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
Page 6 of 25
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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
Page 7 of 25
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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:
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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
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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
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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
Page 20 of 25
-------
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
-------
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.
Page 22 of 25
-------
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
Page 23 of 25
-------
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
-------
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
-------
FIGURES
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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 ^: — :•>-.;
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SITE PLAN
SHORE REALTY
COMMON DEFENSE OROUP
NEW VOftK V. SHORE REALTY
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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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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
-------
TABLES
-------
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
-------
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
-------
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
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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
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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.
-------
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
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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
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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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