken  above the

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mudflats during  low tide to  evaluate  air emissions.   ETX and benzene  were
detected.     Benzene   was  detected  in  three   of  the  five   samples   at
concentrations higher  than  the NYSDEC Ambient Guideline  Concentration (AGC)
of 0.12 ug/m  (highest concentration was 3.23 ug/m  or 1 ppb).   The remaining
compounds were detected  at  levels  within the AGCs.   It should  be noted  that
compounds volatilizing from soils also present air releases.   This pathway is
addressed in the risk assessment.

 VI. SUMMARY OF SITE RISKS

     In  accordance  with  the National Oil and Hazardous Substances Pollution
Contingency Plan (NCP, 40 CFR Part 300),  a  baseline risk  assessment has  been
completed as  one component  of characterizing the  site.   The results  of  the
baseline  risk assessment  are  used  to  help identify  applicable  remedial
alternatives  and select  a remedy.    The  components of  the  baseline  risk
assessment for this site are as follows:

          a review of the site environmental setting;

          identification of site-related chemicals and media of concern;

          an evaluation of the toxicity of the contaminants of concern;
     *
          identification of the possible exposure routes and pathways;

          estimation of  intake  rates,  incremental  risks  and  hazard indices;
          and

          an evaluation of the impacts of the site upon the environment.

     Exposure routes are  the  mechanisms  by  which contaminants  enter the  body
(e.g.,   inhalation,  ingestion,  absorption).    Exposure  pathways  are  the
environmental  media  (e.g.,  soil,  groundwater,   air,  etc.)  through  which
contaminants are carried.

     The risk assessment  for  this  site  (Chapter 3  of the Feasibility  Study)
has  identified the  soils at the site as the most  likely medium  for which a
complete exposure  pathway exists  on a continuous  basis  at  the  site.   This
pathway  includes the  release  of volatile organic  compounds  from  the surface
of the  soils  and subsequent inhalation by potential  site  residents.   A non-
continuous pathway is the air over the mudflats at low tide.   During the time
where  the  mudflats  are exposed,  volatile   organic compounds  evaporate  and
produce  concentrations that exceed state guidelines.

     To  estimate exposure  rates,  representative  compounds  were selected,
conservative assumptions were made, and lifetime intake rates were .calculated
for  the  routes  of inhalation,   ingestion,  and  dermal  absorption.    Five
different usage scenarios were evaluated; commercial use; recreational use by
adults,  recreational  use  by children,  residential  use, and  exposure  to
chemicals associated with the sediments in  the mudflats.  Although the site
and  the  area  immediately surrounding the site are industrial  in  nature,  the
site was purchased  by Shore  Realty ostensibly  for residential  development.
Therefore,  it  was  appropriate to evaluate residential  and   recreational
exposure scenarios  in the  risk  assessment.   Contaminants were divided  into
two  categories, those  that  are  possible/probable carcinogens,  and those that

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may cause non-cancer health effects  (systemic  toxicants).   Toxicity data was
obtained  from  the  Integrated  Risk  Information  System  (IRIS)  and  the  Risk
Assessment Guidance for Superfund (RAGS).

     The  results of  the  assessment indicate  that  left  unremediated,  the
residential  use  scenario  would present  an incremental risk  of cancer  of
approximately 9  X  10-5  (see Table  2).    That  is, living at  the site for  a
lifetime could increase an individual's risk of  developing  cancer by nine in
one  hundred  thousand.     This   results   primarily  from  the  inhalation  of
methylene chloride  and  benzene  which volatilize from site  soils.   Note  that
there are no site residents or  current users and that the  site is secured by
chain link fence.  Trespassers could be exposed to contaminant vapors but not
at significant levels.  Persons  walking across  the mudflats could be exposed
to contaminated groundwater and vapors.                                      >'"

     For the purposes of the risk assessment,  methylene  chloride and benzene
were assumed to be present in site  soils  at concentrations  of 20 ppm and 3.7
ppm respectively.  Methylene chloride was found  in only  one sample at 20 ppm
and  the  laboratory  blank  for this   sample   was   found   to  contain   the
contaminant.  Benzene was detected in only one soil sample (at 0.005 ppm) but
concerns about masking  indicated the need to assume  that benzene was present
in soils at the detection limit.
     M

     The increased risk of 9 X  10-5  exceeds the  one  in one million (or 10-6)
risk level  used  by New  York  State   to indicate  that remedial  action  may be
needed.  Contaminants in excess  of  State  and  federal standards were detected
in groundwater  at  the  site.    EPA   policies and regulations  allow  remedial
actions to be taken whenever  cross-media impacts result that exceeds  one or
more  maximum  contaminant  levels   (MCLs),  which   are  enforceable  water
standards.  The State and  federal MCLs are set at levels that are protective
of human health.  Consequently,  site remediation is  warranted to remove  this
continuous source  of contamination  and   expedite compliance  with  State  and
federal groundwater standards.

     The risks associated  with exposure  to noncarcinogenic contaminants are
determined  using  the  "Hazard   Index"  approach.    The Hazard  Index is  a
comparison of potential levels  of exposure to  site-related  contaminants  with
conservative  estimates  of   an  acceptable   level  of   exposure.     For
noncarcinogens,   a  Hazard  Index greater  than  one   indicates  that  adverse
noncarcinogenic effects  may occur,  while a value  below one indicates  that
such effects are unlikely to occur.   At this site, the total Hazard Index for
exposure to noncarcinogenic related contaminants is less than one, suggesting
that adverse noncarcinogenic effects are not likely to occur.

     The  environmental  assessment  has  identified  impacts  to marine life,
including  reduced  species diversity  and  observed  stress  in  translocated
benthic species,  resulting from the  contamination of  the  site.   Impacts
directly attributable to the site upon  marine  plant and  animal life appear
to be limited to the bulkheads  and   sediments  directly adjacent to the site.
This is thought to  result  primarily from the  discharge of non-aqueous phase
chemicals floating on the water table into the harbor.

     There  are  a  number  of   assumptions,  uncertainties,   and  limitations
associated with these estimates  that are  addressed  in the Feasibility Study.
In general, the main sources of uncertainty include:

                                                               Page 8 of 25

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          nature of receptor population;
          VOC emission rates;
          modelling of exposure levels;
          accuracy of toxicological data; and
          the complex interaction of the uncertainty elements.

     For example, the risk  assessment   identified receptor populations based
upon reasonable potential exposure scenarios.  The most conservative scenario
assumed  that  individuals  would  reside on-site for  a  lifetime.    Other
scenarios  were also  evaluated  for  comparison purposes.    The actual  risk
incurred would be  dependent  upon the  actual location  of the most  exposed
individual(s) and the duration of their exposure.

     The  mathematical   models  used  to  estimate  the   concentrations  of
contaminants presented to receptors  contain  many  assumptions that  can affect
results.  The  input parameters to the  models (e.g.  meteorological  data)  also
have uncertainties  that influence  the output of the models.   Much  of the
toxicological  data  used  is extrapolated  from animal  studies to  estimated
human impacts.  Often these studies  are performed at high concentrations and
produce results that may not occur  at  lower  levels.   Additionally,  these and
other  uncertainty factors  combine  in  ways  that can  increase the  overall
uncertainty  of the  results.    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  at  the  Site,  and  is unlikely  to
underestimate actual risks related to the Site.

     The  increased  risks   identified  by  the baseline risk assessment  in
combination with concerns regarding  the criteria  described below (especially
exceedances  of New  York  State groundwater  standards)  indicate the  need  to
actively remediate  soils  and  groundwater at 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  endangerment  to   public  health,  welfare,  or the
environment.

VII. DESCRIPTION OF THE REMEDIAL ALTERNATIVES

     To determine the most  appropriate method for remediating the  site, the
feasibility  study completed a  process  that can be described in three parts.
The first step identified and  "screened" a  large  number of technologies that
could  be  employed   at   the  site  to   treat,  contain,  or  dispose  of  the
contaminants.  Technologies that passed the initial screening phase were then
grouped into different combinations to form remedial alternatives for further
evaluation.    After an  initial  analysis  to identify the most  promising
alternatives,  a  detailed analysis was  performed  to  serve as the  basis for
selecting a preferred alternative.   This process  is  described in more detail
in the following subsections.

Compilation and Screening of the Technologies

     The results  of the remedial  investigation  indicate  that  five media in
and  around  the  site  have  been  contaminated as  a result  of the improper
management of  hazardous  materials and  wastes.   These media  are  site soils,
site groundwater, the  tidal  sediments adjacent  to  the site,  surface water

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(Hempstead Harbor),  and  the air.   It has been  concluded that three of  the
five media  (i.e.  sediments,  surface water,  and air)  are being  indirectly
contaminated  as  a  result  of  the  direct  contamination of  the  soil  and
groundwater at the site.

     The discharge of  contaminated groundwater from the  site  into Hempstead
Harbor (and Mott's Cove as part of Hempstead Harbor)  results  in contaminants
being transferred into the sediments, the  surface water,  and  by evappration,
into  the air.    Additionally, contaminants  in  the  soils  leach  into  the
groundwater, evaporate into  the air, and  have the  potential  to  transfer to
people and biota that come into contact  with contaminated soils.   Therefore,
the saturated and unsaturated  soils  at the site  are considered the principal
threats posed by the site.
                                                                            -v
     Therefore,  the  initial   screening  process  focused  upon   soil  and
groundwater with the  understanding that  by  directly  addressing these  two
media, the  other three media  would be addressed by  virtue of removing  the
source of contamination to the sediments, surface water and air.

     To generate alternatives capable of addressing  the contamination of each
medium, the three progressively more specific categories of "general response
actions,"  "remedial  technologies,"  and  "process options" were  identified.
For example, regarding soil,  one  of the general response actions considered
was containment.  This was then subdivided into the  two remedial technologies
of  capping  and vertical  barriers  which  was  further  subdivided  into  the
process options  of synthetic,  asphaltic,  and layered caps along  with  sheet
piling and  slurry  walls  as vertical barriers.   A summary of  the  12 general
response actions, 19 remedial technologies, and 41 process options considered
is given in Table 3.

     The initial screening process essentially consists  of evaluating all of
the  identified process  options  against  the  single  criterion of  technical
implementability.   This  also includes  the  evaluation  of the  "No  Action"
alternative which  is carried through the  entire process  to  demonstrate  the
need for remediation at the site and as a requirement of the NCP.

     The  following list  indicates the  process  options  which did  not pass
initial screening and a brief explanation for their  exclusion.

               Technology/Process
Medium         Option Excluded                     Reason

soil
          -solidification/stabilization -not  effective for site wastes
          -land farming                 -inadequate site  conditions
          -off-site pyrolysis           -not  applicable to site wastes
          -on-site RCRA landfill        -inadequate site  conditions
          -in-situ chemical treatment   -not  applicable to site wastes
groundwater
          -vertical barriers            -not  effective
          -oil-water separation         -insufficient "oil" phase
          -precipitation/flocculation   -not  applicable to site wastes
          -ion exchange                 -not  applicable to site wastes
          -chemical reduction            -not  applicable to site wastes
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          Process options that were found to be technically implementable as
a result of the screening process are as follows:

          Process Options Retained for Further Evaluation

         Soil                          Groundwater

     -no action                        -no action
     -containment (layered capping)    -containment  (layered cap)
     -containment (sheet piling)       -extraction
     -off-site disposal                -air  stripping
     -off-site incineration            -in-situ soil venting
     -on-site incineration             -in-situ biodegradation
     -on-site thermal desorption       -discharge to POTW                   ''••
     -in-situ vapor extraction         -discharge to harbor
     -in-situ biodegradation           -reinfiltration

     A  detailed  discussion and  evaluation of the initial  screening  process
can be found in Chapter 5 of the Feasibility Study.

Evaluation of the Alternatives

     Initial Screening

     The remedial technologies  and process options that  passed  the screening
process  were then  assembled into  nine different combinations or  remedial
alternatives.  Theoretically, an immense number of combinations are possible
but the NCP provides  guidance  (40  CFR 300.430(e) (3))  for  how to  assemble
suitable  technologies  into  alternative remedial  actions   for  evaluation.
Three sets of  alternatives are  described:    (1) a range  of  alternatives  that
remove or  destroy  contaminants  to the maximum extent feasible  and eliminate
or minimize  to the degree possible,  the need for long-term management;  (2)
"other alternatives which, at a minimum, treat the principal threats posed by
the site but vary in the  degree of  treatment employed  and the  quantities and
characteristics of  the treatment residuals  and untreated waste  that  must be
managed;"  and  (3)  "one  or  more alternatives  that  involve   little or  no
treatment,  but  provide   protection  of  human  health  and  the  environment
primarily by preventing or controlling  exposure to  ...  contaminants,  through
engineering controls" and other methods to "assure continued effectiveness of
the response action."

     The following  nine remedial alternatives were constructed  and evaluated
against the  short  and  long-term aspects of  three of the balancing criteria;
effectiveness,  implementability,  and  cost  (see  Section  VIII  below  for
descriptions of the criteria).

                    Initial List of Remedial Alternatives

     1.   No Action/Monitoring.
     2.   Multilayered RCRA cap  + groundwater extraction + discharge to POTW
            + monitoring.
     3.   Soil excavation + off-site incineration + monitoring.
     4.   Sheet piling vertical barrier + dewatering  + water treatment +
            soil excavation + off-site incineration  + monitoring.
     5.   Partial soil excavation + on-site thermal  desorption + monitoring.

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     6.   Groundwater extraction + air stripping + discharge + monitoring.
     7.   In-situ soil venting + monitoring.
     8.   Sheet piling vertical barrier + dewatering + water treatment +
            in-situ soil venting + monitoring.
     9.   In-situ soil venting + groundwater extraction + air stripping +.
            in-situ biodegradation + monitoring.

     The initial screening of  these  alternatives against the three balancing
criteria mentioned above took the following factors into consideration.

     The effectiveness evaluation considers:

     a.   the degree to which the alternative under consideration reduces
          the  toxicity,  mobility,   or  volume  of  the  contaminants  through
          treatment;                                                        ''

     b.   how residual risks are minimized;

     c.   how long-term protection is provided;

     d.   how ARARs are complied with;

     e.   how short-term risks are minimized; and

     f.   how quickly the alternative achieves protection.

     The implementability evaluation considers:

     a.   technical feasibility (ability to design, construct, and operate
          the alternative); and

     b.   administrative feasibility (availability and capacity of services,
          equipment,  and personnel  along  with  the  ability  to obtain  the
          necessary approvals from involved regulatory agencies).

     The cost evaluation considers:

     a.   capital costs for design and construction;

     b.   operation and maintenance costs; and

     c.   the present worth of all costs for comparison purposes.

     The result of  the  initial screening process was to  reject  three of the
nine alternatives.  The reasons for rejecting these three are given below.

                        Alternatives Rejected

Alternative 2:  Multilayered RCRA cap + groundwater extraction + discharge
     to POTW + monitoring.

          This  alternative  would  reduce the  infiltration  of  precipitation
     into  site  soils by installing  a  multi-layer  surface cap  designed in
     accordance with the requirements for secure landfills under the Resource
     Conservation  and  Recovery  Act  (RCRA) and its  amendments.   Reducing

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     infiltration would reduce the amount of contaminated groundwater that is
     generated.    A  groundwater  extraction system - would  be  installed  and
     operated   to  reduce   or   eliminate  the   discharge  of   groundwater
     contaminated  to  levels  above  ARARs  into  the   harbor.     Collected
     groundwater  would be discharged into  a nearby  sanitary sewer  line  for
     subsequent treatment at the local Publicly Owned Treatment Works (POTW).

          The alternative was rejected for a number of reasons.   Overall,  its
     long-term effectiveness is dependent upon the successful  operation,  for
     many  years,  of  an   active  collection and  disposal  system along  with
     maintenance  of  the  cap.   The alternative is much less effective  than
     other alternatives  in  achieving the remedial objectives.   Although  the
     mobility of  the contaminants would be  reduced, it  would take decades to
     reduce the overall  volume  of contaminants and their  toxicity  would  not
     be  altered.   Risks would be  controlled  by  containment and  isolation
     which  is  less   preferable   than  a  permanent   remedy   that  removes.
     contaminants directly.   Although technically feasible, it  would likely
     be  administratively  infeasible  due   to  the  difficulty  of  obtaining
     approval to  discharge  untreated groundwater laden  with contaminants to
     the local POTW.

Alternative 3:  Soil excavation + off-site incineration + monitoring.

     "*    In  this  case approximately  30,000  cubic   yards   of  the  most
     contaminated  soils   would  be  excavated  and  transported  off-site  for
     treatment at a  commercial  hazardous waste incinerator.  Soils  would be
     excavated to a  depth three  feet below the existing water table.   Clean
     fill  would  be brought  to  the site to replace the  excavated  material.
     Long-term  groundwater  monitoring  would   be  needed  to  evaluate  the
     effectiveness of the alternative in improving groundwater quality.

          Although there  would be a significant reduction  in the volume  and
     mobility of  the contaminants  in  the  unsaturated  and  shallow  saturated
     soils, deeper soils and contaminated groundwater would not be addressed.
     The  protectiveness  of  the   alternative  would  be  no   greater  than
     alternative  5 and would cost  an  order of magnitude  more.   Significant
     risks from  the  transportation  of  a large  amount  of  contaminated  soil
     long  distances   would   likely  be  incurred.    Groundwater  ARARs  would
     largely not be met,  exposure pathways would remain, and the discharge of
     contaminated groundwater would  continue  to  impact  sediments,  surface
     water, and by evaporation, air.  For these  reasons, the alternative was
     rejected.

Alternative 6:  Groundwater extraction + air stripping + discharge +
     monitoring.

          Shallow groundwater  would be  collected  along  most  of  the border
     between  the  site  and  the  harbor  using  either  recovery  wells,  well
     points, or a collection trench.  Extracted water  would then be treated
     using a  counter-current air  stripping tower.   Treated water  would be
     either discharged to the harbor or the local POTW.   Air  emissions  from
     the  air  stripping  tower would  be treated  by  catalytic  oxidation to
     prevent  exceedances of  air quality  standards.    Long-term monitoring
     would be needed to monitor the effectiveness of the alternative.
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          Although the alternative would reduce or eliminate the discharge of
     contaminated  groundwater  to  the  harbor,   it  would  do  so  without
     addressing the  source  of groundwater contamination  (i.e.,  contaminated
     soils) and would  probably take decades  to  achieve, all of  the remedial
     objectives.    Therefore,  it  would not  address groundwater  ARARs in  a
     reasonable amount of time.  Since soils would not be directly addressed,
     exposure pathways  from volatilization and  direct  contact would  not  be
     addressed.  For these reasons, the alternative was rejected.

     Detailed Analysis:
     The deletion  of  three remedial alternatives from  further consideration
left six for the detailed analysis.  These are renumbered as follows:        ,.

     I.   No action + monitoring.

     II.  Sheet piling vertical barrier + dewatering + water treatment +
          soil excavation + off-site incineration + monitoring.

     III. Partial soil excavation + on-site thermal desorption + monitoring.

     ^V.  In-situ soil venting + monitoring.

     V.   Sheet piling vertical barrier + dewatering + water treatment +
          in-situ soil venting + monitoring.

     VI.  In-situ soil venting + groundwater extraction + air stripping +
          in-situ biodegradation + monitoring.

     The goal of the detailed analysis, as defined by the NCP, is to evaluate
each of  the  viable alternatives against each of the  seven  criteria given in
Section VIII below (Summary of the Comparative Analysis of the Alternatives).
These  criteria  are overall protection  of  human health and  the environment,
compliance  with  ARARs,  short-term  impacts  and  effectiveness,  long-term
effectiveness and  permanence, reduction of toxicity, mobility,  and  volume,
implementability, and cost.

     The  information  below  briefly  describes  each  of  the  alternatives
retained  for  the  detailed  analysis.    Following   the  descriptions  is  a
discussion  that  compares  the  alternatives  with  respect  to  each  of  the
criteria.  It should  be noted that the costs  and  implementation times given
are initial estimates, and include the time needed to design the alternative.
The present  worth values below  estimate  how much  money is needed today to
finance projects that will  take  place  over  several  years.   The present worth
of each  alternative has been calculated based on the time  to implement that
particular alternative and assuming an interest rate of 10%.

Alternative I;  No Action + monitoring.

     Capital Cost:  $0                  Annual O&M:   $80,000
     Present Worth: $.755,000            Time to Implement:   30  years

          In  accordance with  the NCP,  this  alternative  assumes  no direct
     action at  the  site other than monitoring site  conditions,  in this case

                                                               Page 14 of 25

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     groundwater monitoring.   Contaminants  would continue to  discharge  into
     the  harbor  and  volatilize  from  soils.    The  annual  operation  and
     maintenance  costs  (O&M)  are  for  groundwater  monitoring  and  fence
     maintenance.

Alternative II:  Sheet piling vertical barrier + dewatering + water
     treatment + soil excavation + off-site  incineration + monitoring.

     Capital Cost: $238,880,000        Annual O&M:  $1,090,000
     Present worth: $242,931,000*      Time to  Implement:  6 years


          To make it possible to lower the site water table and expose all of
     the  significantly  contaminated soils,  sheet  piling would be  installed
     around the site.  Because there is no shallow impermeable barrier (e.g.*;
     clay or rock) to seat the sheet wall, dewatering would induce salt water
     from the  harbor  into  the site.   It is estimated that to  expose  15  feet
     of soil would  require extracting 1.44  million gallons per day of fresh
     and brackish water.  A total of 2.3 billion gallons would be treated and
     discharged.    All of  the  contaminated  soils   would  be  excavated
     (approximately   105,000  cubic   yards)  and   transported   off-site   for
     incineration.

* The present worth values calculated for alternatives II & III are different
than those  presented in the  Feasibility  Study.   In the  Feasibility Study,
capital costs  were discounted  over  the time  to  implement.    It  is  not  EPA
policy to discount the capital costs.

Alternative III:  Partial soil excavation +  on-site thermal desorption +
     monitoring.

     Capital Cost:  $10,045,000        Annual O&M:  $80,000
     Present Worth: $10,321,000*       Time to  Implement:  2.5 years

          Contaminated soils would be excavated down  to three  feet below the
     water  table  (approximately 34,000 cubic  yards)  treated  in  an  on-site
     thermal  desorption unit,  and  placed  back  into  the ground.    Deeper
     contaminated soils  and groundwater would  not be addressed.   Off-gases
     from the  thermal desorption unit would be treated  in an  afterburner to
     prevent unacceptable emissions of volatile organic compounds.  A 30-year
     monitoring period is included.

Alternative IV:  In-situ venting + monitoring.

     Capital Cost:  $1,230,000         Annual O&M   $440,000 +
     Present Worth: $1,977,000         Time to  Implement:  2.5  years

          This  alternative would  remove volatile contaminants  from  soils
     above  the  water  table by an in-situ vacuum extraction  technique.   This
     entails  a series  of  extraction wells  and  trenches around the  site
     connected  by  piping to  a  vacuum system.   The exhaust from the system
     would  be  treated  (e.g..  catalytic  oxidation)  to  prevent  unacceptable
     emissions.  Saturated soils and groundwater would not be addressed.

Alternative V:  Sheet piling vertical barrier + dewatering + water treatment

                                                               Page 15 of 25

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     + in-situ soil venting + monitoring.

     Capital Cost: $8,650,000           Annual  O&M:   $1,550,000  +
     Present Worth: $11,399,000         Time to Implement:   3 years

          This alternative is similar to Alternative II except that soils are
     treated  in-situ  rather  than  excavated  and  transported  off-site  for
     incineration.  Both soils and groundwater are addressed thereby removing
     the  source  of contamination to  the other media of  concern;  sediments,
     surface water, and  air.   The soil venting process would be the same as
     in Alternative IV except that the dewatering would allow  venting  to 15
     feet below the existing water table instead of to the water table.

 Alternative VI:  In-situ venting + groundwater extraction + air stripping +,.
     in-situ biodegradation + monitoring.                                   'r

     Capital Cost:  $2,390,000          Annual  O&M  $970,000 +
     Present Worth: $4,507,000          Time to Implement:   4 years

          Both saturated  and  unsaturated soils  would be treated  along with
     groundwater  under  this  alternative.     Rather  than  dewatering  the
     significantly contaminated soils entirely as with Alternatives II and V,
     the  water  table would  be  depressed  approximately  three  feet  by  a
     combination  of  pumping   and  covering portions of   the  site  with  a
     synthetic  material   to   reduce  the   infiltration   of   precipitation.
     Volatile  contaminants  would be  removed from the unsaturated  soils and
     treated to prevent release to the atmosphere.

          A  series   of  extraction   wells  would   intercept   contaminated
     groundwater  before  it discharges  to  Hempstead Harbor and Mott's  Cove.
     The  collected  water (approximately 10-30  gallons  per minute)  would be
     treated  in  an  air  stripping   tower.    Air  emissions  would  also  be
     controlled by  catalytic  oxidation  or  an  equivalent  process.   Treated
     water  would  be  fortified  with  nutrients and  an  oxygen  source  before
     being  reinjected into the   site.   This  will  stimulate  the  growth  of
     naturally  occurring bacteria  capable  of  degrading  site  contaminants.
     This  will enhance  the  remediation of the groundwater  and  will also
     address contaminated saturated soils.

VIII.  SUMMARY OF THE COMPARATIVE ANALYSIS OF THE ALTERNATIVES

     The  remedial alternative proposed  for the  site by  the NYSDEC  and the
USEPA  was developed  in  accordance  with  the  New  York State  Environmental
Conservation Law  (ECL) and is  consistent with the Comprehensive Environmental
Response, Compensation,  and Liability Act  of  1980  (CERCLA), 42 USC Section
9601,  et.  seq.,  as amended by  the Superfund  Amendments  and  Reauthorization
Act of 1986  (SARA).   The criteria used  in  evaluating the  potential remedial
alternatives can be summarized as follows:

Threshold Criteria - The first two criteria must be satisfied in order for an
alternative to be eligible for selection.

1.   Protection of  Human Health  and the  Environment—This criterion  is an
     overall and  final evaluation of  the health and environmental  impacts to
     assess whether each alternative is protective. . This evaluation is based

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     upon a  composite  of factors assessed  under other  criteria,  especially
     short/long-term  effectiveness  and  compliance   with   ARARs/SCGs   (see
     below).

2.   Compliance with Applicable or Relevant  and Appropriate New  York  State
     and Federal Requirements  (ARARs)—ARARs  are  divided into the categories
     of chemical-specific (e.g. groundwater  standards), action-specific  (e.g.
     design  of  a  landfill),  and  location-specific  (e.g.  protection  of
     wetlands).  To distinguish between  state and federal  requirements.  New
     York State  refers  to its  ARARs as  Standards,  Criteria,  and Guidelines
     (SCGs).    Certain policies and guidance  that do  not have the  status of
     ARARs/SCGs that are  considered  to be important to  the remedy selection
     process   are   identified  as  To-Be-Considered   (TBC)  criteria..    A
     compilation of federal and state  ARARs/SCGs/TBCs  are included in Tables
     4 and 5.  At this  site, .groundwater  is contaminated to levels above New
     York  State  standards  thereby   contributing  to  the  need  for   site
     remediation.  Table  6  indicates the locations and  concentrations  where
     groundwater concentrations exceed standards.   Table  7  summarizes  the
     comparison of the remedial alternatives with identified ARARs/SCGs/TBCs.

Primary Balancing Criteria  -  The next  five "primary balancing criteria"  are
to  be  used  to weigh major  trade-offs among the different  hazardous  waste
management strategies.

3.   Short-term Impacts  and Effectiveness—The  potential short-term  adverse
     impacts of the remedial action upon  the  community,  the workers,  and the
     environment is  evaluated.   The  length  of  time  needed to  achieve  the
     remedial objectives is estimated and compared with other alternatives.

4.   Long-term  Effectiveness   and  Permanence—If wastes or residuals   will
     remain at the site after the selected remedy has been implemented,  the
     following items are  evaluated:  1) the  magnitude  and nature  of the risk
     presented by  the  remaining wastes;  2)  the adequacy  of the  controls
     intended to limit  the risk to protective levels;  and 3) the reliability
     of these controls.

5.   Reduction  of  Toxicity,   Mobility,  or  Volume—Preference is  given  to
     alternatives that permanently and by treatment significantly reduce the
     toxicity, mobility, or volume of  the wastes  at the  site.  This includes
     assessing the fate of the residues generated from treating the wastes at
     the site.

6. .  Implementability—The  technical  and   administrative   feasibility   of
     implementing the alternative  is evaluated.   Technically,  this includes
     the difficulties associated with  the construction  and operation of  the
     alternative, the   reliability  of  the  technology,  and  the  ability  to
     effectively monitor the effectiveness of the remedy.   Administratively,
     the availability of the  necessary personnel and materiel  is evaluated
     along with potential difficulties in obtaining  special permits,  rights-
     of-way for construction,  etc.

7.   Cost—Capital and operation and maintenance  costs are estimated for the
     alternatives and compared on a present  worth  basis.   Although  cost is
     the last  criterion evaluated,  where two or more alternatives have  met
     the requirements of  the  remaining criteria,  cost  effectiveness can be

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     used as the basis for final selection.

Modifying  Criteria -  These  final criteria  are  taken into  account  after
evaluation of those above.  They are  focused upon  after public  comments have
been received.

8.   Community  Acceptance—Concerns   of  the  community  regarding  the  RI/FS
     Reports  and  the  Proposed  Remedial Action  Plan  are evaluated.    The
     Responsiveness Summary  (Exhibit D)  for this  project identifies  those
     concerns and presents the agencies responses to those concerns.

9.   State Acceptance—In this case,  New York State is the "lead agency" for
     the project  and  the USEPA is the  "support agency."   Therefore,  "State
     acceptance"  is understood  to  refer  to  the  concurrence  between  the
     agencies on the proposed remedy.                                        "*

     The site specific goals  for  remediating this site  can be  summarized in
general as follows:

 1.  Soil - a. Reduce the concentrations of benzene and methylene chloride
          so that  the presence of  these  chemicals  at  the site  do not present
          an added  risk  of cancer  of  more than one in one million under the
          most conservative exposure scenario.

            b.  Reduce the concentrations of organic contaminants in  soils so
          that,  to  the extent feasible,  contaminants  do not leach from soils
          and contaminate groundwater to levels above standards.

2.   Groundwater - Reduce the concentrations of contaminants in groundwater
          to  below NYS  groundwater  standards,  to  the  extent  technically
          feasible.
                                                                /
3.   Sediments - Indirectly remediate sediments by treating the source of
          contaminants to the sediments, site soils and groundwater.

4.   Air - Eliminate the exceedances of ambient air standards over the
          mudflats.

5.   Surface Water - Eliminate the sheen on surface waters to comply  with
          applicable surface water standards.

     The  following  section  addresses  the  alternatives  that  have  been
evaluated to achieve these goals.

     As  discussed above,  the NCP  requires that  when  evaluating potential
remedial alternatives,  the threshold criteria  of overall protectiveness of
human health  and  the  environment  along with  compliance  with  Applicable or
Relevant and Appropriate Requirements (ARARs) must  be met.  The five primary
balancing  criteria  are  then  used  to  weigh   trade-offs  between  the
alternatives.

           Overall Protection of Human Health and  the Environment

     Alternative  II achieves  the highest degree  of protection by virtue of
removing virtually  all  of the source of  the  contamination in  the soils and

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groundwater.  If implemented, Alternative II would allow  unrestricted use of
the site.   This assumes that  the  PAH  contamination in  the sediments would be
reduced to  background  levels  in less  than two years.  This  is  considered to
be   a  reasonable   assumption   given   the  moderate   level  of   sediment
contamination.

     Alternatives III  and IV provide a  much lower degree of protectiveness
because  they do  not address  contaminated  saturated  soils   or  groundwater.
Significant  exposure pathways  would remain  depending  upon the  degree  of
contaminant removal obtained.

     Alternatives V and VI approach a high degree of  protection by removing a
high percentage of contaminants in the soils and groundwater.  Alternative V
is judged to be somewhat  more protective  based upon  the  likely  higher degree
of removal  afforded by vacuum extraction  versus  biotreatment.  Alternative ,y
would entail lowering the site water table by approximately 15  feet and then
extracting contaminants under vacuum.
     The No-Action alternative  (Alt.  I)  would not be protective  because the
only contaminant removal process available would be  natural  attenuation.   It
would take decades to reduce the concentrations to acceptable levels.
     >i
                        Compliance with ARARs

     The most  significant  of the  ARARs at  the  site is  the New  York  State
groundwater  standards.     State  regulations  define  the  best  usage  of
groundwater as a source of drinking water.   Therefore, the assigned standards
are  stringent.   Alternatives II, V,  and VI  include provisions for directly
addressing groundwater contamination and are capable  of  achieving this  ARAR.
They  also  address soil  contamination  as  a  source  of  contaminants to  the
groundwater by leaching.   Alternatives I,  III,  and IV  rely upon  natural
attenuation. Alternatives III and IV  include the removal  of  chemicals in the
unsaturated zone that contribute to groundwater  contamination.   Alternatives
I, III, and IV do not comply with this chemical-specific  ARAR.

     All  alternatives  substantially   comply  with  the  action-specific  and
location specific ARARs except  in one  case.  The New York State Coastal Zone
Management Program includes an overall goal of encouraging the restoration of
waterfront  areas  for  beneficial  and  compatible  uses.     The  No-Action
alternative would not  be in compliance  with  this  goal and  Alternatives III
and IV would be in marginal compliance.

     Currently, there are no ARARs for contaminated  sediments,  but the  State
of   New  York   has  developed   guidance  values  for  evaluating  sediment
contamination.   The concentration of several contaminants in sediments at the
site somewhat exceed these guidance values.  Alternatives II, V, and VI  would
indirectly clean up sediments by eliminating the  source  of contamination and
allowing the contaminants to naturally degrade.  Because  of  the difficulties
associated with  directly  remediating  sediments,  and the  habitat  disruptions
it would cause,  indirect  remediation  is considered preferable  in this  case.
A  monitoring  program  will  be  required  to  ensure   that   the  sediment
contamination does naturally degrade.
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     The NCP  specifies  conditions  under  which a  selected alternative  may
result  in  a  remedy  that   does  not  attain  one  or  more  ARARs  (40  CFR
300.430(f)(1)(ii)(C)).    These  waivers  take into  account  factors  such  as
technical  impracticability   and alternate   approaches  while  ensuring  that
protection of human health and the environment is maintained.

                 Short-Term  Impacts  and Effectiveness

     Alternatives IV,  V, and VI are capable of  achieving  the  remedial goals
in a  fairly  short  period of time while minimizing  impacts  to  the community.
This results from employing in-situ techniques with little disturbance of the
site.   Short-term  environmental impacts could  be created by  dewatering  the
site  (Alt.  II  and  V)  resulting  in salt  water  intrusion.    The  short-term
effectiveness  of Alternative IV  would be  low  because  it  does not  address
saturated  soil and  groundwater contamination  and possible  impacts   to  the
tidal wetlands.  Air pollution control equipment  would  minimize atmospheric
impacts.

     Alternatives II and III involve significant soil excavations which would
expose heavily  contaminated  soils.   Controlling the emissions  of  vapors  and
contaminated  particulate  would  be   difficult   but   could be  done  using
engineering controls.  Transportation  of excavated  soil  (Alt.  II)  would also
present some risk of impacts.

     Alternative  I  would   have no  short-term  effectiveness  and  existing
impacts would continue.
                Long-Term Effectiveness and Permanence

     Alternatives   III   and  IV  would   leave  significant   quantities   of
contaminants behind and rely upon natural flushing of the aquifer to complete
the remediation.   As  with Alternative I, the problem would  not  become worse
with time but would take many years to rectify itself.   Alternatives  II,  V,
and VI would significantly  (or  completely)  remove  contaminants from the site
irreversibly.

       Reduction of Toxicity,  Mobility, and Volume by Treatment

     Alternatives  II,  V, and VI  substantially remove contaminants  from  the
site.  Alternatives III  and IV  would  remove the majority of  contaminants  but
would leave the saturated  soils  and groundwater untreated.   Alternatives  III
through  VI  satisfy  the  preference  of  on-site  treatment  over  off-site
treatment.  Alternative I contains no provisions for treatment.

     All  alternatives  rely  upon  volume  reduction  rather  than  altering
toxicity  or  reducing  mobility  by  containment  techniques.    All  of  the
treatment methods are irreversible.

                           Implementability

     Alternative  II  is  the   least  implementable.    Difficulties  include:
installing  and  maintaining  a  1.3  million  gallon  per  day  water  treatment
system; maintaining a constant  water drawdown over  a  long  period  of time;
off-site incinerator capacity limitations; minimizing fugitive emissions;  and

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the logistics of high volume (approx.  7,000 trips)  truck traffic.

     Alternatives III and V would encounter some of the same difficulties but
to  a  lesser  degree.    The feasibility  of  the biotreatment  component  of
Alternative VI  is based  on bench scale  tests.    The applicability of  this
technology  will be  investigated by  performing  more  extensive pilot  tests
before    full    scale    implementation.       Other   concerns    regarding
technical/administrative  feasibility  and the availability  of  equipment and
personnel are considered manageable.

                                 Cost

     The  present  worth  of the No-Action  alternative (I)  is $755,000.   This
provides for 30 years of monitoring and maintenance.   The cost of  Alternative
II would  be extremely high ($242,931,000) due to the  excavation,  transport;
and incineration  of  large amounts of  contaminated soil and  the treatment of
large  amounts  of  collected water.   The  costs  for  excavation and  thermal
treatment   account   for  the  relatively   high   cost  of   Alternative   III
($10,321,000)  even  though  it  contains  no  provisions  for  treatment  of
groundwater or  saturated soils.   Alternative  IV would accomplish  nearly as
much as Alternative  III but at a much lower cost ($1,977,000).  Alternatives
V  and VI would  likely  achieve  similar levels  of  remediation  but  differ
significantly in  cost  ($11,399,000 vs.  $4,507,000  respectively).   This  is
explained by the  more aggressive dewatering/venting approach  of  Alternative
V.   Alternative  VI  relies  upon  the passive  method  of bioremediation  to
address  saturated soils  and,  in part,  groundwater.    The following  list
summarizes the cost estimates.
           Estimated Present Worth of Costs  of Alternatives

   Alt.   I - No action	$755,000

   Alt.  II - Dewatering/Excavation/Off-site Incineration	$242,931,000

   Alt. Ill - Partial Excavation/Thermal Desorption	 $10,321,000

   Alt.  IV - Soil Venting	$1,977,000

   Alt.   V - Dewatering/Soil Venting	$11,399,000

   Alt.  VI - Soil Venting/Groundwater Extraction/Biodegradation...$4,507,000


ix.  SBT.BCTED REMEDY

     Based upon  the results  of the  Remedial Investigation  and Feasibility
Study  (RI/FS), and  the  criteria for selecting a remedy  under the applicable
laws and regulations, the NYSDEC and  USEPA  have  selected Alternative VI (In-
Situ  Soil  Venting  + Extraction  of Groundwater  + Air  Stripping  + In-Situ
Biodegradation +  Monitoring)  to remediate  the  site.   The  estimated present
worth  and  capital  costs  for  the  remedy are,  respectively,  $4,507,000  and
$2,390,000. The  costs  to operate and maintain  the remedy vary  from year to

                                                               Page 21 of 25

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year.

     The elements of  the proposed remedial program  (Alternative VI:  In-situ
venting + extraction of  groundwater +  air  stripping  + in-situ biodegradation
+ monitoring) are as following (see Figure 5):

     1.   A biotreatability pilot  study  to determine the type and  amount  of
          nutrient and  oxygen additives  needed to  stimulate the  growth  of
          indigenous bacteria capable of biodegrading site contaminants.

     2.   A  remedial  design  program  to  verify   the   components  of  the
          conceptual  design  and  provide  the  details   necessary  for  the
          construction,   implementation,  and  monitoring   of the  remedial
          program.                                                          ^

     3.   Installation and  operation  of a soil  venting (vapor  extraction)
          system consisting of:

          a. installation of  a cover  system on the  ground surface over the
          area  to be vented  to  prevent  short-circuiting  of air into the
          venting system and reduce the infiltration of precipitation  into
          site soils;

          b. installation of  an adequate  number  of  vacuum extraction wells
          and trenches to  remove contaminants  from  the  soils in  accordance
          with the remedial goals;

          c. piping, pumps,  and other appurtenances  to  extract  contaminated
          vapors from the treatment zone; and

          d.  air  pollution- controls  to  limit  air emissions  to  levels
          acceptable to the NYSDEC and USEPA.

     4.   Installation   and  operation  of  a  groundwater  collection  and
          treatment system consisting of:

          a. collection  wells, points,  or  trenches  capable  of  intercepting
          contaminated groundwater before entering Hempstead Harbor or Mott's
          Cove;

          b.  collection   wells  under  the  existing  tank  farm  to  collect
          contaminated groundwater;

          c. pipes,  pumps, and other appurtenances to collect groundwater  to
          a treatment area;

          d.  treatment  of  groundwater  by  air  stripping  (or  equivalent
          process) to levels acceptable to the NYSDEC and USEPA;

          e.  air  pollution  controls  to  limit  air emissions  to  levels
          acceptable to the NYSDEC and USEPA;  and

          f.  reinjection/infiltration   of  treated   water   fortified   with
          nutrients  and  an  oxygen  source  to  stimulate  the  biotreatment  of
          contaminated saturated soils and groundwater.

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     5.   A biotreatment program designed to reduce to the extent practicable
          in   conjunction  with   the   other   process   options   employed,
          contaminants in the saturated soils and groundwater.

     6.   A monitoring  program designed to  evaluate  the performance of  the
          remedial  program while  in operation  and  evaluate its  continued
          effectiveness after discontinuation.

     The performance  standards  to be  obtained  by  implementing the  remedy
include the following:

1.   Soil - a. Reduce the concentrations of benzene and methylene chloride
          so that the presence of  these  chemicals  at  the site do not present
          an added  risk of  cancer  of more than one in one  million  under  the
          most conservative exposure scenario.

            b.  Reduce the concentrations of organic contaminants in soils so
          that, to  the extent  feasible,  contaminants  do  not leach from soils
        .  and contaminate groundwater to levels above standards.

2.   Groundwater - Reduce the concentrations of contaminants in groundwater
          to  below NYS  groundwater  standards,   to  the extent  technically
          feasible.

3.   Sediments - Indirectly remediate sediments by treating the source of
          contaminants to the sediments, site soils and groundwater.

4.   Air - Eliminate the exceedances of ambient air standards over the
          mudflats.

5.   Surface Water  - Eliminate the sheen on surface waters to comply with
          applicable surface water standards.

     If monitoring  indicates  that continued operation  of the remedy  is  not
producing  significant reductions  in the  concentrations of  contaminants in
soils and groundwater,  in  accordance with the NCP, the  NYSDEC and  the USEPA
will  evaluate  whether  discontinuance  of  the  remedy  is  warranted.    The
criteria for  discontinuation  will  include  an evaluation  of the  operating
conditions  and  parameters as  well as a statistical determination  that  the
remedy  has  attained  the  feasible  limit of contaminant reduction  and  that
further reductions would be impracticable.

 X.  STATUTORY DETERMINATIONS

     The following  discussion  describes how  the remedy  complies  with  the
decision criteria in the laws and regulations.

1.   Protection of Human Health and the Environment

     The proposed remedy is protective  in  that it would substantially remove
from the  site the  contaminants  that are the  source  of the  threat  to human
health and  the  environment.   Contaminants in  the  unsaturated soils would be
removed by  in-situ vacuum  extraction techniques  and controlled  to prevent
adverse  air  emissions.    Saturated  soils  would  be  treated  by  in-situ
biodegradation and  by virtue  of treating groundwater.   Groundwater would be

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treated by extraction and  air  stripping  as  well as biodegradation.   Treating
these  media  will  remove  the  source  of contamination  from the  sediments,
surface water,  and  air.    No  unacceptable  short-term  risks or  cross-media
impacts will be caused by implementation of the remedy.•

2.   Compliance with ARARs

     Alternative VI, within a  reasonable degree of certainty,   complies with
all  applicable  or relevant and  appropriate federal and  state  requirements.
The  actual   efficiency   of  the  biotreatment  program,   the   exchange  of
contaminant's between  soils and groundwater,  the possibility of  an off-site
contributor,  and  the hydrogeologic  complexities of  the  site  contribute
uncertainty to the ability of the remedy to attain compliance with all ARARs,
primarily, New York State groundwater standards (6 NYCRR Part 703).   However>
the  evaluation  of  the primary balancing  criteria  indicates  that Alternative
VI  provides  the  best method  for achieving  the  remedial  goals because  it
minimizes short-term risk, is highly implementable, and is cost effective.

     The remedy will continue  to  be  operated and improved as necessary until
such  time  that compliance with  all ARARs  has  been  obtained  or  conditions
indicate that a waiver of the ARAR  is justified based upon conditions given
in the NCP.

3:   Cost-Effectiveness

     Of the  alternatives that  can  achieve  the  remedial  goals and  meet the
threshold evaluation criteria. Alternative VI has the lowest cost.

4.   Utilization   of   Permanent    Solutions   and   Alternative   Treatment
     Technologies  or Resource  Recovery  Technologies to  the Maximum Extent
     Practicable.

     The  NYSDEC  and  the  USEPA  have determined  that the selected  remedy
provides the best balance of tradeoffs among the alternatives for remediating
the  site.   Of the alternatives  that met the threshold criteria  of "overall
protection of human health  and the environment" and "compliance with ARARs,"
the   balancing    criteria   of   "short-term   impacts   and   effectiveness,"
"implementability," and  "cost" were  the  most critical  criteria for selecting
a remedy.   The remaining  alternatives  were  comparable  in  their  ability  to
meet the  remaining criteria  ("long-term effectiveness and  permanence", and
"reduction of toxicity,  mobility, or volume").

     Alternative VI avoids  the short-term impacts  associated with dewatering
the  site  (Alts.  II  &  V)  and  with   the  incineration  of  large  quantities  of
contaminated soils (Alt.  II).   Dewatering the site could adversely affect the
tidal  wetlands  in the  vicinity.    Incineration  would  present  risks  from
exposure to vapors from  excavated soils, transportation,  and  emissions from
the treatment process.

     The excavation  and  incineration of large quantities  of  soil  and the
collection and  treatment  of large amounts of groundwater  pose  technical and
administrative feasibility  difficulties  for Alternative  II.   Although  these
difficulties could be overcome, the  techniques associated with Alternative VI
avoid those difficulties making it more promising.
                                                               Page 24 of 25

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     Alternatives II and V are approximately  50  and  three times more costly,
respectively,  than  Alternative VI  and do  not  present beneficial  qualities
significantly greater than Alternative VI.

     Alternative  VI will  provide  a permanent  solution  by virtue  of  its
ability to remove and destroy site contaminants  rather than simply attempting
to  contain  them.    The  primary   technologies  employed  (in-situ  vacuum
extraction   and   biotreatment)    are   considered   alternative   treatment
technologies.   Therefore,  the selected  remedy  utilizes  permanent  solutions
and treatment technologies to the maximum extent practicable.

5.   Preference for Treatment as  Principal Elements

     The  principal   threat   is   posed  by  contaminated  soils,  and   the
contaminants that leach from  the soils to the groundwater.   As  discussed
above,  treatment rather  than  containment or   disposal,  is  the  principal
element of  the remedy for the principal  threat.  Furthermore,  the proposed
treatment program is an in-situ method which will minimize disturbance of the
site and the surrounding community.
                                                               Page 25 of 25

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FIGURES

-------
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                                             LOCATION OF SITE
                                                SHORE REALTY
                                       f>r*p.*aior COMMON DEFENSE GROUP

                                            NEW YORK V. SHORE REALTY
 SOURCE: U.S.G.S SEA CLIFF NY QUADRANGLE


          MINUTE SERIES (TOPOc'RAPHIci
oir ^: — :•>-.;
                                   ^fciia i—a— ^6.- • i - *, .^,5 -HJ: i \i ; _. x*..:^ a...ia.

-------
 SITE  PLAN
    SHORE REALTY
 COMMON DEFENSE OROUP
NEW VOftK V. SHORE REALTY

-------
Miff

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                                                                                                                                 ••    T*tl HI
 LOCATIONS OF
SAMPLING POINTS
  SHORE REALTY
                                                                                                                               !  COMMON OeMNSe GROUP
                                                                                                                                NCW YORK V. SNORE REALTY

-------
SOIL
THE
AT
PwporBd Fw?


HORIZONS USED TO MAP
EXTENT OF CONTAMINATION
THE
SHORE REALTY SITE
COMMON DEFTNSE GROUP
NEW YORK V. SHORE REALTY
m
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ROUX ASSOCIATES INC
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CXISTWC .
BULKHEAD
   HARBOR  FUEL  OIL. INC.

rCNCE
            HCMPSTEAO

             HARBOR
                                                                                    MOTTS      COVE
                                                                                                              I
                                                                                                                                 EXPLANATION


                                                                                                                              PROPOSED VACUUM WELL LOCATIONS

                                                                                                                              PROrotIO VACUUM TRENCHE8

                                                                                                                              PROPOtCO OROUMO-WATCR
                                                                                                                              REINPILTRATION 8Y8TEM

                                                                                                                              PMOPO8EO OROUNO-WATCR INTERCEPT
                                                                                                                              ANO EXTRACTION 8V8TCM

                                                                                                                              AREA OP 8OIL CONTAINING VOC'8
                                                                                                                              A80VE DEMCOIATION OOAL8
                                                                                                                                               100 FT.
                                                                                                 "" PROPOSED LOCATIONS OF
                                                                                                  GROUND-WATER INTERCEPT &
                                                                                                    REINFILTRATION SYSTEMS
                                                                                                     4 SOIL VENTING SYSTEM
                                                                                                          SHORE  REALTY
                                                                                                                               «r  COMMON oiriNae OROUP
                                                                                                                                 NEW YORK V. 8HORI REALTY

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TABLES

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                                   Table 1
                         Summary of Site Conditions
                        (all values are approximate)
     Area of Site:                    3.2 acres
     Area to Remediate:               1.4 acres
     Average Depth to Water:          8 feet
     Soil Type:                       sand
     Surface Water:                   borders Hempstead Harbor
     Contaminated Media:              soil, groundwater, surface water,
                                      sediments, air
     The following table lists representative contaminants found at the site
and indicates the maximum concentration of that contaminant found in various
media.  The  Remedial  Investigation  Report (See Exhibit A) contains  a  full
description of the nature and extent of the contamination at the site.

                         Representative Contaminants
                Maximum Concentration Detected by Media (ppb)

Contaminant                        Soil       Groundwater   Sediments    Air

ethylbenzene                    1,300,000        5,600          150      0.36
toluene                         2,600,000      350,000           13      0.84
xylenes                         8,400,000       45,000        1,400
benzene                                 5          270            -      1.00
tetrachloroethene                       4          430            3
1,1,1-trichloroethene               7,600           11            ...
naphthalene                        12,000           40           60
benzo(b)fluoranthene                  140            -          810
bis(2-ethylhexyl)phthalate         12,000           20        8,100
lead                               83,000          639      140,000

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Table   2       Estimated  Baseline Incremental  Lifetime Cancer  Risks (ILCR) and Hazard  Indices (HI)
                 for Exposure to Chemicals Identified at the Shore Realty Site  -- Residential Use


Chemical


Elhylbenzene
Toluene
Xylene
Methyfene chloride
TCA
Benzene
Bls(2-ethylhexyt)phthalate (I)
Naphthalene (l.m)
Benzo(a)pyrene equivalents (l.n)
Leed(l)
Notes:

Sol
Concentration hi
ppm (mg/kg)
(a.b)
1.3E+3
2.6E*3
B.4E+3
2.0E»1
7.6E+0
3.7E40
1.2E»1
2.5E+1
7.8E-2
8.3E»1

Estimated
Vapor
Concentration
(mg/m"3)
(c)
2.24E-02
1.35E-01
1.07E-01
1.66E-02
2.09E-05
8.40E-04
6.72E-07
1.40E-06
4.36E-09
4.65E-06

Estimated Lifetime Average
Daily Intake (mg/day)

Inhalation

(d)
5.65E-01
3.39E+00
2.71E»00
4.19E-01
5.27E44
2.12EO2
1.69E4)5
3.53E45
1.10E47
1.17E4M


Dermal
Absorption
(e)
7.05E-02
1.41E41
4.56E-01
1.09E03
4.12E^M
2.01 E-04
6.51 E^M
1.36E43
4.23E-06
4.50E-03


Ingestion

(0
1.10E-OI
2.35E01
7.60E-01
1.81E-03
6.87E-04
3.35E-04
1.09E-03
2.26E^)3
' 7.04E-08
7.50E-03

Estimated
Lifetime Average
Daily Intake -
AD Pathways
(mg/kg/day)
(9)
1.00E42
5.38E-02
5.60E-02
6.03E-03
2.32E-05
3.10E-04
2.50E-05
5.22E4J5
1.63E-07
1.73E-04



CPF

(h)
noncarc.
noncarc.
noncarc.
1.50E42
noncarc.
2.90E-02
1.40E42
noncarc.
1.15E+01
noncarc.



RID

(!)
1.006-01
3.00E-01
2.00E400
6.00E-02
9.00E-02
carcinogen
2OOE-02
3.40E-02
carcinogen
1.40E-03

Eslbnaled
Potential
ILCR

(I)
-
-
-
9.05E45
-
8.99E46
3.5tE-07
-
1.87E48
-


Estimated
HI

M
1.08E-01
1.79E01
2.BOE-02
1.01E01
2.58E^M
-
1.25E43
1.53E^)3
-
1.24E-01

a Maximum level ol compound delected In site-related soils (SC)
b Because ol possible analytical
C Estimated ambient vapor (VC)
masking effects of high
tor arbiter/ soil chemical
levels of ETX the
concentrations of
mean analytical detection
1E+4 mg/k(
) (see Tables
limit Is used for benzene (see text for
3-5 and 3-6) and
more detail)
factored for maximum levels detected.

Note that a

vapor compi

)nent
    from the tidal flats Is Included where appropriate and that for bls(2-ethylhexyl)phthalate. naphthalene, B(a)P equivalents and lead Ihs air concentrations are based on PM10 for fugitive dust.
d  Estimated average daily Intake via Inhalation • (VC • RV * HD • PF * DE * EY) / (DY * LT)
e  Estimated average dairy Intake via dermal absorption • (SC * SA • CA • A • F " AF * DE * EY) / (DY • LT)
f  Estimated average dally Intake via Ingestion - (SC • SA • CA * IF * A * F * OF * DE * EY) / (DY • LT)
g  Sum ol Intake by three pathways of exposure divided by average body weight
h  Carcinogenic potency factors used are for Inhalation and are derived from IRIS (USEPA. 1990a) and SPHEM (USEPA, 1986a)
I  Reference doses for chronic exposure (RfDs) were derived from IRIS (USEPA. 1990a) and SPHEM (1986a)
|  Incremental lifetime cancer risk • CPF (mg/kg/day)"-1 * Lifetime average dally Intake (mg/kg/day)
k  Hazard Index • Lifetime average dairy Intake (mg/kg/day) / RfD (mg/kg/day)
I  Inhalation exposure Is based on exposure to fugitive dust at levels equivalent to PM10 for New York (USEPA, 1990c)
m  Naphthalene and methyl naphthalene concentrations are combined; the RfD Is estimated using New York Stale AQC tor naphthalene (NYS, 1990) because there Is no USEPA RfD
n  Benzo(a)pyrene equivalents represent the  carcinogenic PAHs expressed In terms of the estimated potency of B(a)P (Table 3-3)
Assumptions Used for Estimating Daily Intake
                  Respiratory volume (m"3/hr) (RV) -      1.4
                           Body weight (kg)  (BW) •      70
                                Height (cm)  (HI) -      165
                    Body surface area (cm'2) (SA) •     18083
                                Contact area (CA) •      0.1
                     Soil adherence (mg/cm'2)  (A) «      0.5
    ROUX ASSOCIATES INC
         Conversion factor (kg/mg)  (F)
   Hours exposed/day (hours/day)  (HD)
Days exposed per year (days/year)  (DE)
   Total dayjj per year (days/year)  (DY|
          Exposure Years (years)
                  Lifetime (years)
(LT)
IE 6.
 24
365
365
 70
 70
                               Pulmonary retention factor (PF) -     0.75
                                   Skin absorption factor (AF) •     0.06
                                         Ingesllon factor (IF) «     0.1
                         Gastrointestinal absorption factor (GF) •     1.0
                           Partlculate matter  (ug/m*3)  (pmlO) -     56
                                                                                                                                              07401 Yg.1.SHRT3-11.XLS

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T«Mc
INITIAL SCREENING OF TECHNOLOGIES AND PROCESS OPTIONS
                                                                                                                                        Page 1 of 4
RESPONSE    GENERAL RESPONSE     REMEDIAL
MEDIA        ACTION                   TECHNOLOGY
                                                     PROCESS OPTIONS    DESCRIPTION
Soil
    No Action


    Containment
None
                                          Capping
               Removal
               Treatment of Excavated
               Soil
Not Applicable


Synthetic



Asphalt


Layered


Sheet Piling


Slurry Wall



Excavation


Cement Based
                                                                 Silicate Based
                                                                 (Pozzolanic)

                                                                 Thermoplastic
                                          Biological Treatment     Aerobic
                                                                 (Land farming)
                                                                 Anaerobic
                                          Vertical Barriers
                              Excavation
                              Solidification/
                              Stabilization
No Action
                                             Geolexlile and low permeability gcomembrane fabric
                                             overlain by lopsoil in areas of soil contamination
                                             exceeding remediation goals.

                                             Spray application of layer of asphalt over areas of soil
                                             contamination exceeding remediation goals.

                                             Clay and Synthetic membrane covered by soil over areas
                                             of soil contamination exceeding remediation goals.

                                             Steel interlocking piles driven by a pneumatic pile driver
                                             to act as a ground-water barrier.

                                             A trench excavated through or under a slurry of benlonlle
                                             clay (to an impervious layer) to allow for water-table
                                             depression.

                                             Removal of contaminated soil exceeding remediation
                                             goals.

                                             Contaminated soil would be mixed with cement lo form a
                                             hardened, rock-like mass.                    '

                                             Consists of reacting lime with fine-grained siliceous
                                             materials and mixing with contaminated soil.   '

                                             Involves sealing contaminated soil In an asphalt bitumen  ,
                                             matrix.
                                                                            Degradation of organic* using microorganisms in an
                                                                            aerobic environment.
                                                                            Degradation of organic* using microorganisms In an
                                                                            anaerobic environment.
                                                                                                   SCREENING
Required for consideration
byNCP

Potentially applicable
                                                      Potentially applicable


                                                      Potentially applicable


                                                      Potentially applicable


                                                      Potentially applicable



                                                      Potentially applicable


                                                      Not effective, organic constituent! not Immobilized
                                                      (U.S EPA, 1985; Chcrowasle)

                                                      Not effective, volatile organic constituents not
                                                      chemically Immobilized (Cnemfu)

                                                      Not effective, xylene and toluene diffuse rapidly
                                                      through asphalt
                                                      (U.S. EPA, 1985)

                                                      Not applicable as there b Insufficient level land and
                                                      treatment zone b less then 3 feet above seasonal high
                                                      water level.

                                                      Not applicable lo specific organic contaminants at
                                                      Site
    ROUX ASSOCIATES INC
                                                                                                                      SR07401Y.5.1

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Table  3   IN ITIAL SCKGIiNINO OF TEd OTOLOGIES AND PROCESS OPTIONS
                                                                                                                                                                                  Page 2 of 4
RESPONSE
MEDIA

Soil (conl)
GENERAL RESPONSE
ACTION
REMEDIAL
TECHNOLOGY

Thermal Treatment
(Off-sile)
PROCESS OPTIONS    DESCRIPTION
SCREENING
                                                 Rotary Kiln
                       Combustion in horizontally rotating cylinder designed for    Potentially applicable
                       uniform heat transfer.
                Disposal
                                          Thermal Treatment
                                          (On-site)
                           On-site
                                          Off site
                                                                 Circulating Fluidized
                                                                 Bed
                       Multiple Hearth



                       Pyrolysis



                       Mobile Incineration


                       Thermal Desorplion



                       RCRA Landfill



                       Off-site Disposal
                                                                        Waste injected into hot agitated bed of sand where
                                                                        combustion occurs; waste may require some pretreatment.
                       Was,le injected into a vertical cylinder containing a series
                       of solid, flat hearths. Solid waste often requires
                       prelrealmenl methods.

                       Thermal conversion of organic material into solid, liquid
                       and gaseous components in an oxygen deficient
                       atmosphere.

                       Use of mobile incinerator (Rotary Kiln or circulating
                       fluidized bed) for on-site incineration.

                       Involves the volatilization of VOCs in soil without
                       achieving soil combustion temperatures. VOCs are
                       stripped without destroying the soil.

                       Involves the construction of an on-sile RCRA landfill for
                       disposal of contaminated soil. Future site use restricted
                                                                                        Disposal of contaminated soil at off-site RCRA licensed
                                                                                        disposal facility. Soil may require treatment prior to
                                                                                        disposal due to landban restrictions.
Potentially applicable



Potentially applicable



Not applicable; wastes must contain pure organics



Potentially applicable


Potentially applicable
Not applicable, existing lite structure* and shallow
water-table depth prohibit the construction of RCRA
landfill

Potentially applicable
    ROUX ASSOCIATES INC
                                                                                                                      SR07401Y.S.1

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TaMe 3    INITIAL SCREENING OF TECHNOLOGIES AND PROCRSS OPTIONS
                                                                                                                                                                    Page 3 of 4
RESPONSE
MEDIA
GENERAL RESPONSE
ACTION
Soil (con!)      In-Silu Treatment
Water
               No Action

               Containment
                Extraction
REMEDIAL
TECHNOLOGY

Physical Treatment
                                          Biological
                           None

                           Capping
                           Ground-Water
                           Collection/Pumping
                           Technology
PROCESS OPTIONS


Soil Venting



Biodegralion
                                          Chemical Treatment     Oxidation
                                                                 Reduction
                                                                 Hydrolysis
                       Not Applicable

                       Synthetic
                                                                 Asphalt


                                                                 Layered


                                          Vertical barriers        Slurry walls



                                                                 Sheet piling
                                                                 Extraction Wells
DESCRIPTION
Involves the removal of volatilized organic constituents by
volatilization from contaminated soil via a series of
extraction vents in the unsaluraled soil

Treatment of contaminated soil via microbial degradation
of constituents.  Water, an oxygen source, and nutrients
infiltrated into the area of contaminated soil.
Contaminants are biodegraded and ground water b
pumped to surface for recirculalion to soil or discharge.

Transformation, degradation, and/or immobilization of
organic constituents via the  removal of electrons or
addition of oxygen to the atoms.  Potential for formation
of more toxic or mobile compounds.  Limited available
data.

Oxidation stale of compounds reduced by the addition of
electrons to the atom.  Effectiveness of chemical
reduction of organics in soil not well demonstrated (U.S.
EPA, I985a).

Involves the displacement of a functional group on an
organic molecule with a hydroxyl group from water.
Potential for formation of toxic byproducts.  Not effective
for constituents present at site (U.S. EPA, 1987a).

No Action                                  '

Geolexlile and low permeability geomembrane fabric
overlain by lorisoil in areas of soil contamination
exceeding remedial goals.                             '

Spray application of layer of asphalt over areas of soil
contamination exceeding  remedial goals.

Clay and synthetic membrane covered by soil over areas  .
of soil exceeding remediation goals.

A trench excavated through or under • slurry of benlonlle
clay (to an impervious layer) to shut off ground-water
flow.

Wood, precast concrete or steel interlocking piles driven
by a pneumatic pile driver to act as a ground-water
barrier.

Pumps out contaminated ground water.         T'
SCREENING


Potentially applicable



Potentially applicable





Not applicable





Not applicable




Not applicable




Required for consideration by NCP

Potentially applicable



Potentially applicable


Potentially applicable
                                                                                                                               Not effective; would not prevent ground-water
                                                                                                                               movement Into Hempslead Harbor
                                                                                                    Not effective; would not prevent ground-water
                                                                                                    movement Into Hempslead Harbor


                                                                                                    Potentially Applicable
    ROUX ASSOCIATES INC
                                                                                                                       SR07401Y.5.1

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Table 3     INITIAL SCREHNING OF TOO INOLOGIES AND PROCESS OPTIONS
                                                                                                                                          Page 4 of 4
RESPONSE    GENERAL RESPONSE     REMEDIAL
MEDIA        ACTION                   TECHNOLOGY

Water (com)
                       PROCESS OPTIONS    DESCRIPTION
               Treatment
Biological

Physical
                                           Chemical
                                           In-SItu
                Disposal
                Disposal
Ofl-SHe
                                           On-Site
                       Ext racl ion/Inject ion
                       Wells
Aerobic


Oil-Water Separation


Air Stripping



Carbon Adsorption


Precipitation/
Flocculation

Neutralization


Ion Exchange


Oxidation


Chemical Reduction

Bioreclamation


Air Stripping
(soil vapor extraction)

Chemical treatment

Discharge to POTW

Discharge to Surface-
Wafer Body

ReinCiltration
Removes and recirculates a portion of removed ground
water through the source area to promote contaminant
removal.

Degradation of organics using microorganisms In an
aerobic environment.

Uses mechanical separators to remove oil thus facilitating
further treatment for dissolved contaminants.

Removes volatile organic compounds by blowing * stream
of air up through the downward cascading ground water
in i packed vertical cylindrical tower.

Utilizes activated carbon granules in a series of packed
bed vertical tanks to remove contaminants.

Mixing of lime with flocculating against lo precipitate
metals.

Adjusts pH of treated water stream prior to discharge or
treatment by other processes.

Uses ion-exchange resins to remove halides, metals
sulfales, nitrates and cyanides.

Degradation of  organic compounds through chemical
reactions with oxidants.                      ,

Uses a reducing agent lo form a less  toxic compound.

Promotes mlcrobial  activity (addition of oxygen source
and nutrients) to degrade organic constituents.

Promotes volatilization of organic constituents on the
water table.

Described in soil options

Effective, may require prelreatment prior to discharge.

Requires prelrealmenl lo prevent contravention  of
surface-water standards and guidance values.

Uses injection wells or unfillered trenches.
SCREENING


Potentially applicable



Potentially applicable


Not effective


Potentially applicable



Potentially applicable


Not effective; loo specific


Potentially applicable
                                                                                                                                               Not effective; presence of solids interferes with
                                                                                                                                               operation.

                                                                                                                                               Potentially applicable
 Not effective; loo specialized.

 Potentially applicable


 Potentially applicable


 Not effective for contaminants al Site

 Potentially applicable

 Potentially applicable


 Potentially applicable
    ROUX ASSOCIATES INC
                                                                                                                        SR07401Y.5.1

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 Table 4   Listing of Potential Federal ARARs & TBCs
                                                                  Page Iof3
	^	WATER	

 Safe Drinking Water Act (42 U.S.C. 300fm
 40 CFR 141.11-16            Maximum Contaminant Levels
 40 CFR 141.50-52            Maximum Contaminant Level Goals
 40 CFR 144-147              Underground Injection Control Regulations
 40 CFR 122-125              National Pollutant Discharge Elimination System
 40 CFR 403                  Pretreatment Standards
                                             "~~~    ,--_           f,

 Clean Water Act (33 U.S.C. 1251)
 40 CFR 230                  Guidelines for Specification of Disposal Sites for
                             Dredged or Fill Materials
 40 CFR 231                  Restriction of Disposal Sites for Dredged Materials
 40 SFR 131                  Water Quality Criteria

 Rivers and Harbors Act
 Section 10                   Dredge and Fill Requirements

 "Quality Criteria for Water, 1986" - EPA 44/5-86-001, May 1, 1986, 51 FR 43665
 Health Advisories, EPA Office of Water
 "Developing Requirements for Direct and Indirect Discharge of CERCLA
 Wastewaters, 1987" - USEPA Office of Water Guidance Documents

	AIR	

 Clean Air Act (42 U.S.C. 7401)
 40 CFR 50                   National Primary and Secondary Ambient Air Quality
                             Standards
 40 CFR 61                   National Emissions Standards for Hazardous Air
                             Pollutants
 40 CFR 60                   New Source Performance Standards
 ROUX ASSOCIATES INC                                             SR07401Y.S.1

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 Table  4   Listing of Potential Federal ARARs & TBCs
                                                                   Page 2 of 3
	HAZARDOUS WASTE	

 Resource Conservation and Recovery Act
 40 CFR 264                  Identification and Listing of Hazardous Wastes
 40 CFR 264.18               Location Standards and Prohibitions for TSD
                             Facilities
 40 CFR 264.90 - 109          Ground-water Protection and Monitoring
                                                                         '.
 40 CFR 264.110-120          Closure and Post-closure                      ""
 40 CFR 264.170-176          Containers
 40 CFR 264.190-199          Tanks
 40 CFR 264.270-299          Land Treatment
 40 CFR 264.300-339          Landfills
 40 <£FR 264.340-999          Incinerators
 40 CFR 268.1 - 50            Land Disposal Restrictions
 40 CFR 264 Subpart S     "    Corrective Action at Hazardous Waste Mangement
                             Facilities (Proposed)

 USEPA RCRA Guidance Documents - Design Guidelines
 Land Treatment Units
 Landfill Design
 USEPA Technical Resource Documents
 Hazardous Waste Land Treatment
 Review of In-Place Treatment Techniques for Contaminated Surface Soils, Vol 2,
 USEPA-540/2-84-0036, November, 1984
 Department of Transportation
 49 CFR 107,  171, 172         Hazardous Materials Transport
 Toxic Substances Control Act (15 U.S.C. 2601)
 40 CFR 761.60-79             Storage and Disposal of PCBs
 40 CFR 761.120              PCB Spill Clean-up Policy Rule
 ROUX ASSOCIATES INC                                              SR07401Y.51

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 Table 4   Listing of Potential Federal ARARs & TBCs
                                                                   Page 3 of 3
	MISCELLANEOUS	

 Coastal Zone Management Act of 1972 C16 U.S.C. 14511
 15 CFR 930, 923.45           Air and Water Pollution Control Requirements
 Endangered Species Act of 1973 H6 U.S.C. 15311
 50 CFR 81, 225, 402
 Fish and Wildlife Coordination Act H6 U.S.C. 661-1 --------           -..

 Marine Protection. Research and Sanctuaries Act (33 U.S.C. 14011

 Occupational Safety and Health Act f29 U.S.C. 6511
 29 CFR 1910                 Requirements for Workers Engaged in Response
                             Activities
 Integrated Risk Information System (IRIS). USEPA. 1990
    Carcinogenic Potency Factors (CPF)
    Reference Doses for Chronic Exposure (RfD)

 Health Effects Assessments CHEAsl. USEPA. 1985

 Executive Orders 11988 CFloodplainsI and 11990  CWetlandsl
 USEPA's Policy on Floodplains and Wetlands Assessment for CERCLA Actions,
 August 6, 1985 (40 CFR 6, Appendix A)
 ROUX ASSOCIATES INC                                              SRV740IY.5.1

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   Table  5   Listing of Potential New York State ARARs/SCGs and TBCs
                                                              Page 1 of 2
                                  WATER
   6 NYCRR 701

   6 NYCRR 701.15

   6 NYCRR 702
   6 NYCRR 703

   6 NYCRR 750-757
   6 NYCRR 885

   10 NYCRR 5
   10 NYCRR 170
   TOGS 1.1.1. (9/25/90)

   TOGS 2.1.2 (4/1/88)
 Classifications and Standards of Quality and
 Purity, and Appendix 31
 Derivation of Effluent Limitations; empowers
 State to enforce guidance values for surface
 water where no standards exist
 Special Classifications and Standards
 Ground-water Classifications, Quality
 Standards  and Effluent Standards and/or
 Limitations
 Implementation of NPDES Program in NYS
 Classifies Hempstead Harbor Class SB
 Waters
 Public  Water Supply MCLs
 Water  Supply Sources
 Ambient Water Quality Standards and
 Guidance Values
 Underground Injection/Recirculation (UIR)
 at Ground-Water Remediation Sites
                                   AIR
   6 NYCRR 257
   6 NYCRR 212
Air Quality Standards
General Process Emission Sources
  Air Clean-up Criterion, January 1990, Ambient Guideline Concentrations
                          HAZARDOUS WASTE
  6 NYCRR 371
  6 NYCRR 372
Identification and Listing of Hazardous Waste
Hazardous Waste Manifest System and
Related Standards
ROUX ASSOCIATES INC
                                                                 SR0740IY.5.1

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   Table 5   Listing of Potential New York State ARARs/SCGs and TBCs

                                                              Page 2 of 2

                     HAZARDOUS WASTE (Continued)	
   6 NYCRR 373
   6 NYCRR 373-2
   6 NYCRR 374
   6 NYCRR 360
Location and Design Standards for TSD
Facilities
Final Status Standards for Owners and
Operators of Hazardous Waste
Treatment/Storage/Disposal Facilities

Standards for the Management of Specific
Hazardous Wastes and Specific Types of
Hazardous Waste Management Facilities

Sewage Sludge Destined for Land Application
                             MISCELLANEOUS
  Department of State Coastal Management Program

  State Coastal Policies
  Division of Marine Resource

  6 NYCRR 661



  Division of Fish and Wildlife

  6 NYCRR 182
Chapter 10 Tidal Wetlands, Land Use
Regulations
Endangered Species of Fish and Wildlife
  Sediment Criteria (NYS 1989)
ROUX ASSOCIATES INC
                                                                 SR07401Y.5.1

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  Table <6    Sample Locations and Concentrations Detected in Ground Water
             Above Ground-Water ARARs - ppb
                                                                           Page 1 of 2
  CAS Number    Compound

  VOLATILE ORGANICS

  75-01-4        Vinyl Chloride

  75-09-2        Methylene Chloride
                               10NYCRR5-1
                                 MCL
                           Unless Otherwise Noted
   Concentrations Detected
Above ARARs (ppb)-Jan 1990,
   Unless Otherwise Noted* '"'
  67-64-1
Acetone
  75-34-3        1,1-Dichloroethane


  540-59-0       1,2-Dichloroethene (total)



  71-55-6        1,1,1-TricbJoroethane



  79-01-6        Trichloroethene




  71-43-2        Benzene




  127-18-4        Tetrachloroethene




 108-88-3        Toluene





 100-41-4        Ethylbenzene




 1330-20-7      Xylenes (total)
2
5


50


5

10


5


5



5



5



5




5



15





12 WT-10(1987)
110 WT-2
860 WT-3
970 WT-6
170 WT-2 ':-,
. .2,000 WT-3
590 WT-6
11 WT-7(1987)
6 WT-10(1987)
25 WT-7(1987)
31 WT-10(1987)
77 WT-14
6 WT-7(1987)
7 WT-10(1987)
6 SW-6
29 WT-7(1987)
23 WT-10(1987)
12 WT-14
9 SW-1
18 WT-2
36 WT-5
180 WT-6
6 WT-10(1987)
430 WT-10(1987)
7 WT-13
49 WT-14
22 SW-1
19,000 WT-2
50,000 WT-3
330 WT-5
270,000 WT-6
350 WT-10(1987)
5,400 WT-2
2,700 WT-3
160 WT-5
4,200 WT-6
28,000 WT-2
18,000 WT-3
5,800 WT-5
25,000 WT-6
830 WT-7(1987)
450 WT-10(1987)
ROUX ASSOCIATES INC
                                                                   SR07401Y.5.1

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 Table 5   Sample Locations and Concentrations Detected in Ground Water
            Above Ground-Water ARARs - ppb
                                                                                       Page 2 of 2
 CAS Number     Compound

 SEMI-VOLATILE ORGANICS
                                           10NYCRR5-1
                                              MCL
                                        Unless Otherwise Noted
   Concentrations Detected
Above ARARs (ppb)-Jan 1990
   Unless Otherwise Noted
105-67-9



65-85-0

84-74-2





INORGANICS
               2,4-DimethyIphenol



               Benzole Acid

               Di-n-butylphthalate
7440-38-2
7440-43-9
7440-47-3
7439-89-6
Arsenic
Cadmium
Chromium
Iron
7439-92-1
7439-96-5
              Lead
              Manganese
7440-66-6
             Zinc
50


50
50




25(1)

10


50
300*









25^



300*





300<2)



390 WT-2
230 WT-3
120 WT-5
120 WT-3 .
110 WT-2
77 WT 1
70 WT-5
73 WT-12
73 SW-1
27 WT-3
29 WT-5
55 WT-2
68 WT-12
13 SW-13
57 WT-2
70,900 WT-2
76,200 WT-3
50,300 WT-5
39,100 WT-6
1,840 WT-12
458 WT-13
414 DW-1
520 SW-1
347 SW-4
644 SW-6
631 WT-2
187 WT-5
639 WT-12
278 SW-3
1,690 WT-2
2,690 WT-3
753 WT-5
1,770 WT-6
41 WT-12
56 WT-13
612 WT-2
418 WT-5
581 WT-12
485 SW-3
(a)     Latest sampling results - 1987 data presented for wells not resampled in 1990.
(1)     6NYCRR 703 Standard
(2)     10NYCRR 170 Standard
*      Total of iron and manganese = 500 ppb
ROUX ASSOCIATES INC
                                                                                SR07401Y.5.1

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                                                                                                                                                                                   Page  I of 5
Table 7     Individual  Evaluation  of Final Alternatives
Criteria Alternative 1
No Acllon/Moniluring
Alternative 2
Sheet Piling Wall/
Dewaler/Waler
Treatment/Excavation/
Off-Site Incineration
Alternative 3
Excivatlnn/riiermnl
Description/Monitoring
Alternative 4
In-Sllu Soil
Venting/Monitoring
Alternative 5
Sheet Piling Wall/
Dewatering/Waler
Trealmenl/ln-Sllu Soil
Venting/Monitoring
Alternative 6
In-Sllu Soil Venting/
Extraction of Ground
Water/Air Stripping/In^
Situ Biodegradalion/
Monitoring
Overall Protecllvcness

Human Health Proiection-
  Dlrecl  Contact/Soil
  Ingeilion

  Environmental  Protection
Compliance  with
ARARs/SCGs
Chemical-Specific

  Risk Assessment VOC
  Soil Cleanup Goals
  (Table 4-1)

  10 NYCRR 5.1 MCL
  Standards  Used as
  Ground-water  Goals
  (Table 4-4)
Surface-Waler
Slandards/TBCs
                   (Table 4-
   Div. of Atl Resources
   AGC Guidelines  used  as
   Air Emissions Goals over
   mud dais and from soils
   (Table 4-8)
                            No significant  reduction
                            In risk.  Fencing  deters
                            unauthorized  Siie access

                            Allows  continued
                            leaching Into water  table.
                            Biodegradalion A
                            volatilization  would
                            result In reduction  over
                            lime
Will not meet goals



Will not meel goals




Will not meel goals



Wilt not meel goals
                           Reduces direct contact/
                           soil Ingestlon  risk


                           Prevents contaminants
                           migrating  Into
                           Hempslead Harbor.
                           Installation of sheet
                           piling may have
                           damaging  effect  on
                           marine organisms
Will meet goals



Will meel goals




Will meet goals



Will meet goals
                           Reduces direct contact/
                           Ingesllon  risk
soil
                                                                                      Contamination  Is curtailed
                                                                                      from the treated soil.
                                                                                      Below  the excavation  level
                                                                                      leaching  may continue
                                                                                      which  will, require
                                                                                      monitoring.
                                                                                    Will meel goals
Reduces  direct conlacl^oll
Ingeilion risk


Inhibits contaminants  from
migrating to Hempstead
Harbor with  ground water
       Will meel goals
Reduces  direct contact/
soil Ingesllon  risk


Prevent!  contaminants
migrating Into Hempslead
Harbor.  Installation  of
sheet piling and
dewaiering  may  have
damaging effect  on
marine organisms
                             Will meel goals
Reduces  direct contact/
soil Ingesllon  risk

Prevents  contaminants
from  reaching
Hempslead  Harbor.
                                                                                    Will not meet  goals (except     Will not meel goals (except    May  not meet goals
                                                                                    over long period)              over  long period)             quickly
                                                                                      Will not meel goals
                                                                                    Will meet goals
       Will meel goals
       Will meet goals
                              Will meet goals
                              Will meet goals
                            Will meet goals
                                                               May not meet  goals
                                                               quickly
                             Will meel goals
                             Will meet goals
                                                                                              SR0740I Y.S.I
      ROUX ASSOCIATES INC

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                                                                                                                                                                                Page 2 of S
Table 7     Individual  Evaluation of Final Alternatives
Ctllcfii
Sediment TBCs
Slandards/TCBs (Table 4-
Aliernatlve 1
No Actlon/Monltbrlng
Will not meet goals
Allernallve 2
Sheet Piling Wall/
Dewater/Waler
Treatment/Excavation/
Off-Site Incineration
Will meet goals
Allernallve 3
Excavation/Thermal
Description/Monitoring
Will meet goals
Alternative 4
In-Sllu Soil
Venting/Monitoring
Will meet goals
Allernallve 5
Sheet Piling Wall/
Dewatering/Waler
Trealmenl/In-Sllu Soil
Venting/Monitoring
Will meet goals
Allernallve 6
In-Sllu Soil Venting/
Extraction of Ground
Water/Air Stripping/In-
Situ Blodegradallon/
Monitoring
Will meet goals
Location-Specific

  Slate COailal Policies

Action-Specific

  Standards  Tor Hazardous
  Waste Facility  (Design)

  6NYCRR373

  6NYCRR257

  6NYCRR2I2

  6NYCRR37I

  6NYCRR372

  DOT49CFR 107. 171

  OSHA 29 CFR 1910

  NYS TOO 2.12 (4/1/88)
Will not comply
Will comply
Will comply
Will meet goals
Will comply
Will comply
Does not apply
Does not apply
Does not apply
Does not apply
Does not apply
Does not apply
Does not apply
Does not apply
Does not apply
Does not apply
Does not apply
Will meet standards
Will meet standards
Will meet standards
Will meet standards
Does not apply
Does not apply
Will meet standards
Will meet standards
Does not apply
Does not apply
Does not apply
Will meet standards
Does not apply
Does not apply
Will meet standards
Will meet standards
Does not apply
Does not apply
Does not apply
Will comply
Does not apply
Does not apply
Will meet standards
Will meet standards
Does not apply
Does not apply
Does not apply
Will meet standards
Does not apply

Will meet standards
Will meet standards
Will meet standards
Does not apply
Does not apply
Will meet standards
Will meet goals
Lone-Term  Effectiveness  & Permanence
  Magnitude of residual
  risk - Direct Contact/ Soil
  Ingest Ion
  Adequacy A Reliability
  of Controls
Fencing  deters
unauthorized site access
potential Tor direct
contact with soils

None
Risk Is eliminated
Reliability  Is high
because all contaminants
are removed
Risk Is eliminated
 Reliability moderate,
 partial remediation
                                                                                    Risk Is eliminated
 Reliability Is moderate,
 well proven  technology,
 partial  remediation
                             Risk Is eliminated
 Reliability moderate due
 to difficult  maintenance
 of dcwaterlng
                            Risk eliminated
 Reliability b high due to
 multiple proven
 treatment  technologies
                                                                                           SR07101Y.5.1
      ROUX ASSOCIATES INC

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                                                                                                                                                                                      Page 3 of 5
Table 7     Individual  Evaluation of Final Alternatives
Criteria
Alternative 1
No Aclion/Monllo(ing
Need for five year Review would be
Review. required 10 ensure
adequate protection of
human health & the
environment Is
maintained.
Reduction of ToKlclly. Mobility or Volume Through
Trealmenl Process Used None
Alternative 2
Sheet Piling Wall/
Dewater/Water
Treatment/Excavation/
Off-Site Incineration
None required (at least
five years to complete)
Trealmenl
Air stripping/
Incineration
Alternative 3
Excavation/Thermal
Description/Monitoring
Ground-water monitoring
results must he reviewed.
Thermal dcsorpllon
Alternative 4
In-Situ Soil
Venting/Monitoring
Ground-water monitoring
results must he reviewed
In-silu soil venting
Alternative 5
Sheet Piling Wall/
Dewaiering/Water
Trealmeni/ln-Sllu Soil
Venting/Monitoring
Ground-water
monitoring results must
be reviewed
Air slrlpping/ln-sllu sol)
venting
Alternative 6
In-Silu Soil Venting/
Extraction of Ground
Water/Air Strlpping/ln-
Situ Blodegradallon/
Monitoring
Ground-water
monitoring results must
be reviewed
In-silu soil venting, air
stripping, In-sllu
  Amount  Destroyed  or
  Treated
  Reduction of Toilclly,
  Mobility  or Volume

  Irreversible Treatment

  Type & Quality  of
  Residuals  Remaining
  After Trealmenl

 Statutory  Preference  for
 On-site  Treatment
None



None


None




Does not satisfy
99.9% of organic*



Permanent destruction


Trealmenl  is Irreversible

No delectable  residuals



Does not satisfy
99.9% volalilcs In treated      95% destruction
soils removed and
destroyed

Permanent destruction         Permanent destruction.
Treatment Is Irreversible

Residuals In soils below  the
waler  table and ground
water

Satisfies
Trealmenl  is Irreversible.

Residuals In soils below
the waler table and ground
water

Satisfies
                             Removes  and destroys
                             99% of volatile  organic
                             compounds

                             Permanent destruction
                                                                                        biodegradalion;

                                                                                        95% destruction
                                                                                                                                                                               Permanent destruction
Treatment  Is Irreversible     Trealmenl Is Irreversible
Possible low levels of
residuals
Satisfies
Possible low levels of
residuals


Satisfies
                                                                                               SR0740I Y.S.I
       ROUX ASSOCIATES INC

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                                                                                                                                                                                     Page 4 of 5
Tahlc 7
            Individual  Evaluation of Final Alternatives
Criteria Alternative 1
No Action/Monitoring
Alternative 2
Sheet Piling Wall/
Dewaier/Water
Treatment/Excavation/
Off-Site Incineration
Alternative 3
Excavation/Thermal
Description/Monitoring
Alternative 4
In-Siiu Soil
Venilng/Monltoring
Alternative 5
Sheet Piling Wall/
Dewaterlng/Water
Trealmenl/ln-Sllu Soil
Venting/Monitoring
Alternative 6
In-Sllu Soil Venllng/
Extraction nf Ground
Walcr/AIr Strlpplng/ln-
Sllu Blodegiadatlon/
Monitoring
Short-term Effectiveness
  Communliy  Protection






  Worker Protection


  Environmental  Impacts
  Time Until Action Is
  Complete
                               No additional  risk
No significant  risk


Continued  Impact from
existing conditions for an
undetermined  number  of
yean
Not applicable
Excavation  would release
dust and organic vapors
to surrounding
population;  increase  in
heavy  truck  traffic  and
noise

Compliance  with  health
and safely plan required.

Airborne  particulates
may affect  surface-water
quality, sheet piling  walls
•nd dewatering  may
affect  marine organisms,
salt water In aquifer

6 years
                                                        Excavation  and thermal
                                                        desorpllon  unit will  release
                                                        dust and organic  vapors  to
                                                        surrounding population.
Compliance wiih health &
safely  plan required.
Airborne  paniculalcs
affect  surface-water
quality.
 1.5 years
                              Minimum impact  on
                              community.
        Compliance with  a health
        and safety plan.
may    None
         1.5 years
                                     Minimum  Impact on
                                     community
Compliance with health
& safely plan required.

Sheet piling and
dewatering  may cause
damage to local
ecosystem
2 yean
                            Minimum Impact on
                            community
Compliance with health
& safety plan required.

None
3 yean
 ImplementabllllY

  Ability  to Construct  &
  Operate
No construction  or
operation
  Ease of Doing More
  Action  If Needed
 If monitoring indicates
 more action is needed,
 PS/ROD  may need to be
 repeated.
 No room to stockpile
 excavated  soil; therefore,
 excavation/truck   loading
 will be simultaneous;
 sheet piling difficult  due
 to absence  of subsurface
 layer;  no room for water
 treatment  facility

 Can be expanded,  but
 dewalcring   process will
 be difficult   to maintain
Thermal desorpllon fairly
easy lo operate.  Excavation
may be difficult  near water
table
 Can handle varying volume
 & concentration.  Depth
 limited by water  table.
         Readily available
         System cannot  be
         expanded  below water
         table.
Difficult  lo maintain
dewalerlng  process; sheet
piling difficult  due lo
absence  of subsurface
layer
{System cannot be
expanded.
 Readily  available
 System can be expanded.
                                                                                              SR07401Y.S.I
       ROUX ASSOCIATES INC

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                                                                                                                                                                        Page 5 of 5
Table 7    Individual Evaluation of Final Alternatives
Criteria
Ability to Monitor
Effectiveness
Alternative )
No Action/Monitoring
Not applicable
Alternative 2
Sheet Tiling Wall/
Dewater/Water
Treatment/Excavation/
Off-Site Incineration
Difficult to monitor
effectiveness until
complete.
Alternative 3
Excavation/Thermal
Description/Monitoring
Ground-water monitoring
will define effectiveness.
Alternative 4
In-Silu Soil
Venting/Monitoring
Ground-water monitoring
will define effectiveness.
Alternative 5
Sheet 1'iling Wall/
De watering/Water
Trealment/ln-Silu Soil
Venting/Monitoring
Difficult to monitor
effectiveness until
complete.
Alternative 6
In-Situ Soil Venting/
Extraction of Ground
Water/Air Slripping/ln-
Silu Biodegradalion/
Monitoring
Ground-water
monitoring will define
effectiveness.
  Ability to Obtain
  Approvals and Coordinate
  with Other Agencies

  Availability of Services &
  Capabilities
No approval necessary     Uncertain
No services or capacities
required
Availability of              None required
Equipment. Specialist and
Materials
Difficult to locate water-
treatment system to
handle the amount of
water pumped; need
more than one landfill
for soil removed.

No special equipment
Difficulty in removing
2.300 mgd for
dewatering. Restricted by
jimited off-site
incinerator capacity.
                          Difficult to obtain
Need trained operators
                                                                                  Needs mobile thermal
                                                                                  desorplion unit and
                                                                                  trained operators.
                            Readily available
Readily available
                                                                                No specialist required
                                                                                Equipment and materials
                                                                                are readily available.
                           Uncertain
                                                                                                                                      Difficult to locate water
                                                                                                                                      treatment system to
                                                                                                                                      handle required volume
                                                       May be difficult to locale
                                                       water treatment system
                                                       for large volume of
                                                       water.
                                                                                                                                                               • Readily available
Readily available
                                                     No specialist required
Availability of
Technologies
Capital Cost
O & M Cost
Present Worth Cost
None required
$80.000. (30 years)
955.000.
Readily available
S238.880.000
S 1.090.000
$187.351.000
Well developed. May
require pilot testing.
$10.045.000
S80.000
$10.044,000
Readily available
SI. 4 20.000
$ 550.000
$2,312.000
Readily available
S 9,000.000
$ 1.790,000
$12.166.000
Readily available
$2,390,000
S 970.000
$4.507,000
                                                                                        SR0740I V.S.I
      ROUX ASSOCIATES INC

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EXHIBITS

-------
                                  EXHIBIT A
                           ADMINISTRATIVE RECORD
                        SHORE REALTY SITE (#130006)
                 AKA APPLIED ENVIRONMENTAL SERVICES  SITE
A. Reports and Work Plans

1.   "Feasibility Study:   Shore  Realty  Site;  Glenwood Landing,  New  York,"
     prepared by Roux Associates, Inc.,  April  17,  1991.

2.   "Remedial  Investigation:   Shore Realty  Site;  Glenwood Landing,  New
     York," prepared by Roux Associates, Inc., April  16,  1991.

3.   "Feasibility Study:   Shore  Realty  Site;  Glenwood Landing,  New  York," '-,
     prepared by Roux Associates, Inc.,  February 14,  1991.

4.   "Remedial  Investigation:   Shore Realty  Site;  Glenwood Landing,  New
     York," prepared by Roux Associates, Inc., February 1,  1991.

5.   "Feasibility Study:   Shore  Realty  Site;  Glenwood Landing,  New  York,"
     prepared by Roux Associates, Inc.,  September  1990.

6.   "Remedial  Investigation:   Shore Realty  Site;  Glenwood Landing,  New
     York," prepared by Roux Associates, Inc., August 1990.

7.   "Supplemental  Remedial  Investigation:    Shore  Realty  Site;  Glenwood
     Landing, New York," prepared by Roux Associates, Inc., April 1990.

8.   "Work Plan:  Additional Investigations; Remedial Investigation/
     Feasibility  Study;  Shore Realty Site; Glenwood Landing, New  York,"
     prepared by Roux Associates, Inc.,  October 2, 1989.

9.   "Remedial  Investigation:   Shore Realty  Site;  Glenwood Landing,  New
     York," prepared by Roux Associates, Inc., August 1988.

10.  "Remedial  Investigation:   Shore Realty  Site;  Glenwood Landing,  New
     York," prepared by Roux Associates, Inc., February 1988.

11.  "Work Plan:  Remedial Investigation and  Feasibility Study;  Shore  Realty
     Site; Glenwood Landing,  New York," prepared  by Roux Associates,  Inc.,
     May 1987 (as Appendix B to Stipulation  and Order in item A.12 below).

12.  "Stipulation and Order, United  States  District  Court,  Eastern  District
     of New York; The  State of New York, Plaintiff,  against,  Shore  Realty
     Corp., et al, Defendants," 84 Civ.  0864,  signed September 16, 1987.


B.  Government Comments on RI/FS Reports

1.   Re: February 1991 RI/FS Reports; letter from G.  Johnson (NYSDOL) to P.
     Paden (for PRPs), dated March 5, 1991.

2.   Re:  August/September  1990  RI/FS   Reports;  letter from  G.   Johnson
     (NYSDOL) to P. Paden  (for PRPs), dated November 1, 1991.

                                                           Page 1 of 4

-------
3.   Re: August/September  1990 RI/FS  Reports;  letter from  J.  Hangartner
     (USEPA) to A. English (NYSDEC), dated October 16, 1990.

4.   Re: August 1988 RI Report and April 1990 Supplemental  RI Report;  letter
     from C. Petersen (USEPA) to A. English (NYSDEC), dated June 28, 1990.

5.   Re: August 1988 RI Report and April 1990 Supplemental  RI Report;  letter
     from G. Johnson (NYSDOL) to P. Paden (for PRPs), dated June 21, 1990.

6.   Re: Analytical Data;  letter  from T. Larson (NYSDEC)  to  P.  Roux (Roux
     Associates), dated December 23, 1988.

7.   Re: Analytical Data;  letter  from T. Larson (NYSDEC)  to  P.  Roux (Roux
     Associates), dated October 4, 1988.
                                                                            ',
8.   Re: February  1988  RI Report; letter  from  G.  Johnson  (NYSDOL)  to P.
     Paden  (for PRPs), dated May 2, 1988.


C.  Environmental Reports and Guidance

1.   "Sediment Criteria - December 1989:   Used  as  guidance by the Bureau of
     Environmental Protection, Division of Fish and Wildlife, New York State
     Department of Environmental Conservation."

2.   Claims of  Natural  Resource Damages -  Letter  to U.S.  District Court
     Judge  J.B. Weinstein from Assistant Attorneys General G.J.  Johnson  and
     S. Miller, New York State Department of Law, dated September 6, 1990.

3.   "Assessment of the  Impact of Leachate Upon Estuarine Biota:   Applied
     Environmental Services  Facility,  Glenwood  Landing, Hempstead  Harbor,"
     prepared by the Nassau County Department of Health, dated August 1987.

4.   Department of Commerce Comments - received May 23, 1988.


D.   Documentation of NYS Financed Removal  Action:

1.   Declaration of Imminent Danger -  Letter from  J.J. Dowling,  Commissioner
     of the Nassau County  Department  of Health  to NYSDEC  Commissioner H.G.
     Williams, dated May 29, 1985.

2.   "Findings of  Fact  and Determination:   In  the Matter  of  an Inactive
     Hazardous Waste Disposal  Site  Remediation  Program for One  Shore  Road,
     Glenwood  Landing,  New  York,"  signed  by  NYSDEC  Commissioner  H.G.
     Williams, dated May 31, 1985.

3.   Memorandum  from  N.H.  Nosenchuck,  Director,  Division of Solid and
     Hazardous Waste  to  NYSDEC Commissioner H.G.  Williams, dated  June  4,
     1987.

4.   Final   Contractor's  Application  for  Payment;  from  removal action
     contractor, Waste Conversion, Inc., endorsed April 11, 1988.

5.   From G. Johnson to D. Peirez (for Shore Realty), dated September 18,

                                                           Page 2 of 4

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   .  1986.


E.  Correspondence Regarding ARARs

1.   From G. Johnson (NYSDOL) to P. Paden (for PRPs), dated July 12, 1990.

2.   From B. Mullen (USEPA) to G. Johnson (NYSDOL),  dated July 11, 1990.

3.   From S. McCormick  (NYSDEC)  to J.  Worrall (Roux Associates), dated May
     18, 1990.

4.   From G. Johnson (NYSDOL) to P. Paden (for PRPs), dated July 28, 1988.

5.   From G. Johnson (NYSDOL) to P. Paden (for PRPs), dated July 13, 1988.
                                                                            r

F.  Correspondence Regarding Changes to the RI

1.   Re: Soil Vapor Survey; letter from A. English (NYSDEC) to P. Roux  (Roux
     Associates), dated June 22, 1990.

2.   Re: Pilot  Venting  Study;  letter from A.  English  (NYSDEC)  to P. Roux
     (Roux Associates), dated April 23, 1990.

3.   Re: Drilling  Technique;  letter from A.  English (NYSDEC) to  P.  Roux
     (Roux Associates), dated November 29, 1989.

4.   Re: Air  Analyses;  letter from A.  English (NYSDEC) to P.  Roux (Roux
     Associates), dated November 6, 1989.

5.   Re: Agreement  to  Perform Supplemental  RI;  letter  from P.  Paden (for
     PRPs) to G. Johnson (NYSDOL), dated October  10,  1989.


G.  Waste Analysis Reports

1.   ERCO - March 1984.

2.   SCA Services/Chemical Waste Mgmt.  Co.,  ENRAC Div. - August 6, 1985.

3.   Compuchem - August 8, 1985.

4.   Waste Conversion - October 1985

5.   ENSECO - March 24, 1986.


H.   Public Participation Documents

1.   Record of Decision:  Applied Environmental Services Site; also known
     as the Shore Realty Site (#130006); June 1991.

2.   Proposed Remedial  Action Plan:  Shore Realty Site; AKA Applied
     Environmental  Services Site; April 1991.

                                                           Page 3 of 4

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3.   Responsiveness Summary - Exhibit D of Record of Decision

4.   Transcript of Public Meeting; North Shore High School,  May 15,  1991.

5.   Public Notice, Press Release, Invitation/Fact Sheet,  and Agenda;  for
     public meeting - North Shore High School, May 15,  1991.

6.   Public Notice, Press Release, Invitation/Fact Sheet,  and Agenda; public
     information information meeting  - North Shore High  School,  September
     18, 1990

7.   Transcript of Public Meeting; North Shore High School,  August 12, 1987.

8.   Public Notice;  Public  Meeting,  North  Shore  High  School, August 12,  £•
     1987.

9.   Public Notice and Fact Sheet regarding February 1988  RI Report.

10.  "Public Participation  Work Plan  for  Shore Realty Site at  Glenwood
     Landing," prepared  by  the  New York State  Department of Environmental
     Conservation.
                                                           Page 4 of 4

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                                  EXHIBIT B
         NEW YORK STATE DEPARTMENT OF ENVIRONMENTAL CONSERVATION
                 DIVISION OF HAZARDOUS WASTE REMEDIATION
                 INACTIVE HAZARDOUS WASTE DISPOSAL REPORT
CLASSIFICATION CODE: 2
           REGION: 1
NAME OF SITE  : Shore Realty Company  (AES)
STREET ADDRESS: One Shore Road
TOWN/CITY:                          COUNTY:
Glenwood Landing                    Nassau

SITE TYPE: Open Dump-  Structure-X Lagoon-
ESTIMATED SIZE: 3         Acres

SITE OWNER/OPERATOR INFORMATION:
       SITE CODE: 130006
       EPA ID: NYD980535652
                                       ZIP:
                                       11547

                    Landfill-  Treatment Pond-
CURRENT OWNER NAME....
CURRENT OWNER ADDRESS.
OWNER(S) DURING USE...
OPERATOR DURING USE...
OPERATOR ADDRESS	
Shore Realty Inc.
1 Shore Rd. ,  Glenwood Landing, NY
Mattiace
Mattiace/ & Applied Env'l Service
Garvies Point Road, Glen Cove/ Glenwd Land
PERIOD ASSOCIATED WITH HAZARDOUS WASTE: From 1978
                                To  1984
SITE DESCRIPTION:
Shore Realty Company is owned by the Joseph Saleh and Ammon Bartur and
operated by the Applied Environmental Services (AES).  Prior to their
occupancy, this site was leased and operated by Mattiace Petrochemicals.
During -fine operation by Mattiace, several spills of petrochemicals and
organics occured: including a overturned trailer containing a toluene
like substance in October 1978.  This substance was found seeping into
Hempstead Harbor from the site.  An opening was made level to depth of
the groundwater and was dug parallel to the sea wall.  A recovery pump,
which removes floating products from the groundwater, was installed and
approximately 500 gallons of hydrocarbons are eliminated each month.  A
series of monitoring wells approx. 15 ft deep was installed in the
upgradient side of the opening.
In September 1980, an analysis of soil and groundwater samples indicated
both to be contaminated with volatile halogenated hydrocarbons and
volatile nonhalogenated hydrocarbons.  As of April 1990, the trench
recovery system was still in operation and contaminated soil has been
removed from the site.  However, contamination of the upper glacial
aquifier and potential contamination of deeper confined aquifier is
possible.  Also there is potential for contamination of surface waters
of Hempstead Harbor.  Equally important is the fact that there are over
70,000 people who are served by groundwater taken from wells within 3
miles of the site, all which are potentially threatened by the confirmed
contamination of the upper aquifier.   Soil samples detected toluene(1953
ppb; xylene(9910 ppb).  Water samples detected benzene; toluene; xylene.
HAZARDOUS WASTE DISPOSED:
               TYPE
    Confirmed-X
Toluene
Xylene
Ethyl Benzene
Suspected-
  QUANTITY (units)
                         3000 gallons
                                                          Page 1-11

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                                               SITE CODE: 130006
ANALYTICAL DATA AVAILABLE:
Air-X  Surface Water-X Groundwater-X Soil-X Sediment-X

CONTRAVENTION OF STANDARDS:
Groundwater-X     Drinking Water-X       Surface Water-        Air-

LEGAL ACTION:

TYPE..: Fed. Dist. Court      State- X          Federal-'
STATUS:     Negotiation in Progress-       Order Signed- X

REMEDIAL ACTION:

Proposed-       Under design-         In Progress-X       Completed
NATURE OF ACTION:  RI-FS

GEOTECHNICAL INFORMATION:
SOIL TYPE: 130008Fill
GROUNDWATER DEPTH: 10 feet

ASSESSMENT OF ENVIRONMENTAL PROBLEMS:

Groundwater, soil and sediment contamination - possible impact on
surface water.
ASSESSMENT OF HEALTH PROBLEMS:

Based on the available information there are potential exposures to
hazardous substances for residents adjacent to the site and for
recreational users of Hempstead Harbor.  Soil vapor monitoring on-site
indicates vadose zone contamination throughout the site.  Therefore the
potential for soil vapor migration needs to be evaluated.  Access to
the site is restricted.  However, contamination of Hempstead Harbor by
active contaminant seeps from the bulkhead is occurring and exposure to
contaminants by recreational users of the boat launching ramp adjacent
to the bulkhead may occur.  The RI/FS lacked sufficient data for
assessing the potential exposures associated with this site.  A
supplemental investigation which called for the installation of another
deep well in the northwest corner of the site and soil vapor testing to
determine if soil vapor is migrating off-site was developed to address
deficiencies in the investigation data.
                                                             Page 1-12

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                                 EXHIBIT C
                              PROJECT MILESTONES
                         SHORE REALTY SITE (#130006)
                   AKA APPLIED ENVIRONMENTAL SERVICES SITE
                          (some dates approximate)
1939-1977      Site used for bulk storage of petroleum products.

1977-1980      Site leased to Mattiace Petrochemical Co. to store
               petrochemical products.

1978           Toluene spill.

1980-1983      Site leased to Applied Environmental Services (AES) and    ^
               Hazardous Waste Disposal (HWD).  Operated as hazardous waste
               storage and treatment facility.

10/83          Site purchased by Shore Realty Corp.

1/84           AES evicted from site

3/1/84         At request of NYS Attorney General, U.S. District Court orders
               Shore Realty to clean up site.

6/84-9/84      Shore Realty removes 255 of 410 drums containing hazardous
               wastes from the site then refuses to complete cleanup of
               remaining drums and tanks.

5/31/85        NYSDEC initiates procedures to complete cleanup at state
               expense.

9/13/85        After being held in contempt of court and fined, Shore Realty
               completes removal of drums of chemicals from site.

11/85-9/86     NYSDEC contractor performs surficial cleanup of site removing
               approximately 700,000 gallons of hazardous wastes at a cost of
               $3.1 million.

6/86           Site placed on federal National Priorities List.

8/12/87        Public Meeting - North Shore High School.

9/16/87        Court orders defendants to perform Remedial Investigation and
               Feasibility Study (RI/FS).

2/88           First draft of RI Report submitted to State.

3/88           Public notice of availability of RI Report.

5/88           State rejects RI Report.

8/88           Revised RI Report submitted.

10/88          Revised RI Report rejected.

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10/88-1/89     Meetings and correspondence to develop work plan for
               additional site investigation work to complete RI.   Work plan
               approved 10/10/89.

11/9/89        Field work for Supplemental RI begins.

4/90           Supplemental RI Report submitted.

6/90           Supplemental RI Report rejected.

8/90           RI Report resubmitted.

9/90           First draft of FS submitted.

9/18/90        Public Meeting - North Shore High School
                                                                          -.'f
11/1/90        RI/FS Reports rejected.

2/91           RI/FS Reports resubmitted.

3/5/91         RI/FS Reports rejected

4/17/91        RI/FS Reports resubmitted.

4/17/91        Public notice of availability of RI/FS Reports and public
               meeting to discuss proposed remedy.

5/15/91        Public meeting - North Shore High School.

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                                 EXHIBIT D
                           RESPONSIVENESS SUMMARY
                        PROPOSED REMEDIAL ACTION PLAN
                      SHORE REALTY SITE - ID NO. 130006
                   AKA APPLIED ENVIRONMENTAL SERVICES SITE
      The  issues  addressed below were raised during a public meeting held on
May 15, 1991 at the North Shore High School in Glen Head,  New York.  The
purpose of the meeting was to present the Proposed Remedial Action Plan
(PRAP) for the site and receive comments on the PRAP for consideration
during the final selection of a remedy.  The transcript from the meeting is
included in the administrative record for the site which is open for public
review.  The public comment period on the PRAP extended from April 22, 19'B1
to May 24, 1991.   The issues raised have been grouped into the following
five categories.

I.    Issues  Regarding the Proposed Remedy

Issue #1:  How is the feasibility of a proposed remedy defined and who makes
      the  determination?

Response: Proposed remedies are evaluated against nine criteria given in the
      National  Oil  and Hazardous Substances Pollution Contingency  Plan
      ("NCP") to  determine if  they are  feasible.   The first two  criteria,
      "protection of  human health  and the environment"  and  "compliance with
      applicable  or relevant and appropriate New York State and  federal
      requirements,"  are  threshold criteria that must be satisfied for an
      alternative to  be eligible for selection. The next five  "primary
      balancing criteria" are  used to compare  major tradeoffs  among the
      different remedial  strategies.  These five are "short-term impacts and
      effectiveness," "long-term effectiveness and permanence,"  "reduction
      of  toxicity,  mobility, and volume," "implementability,"  and  "cost."
      The  final two "modifying criteria" of "state acceptance" and
      "community  acceptance" are evaluated after comments on the proposed
      remedy  have been received.   In this case, New York State is  the  "lead
      agency" for the project  and  the USEPA is the "support agency."
      Therefore,  "State acceptance" is  understood  to refer  to  the
      concurrence between the  agencies  on the  proposed  remedy.  These  nine
      criteria  are  described in more detail in the PRAP and the  Record of
      Decision  (ROD).

           As explained above, the NYSDEC and the USEPA are responsible for
      evaluating  the  feasibility of the proposed remedy in  accordance  with
      these nine  criteria.

Issue #2:  How long will  it take to complete the remedial process?

Response: The Feasibility Study concludes that the active portion of the
      remedial  program will take three  years to complete  .  Adding one year
      for  design  of the system, the remedial process would  take  a  total of
      four years.   Given  the uncertainties involved, it is  quite possible
      that the  remedy will take longer, perhaps five to seven  years.
                                                            Page 1 of 16

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Issue #3: If cost were no object, would a different alternative have been
     proposed?

Response: The proposed alternative was judged to be the best selection after
     evaluating  all of  the  governing  criteria.   In this case,  the selection
     of  the proposed  alternative was  not affected by the cost.  In fact,
     the proposed  alternative  is significantly more expensive  than some of
     the others  considered, but  it has the  lowest cost of those that passed
     the threshold criteria.

Issue #4: Can we name three sites where the technologies that comprise the
     proposed remedy  have been shown  to work?

Response: Assessing the expected reliability of the remedy is best addressed
     by  evaluating the  components of  the remedy.  The main  components are1
     in-situ soil  venting,  groundwater extraction and treatment, and
     biotreatment. Soil venting has  been demonstrated and  evaluated as
   •  part  of the EPA  Superfund Innovative Technology Evaluation (SITE)
     Program, and  has been  effectively used at sites in Michigan, Puerto
     Rico,  and Massachusetts.  The technology has also been used
     extensively in the remediation of leaking underground  petroleum
     storage tanks.   The bulk  of the  contaminants at the Shore Realty site
     are volatile  chemicals also found in petroleum products and are
     expected to respond well  to venting.

           Groundwater extraction and treatment is very common, but its
     effectiveness is controversial.  Similar systems have  been used at
     dozens of sites  around the  country, with varying effectiveness. The
     conditions  at this site that favor the likely effectiveness of the
     groundwater treatment  program are;  (1) the  relatively  small size of
     the site;  (2) the  low  density of the major  contaminants and an upward
     hydraulic gradient that combine  to keep contaminants at shallow depths
     and more accessible for treatment;  (3) the  characteristics of the soil
     (e.g.  lack  of large amounts of organic matter); and the amenability of
     the contaminants to treatment.

           The component with the shortest  "track record" in the remediation
     of  sites is the  biotreatment program.   The  technology  has been studied
     extensively at the bench  and pilot scale at sites around  the country,
     and is underway  or completed at  Superfund and other hazardous waste
     sites  in Minnesota, Michigan, and New  York.  The results  of a bench
     scale  test  performed on site soils are promising.  The main advantage
     of  the biotreatment program is its contribution to reducing the time
     needed to attain the remedial objectives for groundwater  by
     stimulating the  in-situ biodegradation of contaminants.

           The combination of technologies  that comprise the remedy is
     somewhat unique, as is the  site  itself.  Therefore, three sites with
     equivalent  conditions  and the same remedy cannot meaningfully be
     identified.   However,  the proposed remedy is  judged to be the best
     method for  addressing  the contamination at  this site.

Issue #5:  How much will the remedy cost?

Response: The feasibility study concludes that the present worth of the

                                                            Page 2  of  16

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     remedy  (in  1991  dollars) is $4,507,000.  Stated another way,
     $4,507,000  deposited  into an interest bearing account in 1991, and
     payed out over the  life of the remedy, should be sufficient to fund
     the  remedy.

Issue #6:  Will some sort of bond be required to .assure that  adequate funds
     are  available?

Response: Negotiations are underway between the State of New  York and the
     responsible parties to provide funds for the remedy.  If completed, an
     agreement for the responsible parties to fund the remedy will be
     incorporated into an  order issued by the federal court.  If an
     agreement is not reached, it is likely that monies to remediate the
     site would  initially  come from the federal "Superfund."  The costs  \
     incurred would then be recovered in legal actions against the
     responsible parties.

Issue #7:  Why aren't hazardous waste companies required to post bonds
     providing for site  cleanup?

Response: Under the federal Resource Conservation and Recovery Act (RCRA)
     and, in this case,  New York State laws and regulations, companies that
  Si  treat,  store, or dispose of hazardous wastes are required to provide  a
     financial assurance mechanism to properly close a facility after
     operations  have  ceased.  Many of these laws and regulations came into
     effect  sometime  after the bulk of the operations that led to the
     contamination of this site, and they were not always complied with
     after they  came  into  effect.

Issue #8:  When will the remedy begin?

Response: Three main things must occur before the remedy begins. A
     pilot project must  be completed to more carefully define the best
     operating conditions  for the biotreatment program.  Second, the design
     of  the  full-scale remedy must be completed and approved by the State
     and  the USEPA.   Lastly, the provisions and conditions for  completing
     the  remedy  must  be  agreed upon and incorporated into a consent decree
     issued  by the court.   Assuming that a settlement to fund the remedy is
     obtained by mid-1991, it is anticipated that construction  should begin
     in mid-1992.

II.  Issues  Regarding Existing Health Effects

Issue #9:  What are the cumulative health effects on area residents
     from the release of contaminants from this site and the other
     contaminant sources (including potential future sources) in the area?

Response: A number of commentors raised this issue directly or
     indirectly  during the public meeting.  In accordance with  the
     requirements of  the National Contingency Plan  (NCP), the RI/FS
     evaluated the potential health effects of the release of contaminants
     at  the  site assuming  that no remedy were implemented.  Naturally, this
     assessment  was based  upon information gathered during the  remedial
     investigation carried out between October 1987 and March 1990.
     Therefore,  the assessment is site specific and based upon  existing.

                                                           Page 3 of  16

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      not previous  conditions,  for  which  data  is not available.

           Unfortunately, the performance of a meaningful area wide health
      assessment would  be extremely difficult  and well beyond the allowable
      scope  of  this project.  Determining the  contribution of past
      contamination from multiple sources in the area to -current health
      effects would be  essentially  impossible.  This is due to the lack of
      adequate  environmental  data from  the past, and the  difficulties
      associated with isolating the impacts  from individual  sources  in the
      area.  However, many conservative assumptions are built into the risk
      assessment.   For  example, the on-site  resident was  assumed to  be
      present at the site,  and  potentially exposed, 24 hours per day, 365
      days per  year, for 70 years.

Issue #10:  What effects can the contaminants at the site have,  and have  •""
      had, on our health?

Response: Section 3.4 of the Feasibility Study (Toxicity Assessment)
      discusses the possible  effects of exposure to site  contaminants.  The
      baseline  risk assessment  concluded  that  the existing conditions at the
      site do not present a significant health risk to off-site residents.
      This means that the risk  of developing cancer from  off-site exposure
  ^   to contaminants migrating from the  site  and the mudflats is less than
      one in one million, and that  non-cancer  health effects are not
      expected.

           In the hypothetical scenario where someone lived on the site for
      their  entire  lifetime,  that person's incremental risk  of developing
      cancer would  be approximately nine  in  one hundred thousand (compared
      with an incidence of 28,000 in 100,000 in the general  population for
      all forms of  cancer).   Non-cancer health effects would not be
      expected.

           Since the data that would be needed to evaluate past conditions
      is not available,  it would be inappropriate to speculate on the
      effects of past exposures.

Issue #11:  Does site contamination threaten the local drinking water supply?

Response: No.   Drinking water around the site is obtained through a public
      water  system  which is supplied from out  of the area.   There are no
      public supply wells within one mile of the site.  Contaminated
      groundwater underneath  the site discharges to the west into Hempstead
      Harbor, away  from populated areas and  not into aquifers that serve as
      current sources of potable water.

Issue #12:  Does the risk assessment address potential impacts to infants and
      unborn children?

Response: The risk assessment does address potential impacts to children and
      adults, but due to the  uncertainties inherent in meaningfully
      evaluating exposures to infants and unborn children, baseline  risk
      assessments do not typically  address these populations directly.

Issue #13:  Prevailing winds appear to carry air over the site towards

                                                            Page 4 of 16

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      local  residences.

Response: Since chemicals were removed from tanks and containers at the
      site during  1985-1986,  the remaining contamination is primarily in the
      shallow groundwater  and soils near the water table.  After evaluating
      air emissions  from the  site under current conditions, the RI/FS
      Reports conclude that off-site impacts on air quality are not
      significant.

III.  Issues Regarding Hempstead Harbor

Issue #14: Do all chemicals from the site flow into the Harbor?

Response:  The results of the remedial investigation indicate that
      contaminated groundwater does indeed discharge  into Hempstead Harbor^.
      This has resulted in a  petroleum-like sheen at  certain  times in the
      small  cove to  the west  of the site.  It  is likely that,  in the past,
      significant  quantities  of chemicals have been released  into the
      harbor.  In  particular,  records  indicate that a toluene spill at  the
      site in 1978 released an unknown quantity of this chemical into the
      harbor.  Under existing conditions, calculations indicate that outside
      of the immediate vicinity of the site, the surface water
      concentrations of the released chemicals is not significant.

Issue #15: Is it safe to swim at the local beaches?

Response: Although studying local beaches was beyond the scope of this
      project, the water quality of public beaches is regularly monitored by
      the County Department of Health.  Calculations  based on the known
      concentrations of contaminants in the groundwater, indicate that  it is
      very unlikely  that site related  contamination would create unsafe
      conditions at  nearby beaches.

Issue #16: What have marine biologists found regarding impacts to flora
      and fauna around the site?

Response: In  1987, the Office of Marine Ecology of the Nassau County
      Department of  Health produced a  report describing the impacts to
      marine biota resulting  from exposure to  chemicals released from the
      site.   Species occurrence and abundance  data were gathered, along with
      sediment samples from the mudflats"  in the western cove.  This cove,
      approximately  one acre  in size,  was divided into three  areas: "inner
      cove," "mid-cove," and  "outer cove."  The inner cove, along with  the
      adjacent wooden bulkhead, was described  as  a zone of "severe  impact"
      indicating a lack of expected biota and  an  inability to support
      relocated organisms.  The mid-cove was described as exhibiting
      "variable" or  "patchy"  impacts and the outer cove  (which extends  to
      the edge of  the site) was described as a zone of "minimal  impact."

TV.   General Site Issues

Issue #17: Why were the tanks and piping not removed  from the site?

Response: The removal action funded by the NYSDEC in  1985-1986 focused
      on the imminent danger  presented by the  presence of the chemicals

                                                           Page 5  of  16

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      in  the  tanks,  containers,  and pipes at the site.  Once emptied, the
      tanks and  pipes  no  longer  presented an imminent threat, and  it would
      not have been  reasonable to  spend public monies to remove them.  The
      owner(s) of  the  site  did not volunteer to remove them.

Issue #18: Why did the site get into the shape it is in?

Response: Contamination of the site resulted from the improper storage
      and handling of  hazardous  chemicals and wastes by persons operating
      the site over  an extended  period of time.

V.    Information  Issues

Issue #19: Can local officials be subpoenaed to force them to attend
      public  meetings  such  as this?                                      ""

Response: No, they cannot.  However, through citizen participation programs,
      the agencies strive to create  the opportunities and  circumstances that
      encourage  participation by all  affected or interested citizens and
      officials.

Issue #20: Will there be more public meetings regarding the remediation
      of  this site?

Response: Since the selected remedy does not differ from the proposed
      remedy, no additional meetings  are planned.   If significant  new issues
      arise during the course of the  remedial program that could impact area
      residents, notices  will be issued and additional meetings may be held.

Issue #21: Will the public be notified when the final remedy has been
      selected?

Response: Yes.   A legal notice describing the selected remedy will be
      published  in local  newspapers  along with other notices.  The Record of
      Decision will  be placed in local information  repositories.

Issue #22: Has a date been set for this case to go before the court
      again?

Response: Yes.   Judge J. Weinstein (U.S.  District Court, Eastern
      District of  New  York) has  directed the parties to  return to  court on
      July 15, 1991.
      The following  comments were submitted to the  agencies  in a letter
dated May 23, 1991 from Mr. Donald W. Stever, liaison counsel to a group of
parties known as the New Defendants in the litigation involving this site.

VI.   Groundwater Extraction and Treatment  is Unnecessary

Issue #23: The removal efficiency of any pump and treat system will be quite
      low because the  groundwater concentrations  of the  target substances
      are very  low.

Response: Groundwater is monitored at three levels at the site; WT-series

                                                            Page 6 of 16

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     wells  screened  at  the  water table, SW-series wells screened
     approximately 15 feet  below the water table, and DW-series wells
     screened approximately 50 feet below the water table.  There are 22
     contaminants in groundwater that exceed groundwater standards.  On a
     mass basis, three  contaminants comprise a great majority of the
     contamination.  These  are ethylbenzene, toluene, and xylenes, or ETX.
     The WT-series wells  are highly contaminated with many compounds
     including ETX at concentrations up to 350,000 parts-per-billion (ppb)
     which  is 70,000 times  the applicable standard.  This results from the
     fact that most  of  the  contaminants float on the water table and
     dissolve into the  shallow groundwater.  The fact that these high
     levels are not  just  a  sampling artifact resulting from the presence of
     floating chemicals is  evidenced by the presence of high levels of
     contaminants in wells  where there is no floating chemical or sheen.
     The SW-series wells  are contaminated with relatively low levels of \
     chlorinated organic  compounds at concentrations up to 60 times the
     applicable groundwater standard.  The DW-series wells are
     uncontaminated.

           Therefore, the upper 15 feet of the aquifer is  highly
     contaminated by volatile non-chlorinated organic compounds.
     Chlorinated organic  compounds are present at relatively low levels at
     the 15 foot level  and  at relatively high levels closer to the water
     table.

           The extraction and treatment program will focus on the upper 15
     feet of the aquifer  and will address both contaminated groundwater and
     saturated soils.   Removal efficiencies are expected to be good.

           The ROD states that if monitoring indicates that continued
     operation of the remedy is not producing significant reductions in the
     concentrations  of  contaminants in soils and groundwater, the NYSDEC
     and the USEPA will evaluate whether discontinuance of the remedy is
     warranted.  The criteria for discontinuation will include an
     evaluation of the  operating conditions and parameters as well as a
     statistical determination that the remedy has attained the feasible
     limit  of contaminant reduction and that further reductions would not
     be technically  feasible or needed to be protective of human health or
     the environment.

Issue #24:  The imposition of groundwater standards to this site is
     arbitrary and capricious for the following reasons:

     a.    the contaminated aquifer is not a current or potential future
           source of  drinking water;

     b.    groundwater discharges to the harbor and does not
           recharge aquifers used for drinking water;

     c.    any attempt to utilize site groundwater would result in salt
           water intrusion making the aquifer unusable;

     d.    soil venting will eliminate any threat of significant
           concentrations of ETX from discharging and creating a sheen on
           the mudflats and will prevent, the presence of detectable levels

                                                           Page  7 of  16

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           of contaminants in the harbor at the point of discharge; and

      e.    it is not cost effective.

Response: Rather than being arbitrary and capricious, the application
      of  groundwater  standards  as  remedial  goals  at  this  site  is  a
      straightforward application  of a regulation in place  since  1978  (6
      NYCRR 703.5).   This  regulation states that  the best usage of  fresh
      ground  waters is as  a  source of potable water  supply.  Federal law and
      regulations provide  that  an  applicable standard may be waived only if
      one or  more of  six grounds are met  (ref.  40 CFR 300.430  (f)(l)(ii)(C)
      of  the  NCP).  Of these six,  the only  potentially  applicable waiver
      would be  that complying with the requirement would  be technically
      impracticable from an  engineering perspective.  Since the reduction of
      volatile  contaminants  in  groundwater  is practical as  well as        ':-r
      practicable, this waiver  cannot be  invoked.

           Although it is unlikely that shallow groundwater from the site
      would be  used as a source of drinking water, other  uses  that  could
      expose  users to contaminants cannot be ruled out.   For example,  a
      nearby  country  club  uses  groundwater  from the  upper aquifer for
      refrigeration and irrigation (gardening,  etc.).

           Although any off-site withdrawal wells capable of drawing in
      contaminated groundwater  from the site would also induce salt water
      intrusion from  the harbor, on-site  withdrawal  wells would not
      necessarily induce salt water intrusion.  Therefore,  it  is  not true
      that any  use of site groundwater would induce  salt  water intrusion.

           Without extracting and treating groundwater, highly contaminated
      shallow groundwater  will  continue to  discharge to the harbor.  At the
      point of  discharge,  contaminants would certainly  be above detectable
      levels.   Since  the saturated soils  associated  with  the shallow
      groundwater are also contaminated,  chemicals would  continue to leach
      from the  soil into groundwater for  many years,  probably  decades.

           The criterion of cost effectiveness cannot properly be addressed
      until after the threshold criteria  for selecting  a  remedy have been
      met.  One of those criteria  is that the remedy meets  all applicable or
      relevant  and appropriate  requirements (ARARs).  As  discussed  above,
      groundwater standards  are applicable  standards at this site.
      Therefore, the  "cost effectiveness" of a  remedy that  does not address
      this threshold  criterion  is  not meaningful.

VII.  Off-Site  Source(s) of  Contaminants

Issue #25:  The ROD should indicate that the chlorinated organic
      contaminants (COCs)  found in the SW-series  wells  come from  an off-site
      source  for the  following  reasons:

      a.    COCs are found in monitoring wells near the upgradient boundary
           of the site;

      b.    COCs are not identified as contaminants of concern;


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      c.    COCs are not found in soils; and

      d.    remedial costs would be significantly increased by attempting to
           remediate COCs in the SW-series wells.

Response: The only method for determining whether COCs found on-site come
      from one  or more  upgradient, off-site sources is to obtain a sample of
      upgradient, off-site groundwater.  No existing wells qualify for this
      role.   COCs have  indeed been identified as contaminants of concern as
      have all  contaminants  found in groundwater at concentrations above the
      applicable standards.   COCs have  been found in varying concentrations
      at  all  soil levels  on  the  site, and  in locations not necessarily
      indicating an  off-site source (see RI Report figures 10,  12, 18, &
      19).
                                                                         t
           It is true that it would not be appropriate to attempt to
      remediate a source  of  contamination  located upgradient of the  site
      solely  by on-site collection and  treatment of groundwater.  For this
      reason, the ROD calls  for  the installation of an appropriately located
      monitoring well to  determine if there is an upgradient contributor to
      contamination  at  the site.  In addition, the ROD does not require
      additional treatment designed specifically to treat the COCs.
      Potential additional costs would  be  realized only  if the  length of
      treatment is extended  to remove COCs. However, by  that time, the
      source  of COCs should  be clarified.
      The  following  comments  were  submitted to the  agencies  in  a  letter
dated May 23, 1991 from Mr. George R. Lawrence.

VIII.  Other Contributing Sources

Issue #26: What is the petroleum contribution from the existing asphalt
      covering?

Response:  The existing asphalt covering over portions of the site is
      not  considered a  significant source of petroleum related  contaminants.
      The  quantities of contaminants  potentially leached  from weathered
      asphalt are  extremely small  in  comparison to  the quantities of
      contaminants found on-site.

Issue #27: What is the expected contribution.of petroleum compounds
      from storm water  discharge to the  inlet, since  tides and  prevailing
      winds  tend to  drive floatables  on  to the mud  flats?

Response:  As with the contribution from the existing asphalt,  the
      contribution of petroleum contaminants from area storm water
      discharges is  not considered significant.  While such  storm water
      discharges might  slightly contribute to sediment contamination  on  the
      mud  flats, they do not  contribute  to the soil contamination that is
      the  principal  threat at the  site.  Additionally, the contamination
      found  in the sediments  is not the  primary reason for remediating the
      site.

Issue #28: How much contribution from the Port Washington landfill,

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      either  floatable materials or groundwater, is expected to end up at
      the  site?

Response:  No modeling has been performed to try to quantify the
      potential  contribution  of contaminants from  the Port Washington
      landfill to  the site.   However, as with the  storm water discharges,
      any  contribution would  affect only the sediments, rather than the site
      soils and  groundwater that are far more contaminated.

Issue #29:  The Northeast section has been determined to have high
      readings on  the photoionization detector.  How much investigation will
      be done to determine the source?

Response:  The northeast corner of the site exhibited elevated soil gas
      readings in  the first soil gas survey.  As explained in the Remedial
      Investigation  Report, additional  surveys were performed to confirm
      this unexpected finding.  The two subsequent surveys found background
      soil gas readings  in this area, leading to the conclusion that the
      initial survey was not  representative of actual conditions;  No
      further investigations  will  be performed.

Issue #30:  The cross sections indicate that there is contamination
  ^   north of the Site.  There is not  enough up-gradient information to
      determine  the  origin of the  contamination.   Will additional test wells
      be installed to locate  and quantify  the source of this contamination?

Response:  The cross sections indicate only that there is contamination
      in the  furthest upgradient on-site wells.  The information currently
      available  is not sufficient  to determine whether the contamination
      found in those wells is from an on-site or off-site source.  Some
      additional work will be performed, including installation of at least
      one  upgradient monitoring well, to make that determination.

Issue #31: Page 3-13 of the RI states that "the three detections of
      airborne benzine  (sic)  which could result from volatilization of the
      Site compounds migrating through  bulkheads and over the tidal flats
      may  also be  attributed  to the adjacent terminal operations."  Has this
      possibility  been investigated and if so, what were the results?

Response:   The quoted text is actually found at Page 3-13 of the
      Feasibility  Study.  No  investigation beyond  that reported in the RI/FS
      has  been performed.  The work necessary to isolate the contamination
      contributed  by the adjacent  oil terminal is  not warranted, since it
      would not  affect remedy selection at the site.

Issue #32: Page 61-1 of the RI states that "the results of this survey
      conducted  during May, 1990,  indicated background reading  through the
      northern portion of the Site, consequently this data  is not  considered
      representative of  soil  vapor conditions."  This set of readings is
      significant  if contamination is entering from upgradient  areas.  When
      will an investigation be conducted to determine the source of this
      vapor?

Response:  As  explained in the response to Issue #29, the northeast corner of
      the  site exhibited elevated  soil  gas readings  in the  first soil gas

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     survey.  Additional surveys were performed to confirm this unexpected
     finding.  The two subsequent surveys found background soil gas
     readings in this area, leading to the conclusion in the Remedial
     Investigation Report that the initial survey was not representative of
     actual conditions.  No further investigation will be performed (see
     also  Issue #30).

Issue #33:  The RI  indicated that low PPM of  chlorinated solvents in
     SW-1  "May be from off Site since SW-1 is generally down gradient from
     SW-6".  If this is true, what affect would this off site contaminant
     have  on remediation?  Why hasn't it been confirmed?

Response: As evidenced by use of the word "may",  an off-site  source of
     contaminants is suggested but not proven.  If it is true that off-site
     sources contribute to groundwater contamination at the site, that
     would not affect the preferred alternative.  The preferred alternative
     was selected for its ability to effectively treat the variety of
     contaminants found at this site.  As noted above (see Issue #30), some
     investigation to determine whether or not there are off-site sources
     of  contamination is planned.

Issue #34:  The proposed remedial action  plan page (6 and 7)  indicates
     that  the SW series wells screened at the C + D soil horizons contain
     chlorinated organic compounds that "may be the result of off site
     contamination".  There are no adequate up gradient wells to confirm or
     disprove this.  What action has been proposed to determine the source
     of  contamination, to prevent recontamination of the remediated areas
     and to investigate the upgradient areas?

Response: This issue has been addressed  in the response to Issue #30.

Issue #35:  Because of the nature of the  Harbor Fuel operations,  it is
     possible that they may have contributed to the groundwater
     contamination.  Are there sufficient test wells installed to measure
     the quality of the groundwater that flows from the Harbor Fuel
     property onto the Site?

Response:  Although the Remedial Investigation did not attempt to
     determine the direction of groundwater flow on the Harbor Fuel
     property, considering the water table configuration on-site  (Figure 2-
     2 in  the FS) and the location of the Harbor Fuel property, groundwater
     does  not appear to flow from Harbor Fuel onto the site.  This
     conclusion is supported by the absence of petroleum related
     contaminants from the furthest upgradient wells.

Issue #36:  The RI  identifies the Penetrex Site as an inactive hazardous
     waste site.  This site is upgradient from the Shore Site so  there is a
     possibility of contamination from it.  What steps have been  taken to
     investigate contamination from the Penetrex Site?  Are there  any
     monitoring wells on the Penetrex Site and if so, what do test  results
     indicate?  Are the contaminants on the Penetrex Site the same  as those
     discovered on the Shore Site?

Response: The Penetrex Site has been considered,  and does not appear to
     contribute contaminants to the Shore Site.  . An examination of  the data

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      from the Penetrex  Site  indicates that groundwater flows to the west
      and  discharges  to  Hempstead Harbor.  Although some of the same
      chlorinated volatile organics  found at the Shore Realty Site are also
      found at the  Penetrex Site, Penetrex is  located north of Shore and is
      not  upgradient.  Therefore, it is not likely to affect groundwater
      quality at the  Shore Site.
DC. GROUNDWATER CONTAMINATION;

Issue #37: Page 4-17 of the Feasibility study states that attaining the
      state Maximum Contaminant  Level  (MCL) would not be  practical.  How is
      this reconciled with  the State's objective of  attaining drinking water
      quality groundwater?                                               ^

Response:  EPA and NYSDEC believe that the preferred alternative is a
      practical  remedy  capable of  achieving State MCLs  in the groundwater.
      The FS  states at  page 4-17 that remedial options  which "guarantee"
      reaching MCLs are technically  impractical.  However,  the selected
      remedy  is  workable and has the potential to reach MCLs if  implemented
      and operated  properly and  proceeds as expected.   No remedy is  100
      percent "guarantee[d]."

Issue #38: How was it determined that groundwater beneath the mudflats
      rises from the lower  areas to  the upper areas  (except for  the  first
      10-20 feet)?   Any dissolved  or free  product is most likely to  be near
      the surface.   What is the  affect of  the tide on groundwater movements
      and this product?

Response: The determination regarding vertical flow of groundwater
      under the  site is based  on hydrographs comparing  the groundwater
      levels  in  the deep,  shallow, and water table wells.   The groundwater
      flow direction under  the mud flats was not predicted but multilevel
      sampling/analysis shows  that the concentration of contaminants does
      not increase  with depth.   The  upper  portion of the  aquifer below the
      site undergoes a  reversal  of vertical flow direction with  each tidal
      cycle,  while  the  deeper  portions of  the aquifer exhibit a  constant
      upward  flow.   The tide does  affect groundwater movement in the upper
      portion of the aquifer.  At  the water table, the  groundwater elevation
      fluctuates only a few inches with each tidal cycle.   This  movement
      tends to spread the floating product across a  narrow band  of soil in
      the upper  aquifer.  That narrow band will be dewatered under the
      preferred  alternative, and decontaminated by the  soil venting  system.

Issue #39: If the groundwater is rising where is it coming from, upland
      areas behind  the  Site (upgradient) or is it rising  up due  to the
      buoyancy of fresh water  on the salt  water interface?

Response: The groundwater is probably coming from upland areas,  although the
      Remedial Investigation did not perform a study of the regional
      groundwater flow  regime.

Issue #40: Since the 1988 report,  the line of contamination has
      progressed toward Hempstead  Harbor with the subsequent reduction of
      contaminants  in the upgradient areas of the Site.   This indicates that

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      the  natural  flushing  of  1989-91 removed a good deal of the groundwater
      contamination.   How long will it be before the Site is purged of
      contaminants and meets state standards if natural remediation is
      allowed to continue unaided by other remediation methods?

Response:  It is not possible to accurately estimate the length of time
      necessary for the  site to naturally remediate to meet ARARs.  This
      option  was considered as Alternative I - No Action in the Feasibility
      Study,  and was  rejected  due to uncertainty that ARARs would ever be
      achieved, and the  unacceptable length of time for remediation under
      the  most optimistic assumptions.  Experience at other hazardous waste
      sites indicates that  as  contaminant concentrations drop the process of
      natural remediation slows, typically taking decades at sites with
      heavy contamination such as this site.                              ..

X. NEED FOR REMEDIATION

Issue #41: The hazard index for this Site is less than one (1).  This
      is below the threshold for posing a health risk.  Why then  is it
      necessary to do subsurface remediation?

Response:  The hazard index is only one indicator of the need for
      remediation  and addresses only non-carcinogenic health effects.  The
      Remedial Investigation found concentrations of contaminants in the
      groundwater  at  concentrations exceeding the health based  New York
      State groundwater  quality standards, and estimated an increased  cancer
      risk of 9 x  10~s.  These findings clearly indicate the need for
      remediation  of  the site. The only way to remediate the site is  to
      remediate the subsurface contamination that is the source of
      contamination at the  site.

Issue #42:  The remedial action plan stated that Site impacts on animal
      and  marine life appear to be limited to the bulkhead and  sediments
      directly adjacent  to  the Site.  Why does the State propose  to
      remediate the entire  Site if only a small percentage of the property
      is now  considered  impacted?  Harbor Fuel Oil is adjacent  to the  Site
      and  the Port Washington  Landfill is across the harbor.  Do  these
      facilities have an impact on the animal and marine life near the Site?

Response:  Impacts to marine life on the bulkhead and sediments were not
      the  only documented environmental impacts at the  site.  Other media at
      the  site are also  significantly impacted.  Contaminated  soils are the
      source  of contamination  impacting groundwater, sediments,  surface
      waters,  and  air at the site.  Only by removing the source of
      contamination can  impacts to all the other media  be remediated.  The
      question regarding the Harbor Fuel Oil Terminal and Port  Washington
      Landfill has been  previously addressed under Issues 29 and 34.
      Additionally,  the  contamination found in the sediments is not the
      primary reason for remediating the site.

XI. SURFACE WATERS

Issue #43: The Report states  that at low tide,  a "sheen is visible on the
      mudflat next to the Site."  Is this unique  for the mudflats in
      Hempstead Harbor?  Do other mudflats in the Harbor experiences similar

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      "sheens"?  And  if  they do, how is the origin of the materials forming
      the  "sheen"  determined?

Response:  The Remedial Investigation did not include an examination of
      other  mudflats  for a  sheen.  Based on observations at the Site, the
      sheen  that appears is a  result of groundwater  discharge through the
      wooden bulkhead.   The sheen results from the non-aqueous phase liquids
      (NAPL) floating on the surface of the groundwater.  The NAPL sheen is
      a violation  of  New York  State surface water quality standards.

XII. FUTURE USE OF THE SITE

Issue #44: The plan for the clean-up was based on the standard that a
      person could live  on-site  for 24 hours a day for  70 years and not be"
      at risk.  The Town of North Hempstead has zoned the site a "Business B
      District".   The town  zoning regulations do not permit residential
      housing in a "Business B District."  It is well established that
      zoning authority is retained by local government  unless the State has
      a justifiable reason  to  preempt.  In this case, the plan is requiring
      a clean-up standard compatible with a residential district.  Why has a
      clean-up standard  been chosen that is in conflict with the town
      zoning? Why wasn't a clean-up standard chosen that would be more
      consistent with the use  of property zoned as a "Business B District"?

Response:  The cleanup standards chosen for this site are based on State
      and  federal  law, and  neither conflict with nor preempt local zoning.
      Cleaning up  a site to a  standard allowing future  residential use does
      not  require  the town  to  rezone for residential use.  However, if
      future changes  in  local  zoning open this site  for residential
      development,  which is possible given the history of the site and the
      waterfront location,  the cleanup must be protective of human health.

Issue #45: The risk assessment for this Site factored in future use by
      human  inhabitants.  However, the risk assessment  did not include the
      possibility  of  restricting the use of the land by a covenant to the
      deed.   A covenant  could  regulate human presence on the Site by
      permitting only certain  activities.  This would be consistent with the
      town zoning  of  the Site  as a "Business B District".  Limiting the
      future uses  of  the Site  would greatly reduce the  remediation costs.
      Why  wasn't this possibility considered?

Response:  The National Contingency Plan (NCP)  states that:

      The  use of institutional controls shall not substitute for active
      response measures  (e.g., treatment and/or containment of source
      material, restoration of ground waters to their beneficial uses)
      as the sole  remedy unless  such active measures are determined not
      to be  practicable,  based on the balancing of the  trade-offs among
      alternatives  that  is  conducted during the selection of the
      remedy.

           Deed restrictions are considered institutional controls, and are
      inherently less effective than site remediation.  During the  selection
      of the remedy for  this site, the use of treatment was determined to be
      practicable  based  on  the balancing of tradeoffs mandated under federal

                                                           Page  14 of  16

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      law.   Therefore,  institutional controls could not be considered.
      Regardless  of  future use, groundwater under the site must be
      remediated  to  comply with groundwater quality standards, so cost would
      not be affected by  limiting future use of the site to industrial
      activity.

XII. PREFERRED ALTERNATIVE

Issue #46: Remedial alternative VI proposed depressing the water table
      approximately  3 feet by a pumping operation.  Where will this water be
      pumped to?  Will  this water be treated to remove .contaminants?  What
      is the estimated  volume of water that will be pumped?

Response:  The water will be treated by air stripping or an equivalent
      process.  A portion of the treated water will be used in the        >
      biodegradation system, and the remainder will be discharged either to
      the  local wastewater treatment plant or directly to the harbor.  In
      either case, the  discharge will be treated and monitored to ensure
      compliance  with all applicable discharge standards.  The Feasibility
      Study  estimates a pumping rate between 10 and 30 gallons per minute.
      A more reliable estimate will be developed as part of the remedial
      design.

Is&ue #47: Remedial alternative VI proposes the  addition of nutrients
      and oxygen  into treated water before it is reinjected into the  site.
      What method would be used for the reinjection?  Where on the site
      would  the reinjection be done?  On other sites, deep well injection
      has not worked because of screen load up by biological organisms at
      the discharge  point.  Has this problem been investigated and if so,
      what were the  findings?  What affect will the injection have on the
      pumping operation for lowering the water table?

Response:   The method of reinjection will be determined during system
      design, but will  probably involve wells, well points, trenches, or a
      combination of all  three.  Reinjection will probably be done in the
      northeast portion of the site, and at the toe of the slope on the
      western side of the site as shown in Figure 5-5 of the Feasibility
      Study.  A survey  of bioremediation work did not reveal any obstacles
      to reinjection that cannot be overcome by proper selection and  design
      of the reinjection  system.  Reinjection and pumping rates will  need to
      be properly balanced to maintain the desired depression of the  water
      table  and adequate  flow of nutrients to the saturated zone.

Issue #48: Remedial alternative VI proposes the  treatment of "both
      saturated and  unsaturated soils".  Does this mean that all of the soil
      on the Site will  be treated?  Or does it mean that only specific areas
      of the Site with  significant concentrations of contaminants will be
      treated?  If so,  what areas will be treated and what is the criteria
      for choosing these  areas?

Response:  Soil venting to treat unsaturated soils will be performed in
      the central elevated area around the storage tanks, and down the slope
      to the west and southwest as shown in Figure 5-5 of the Feasibility
      Study.  Biodegradation will treat saturated soils in roughly the same
      area as the soil  venting.  These areas were selected based on the

                                                           Page  15 of 16

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      concent-rations  of  contaminants  found during the Remedial
      Investigation,  and encompass  all of the areas of  significant
      contamination.   The precise areas will be further defined  during
      remedial  design.

Issue #49: The lower elevations of the Site have a history of flooding
      to a depth  of 2 to 3 feet during spring tides when 'there are high off
      shore winds.  What affect would this flooding have on  the  remediation
      plans in  general and the  in-situ biodegradation portion in particular?
      The RI  shows that  the largest concentration of contaminants are in the
      low lying areas that are  most susceptible to flooding.  Is it prudent
      to introduce biodegradiants to  soil that will be  flooded by salt
      water?  What affect does  salt water have on the biodegradiants that
      the RI  proposes to use?
                                                                         ir
Response: The potential for flooding will be considered in the design
      of the  systems  that will  be placed on the low lying  areas  of the site,
      but does  not affect the remediation plans in general.  The proposed
      biodegradation  process involves the injection of  only  nutrients and  a
      source  of oxygen into the groundwater.  Complex interactions resulting
      from the  infiltration of  salt water are not expected.  However, the
      possibility 'can be examined during remedial design.

    . HYPOTHETICAL SITUATION

Issue #50: If a legal hazardous waste operation was operating on the
      Site, would the presence  of one (1) Part Per Billion of Benzine  (sic)
      on the  mud  flats be acceptable  to the State?

Response:  It is not appropriate to address such a hypothetical situation
      without additional information.  The Site requires remediation because
      it presents a significant threat to human health  and the environment
      and does  not comply with  ARARs, not solely due to the  presence of
      benzene on  the  mud flats.
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