EPA/ROD/R02-95/245
August 1995
EPA Superfund
Record of Decision:
Carroll & Dubies Sewage Disposal,
Port Jervis, NY
3/31/95
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DECLARATION FOR THE RECORD OF DECISION
SITE NAME AND LOCATION
Carroll and Dubies Superfund Site
Town of Deerpark, Orange County, New York
STATEMENT OF BASIS AND PURPOSE
This decision document presents the selected remedial action for
the Carroll and Dubies Superfund Site (the Site), which was
chosen in accordance with the Comprehensive Environmental
Response, Compensation, and Liability Act (CERCLA) of 1980, as.
amended, and to the extent practicable, the National Oil and
Hazardous Substances Pollution Contingency Plan (NCP). This
decision document explains the factual and legal bases for
selecting the remedy for this Site. The information supporting
this remedial action decision is contained in the administrative
record for this Site. The administrative record index is
attached (Appendix III).
The New York State Department of Environmental Conservation
(NYSDEC) concurs with the selected remedy as per the attached
letter (Appendix IV). . ' .
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 a imminent
and substantial endangerment to public health, welfare, or the
environment.
DESCRIPTION OF THE SELECTED REMEDY
This operable unit (OU1) represents the first of two operable
units planned for the Site. This operable unit addresses, the
source areas (lagoons and surrounding impacted soils) at the Site.
and actions needed to ensure that the source areas do not pose a
threat to human health or the environment, including any
potential cross media impacts to groundwater. The second
operable unit (OU2), which is currently in progress, will further
characterize the fate and transport of the contaminants emanating
from the Site and will serve as the basis for the decision on a
final groundwater remedy.
The major components of the selected remedy include:
o Excavation of all materials.from lagoons 1, 2, 3, 4, 6, 7
and 8, as well as the soils in the vicinity of those
lagoons, which exceed the excavation levels specified in the
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Selected Remedy section of the Decision Summary, EPA's
current estimate of the volume of the materials requiring
excavation is approximately 20,300 cubic yards (cy) .
However, the actual volume will be further determined during
the implementation of the remedy.
o Treatment of excavated soil/sludges which contain organic
constituents above the treatment levels specified in the
Selected Remedy Section of the Decision Summary (estimated
at 13,800 cy) via on-Site ex-situ vapor extraction.
o Additional treatment of lagoon 7 soils/sludges (estimated
at 3,400 cy) via on-Site ex-situ bioslurry (treatment
targeted primarily for semi-volatile contaminants) .
o Stabilization/solidification of soils/sludges which fail
the Resource Conservation and Recovery Act's Toxicity
Characteristic Leaching Procedure (TCLP) for inorganic
constituents (estimated at 5,700 cy) .
o Placement of treated and untreated soils/sludges in a
lined and capped cell consistent with modified requirements
of New York Code of Rules and Regulations Part 360. The
base of the cell will consist of a high density polyethylene
(HDPE) liner and a sand drainage layer. The cell will be
sloped to a leachate collection system. The cap will
consist of'a low-permeability clay layer, an HDPE membrane,
a sand drainage layer and a topsoil cover layer.
o Development of an air-monitoring system and installation
of air pollution control equipment to ensure compliance with
air pollution control regulations; and
o .Recommendations that deed and well restriction's be
imposed to protect the integrity of the cap.
Although the use of the bioslurry process to treat lagoon 7
materials appears to be a promising means of treating the semi-
volatile organics, further treatability studies are necessary to
demonstrate that this process can reduce the complex mix of
constituents in lagoon 7 to remediation goals. Because of the
existing uncertainty, a contingency remedy will be implemented if
treatability study results indicate that bioslurry will not be
effective in reducing the levels of contaminants in lagoon 7
materials, particularly semi-volatile contaminants, to
remediation goals. The major components of the contingency
remedy are identical to those of the selected remedy with the
following exception:
Excavation and off-Site treatment (as necessary) and
disposal of lagoon 7 materials at a RCRA (Subtitle C)
permitted treatment, storage and disposal facility; it is
assumed that thermal treatment, i.e., incineration or low
temperature thermal treatment, will* be necessary to reduce
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the contaminants to appropriate Land Disposal Restriction
(LDR) levels.
STATUTORY DETERMINATIONS
The selected remedy and contingency remedy are protective of
human health and the environment, comply with federal and state
requirements that are legally applicable or relevant and
appropriate to the remedial action and are cost-effective. The
selected remedy and contingency remedy utilize permanent
solutions and alternative treatment technologies to the maximum
extent practicable and satisfy the statutory preference for
remedies that employ treatment that reduces toxicity, mobility,
or volume as a principal element. Because the selected remedy
and contingency remedy will necessitate restrictions on the use
of the site, a five-year review will be required to ensure the
integrity of the containment system.
Jeanne M. Fox,/"
Regional Adrtrfnistrat
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DECISION SUMMARY
Carroll and Dubies Superfund Site
Town of Deerpark
Orange County, New York
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY.
Region II
New York, New York
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TABLE OF CONTENTS
SITE NAME, LOCATION AND DESCRIPTION 1
SITE HISTORY AND ENFORCEMENT ACTIVITIES 2
HIGHLIGHTS OF COMMUNITY PARTICIPATION . 3
SCOPE AND ROLE OF OPERABLE UNIT 3
SUMMARY OF SITE CHARACTERISTICS 4
SUMMARY OF SITE RISKS 8
REMEDIAL ACTION OBJECTIVES 11
DESCRIPTION OF REMEDIAL ALTERNATIVES 12
SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES 17
SELECTED REMEDY 22
STATUTORY DETERMINATIONS 27
DOCUMENTATION OF SIGNIFICANT CHANGES 32
ATTACHMENTS
APPENDIX I. FIGURES
APPENDIX II. TABLES
APPENDIX. III. ADMINISTRATIVE RECORD INDEX
APPENDIX IV. STATE LETTER OF CONCURRENCE
APPENDIX V. RESPONSIVENESS SUMMARY
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SITE NAME, LOCATION AND DESCRIPTION
The Carroll and Dubies Superfund Site (the Site) occupies
approximately 3 acres in the Neversink Valley, just northeast of
the City of - Port Jervis on Canal Street in the Town of Deerpark,
Orange County, New York (see Figure 1) . The Site is occupied by
an office building and a garage. The waste disposal areas at the
Site include seven lagoons. Several automobiles from previous
salvage operations have been abandoned on-Site. Numerous
portable toilets are also stored on-Site.
The northwest boundary of the Site is formed by the valley wall,
which consists of exposed bedrock with talus comprising .the base.
The southeast boundary and a portion of the northeast boundary of
the Site are formed by remnants of the former Delaware and Hudson
(D&H) Canal and towpath. The remainder of the northeast property
boundary is formed by the valley wall arid an active sand and
gravel quarry. Adjacent to the southern boundary of the Site is
the City of Port Jervis Landfill. The landfill is no longer
active; however, Orange County currently operates a solid waste
transfer station on a portion of the landfill property.
Approximately 1,500-feet to the east of the Site is Gold Creek
and its associated wetlands. The Neversink River is located
approximately 2,000-feet beyond Gold Creek. Gold Creek and the
Neversink River drain into the Delaware River.
The Site ranges from approximately .440 to 520 feet above mean sea
level. The materials encountered underlying the Site consist of
glacially derived unconsolidated materials underlain by
consolidated bedrock. The thickness of the unconsolidated
overburden materials ranges from zero feet at the exposed bedrock
slope forming the northwestern Site boundary, to over 60 feet
along the towpath. The glacially derived materials consist of
two distinct units, including a glacial till unit overlain by
glacial outwash deposits. The outwash deposit was observed to
vary in thickness from 31 feet to 52 feet along the downgradient
edge of the Site. The outwash deposits typically consist of
medium dense to very dense brown sand with some clayey silt and
gravel. The glacial till deposits are characterized as dense to
very dense dark grey silt with sand and gravel. The glacial till
is not continuous beneath the Site, and appears to pinch out
toward the northwestern edge of the Site. The depth to
groundwater from ground surface ranges from approximately 30 to
40 feet along the southeastern boundary of the Site. Groundwater
movement is generally towards the southeast.
The major aquifer system used for potable water supply in Orange
County is comprised of the bedrock and the sand and gravel
deposits in the valley. No residential wells have been found to
exist between the Site, and Gold Creek. However, approximately 90
residential wells exist downgradient of the Site between Gold
Creek and the Neversink River. The nearest residence and
residential well is located approximately a quarter of a mile
downgradient of the Site.
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SITE HISTORY AND ENFORCEMENT ACTIVITIES
From approximately 1970 to 1979, the Site was used.for the
disposal of septic and municipal sewage sludge, as well as
industrial wastes, primarily from the cosmetic industry. The
industrial wastes were deposited in one or more of the seven
lagoons located at the Site (lagoons 1 through 4 and 6 through 8
depicted in Figure 2). Initially, it was believed that the
industrial wastes were deposited only in lagoons 1 through 4. In
July 1992, however, the Site was expanded to include the
investigation of areas believed to contain four additional
filled-in lagoons (lagoons 5, 6, 7 and 8). These lagoons were
tentatively identified in historical aerial photographs.
Trenching in the area of lagoons 6, 7 and 8 confirmed the
presence of sewage sludge and industrial waste; trenching in the
area of lagoon 5 revealed the presence of tires instead of
industrial waste. The dimensions of lagoons 1, 2, 3, 4., 6, 7 and
8 are approximately 100 feet by 60 feet, 200 feet by 60 feet, 100
feet by 35 feet, 100 feet by 40 feet, 60 feet by 20 feet, 100
feet by 45 feet, and 150 feet by 40 feet, respectively.
In 1978, lagoon 3 was ignited by the Port Jervis Fire Department
in order to practice suppression of chemical fires. After this
incident, lagoons 3 and 4 were filled in with soil and the area
was revegetated. With the exception of lagoons 1 and 2, all of
the lagoons . have been covered with soil. Lagoons 1 and 2 were
.left uncovered and are surrounded by a. wooden fence. In .June
1979, the New York State Department of Environmental Conservation
(NYSDEC) prohibited the disposal of industrial wastes at the
Site. The Site continued to be used for the disposal of septic
and municipal sewage wastes until 1989.
In February 1987, NYSDEC issued a Phase II Investigation Report
which summarized past investigations and included a Hazard
Ranking System (MRS) score for the Site. Based on the HRS score,
the Site was proposed for inclusion on the National Priorities
List (NPL) in June 1988 and was placed on the NPL in February
1990.
On September 25, 1989, the United States Environmental Protection
Agency (EPA) sent "special notice" letters pursuant to Section
122(e) of CERCLA, 42 U.S.C. §9622(e), to four potentially
responsible parties (PRPs), Kolmar Laboratories, Inc. (Kolmar),
Wickhen Products, Inc. (Wickhen) , Reynolds Metals Company, Inc.,
and Carroll and Dubies .Sewage Disposal Facility, Inc., affording
them the opportunity to conduct the Remedial Investigation and
Feasibility Study (RI/FS) for the Site. (PRPs are companies or
individuals who are potentially liable under CERCLA for the costs
of responding to the release and threat of release of hazardous
substances at and from a site.) The PRPs were given 60 days in
which to submit a good faith offer to undertake or finance the
RI/FS fbr the Site.
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On November 30, 1989, two of the four PRPs, Kolmar and Wickhen,
submitted to EPA a good faith offer to perform the RI/FS. An
Administrative Order on Consent, Index No II-CERCLA 00202, was
signed by the two PRPs and by EPA in February 1990: This work
has been conducted under EPA's .supervision.
During the RI, EPA learned from the City of Port Jervis that it
owned a major portion of the Site property where the lagoons are
located. In an April 22, 1993 letter, EPA notified the City that
it was also a PRP for the Site. After issuance of the ROD, all
the PRPs will be offered the opportunity to design and implement
the selected remedial alternative for the Site.
HIGHLIGHTS OF COMMUNITY PARTICIPATION
The RI/FS reports and the Proposed Plan for the Site were
released for public comment on August 4, 1994. These documents
were made available to the public in the administrative record
file at the EPA Docket Room in Region II, 26 Federal Plaza, Room
2900, New York, New York and at the Deerpark Town Hall, Drawer A,
Huguenot, New York. The Proposed Plan was sent to members of the
public on EPA's mailing list on August 3, 1994. A public notice
announcing the availability of these documents was issued on
August 15, 1994 in The Times Herald Record. The public comment
period was held from August 4, 1994 through September 2, 1994.
During the public.comment period, EPA held .a public meeting to
present the RI/FS reports and the Proposed Plan; answer
questions, and accept both oral and written comments. The public
meeting was held in the auditorium of the Port Jervis High
School, Port Jervis, New York on August 23, 1994. At this
meeting, representatives from the NYSDEC, EPA and the New York
State Department of Health (NYSDOH) answered questions about
concerns related to the Site and the remedial alternatives under
consideration. Responses to the comments received at the public
meeting and to written comments received during the public
comment period, are included in the Responsiveness Summary (see
Appendix V).
SCOPE AND ROLE OF OPERABLE UNIT
This ROD addresses the first of two operable units planned for
this Site. This operable unit (OU1) addresses the source areas
(lagoons and surrounding impacted soils) at the Site and actions
needed to ensure that the source areas do not pose a threat to
human health or the environment, including any potential cross
media impacts to groundwater. The second operable unit (OU2)
investigation, which is currently underway, will address the need
for remediating contaminated groundwater underlying the Site.
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The two PRPs who performed the RI/FS for the first operable unit
are currently performing the RI/FS for the second operable unit
under supervision by EPA. '
The purpose of the response action under OU1 is to prevent
leaching of contaminants in the soils/sludges at levels which
will contribute to the contravention of groundwater quality and
drinking water standards in the groundwater in the vicinity of
the Site, as well as to minimize potential risks to hypothetical
workers who might take part in excavation activities in
contaminated areas in the future.
SUMMARY OF SITE CHARACTERISTICS
The intent of the investigation was to characterize the soil
quality of the seven lagoons at the Site and any potential cross
media impacts to the groundwater quality in the vicinity of these
lagoons. The remedial investigation consisted of drilling
borings and constructing monitoring we.lls, collecting soil and
groundwater samples, and conducting ambient air quality and
seismic surveys. The PRPs hired Blasland & Bouck Engineers to
implement the RI/FS.
.Between July and September 1991, approximately 20 soil/sludge
samples were collected from lagoons 1 through 4 and the .
surrounding soils; these samples were analyzed for organic and
inorganic constituents. During January and February 1993, 54
additional soil samples were collected to further delineate the
horizontal extent of lagoons 1 through 4 and to characterize the
berm soil around lagoons 1 and 2. Various organic constituents
were detected in these lagoons and the surrounding soils. Some
of the highest concentrations of organic contaminants detected
included benzene (650 parts per million (ppm)), 1,2-
dichlorobenzene (43.0 ppm), 1,4-dichlorobenzene (250 ppm),
tetrachloroethene .(290 ppm), and toluene (370 ppm). Inorganic
constituents detected in lagoons 1 through 4 and surrounding
soils included arsenic (10.7 ppm), barium (1,290 ppm), chromium
(137 ppm), cyanide (320 ppm), lead (1,400 ppm), and nickel (368
ppm) .
Higher levels of organic and inorganic constituents were detected
in lagoons 6, 7 and 8. Approximately 45 soil and sludge samples
were collected from within and around the perimeter of lagoons 6,
7 and 8 during January and February 1993. Some of the highest
concentrations of organic contaminants detected included benzene
(2,800 ppm), tetrachloroethene (12,000 ppm), and toluene (13,000
ppm) . Inorganic constituents detected in lagoons 6, 7 and 8
included arsenic (9.7 ppm), barium (933 ppm), chromium (16,000
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pptn) , and lead (609 ppmj . In general, organic compounds were
detected at higher concentrations in lagoon 7, and inorganic
compounds were detected at higher concentrations in lagoon 8.
Five background soil samples were collected from areas not
affected by Site contamination to use as a point of reference.
One of the five soil samples was analyzed for organic
constituents. All five background soil samples were analyzed for
inorganic constituents. Other than 0.01 ppm of methylene
chloride,, organic compounds were not detected in the soil sample
collected to assess background concentrations of organic
compounds. The highest concentrations of various inorganic
constituents detected in the background soil samples included 7.0
ppm of arsenic, 43.1 ppm of barium, 61.9 ppm of chromium, 45.6
ppm of lead, and 36.7 ppm of nickel. Cyanide was not detected in
any of the background soil samples.
Tables 1 and 2 summarize the contaminant concentration averages
and ranges for the source area materials and the background soil
samples. In Tables 1 and 2, the NYSDEC soil cleanup levels
(Technical and Administrative Guidance Memorandum (TAGM) No.
4046) are provided in place of the background soil concentrations
for organics since only one organic compound was detected in the
background soil sample. Figure 2 shows the location of the soil
borings.
The source materials from lagoons 1, 2, 7 and 8 were tested using
the toxicity characteristic leaching procedure (TCLP) to
determine if these materials would be considered Resource
Conservation and Recovery Act (RCRA) hazardous waste based on the
characteristic of toxicity. The source materials from lagoons 1
and 2 did not leach organic or inorganic constituents at
concentrations above the regulatory criteria for determining
waste to be a RCRA characteristic waste. The source materials
from lagoon 7 failed the TCLP for benzene, tetrachloroethene,
trichloroethene and vinyl chloride and are therefore considered
RCRA hazardous waste based on the characteristic of toxicity.
Lagoon 8 failed the TCLP for benzene and chromium; therefore,
these materials would be considered RCRA hazardous waste based on
the characteristic of toxicity. All materials which exceed TCLP
levels would be subject to pretreatment.in order to satisfy RCRA
land disposal restrictions (LDRs).
Grouhdwater
During August 1991, December 1991, March 1993 and October 1993,
groundwater samples were collected from the vicinity of the
lagoons and analyzed for organic and inorganic compounds.
Monitoring wells located downgradient of lagoons 1 through 4 were
sampled during August 1991, December 1991 and March 1993, and
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monitoring wells located downgradient of lagoons 6, 7 and 8 were
sampled in October 1993. These monitoring wells monitor the
bedrock, the glacial till, the glacial outwash or both the
glacial till and outwash units. Figure 3 shows the location of
the monitoring wells at the Site.
Four organic compounds, benzene, 1,2-dichloroethene (total),
tetrachloroethene and trichloroethene, were detected above the
Federal and/or State drinking water standards in the monitoring
wells located downgradient of lagoons 1 through 4 during August
and December 1991 and March 1993. These four organic compounds
were detected in the monitoring wells that monitor the glacial
outwash or both the glacial till and outwash. Organic
contaminants were not detected above Federal or State drinking
water standards in any of the bedrock or glacial till monitoring
wells. Aside from tetrachloroethene detected in monitoring well
OW-6, organic compounds were only detected above the Federal
and/or State drinking water standards at monitoring wells located
along the D&H towpath (e.g., OW-2, OW-3 and MW-4) . The
monitoring wells located downgradient of the D&H towpath (e.g.,
OWr5, OW-6, OW-7 and OW-8) were installed in 1993 and were only
sampled in the October 1993 sampling event. The four organic
contaminants noted above were detected in higher concentrations
in 1991 than in 1993. The highest concentrations of organic
compounds detected above drinking water standards were benzene at
52 parts per billion (ppb) in monitoring well OW-3, 1,2-
dichloroethene (total) at 230 ppb in monitoring well OW-2,
tetrachloroethene at 130 ppb in monitoring well OW-2, and
trichloroethene at 41 ppb in monitoring well MW-2. The Federal
and State drinking water standards for benzene, tetrachloroethene
and trichloroethene are all 5 ppb. The State drinking water
standard for 1,2-dichloroethene isomers is 5 ppb, which is more
stringent than the Federal standard.
Inorganic compounds (arsenic, beryllium, chromium, lead and
nickel) were detected above the Federal and/or State drinking
water standard in monitoring wells located downgradient of
lagoons^1 through 4 only during the 1991 sampling events. During
the March 1993 sampling, only cadmium Was detected above drinking
water standards. Cadmium was detected in monitoring well OW-3 at
6 ppb, which is slightly higher than the Federal and State
drinking water standard of 5 ppb.
During the October 1993 sampling of monitoring wells located
downgradient of lagoons 6, 7 and 8 (OW-9, OW-10, OW-11, OW-12,
OW-13, OW-14 and BW-5), benzene was detected "above both the
Federal and State drinking water standards; seven other organic
compounds were detected above the State drinking water standards
but below the Federal drinking water standards. The highest
concentrations of organic compounds detected were benzene at
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1,300 ppb in monitoring well OW-12; 1,3,5-trimethylbenzene at 12
ppb in monitoring well OW-ll; 1,2,4-trimethylbenzene at 44 ppb in
monitoring well OW-12; 1,2-dichloroethene (total) at 12 ppb in
monitoring well OW-13; ethylbenzene at 9.8 ppb in monitoring well
OW-12; toluene at 9.6 ppb in monitoring well OW-12; and xylene at
40 ppb. in monitoring well OW-12. The State drinking water
standard for 1,3,5-trimethylbenzene, 1,2,4-trimethylbenzene,
ethylbenzene, toluene, and xylene is 5 ppb. The Federal drinking
water standard is 700 ppb for ethylbenzene, 1,000 ppb for toluene
and 10,000 ppb for xylene. A Federal drinking water standard
does not exist for 1,3,5-trimethylbenzene or 1,2,4-
trimethylbenzene .
Nine inorganic compounds were detected above Federal and/or State
drinking water standards in the seven monitoring wells located
downgradient of lagoons 6, 7 and 8. However, six of the nine
inorganic compounds were detected above standards only in
monitoring well OW-10. Chromium, lead and nickel were detected
above drinking water standards in more than one monitoring well
and were detected at levels that ranged from 106 to 2,930 ppb,
19.1 to 924 ppb and 100 to 1,560 ppb, respectively. The
inorganic compounds detected above drinking water standards in
monitoring well OW-10 were about an order of magnitude higher
than the levels detected in the other monitoring wells. The
Federal drinking water standards for chromium and nickel are set
.at 100 ppb;. the Federal action level for lead is 15 ppb. The
State drinking water standards for chromium and lead are 100 and
50 ppb, respectively. A State drinking water standard does not
exist for nickel.
The NYSDOH performed a limited sampling of off-Site private wells
in 1991 and again in 1993 for organic and inorganic constituents.
Organic constituents were not detected in the groundwater from
these wells, and inorganic constituents were detected below
drinking water standards.
As previously mentioned, an investigation to. determine the
lateral and downgradient extent of the groundwater plume is.
currently underway and will be reported in the RI for the second
operable unit.
Ambient Air Monitoring and Geophysical Surveys
A seismic survey and an ambient air survey were conducted at the '
Site. The ambient air survey, indicated that the Site does not
have an adverse impact on air quality. The seismic survey
provided additional information on the Site geology.
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SUMMARY OF SITE RISKS
Based upon the results of the RI, a baseline risk assessment was
conducted to estimate the risks associated with current and
future Site conditions. The baseline risk assessment estimates
the human health and ecological risk which could result from the
contamination at the Site, if no remedial action were taken.
As part of the baseline risk assessment, the following four-step
process is utilized for assessing Site-related human health risks
for a reasonable maximum exposure scenario: Hazard
Identification--identifies the contaminants of concern at the
Site based on several factors such as toxicity, frequency of
occurrence, and concentration. Exposure Assessment--estimates
the magnitude of actual and/or potential human exposures, the
frequency and duration of these exposures, and the pathway (e.g,
ingesting contaminated well-water) by which humans are
potentially exposed. Toxicity Assessment--determines the types
of adverse health effects associated with chemical exposures, and
the relationship between magnitude of exposure (dose) and
severity of adverse effects (response). Risk Characterization--
summarizes and combines outputs of the exposure and toxicity
assessments to provide a quantitative (e.g., one-in-a-million
excess cancer risk) assessment of Site-related risks.
The risk assessment was prepared before the analytical soil data
associated with lagoons 6, 7 and 8 were available. Therefore,
only the data collected from lagoons 1 through 4 during July and
September 1991 were used in the risk assessment. A separate risk
assessment was not prepared for lagoons 6, 7 and 8, since it was
anticipated that remedial action would be taken at these lagoons
due to the levels of contaminants found, the presence of
hazardous waste and cross media impacts to groundwater. Higher
baseline risk levels would be expected if the analytical soil
data from lagoons 6, 7 and 8 were included in the risk
assessment.
The baseline risk assessment began with selecting contaminants of
concern which would be representative of Site risks. These
contaminants included, but were not limited to benzene, 1,2-
dichlorobenzene, tetrachloroethene, toluene, arsenic, barium,
chromium, cyanide, lead, and nickel. The summary of the
contaminants of concern (COCs) is provided in Table 3.
The baseline risk assessment addressed the potential risk to
human health by identifying potential exposure pathways by which
the public might be exposed to contaminant releases at the Site
under current .and future land-use conditions. The exposure
pathways under the current land-use conditions included the
exposure to adult and child trespassers through the dermal
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contact with standing water contained in lagoon 1, and through
the ingestion, inhalation and dermal contact of soils and
sludges. When considering future land use, the exposure pathways
included the ingestion, inhalation and dermal contact of soils
and sludges by construction workers. Because the Site is
surrounded by a cliff, a landfill and a quarry, future
residential use of the property was not considered as a
reasonable scenario. The exposure pathways considered under
future and current land-use conditions are listed in Table 4.
Under current EPA guidelines, the likelihood of carcinogenic
(cancer causing) and non-carcinogenic effects due to exposure to
Site chemicals are considered separately. It was assumed that
the toxic effects of the Site-related chemicals would be
additive.. Thus, carcinogenic and non-carcinogenic .risks
associated with exposures.to individual compounds of concern were
summed to indicate the potential risks associated with mixtures
of potential carcinogens and non-carcinogens, respectively.
Potential carcinogenic risks were evaluated using the cancer
potency factors developed by EPA for the compounds of concern.
Cancer slope factors {SFs) have been developed by EPA's
Carcinogenic Risk Assessment Verification Endeavor for estimating
excess lifetime cancer risks associated with exposure to
potentially carcinogenic chemicals. SFs, which are expressed in
units of (mg/kg-day) "1, are multiplied by the estimated intake of
a potential carcinogen, in mg/kg-day, to generate an upper-bound
estimate of the excess lifetime cancer risk associated with
exposure to the compound at that intake level. The term "upper
bound" reflects the conservative estimate of the risks calculated
from the SF. Use of this approach makes the underestimation of
the risks highly unlikely. The SF for the compounds of concern
are presented in Table 5.
EPA's acceptable cancer risk range is 10"4 to 10"6 which can be
interpreted to mean that an individual may have a one in ten
thousand to a one in a million increased chance of developing
cancer as a result of a site-related exposure to a carcinogen
over a 70-year lifetime under the specific exposure conditions at
a site. The results of the baseline risk assessment indicated
that the soils and sludges associated with lagoons 1 through 4
pose no unacceptable carcinogenic risk to human health. The sum
of the current cancer risks for the exposure pathways for adult
and child trespassers was 5 x 10"7 (five in ten million) and 3 x
10~6 (three in a million), respectively. The overall future
carcinogenic risk for construction workers, through ingestion,
inhalation and dermal contact of contaminated soils and sludges,
was estimated to be 4 x 10"6 (four in a million) . These
carcinogenic risks are within EPA's acceptable risk range. A
summary of the carcinogenic risks are presented in Table 6.
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Noncarcinogenic risks were assessed using a hazard index (HI)
approach, based on a comparison of expected contaminant intakes
and safe levels of intake (Reference Doses) . Reference doses
(RfDs) have been developed by EPA for indicating the potential
for adverse health effects. RfDs, which are expressed in units of.
mg/kg-day, are estimates of daily exposure levels for humans
which are thought to be safe over a lifetime (including sensitive
individuals) . Estimated intakes of chemicals from environmental
media (e.g.. the amount of a chemical ingested from contaminated
soil) are compared with the RfD to derive the hazard quotient for
the contaminant in the particular medium. The HI is obtained by
adding the hazard quotients for all compounds across all media.
An HI greater than 1 indicates that the potential exists for
noncarcinogenic health effects to occur as a result of site-
related exposures -. The reference doses for the compounds of
concern at the Site are presented in Table 7.
The calculated HI values for adult and child trespassers are less
than 1, which EPA has determined to be acceptable. The total
exposure HI for construction workers assumed to be participating
in excavation and grading activities was estimated to be 3.0.
Therefore, there may be unacceptable noncarcinogenic risks
associated with the construction worker scenario. The primary
contributor to this risk is chromium-containing dust which could
be inhaled, during excavation activities. Chromium containing
dust contributed approximately 70 percent to the HI. A summary
of the noncarcinogenic risks are presented in Table 8.
As previously noted, higher risk levels from exposure to
contaminated soil would have resulted if the analytical soil data
from lagoons 6, 7 and 8 were included in the risk assessment. A
risk assessment to identify the potential risk to human health
through groundwater exposure pathways will be prepared during the
second operable unit. As indicated by the groundwater sampling
data, contaminants from the soil are migrating into the
groundwater at concentrations above Federal and State health-
based drinking water standards.
The qualitative .ecological assessment concluded that the Site
provides low to moderate habitat value to wildlife. The.degree
of physical disturbance on-Site and lack of continuous quality
habitat in adjacent areas restrict the diversity and extent of
wildlife use at the Site. Therefore, only minor impacts on
wildlife are expected to occur.
Uncertainties
The procedures and inputs used to assess risks in this
evaluation, as in all such assessments, are subject to a wide
variety of uncertainties. In general, the main sources of
uncertainty include:
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- environmental chemistry sampling and analysis
- environmental parameter measurement
- fate and transport modeling
- exposure parameter estimation
- toxicological data.
Uncertainty in environmental sampling arises in part from the
potentially uneven distribution of chemicals in the media
sampled. Consequently, there is significant uncertainty as to
the actual levels present. Environmental chemistry-analysis
error can stem from several sources including the errors inherent
in the analytical methods and characteristics of the matrix being
sampled.
Uncertainties in the exposure assessment are related to estimates.
of how often an individual would 'actually come in contact with
the COCs, the period of time over which such exposure would
occur, and in the models used to estimate the concentrations of
the contaminants of concern at the point of exposure.
Uncertainties in toxicological data occur in extrapolating both
from animals to humans and from high to low doses of exposure, as
well as from the difficulties in assessing the toxicity of a
mixture of chemicals. These uncertainties are addressed by
making conservative assumptions concerning risk and exposure
parameters throughout the assessment. As a result, the Risk. .
Assessment provides upper-bound estimates of the risks to
populations near the Site, and is highly unlikely to
underestimate actual risks related to the Site.
Actual or threatened releases of hazardous substances from this
Site, if not addressed by implementing the response action
selected in the Record of Decision (ROD), may present a imminent
and substantial endangerment to the public health, welfare, or
the environment.
REMEDIAL ACTION OBJECTIVES
Remedial action objectives are specific goals to protect human
health and the environment. These objectives are based on
available information and standards such as applicable or
relevant and appropriate requirements (ARARs) and risk-based
levels established in the risk assessment. The remedial action
objectives for the source areas at the Site are (1) to prevent
leaching of contaminants in the soils/sludges at levels which
will contribute to the contravention of groundwater quality and
drinking water standards in the groundwater in the vicinity of
the Site; and (2) to minimize potential risks to hypothetical
excavation, workers.
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DESCRIPTION OP REMEDIAL ALTERNATIVES
CERCLA requires that each selected site remedy be protective of
human health and the environment, be cost effective, comply with
other statutory laws, and utilize permanent solutions and
alternative technologies and resource recovery alternatives to
the maximum extent practicable. In.addition, the statute
includes a preference for the use of treatment as a principal
element for the reduction of toxicity, mobility, or volume of the
hazardous substances.
This ROD evaluates in detail six remedial alternatives for
addressing the soil and sludge contamination at the Carroll and
Dubies Superfund site. As used in the following text, the time
to implement reflects only the time required to implement the
remedy, and does not include the time required to design the
remedy, procure contracts for design and construction or to
negotiate with responsible parties for implementation of the
remedy, conduct operation and maintenance, or conduct long-term
monitoring.
Alternative 1: No Action
Capital Cost: $ 0
O & M/yr Cost: $ 0
Present Worth: $ 0
Time to Implement: 0 months
The Superfund program requires that the "no-action" alternative
be considered as a baseline for comparison with other
alternatives. Under this alternative, the contaminated soil
would be left in place without treatment. The Site would remain
in its current condition and no effort would be made to change
the current Site conditions.
Alternative 2: Limited Action
Capital cost: $ 52,000
0 & M/yr Cost: $ 18,000
.Present Worth: $ 328,660
Time to Implement: 6 months
This alternative consists of institutional controls such as deed
restrictions to limit future use of the Site and complete fencing
of the Site to minimize potential human exposure to the source
area materials. The limited action alternative would not utilize
any remedial technologies for the treatment of the source areas.
A long-term groundwater monitoring program would be implemented
to track the migration of contaminants from the source areas into
the groundwater utilizing existing monitoring wells at the Site
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(This monitoring program may be addressed as part of OU2
groundwater remedial activities.)
Alternative 3: Low-Permeability Cap with Slurry Cut-Of£ Wall
Capital Cost: $ 3,299,816
0 & M/yr Cost: $ 147,060
Present Worth: $ 5,560,128
Time to Implement: 12 months
This alternative includes the construction of a low-permeability
cap over the. source materials to minimize the infiltration of
precipitation. Limiting the amount of water which percolates
through the source materials would reduce the leaching of the
chemical constituents into the groundwater underlying the Site.
In addition to the cap, a slurry cut-off wall would be installed
around the source area to minimize the migration of soil gas and
leachate from the impacted source areas into the surrounding
soils and to minimize the movement of groundwater through the
source area materials. The cap would be constructed of a low-
permeability material such as natural clay, geosynthetics,
asphalt or combinations of these materials. Additional drainage
and top soil layers would be included to achieve a well drained,
vegetated surface upon completion. Deed restrictions would be
recommended to limit future use of the Site in order to protect
the integrity of the cap.
The slurry cut-off wall would be constructed by excavating
vertical trenches while filling the excavation with a soil-
bentonite slurry.. The slurry wall would be keyed into the
bedrock unit which underlies the Site. This bedrock unit
consists of shale and silt stone and ranges from ground surface
to 60 feet below grade. Groundwater at the Site is present
within the overburden soil materials. Therefore, hydrodynamic
controls to maintain an inward groundwater flow gradient within
the cell would be required to prevent any leakage from the cell
into downgradient groundwater. Hydrodynamic controls would
include pumping groundwater from within the capped area. The
collected water would be treated on-Site in a granular activated
carbon (GAC) adsorption treatment system to meet New York State
Pollution Discharge Elimination System (SPDES) requirements prior
to discharge. The spent carbon would be regenerated or shipped
off-Site to an appropriate disposal facility. Groundwater
monitoring would be performed annually in coordination with OU2
groundwater remedial activities.
Alternative 4: Stabilization/Solidification and Placement into
an On-Site Containment Cell
Capital Cost: $ 5,389,215
O & M/yr Cost: $ 26,400
Present Worth: $ 5/794,983
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Time to Implement: 12 months
This alternative involves the physical removal of approximately
20,300 cubic yards (cy) of source area materials and treatment of
these materials through stabilization/solidification.
Stabilization/solidification is a process by which stabilizing
agents such as cement-based, pozzolanic-based, asphalt-based, and
organic-polymer-based agents are mixed with the source area
materials to convert the waste to a more stable form. To ensure
compliance with air pollution control regulations, capture' and
control mechanisms would be installed, as necessary, to control
air emissions containing organic constituents emitted during the
stabilization/solidification process. Air monitoring would also
be conducted during implementation of this alternative to
determine the .need for additional engineering controls.
The stabilized mass would then be placed into a lined and capped
cell, which would comply with modified requirements specified in
the New York Code of Rules and Regulations (Part 360) . The base
of the cell would consist of a high density polyethylene (HDPE)
liner and a sand drainage, layer. The cell' would be sloped to a
leachate collection system located adjacent to the cell to
collect any leachate that is generated by the solidified
materials. Once the source area materials are placed into the
cell, a cap would be constructed over the cell to minimize the
infiltration of rainwater. The cap would consist of a low-
permeability clay layer, an HDPE membrane, a sand drainage layer,
and a topsoil cover layer. Deed restrictions would be
recommended to limit future, use of the Site in order to protect
the integrity of the cap. Leachate would be removed periodically
from the leachate collection system and sent off-Site for
treatment and disposal in compliance with applicable regulations.
Groundwater monitoring would be performed annually in
coordination with OU2 groundwater remedial activities.
Alternative 5.: Organics Treatment via Ex-Situ Vapor Extraction,
Ex-Situ Bio slurry or Low-Temperature Thermal Desorption;
Inorganic Treatment via Stabilization/Solidification, and
Placement into an On-Site Containment Cell
Capital' Cost: $ 8,105,000
O & M/yr Cost: $ 28,000
Present Worth: $ 8,535,000
Time to Implement: 12 months
The title/name and description of this alternative has been
modified from that presented in the Proposed Plan and FS to
reflect the change in emphasis on the likely type of process to
treat organic contaminants. This change was warranted by
additional information that was presented during and subsequent
to the August 23, 1994 public meeting. (Please refer to the
community acceptance and Documentation of Significant changes
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sections of this document, as well as Appendix V, the
Responsiveness Summary.) The Proposed Plan and other information
disseminated at the- public meeting indicated that one or a
mixture of three different processes might be used to treat
organic contaminants. At that time, the emphasis was placed on
the use of Low-Temperature Thermal Desorption (LTTD) as the
treatment process; the current emphasis is on the use of a
mixture of ex-situ vapor extraction and bioslurry as the
treatment processes for the organics. The costs of implementing
this alternative have also been refined to reflect the change in
emphasis on treatment from the higher cost portion of LTTD to the
lower cost options of vapor extraction combined with bioslurry.
This alternative consists of excavating materials from lagoons 1,
2, 3, 4, 6, 7 and 8and soils in the vicinity of these lagoons
(estimated to be 20,300 cy). Materials, which exceed organic
contaminant treatment levels (estimated to be 13,800 cy) and/or
inorganic contaminant treatment levels, would undergo treatment
prior to disposition into a lined cell; the remaining materials
would be deposited directly into the lined cell without
treatment. Materials from lagoons 1, 3, 7 and 8 (approximately
13,500 cubic yards) which contain high concentrations of organic
contaminants would be treated to reduce the levels of organic
contaminants. Three options are included under this alternative
as options for organic treatment: LTTD, vapor extraction, and
bioslurry. These processes are described below.
LTTD is a process by which soils/sludges are heated and the
organic constituents are desorbed from the soils/sludges and
volatilized into an induced air flow. The soils/sludges are
heated to temperatures ranging from 200°F to 1,200°F. Air or
nitrogen carrier gas is passed over the soils/sludges to collect
the volatilized organic constituents. The carrier gas is then
passed through a condenser, carbon adsorption bed, cyclone and/or
a baghouse to limit emissions to within the air pollution control
regulatory requirements. In vapor extraction, air is drawn
through the soil to vaporize and remove organic contaminants in
the soil. The air flow also provides indigenous microorganisms
with sufficient oxygen to degrade organic contaminants present in
the soil. In bioslurry treatment, the contaminated soil is mixed
with water to form a slurry which is fed to a bioreactor and
aerated. The principal objective of aeration is to supply
sufficient oxygen throughout the slurry to promote aerobic
micrbbial activity that will degrade the organic contaminants in
the soil. Nutrients for the microorganisms are also added to the
bioreactor.
Any air emissions generated from organics treatment via LTTD,
vapor extraction, or bioslurry treatment would be treated as
necessary to meet air pollution control regulations. Regardless
of whether LTTD, vapor extraction or bioslurry treatment is
utilized, the cleanup criteria for organic compounds presented
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later in this document would have to be met (see Remediation
Goals under Selected Remedy). Air monitoring would be conducted
during implementation of this alternative to ensure air emissions
are within regulatory limits. Further treatability studies would
be required to demonstrate the ability of any of these processes
to effectively treat the organic constituents in the waste,
particularly the lagoon 7 materials.
Upon completion of the treatment of lagoons 1, 3, 7 and 8 for
their organic constituents, lagoons 6 and 8 (approximately 5,700
cy) would be treated through stabilization/solidification to
reduce the mobility of the inorganic constituents. Additionally,
if source area materials from lagoons 1, 2, 3, 4 and 7 exceed the
RCRA-Regulated Levels for TCLP for inorganic constituents, they
would also be stabilized/solidified. Additional source area
materials may also be stabilized/solidified in order to achieve
adequate load bearing capacity. All excavated source area
materials (estimated to be 20,300 cubic yards) would then be
placed in a lined cell with a well for leachate collection, and
then capped. The lined cell and cap are the same as that
described in Alternative 4. Deed restrictions would be
recommended to limit future use of the Site in order to protect
the integrity of the cap. Leachate would be removed periodically
from the leachate collection system and sent off-Site for
treatment and disposal in compliance with applicable regulations.
Groundwater monitoring would be performed annually in
coordination with OU2 groundwater remedial activities.
Alternative 6: Off-Site Disposal at a Permitted Landfill
Capital Cost: $ 32,679,764
0 & M/yr Cost: $ 0
Present Worth: $ 32,679,764
Time to Implement: 12 months
This alternative consists of excavating 20,300 cy of source area
materials and transporting these materials off-Site to a RCRA-
permitted treatment, storage and disposal facility for treatment
and disposal, as appropriate. The majority of the excavated
materials would be placed directly into lined 20 cy roll-offs.
Some of the source area materials might need to be dewatered
prior to off-Site transportation. Each roll-off would be sampled
to characterize the source area materials prior to transportation
off-Site. Based on the analytical data available for the source
area materials, the materials from Lagoons 6, 7 and 8 would
require pretreatment to meet the LDRs prior to disposal at a
RCRA-permitted landfill. Air monitoring would also be conducted
during implementation of this alternative to determine the need
for engineering controls.
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It is estimated that the volume of source area materials that
would require pretreatment prior to land disposal is
approximately 9,130 cy. For purposes of evaluating this
alternative, incineration and solidification were considered to
be the appropriate pre-treatment methods to address the source
area materials which do not meet LDRs.
SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES
During the detailed evaluation of remedial alternatives, each
alternative was assessed utilizing nine evaluation criteria as
set forth in the National Contingency Plan, 40 CFR
§300.430 (e) (9) (iii) and the Office of Solid Waste and Emergency
Response (OSWER) Directive 9355.3-01. These criteria were
developed to address the requirements of Section 121 of CERCLA,
42 U.S.C. §9621 to ensure all important considerations are
factored into remedy selection decisions.
The following "threshold" criteria are the most important, and
must be satisfied by any alternative in order to be eligible for
selection:
1. Overall protection of human health and the environment
addresses whether or not a remedy provides adequate
protection and describes how risks posed through each
exposure pathway (based on a reasonable maximum exposure
scenario) are eliminated, reduced, or controlled through .
treatment,, engineering controls, or institutional controls.
2. Compliance with Applicable or Relevant and Appropriate
Requirements addresses whether or not a remedy would meet
all of the applicable, or relevant and appropriate
requirements of federal and state environmental statutes and
requirements or provide grounds for invoking a waiver.
The following "primary balancing" criteria are used to make
comparisons and to identify the major trade-offs between
alternatives:
3. Long-term effectiveness and permanence refers to the ability
of a remedy to maintain reliable protection of human health
and the environment over time, once cleanup goals have been
.met. It also addresses the magnitude and effectiveness of
the measures that may be required to manage the risk posed
by treatment residuals and/or untreated wastes.
4. Reduction of toxicity, mobility, or volume through treatment
is the anticipated performance of a remedial technology,
with respect to these parameters, that a remedy may employ.
5. Short-term effectiveness addresses the period of time needed
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to achieve protection and any adverse impacts on human
health and the environment that may be posed during the
construction and implementation periods until-cleanup goals
are achieved.
6. Implementability is the technical and administrative
feasibility of a remedy, including the availability of
materials and services needed.
7. Cost includes estimated capital and operation and
maintenance costs, and the present worth costs.
The following "modifying" criteria are considered fully after the
formal public comment period on the Proposed Plan is complete:
8. State acceptance indicates whether, based on its review of
the RI/FS and the Proposed Plan, the State supports,
opposes, and/or has identified any reservations with the
preferred alternative.
9. Community acceptance refers to the public's general response
to the alternatives described in the Proposed Plan and the
RI/FS reports. Factors of community acceptance to be
discussed include support, reservation, and opposition by
the community.
A comparative analysis of the remedial alternatives based upon
the above evaluation criteria follows.
Overall Protection of Human Health and the Environment
All alternatives, except for no action, would offer some degree
of protection of human health, and the environment; Alternative 1,
no action, offers no protection. Alternative 6 would be most
protective of human health and the environment in the vicinity of
the Site, since source area materials would be removed from the
Site. Alternatives 4 and 5 would mitigate cross-media impacts to
the groundwater from the source and therefore would be protective
of human health and the environment. Alternative 5 would,
however, provide a higher degree of overall protection of human
health and the environment than Alternative 4, since it would
permanently remove organic contaminants from source area
materials having high levels of organic contamination.
Alternative 3 does not include any treatment, therefore it would
not be as protective to human health and the environment as
Alternatives 4, 5 and 6. Alternative 2 would be less protective
of human health and the environment than Alternatives 3, 4, 5,
and 6, since it would rely on the proper enforcement of
institutional controls and would not reduce the leaching of
chemical contaminants to the Site groundwater.
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Compliance with ARARs
All remedial technologies proposed for use in Alternatives 3, 4,
5 and 6 would be designed and implemented to meet ARARs and are
therefore similar in their compliance with ARARs. Wastes would
be treated using specific technologies or treated to specific
treatment levels, as appropriate, to comply with air pollution
control and RCRA hazardous waste regulations. Federal and State
regulations dealing with the handling and transportation of
hazardous wastes to an off-Site treatment facility would be
followed with regard to Alternative 6. Alternative 2, 3, 4 and 5
would require compliance with various state and/or local
requirements for implementing deed restrictions. Alternatives 1
and 2 would not comply with State closure ARARs. In addition,
for reasons discussed below under Long-Term Effectiveness and .
Permanence, Alternative 6 followed by Alternatives 5, 4, and 3
would best minimize cross-media impacts of contaminants migrating
from soil to groundwater, thereby enabling groundwater standards
to be achieved in a shorter time frame. Alternatives 1 and 2
would not provide this benefit.
Long-Term Effectiveness and Permanence
Alternative 6 would provide the highest degree of long-term
effectiveness and permanence, since the contaminated soils would
be permanently removed from the Site and, following any necessary
treatment, disposed of at a RCRA permitted disposal facility.
Alternatives 4, 5 and 6 would mitigate the leaching of
contaminants to the underlying groundwater. Alternative 5 would,
however, provide the highest degree of long-term effectiveness
and permanence among the on-Site alternatives, since organic
contaminants would be permanently removed from the source area
materials having high levels of organic contamination; it would
also effectively address inorganic contaminants. Unlike
Alternative 5, Alternative 4 has not been proven effective for
treatment of organic contaminants and relies on the containment
cell and the leachate collection system to prevent the leaching
of organic contaminants into the groundwater; Alternative 4 does,
however,.effectively address inorganic contaminants over the
long-term. Alternative 3 does not include any treatment of
contaminants; the permanence of Alternative 3 would rely on the
continued maintenance of the cap and slurry cutoff wall, and the
operation and maintenance of the hydraulic control system.
Alternatives 1 and 2 would not provide any active treatment or
containment and therefore would not be effective over the long-
term or provide permanent protection of the groundwater
underlying the Site.
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Reduction in Toxicitv. Mobility, or Volume Through Treatment
To the extent that the materials disposed of off-site would be
treated prior to disposal, Alternative 6 would provide a
reduction in mobility, toxicity, and volume of the organic and
inorganic chemical contaminants present at the Site. Alternative
5 would significantly reduce the mobility, toxicity, and volume
of organic contaminants in the source areas having high levels of
organic contamination by permanently removing the organics from
these materials. Alternative 5 would provide a reduction in the
mobility of the inorganic contaminants through stabilization/
solidification of the source area materials failing TCLP and
placement of all source area materials in a lined containment
cell with a leachate collection system. Alternative 4 would
provide a reduction in the mobility of the organic and inorganic
contaminants present in the source area materials through
stabilization/solidification of the materials and placement of
the solidified materials in a lined containment cell with a
leachate collection system. However, as noted previously, the
long-term effectiveness of stabilization/solidification for
immobilizing organic contaminants has not been demonstrated.
Alternative 3 would not provide a reduction in the toxicity or
volume of the organic and inorganic contaminants in the source
area materials; however, this alternative would reduce the
mobility of the chemical constituents through capping, installing
a slurry cut-off wall and pumping groundwater from within the
capped area. Alternatives 1 and 2 would provide no reduction in
contaminant mobility, toxicity, or volume.
Short-term Effectiveness
Alternatives 1 and 2 would- result in no additional risk to the
community or workers during implementation (0 months and six
months, respectively), since source area materials would not be
disturbed. Alternatives 3, 4, 5 and 6 would each require
approximately one year to implement and would include activities
such as excavation and handling of contaminated soils/sludges
that could result in short-term exposures to on-Site workers and
the community during implementation due to the generation' of
fugitive dust. Mitigation measures such as water sprays to
suppress dust would be implemented to control short-term
environmental impacts associated with off-Site dust migration.
Alternative 5 would also result in the potential exposure to on-
Site workers and the community to air emissions associated with
the ex-situ vapor extraction and bioslurry treatment systems.
The air emissions from these units would be controlled by
implementing air emission treatment systems and air emission
monitoring programs in accordance with Federal and State
regulations. Alternative 6 would also include activities such as
off-Site transport of contaminated soils/sludges that could
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result in potential exposure to the community. To reduce the
potential risks to the community and the environment resulting
from an accident during transportation, a traffic control plan
would be developed. '"
Implementability
All alternatives are technically feasible and could be
implemented at the Site. Alternatives 1 and 2 are the easiest to
implement, followed by Alternative 6. A treatability study would
be necessary to demonstrate that Alternative 4
(stabilization/solidification) is able to render the lagoon 7
material nonhazardous based on the characteristic of toxicity.
The nature of the materials, particularly the lagoon 7 materials,
may also pose some problems with the organic treatment options
specified under Alternative 5. Although additional treatability
studies are warranted to demonstrate the effectiveness of the
Alternative 5 treatment options, it is anticipated that each of
the options could effectively treat all.but the lagoon 7
materials. Lagoon 7 materials could be effectively treated with
a combination of technologies.
A combination of physical and chemical factors make the lagoon 7
materials highly problematic to treat: the materials have a high
clay and moisture content, and significant concentrations of both
volatile and semivolatile organic compounds. As a result,
problems are likely to arise with implementation of each of the
Alternative 5 processes, if utilized singly to address the lagoon
7 materials. While it is believed that lagoon 7 materials that
are processed through the LTTD could be treated to remedial
action objectives, treatability studies have indicated that some
commonly used LTTD units could experience materials handling
problems while processing the lagoon 7 materials; prior to
implementing LTTD, additional treatability studies would be
required to assure that such material handling problems could be
minimized. Ex-situ vapor extraction is likely to be effective in
handling the volatile fraction of .contaminants in the lagoon 7
materials; however, it would not likely be effective at treating
the semi-volatile fraction. Biosluirry, on the other hand, would
be expected to be effective in handling the semivolatile fraction
of the lagoon 7 materials. Therefore, it appears as though use
of ex-situ vapor extraction for treatment of volatiles, and
subsequent treatment of semivolatiles with bioslurry,' would be
the most implementable combination of treatment options under
Alternative 5; this combination would avoid the material handling
problems which would be expected to be encountered with LTTD.
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Cost
According to the present worth cost estimates for .all
alternatives evaluated, Alternative 6 ($32., 679,764) would be the
most costly alternative to implement, followed by Alternative 5
($8,535,000) . The present worth cost for Alternatives 4 and 3
would be about the same ($5,794,983 and $5,560,128,
respectively). Alternatives 2 and 1 would be the least costly to
implement ($328,660 and $0, respectively). Present worth
considers a 5% discount rate, and a 30-year operational period
for Alternatives 2, 3, 4 and 5. Since Alternatives. 6 arid 1 do
not require any O & M costs, their present worth costs are
equivalent to their capital cost.
State Acceptance
The State of New York, through the NYSDEC, concurs with EPA's
selected remedy. The NYSDEC's letter of concurrence is in
Appendix IV.
Community Acceptance
The Proposed Plan indicated that EPA's preferred alternative was
Alternative 5 with the LTTD treatment option. A number of
commenters voiced their opposition to any on-Site treatment which
consisted of combustion of contaminants and subsequent emission
of any quantity of hazardous materials. The residents were
concerned that some of the potential LTTD units were in effect
incinerators. The community preferred that the materials be
excavated and transported off-Site for treatment and/or disposal
(i.e., Alternative 6). However, EPA received a letter from the
Deerpark Environmental Commission stating that "...all things
considered, Alternative 5 is the best one." Other commenters,
notably some of the PRPs for the Site, indicated their preference
for on-Site treatment so long as the organics treatment process
incorporated the bioslurry and vapor extraction treatment
options, rather than LTTD. These and other comments and concerns
received from the community during the public comment period are
identified and addressed in the Responsiveness Summary which is
attached as Appendix.V to this document.
SELECTED REMEDY
Based upon consideration of the requirements of CERCLA, the
detailed analysis of the alternatives, and public comment, EPA
and NYSDEC have determined that Alternative 5 (excluding the LTTD
option), which calls for remediation- of the contaminated source
area materials via stabilization/solidification of inorganics and
ex-situ vapor extraction and bioslurry of organics, is the
appropriate remedy for the first operable unit of the Carroll and
Dubies Superfund Site. It is important to highlight that
materials from lagoons 1, 3- and 8 (approximately 10,100 cy) which
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contain high concentrations of organic contaminants would be
treated via ex-situ vapor extraction, while the lagoon 7
materials (approximately 3,400 cy of highly contaminated
materials) will be treated via ex-situ vapor extraction
(treatment primarily targeted at the volatile organic fraction of
organics) followed by bioslurry (treatment targeted at the
.semivolatile fraction of organics). LTTD has been specifically
excluded from the selected remedy due to potential implementation
problems, significant cost, and public (including responsible
party) opposition.
The selected remedy permanently removes organic contaminants from
source area materials and reduces the mobility of inorganic
contaminants through stabilization/solidification and placement
of source area materials in a.lined containment cell constructed
on-Site. Alternative 5 ensures that no leaching of contaminants
to the underlying aquifer will occur. The elimination of cross-
media impacts will have a positive impact on the effectiveness of.
any future groundwater restoration program that could be
implemented at the Site.
Aside from Alternative 6, Alternative 5 is the only alternative
that permanently removes the significant levels of organic
contaminants from the source area. However, Alternative 6 is
over three times the cost of Alternative 5 and will not comply
with the statutory preference for treatment as. a principal
element, if the materials are not treated prior to disposal. The
other proposed alternatives which cost much less than the
preferred alternative do not permanently remove contaminants from
the source area materials. The preferred alternative will
provide the best balance of trade-offs among alternatives with
respect to the evaluating criteria. EPA and NYSDEC believe that
the preferred alternative will be protective of human health and
the environment, comply with ARARs, be cost effective, and
utilize permanent solutions and alternative treatment
technologies or resource recovery technologies to the maximum
extent practicable. The remedy also will meet the statutory
preference for the use of treatment as a principal element.
The major components of the selected remedy include:
o Excavation of all materials from lagoons 1, 2, 3, 4, 6, 7
and 8, as well as the soils in the vicinity of those
lagoons, which exceed the excavation levels specified in the
Selected Remedy section of the Decision Summary.. EPA's
current estimate of the volume of the materials requiring
excavation is approximately 20,300 cubic yards (cy) .
However,.the actual volume will be further determined during
the implementation of the remedy.
o Treatment of excavated soil/sludges which contain organic
constituents above the treatment levels specified in the
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Selected Remedy Section of the Decision Summary (estimated
at 13,800 cy) via on-Site ex-situ vapor extraction.
o Additional treatment of lagoon 7 soils/sludge's (estimated
at 3,400 cy) via on-Site ex-situ bioslurry (treatment
targeted primarily for semi-volatile contaminants).
o Stabilization/solidification of soils/sludges which fail
the Resource Conservation and Recovery Act's TCLP for
inorganic constituents (estimated at 5,700 cy) .
o . Placement of treated and untreated soils/sludges in a
lined and capped cell consistent with modified requirements
of New York Code of Rules and Regulations Part 360. The
base of the cell will consist of a high density polyethylene
(HDPE) liner and a sand drainage layer. The cell will be
sloped to a leachate collection system. The cap will
consist of a .low-permeability clay layer, an HOPE membrane,
a sand drainage layer and a topsoil cover layer.
o Development of an air-monitoring system and installation
of air pollution control equipment to ensure compliance with
air pollution control regulations; and
o Recommendations that deed and well restrictions be
'. imposed to protect the integrity of the cap.
Although the use of the bioslurry process to treat lagoon 7
materials appears to be promising, further treatability studies
are necessary to demonstrate that this process can reduce the
complex mix of constituents in lagoon.7 to remediation goals.
Because of the existing uncertainty, a contingency remedy will be
implemented if treatability study results indicate that bioslurry
in combination with ex-situ vapor extraction will not be
effective in reducing the levels of contaminants in lagoon 7
materials, particularly semi-volatile contaminants, to
remediation goals. . The maj.or components of the contingency
remedy are identical to those of the selected remedy with the
following exception:
Excavation and off-Site treatment (as necessary) and
disposal of lagoon 7 materials at a RCRA (Subtitle C)
permitted treatment, storage and disposal facility; it is
assumed that thermal treatment, i.e., incineration or low
temperature thermal treatment, will be necessary to reduce
the contaminants to appropriate LDR levels.
Off-Site thermal treatment was selected as the contingency remedy
rather than on-Site LTTD, due to implementability concerns, as
well as community and responsible party opposition to treatment
of these or other materials on-Site with a thermal treatment
unit. Although the cost estimate for treating these materials
24
-------
off-Site appears to be much higher than on-Site treatment with
LTTD (approx. $5.7M vs $3.2M), the off-Site cost estimate was
very conservative, and assumed that all lagoon 7 materials would
require incineration. If the materials were treated off -Site via
LTTD or other means, the cost could be similar to or less than
that for on-Site treatment with LTTD. This similarity in costs
results from the significant costs ($1.6M) solely related to
mobilizing a LTTD unit to the Site.
Remediation Goals
Two types of remediation criteria have been established. The
first criterion delineates the source area materials that require
excavation for treatment and/or containment . The second
criterion determines the cleanup level for the excavated source
area materials; those materials above the cleanup level will
require treatment .
All lagoon materials are to be excavated for treatment and/or
placement into an on-site containment cell. The NYSDEC TAGM soil
cleanup levels for organic compounds were utilized to derive
excavation levels that will be used to determine the volume of
soils impacted by the lagoon materials which will also require
excavation for treatment and/or containment. The TAGM soil
cleanup' levels are objectives which were established by NYSDEC
and are conservatively set at concentrations that are protective
of human health and groundwater quality. Therefore, contaminants
of concern (COCs) were selected for comparison to the NYSDEC TAGM
levels based on: their mobility (propensity to migrate from the
soil to the groundwater); their frequency of detection in the
soil and in the groundwater, and their concentration level. The
organic indicator COCs and their excavation levels are as
follows :
Indicator COCs .
Benzene
1, 2-Dichlorobenzene
1,4-Dichlorobenzene
Di-n-butylphthalate
Naphthalene
Tetrachloroethene
Toluene
Trichloroethene
Excavation Level (ppm)
0.06*
7.9
6.0
8.1
13.0
1.4
1 . 5
1 . 0
"The practicality of excavating to this level will be
evaluated upon obtaining additional environmental data
during the remedial design.
25
-------
All excavated source area materials will be placed into an on-
site containment cell which will further mitigate the leaching of
contaminants to the underlying groundwater. Source area
materials containing contaminants which exceed the treatment
levels will be treated prior to placement in the on-site
containment cell. The NYSDEC TAGM levels and the RCRA-universal
treatment standard (UTS), were utilized to derive treatment
levels for the organic indicator COCs. The UTS were recently
promulgated (September 19, 1994) under the RCRA LDRs. program for
listed wastes, as well as for those materials (including soil and
debris) containing organic constituents at levels which a 'waste
is considered hazardous based on the characteristic of toxicity,
i.e., those identified with the RCRA codes D010 through D043
based on TCLP (organic TCLP constituents). The UTS for TCLP
constituents are considered to be applicable treatment standards
for characteristic wastes present at the site. The least
stringent TAGM or.UTS number was utilized as the treatment level
for those organic indicator COCs which are not TCLP constituents.
The treatment levels for the organic compounds are as following:
Indicator COCs Soil Treatment Levels (ppm)
Benzene 10.0
1,2-Dichlorobenzene 7.9
1,4-Dichlorobenzene 6.0
Di-n-butylphthalate . 28.0
Naphthalene 13.0
Tetrachloroethene 6.0
Toluene 10.0
Trichloroethene 6.0
Additional indicator COCs may be added to this list at the
conclusion of the bioslurry treatability study, if the study
indicates that significant levels of degradation products are
generated during the biodegradation of the lagoon 7 materials.
Additionally^ if treatability study data indicate that bioslurry
combined with ex-situ vapor extraction will not effectively treat
lagoon 7 materials, the contingency remedy will be implemented;
under this scenario, the lagoon 7 materials would be excavated
and treated off-Site via a specific technology or to treatment
levels specified by the LDRs.
For the inorganic contaminants, the highest level of indicator
contaminants detected in the background soil samples collected
from the Site will be utilized to determine the extent of
excavation. Chromium and nickel are being used as indicator
chemicals. The highest levels of chromium and nickel detected in
background samples were 61.9 ppm and 36.7 ppm, respectively.
Lagoons 6 and 8 and any other excavated materials which fail the
RCRA^-TCLP levels for inorganic constituents will require
stabilization/solidification. Stabilized/solidified- materials
-------
will be subject to. further TCLP testing prior to placement in the
lined cell to ensure that the treated material no longer exceeds
the RCRA-regulated TCLP levels (e.g., 5.0 ppm for chromium and
for lead). In addition, materials treated to reduce the leachate
concentration are required to have an unconfined compressive
strength of at least 3,500 pounds per square foot as determined
by ASTM D-21^6.
The estimated amount of source area material that would be
excavated for treatment and/or containment is 20,300 cy. The
breakdown of the 20,300 cy by lagoon is as follows: 2,600 cy from
lagoon 1; 3,950 cy from lagoon 2; 2,300 cy from lagoon 3; 2,310
cy from lagoon 4; 520 cy from lagoon 6; 3,420 cy from lagoon 7;
and 5,200 cy from lagoon 8. This estimate will be refined during
the soil sampling to be conducted during the implementation of
the. remedy.
STATUTORY DETERMINATIONS
Under its legal authorities, EPA's primary responsibility at
Superfund sites is to undertake remedial actions that are
protective of human health and the environment. In addition,
Section 121 of CERCLA establishes several other statutory
requirements and preferences. These specify that when complete,
the selected remedial action for the Site must comply with
applicable or relevant and appropriate environmental standards
established under federal and state environmental laws unless a
statutory waiver is justified. The selected remedy also must be
cost-effective and utilize permanent solutions and alternative
treatment technologies or resource-recovery technologies to the
maximum extent practicable. Finally, the statute includes a
preference for remedies that employ treatment that permanently
and significantly reduces the volume, toxicity, or mobility of
hazardous substances. The following sections discuss how the
selected remedy meets these statutory requirements.
Protection of Human Health and the Environment
Alternative 5 and the contingency remedy are considered to be
fully responsive to this criterion and to the identified remedial
response objectives. The selected remedy and contingency remedy
protect human health and the environment through the treatment of
the more highly concentrated organic contaminants in the source
area materials, the immobilization of the more highly
concentrated inorganic contaminants and the placement of source
area materials into a lined containment cell with a multi-layered
cap and a leachate collection system.
27
-------
Compliance with ARARs
Alternative 5 and the contingency remedy will comply with all the
chemical-, action-, and location-specific ARARs. Chemical
specific ARARs are usually health- or risk-based numerical values
used to determine acceptable concentrations of chemicals that may
be found in or discharged to the environment (e.g., maximum
contaminant levels (MCLs) that establish safe levels of
contaminants in drinking water); location-specific ARARs restrict
actions or contaminant concentrations in certain environmentally
sensitive areas .(e.g., floodplains and wetlands); action-specific
ARARS are usually technology- or activity-based requirements or
limitations on actions or conditions involving specific
substances (e.g., RCRA standards applicable to generators of
hazardous waste). The specific ARARs for the selected remedy and
contingency remedy are the same and are listed below.
Action-specific ARARs:
* CAA-National Ambient Air Quality Standards (40 CFR 1-99)
* CAA-Prevent ion of Significant Deterioration of Air
Quality (40 CFR 51.2)
* CAA-New Source Performance Standards (40 CFR 60)
* CAA-National Emission Standards for Hazardous Air
Pollutants (40 CFR 61)
* DOT-Rules for Transportation of Hazardous Materials
(49 CFR Parts 107, 171.1-172.558)
* New York State Air Resources Regulations - General
Provisions (6 NYCRR Part 200)
* New York Emissions Testing, Sampling, and Analytical
Determinations (6 NYCRR Part 202)
* New York General Prohibitions (6 NYCRR Part 211)
* New York Regulations for General Process Emission Sources
(6 NYCRR Part 212)
* New York Air Quality Classification System (6 NYCRR Part
256)
* New York Air Quality Standards (6 NYCRR Part 257)
* New York Air Quality Area Classifications - Orange County
(6 NYCRR Part 293)
* Solid Waste Management Facilities (6 NYCRR Part 360)
28
-------
* Waste Transporter Permits (6 NYCRR Part 364)
* New York Hazardous Waste Management System. (6 NYCRR Part
370)
* Identification and Listing of Hazardous Wastes (6 NYCRR
Part 371)
* Hazardous Waste Manifest System and Related Standards for
Generators, Transporters, and Facilities
(6 NYCRR Part 372)
* Final Status Standards for Owners and Operators of
Hazardous Waste Treatment, Storage,, and Disposal
Facilities (6 .NYCRR Part 373)
* Land Disposal Restrictions (6 NYCRR Part 376)
* NYSDEC Water Quality Regulations for Surface Waters and
Groundwater (6 NYCRR Part 700-705)
* OSHA-General Industry Standards (29 CFR 1910)
* OSHA-Safety and Health Standards (29 CFR 1926)
* OSHA-Recordkeeping, Reporting, and Related Regulations
(29 CFR 1904) .
* RCRA Section 3003-Standards Applicable to Transporters of
Applicable Hazardous Wastes (40 CFR 170 to 179, 40 CFR
262 and 263)
* RCRA-Standards Applicable to Generators of Hazardous
Waste (40 CFR 262)
* RCRA-Standards for Owners and Operators of Hazardous
.Waste Treatment, Storage, and Disposal Facilities (40 CFR
264)
* RCRA-Organic Air Emissions Standards for Process Vents
and Equipment Leaks (40 CFR 264, Subparts AA and BB)
* RCRA-Miscellaneous Units (40 CFR 264, Subpart X)
* RCRA-Surface Impoundments, Waste Piles, Landfills and
Land Treatment Units (40 CFR 264)
* RCRA-Preparedness and Prevention (40 CFR 264.30-264.31)
* RCRA-Contingency Plan and Emergency Procedures (40 CFR
264.50-264.56)
29
-------
* RCRA-General Standards (40 CFR 264.111)
* RCRA-Closure and Post-Closure (40 CFR 264.110-264.120)
* RCRA-Land Disposal Restrictions (40 CFR 268)
* RCRA-Identification and Listing of Hazardous Wastes
(6 NYCRR Part 371)
Chemical-Specific ARARs
* CAA-National Ambient Air Quality Standards (40 CFR 1-99)
* CAA-Prevention of Significant Deterioration of Air
Quality (40 CFR 51.2)
* CAA-New Source Performance Standards .(40 CFR 60)
* CAA-National Emission Standards for Hazardous Air
Pollutants (40 CFR 61)
* New York Emissions Testing, Sampling, and Analytical
Determinations (6 NYCRR Part 202)
* New York General Prohibitions (6 NYCRR Part 211)
* New York Regulations for General Process Emission Sources.
(6 NYCRR Part 212)
* New York Air Quality Classification System (6 NYCRR Part
256)
* New York Air Quality Standards (6 NYCRR Part 257)
* New York Air Quality Area Classifications - Orange County
(6 NYCRR Part 293)
* RCRA-Regulated Levels for Toxic Characteristics Leaching
Procedure Constituents (40 CFR 261)
* RCRA-Land Disposal Restrictions (40 CFR 268)
Location-Specific ARARs
* Clean Water Act (Section 404, 33 USC 1344)
* Fish and Wildlife Coordination Act (16 USC 661)
* National Historic Preservation Act (16 USC 470)
30
-------
Other Criteria, Advisories, or Guidance To Be Considered
* Executive Order 11990 - Protection of Wetlands
* Executive Order 11988 (Floodplain Management)
* NYSDEC Technical and Operations Guidance Series (TOGS)
* NYSDEC Technical and Administration Guidance Memoranda
(TAGMs)
* NYSDEC Air Guide 1 - Guideline for the Control of Toxic
Ambient Air Contaminants
Cost-Effectiveness
The selected remedy and contingency remedy provide overall
effectiveness proportional to cost. The estimated present worth
cost of the selected remedy is $8,535,000, which represents
capital and present worth 0 & M costs of $8,105,000 and $430,000,
respectively. A detailed estimate of the cost of the selected
remedy is provided in Table 9. The estimated present worth cost
of the contingency remedy is $14,194,600, which represents
capital and present worth O & M costs of $13,764,600 and $430,000
respectively. A detailed estimate of the cost of the contingency
remedy is presented in Table.10.
Utilization of Permanent Solutions and Alternative Treatment
Technologies to the Maximum Extent Practicable
EPA and NYSDEC have determined that the selected remedy, followed
by the contingency remedy, represents the maximum extent to which
permanent solutions and treatment technologies can be utilized in
a cost-effective manner for the source control operable unit at
the Site. Of those alternatives that are protective of human
health and the environment, EPA and NYSDEC have determined that
this selected remedy, followed by the contingency remedy,
provides the best balance of tradeoffs in terms of long-term
effectiveness and permanence, reduction in toxicity, mobility or
volume achieved through treatment, short-term effectiveness,
implementability, and cost, also considering the statutory
preference for- treatment as a principal element and considering
state and community acceptance.
31
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Preference for Treatment as a Principal Element
The selected remedy and the contingency remedy address the
principal threats posed by the Site lagoon sludges and soils by
achieving significant reductions in the- concentration of organic
contaminants and by stabilizing/solidifying the inorganic
contaminants. Therefore, the statutory preference for remedies
that employ treatment as a principal element is satisfied.
DOCUMENTATION OF SIGNIFICANT CHANGES
The preferred alternative presented in the Proposed Plan was
modified to reflect the change in emphasis on the likely type of
process to treat organic contaminants; this change was warranted
by additional information that was presented during and
subsequent to the August 23, 1994 public meeting. The Proposed
Plan and other information disseminated at the public meeting
indicated that one or a mixture of three different processes
might be used to treat organic contaminants under Alternative 5.
At that time, the emphasis was placed on the use of LTTD as the
likely treatment process with the option for vapor extraction or
bioslurry to be used in place of, or in combination with, LTTD.
As detailed in the Responsiveness Summary, significant public
comment was received during the comment period which opposed the
use of any type of on-Site thermal treatment. Other comments
.were received indicating that vapor extraction and bioslurry
could be used effectively and at considerably less cost than
LTTD.
Additionally, some preliminary Site-specific treatability study
data indicated that treatment of lagoons 1, 3, and 8 via ex-situ
vapor extraction, and treatment of lagoon 7 materials via ex-situ
vapor extraction (primarily targeted for volatile organic
contaminants) and bioslurry (primarily targeted at semivolatile
organic compounds) could be effective. Therefore, Alternative 5
was modified to reflect the use of bioslurry and vapor extraction
to treat the materials significantly contaminated with organic
compounds. In addition, Alternative 5 was further modified to
specifically exclude LTTD from the selected remedy due to
potential implementation problems, significant cost, and public
(including responsible party) opposition.
Due to the uncertainty regarding the ability of any on-Site
treatment process (excluding high temperature incineration) to
effectively treat the lagoon 7 materials, excavation with off-
Site treatment (as necessary) and. disposal is being selected as a
contingency remedy for these materials. This component of the
contingency remedy was adapted from Alternative 6. Under the
contingency remedy, as in Alternative 6, it was assumed that the
lagoon 7 materials would need to be treated via incineration,
although other means of less costly treatment (if necessary)
could be utilized in order -to satisfy LDRs.
32
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APPENDIX I
FIGURES
-------
FIGURES
Figure 1 - Site Location Map
Figure 2 - Sample Location Map
Figure 3 - Groundwater Monitoring Well Location Map
-------
FIGURE
CARROLL AND DUBIES SITE
PORT JERV1S, NEW YORK
SITE LOCATION MAP
2000
SOURCE: USGS 71/2 MIN.TOPOGRAPHIC QUAD.
PORT JERVIS NORTH, HY-PA 1969.
8LASLANO & 80UCX ENGINEERS, P.C.
J
-------
LANDFILL
LCCEHQ
MCMrORMO VCU'M GLACUL OUTWASH
UOMronW HCU.-IN OAOAL 1U
iMMTORmo «OJ. M ounusViu.
HOMTORiNO »m. IN eottocx
COHBORtra
SCR. BOUND (1103)
ttDIUtNt SMVUNO IOCAITOH
Km. OA3 SAUPUNO IOCAHON
SHOCK mwr (ron SOSMIC sumcr)
ACCCSS PONT SOL SAUPU
NTDIWUICM SAWU
OJCVA1MNS BASED ON NAIUNAI. \CflHCAl. DATUM
»»ioe\«iecimii.»»
ORAPMC SCAU - in
90 0
"II"'""
,00
V ww MM suit fBUCAnoN IA«
In chorgo ot_
Doslgned by_
Drown by
ChacKad by_
CARROLL AND DUBIES SITE
PORT JERVIS. NEW YORK
SAMPLE LOCATION MAP
810.06
o«u
NOVEMBER 1993
FIGURE
2
-------
M01t» UVAlmS IUO> W NMCMN. VCTHO* MWH
MUB.
In charge ot
l«n«d bjr
Drcwn by.
Chidm) by
LAHAND. BOUCK UE. tHC.
CARROU. AND DUBIES SHE
PORT JERV1& NEW YORK
GROUND-WATER MONITORING WELL
LOCATION MAP
810.06
JANUARY 1904
FIGURE
3
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APPENDIX II
TABLES
-------
TABLES
Table 1 - Concentration Averages and Ranges for Lagoons 1-4, 6,
7, and 8 - Inorganics
Table 2 - Concentration Averages and Ranges for Lagoons 1-4, 6,
7, and 8 - Volatile Organics, Semi-Volatile Organics,'
PCBs, and Pesticides
Table 3 - Summary of Chemicals of Concern in Soils\Sludges
Table 4 - Summary of Exposure Pathways
Table 5 - Available Toxicity Criteria for the Carcinogenic
Chemicals of Interest
Table 6 - Summary of .Cancer Risks
Table 7 - Available Toxicity Criteria for the Noncarcinogenic
Chemicals of Interest
Table 8 - Summary of Hazard Indices
Table 9 - Detailed Cost Estimate for Selected Remedy: Ex-situ
Vapor Extraction, Bioslurry Treatment, Stabilization, and On-Site
Containment
Table 10 - Detailed Cost Estimate for Contingency Remedy: Off-
Site Incineration of Lagoon 7 Materials, Ex-Situ Vapor
Extraction, Stabilization, and On-Site Containment
-------
TABLE 1
CARROLL &DUBIES SITE
POHT JEJM3, NEW YORK
CONCENTRATION AVERAGES AND RANGES FOB LAGOONS 1-4.6. 7. AND 8 - INORGANICS
InofQdraQ
Aluminum
Antimony
Aitenio
Barium
Baryfllum
Cadmium
Calehm
Chromium
Coban
Copper
bon
Uad
Magnesium
Manganese
Mercury
Nk**l
Polattium
Selenium
SOvtr
Sodium
Thallium . ' -
Vanadium
Zno
Cyankto
Lagoon 1
Concentration
Range1
5,600-14,100
<11.2-I6.3'
3.8-7.3
10.8-1,290
<0,234.88
<0.8-t6.8
137-14.400
7.1-113
6.1-11.0
It. 3- 1,490
395-29,200
6.9-1.400
1,710-3.830 .
150-472
<0.1Z-7.2
<9.1-368
< 193-1, 490
-------
TABl£ 1
(Continued)
CARROU. & DUB1ES SITE
PORT JERVB. NEW YORK
CONCENTRATION AVERAGES AND RANGES FOR LAGOONS 1-4.6. 7. AND 8 - INORGANICS
horgarso
Aluminum
Antimony
Arsenic
Barium
Beiyffium
Cadmium
CaWum
Chromhm
Cobafl
Copper .
kon
Lead
Magnesium
Manganese
Mercury
Nickel
Potassium
Selenium
Sttvei
Sodun
ThaUum
Vanadium
Zinc
Cyanide
Lagoon 0
Concentration
Rang,'
5.160-9.620
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TABLE 2
CARROLL & CUBES SITE
POm JERVIS, NEW YORK
COHCENTUATION AVERAGES AND RANGES FOR LAGOONS 1-4. 6. 7. AND 6 - VOLATILE ORBAHICS. SEM-VOLA1ILE ORGANICS. PC8S. AND PESTODCS
PHrametat
VbtaSe Ctganka
Vinyl CNorl*
Melhyfone Chloride
Acetone
Cuban DioJRdt
1,1-OlcHofMlhene
l.t-Diehtoroiilhinf
1,2-Dichloroathene (total)
Chloroform
2-BuUnona
1.1.1-TricNoroelnane
Irichloroethent
1,1,2-Trlchlotoethane
Benzene
4-Methyt-2-P«ntanone
2-H«xanone
TettaeNoioethana
Toluane
Chloiotwrutna
Ethytbenzene
Lagoon 1
Coma nil aBoo
Rang«'
Aveiaga
Conoontfatfofr
lagoon 2
Ctxnenbation
Ranga1
Average
Conoentialian*
LsgoonS
Concentration
Range'
Avnage
Conoonbaliurr
<0,011-
OMedrve*
<00lt-<0.058
0.007-
-------
TABIH 2
(ConbnuBcQ
CARROLL &DUBIES SITE
PORT JERVIS. NEW YORK
CONCENTRATION AVERAGES AND RANGES FOR LAGOONS 1-4.6. T. AND 8 - VOLATHE ORGANIC3. SEM-VDLATIU- OBGANIC3. PCO3. AND PESTtOOES
Paiametet
Total Xylena*
Seml-VolalflaClnjaric.
r»-jnrJ
rnonoi
1.3-DicWo(oberucn»
^^
t ,2-Dichlorobenzena
2-Melhylpnenool
2£-Oxybii(t-cNoiopropane)
4-Melhytphtnol
Nitrobenzene
ItophoionB
1 ,2.4-Trichlorobenzene
Naphthalene
4-CHoroanHina
S-MelhytnaphthBlene
2-CHoronaphthalent
Acenaphlhyl«na
Aeenaphlhena
Dbenzolutan
Lagoon 1
ConoenbaBon
Ranga1
0.021-<8.3*
0.014-0.3*
0.01-<8.3*
0.01
4.18
18.37
67.64
<0.01
<0.37-<0.4B
<0.37-<0.49
<0.37-<0.4B
<0.37-<0.49
0.064-<0.39*
<0.37-<0.4B
0.1-0.78
0.013-0.016*
<0.37-<0.4B
<0.37-<0.49
0.0t8-<0.39*
<0.37-<049
Avmaga
Conoonbabou
0.0058
<0.20
0.16
0.20
0.25
<0.20
<0.20
<0.20
<0.20
<0.20
0.16
<0.20
0.32
0.10
<0.20
<0.20
0.15
<0.20
TAGMOanip
(Xiedh**
1.2
0.03
1.6
8.5
7.9
0.1
NA
0.9
0.2
NA
3.4
13.0
0.22
36.4
NA
41.0
90.0
6.2
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TABUE 2
(Conbu>4
CARROU*. CUBES sire
PORT JDMS. NEW YORK
OONCENIBATK3N AVERAGES AND RANGES FOB LAGOONS 1-4.6.7. AND 8 - VOLATILE ORGANICS. SEMI-VOLATHE ORGANICS. PC83. AND PESTICIDES
PwanwM
2,4-Diribololuam
Diettiytphthalali
4-CNoiophenyl-phenylalher
Fhntana
N-NibDKxfphenytamln* (1) .
Phananlhiana
AnttMcani
Caibareto
Q-n-butylphlhalata
Fluotanlhem
Pyiane
Butyttxnzytphlhalata
3.3'-DicNorabenzidna
Beiuo(a)anlhfacana .
Chryune
bic(2-ElhyDwxyl)ptilhalala
Di-n-odylphlhBlata
GenzofbJIIuoianlhana
Benio(k)lluo)anlhen«
lagoon 1
ConoonUattan
Banga'
<0.37-<8.3
<0.37-<8.3
<0.37-<8.3
<0.37-<8.3
<0.37-<8.3
0.021-22.0
0.025-5.0
0.003-7.5
0.009-48.0
0.037-21.0
0.037-28.0
0.18-0.98'
<0.37-<8.3
0.08-8.8
0.11-10.0
0.048-130
0.054-0.36'
<0.37-6.5
<0.37-5.0
Aveiaga
Concei*allot^
<0.9I
<0.37-<0.49
<0.37-<0.49
<0.37-<0.49
0.12-<0.39*
0.015-<0.39*
<0.37-<0.49
0.047-0.29
0.07-<0.39*
0.24-<0.3B*
<0.37-<0.4B
<0.37-<0.49
<0.37-<0.49
<0.37-<0.49
0.033-0.034'
<0.37-<0.49
<0.37-<0.49
<0.37-<0.4B
Avoiaga
Conoentiotion'
<0.20
0.15
<0.20
<0.20
<0.20
0.17
0.15
<0.20
0.18
0.16
0.20
<0.20
<0.20
<0.20
<0.20
0.14
<0.20
<020
<0.20
TAGMOearafi
Gtioclna*
NA
7.1
NA
350.0
NA
220.0
700.00
NA
6.1
1.9000
665.0
122.0
0.014
3.0
0.4
435.0
120.00
1.1
1.1
-------
TABLE 2
(Oonttnuao)
CARROLL &DUHESSTE
PORT JERMS. NEW YORK
CONCENTRATION AVERAGES AND RANGES KOR LAGOONS 1-4.6.7. AND 8 VOLATILE ORBANICS. SEMI-VOLATltE ORGANICa PCB3. AND PESTICIDES
Paiametar
Benzo(a)pyiana
lndeno(t.2,3-ed)pyitn«
Benzo(g.h,l)peiylana
Lagoon 1
t*imnmi Jialtnii
\AM UW Bl WWII
Rang"1
0.29-4.2
<0.37-<8.3
<0.37-<8.3
Avaag,
Cbnd&nb&fiofr
090
<0.8I
-DDD
EndocUlan SUIala
4.4-DOT
EndrlnAMehyda
Atpha-CHoidani
Gonma-CHoidan*
Aioclo(-t248
Atodor-1254
<0.0037-<0.77
<0.0037-<0.77
<0.0037-<0.77
-------
TAKE 2
(CortinuBcO
CARROLL &LXIHESSfTE
PORT JERVB, NEW YORK
CONCENTRATION AVERAGES AND RANGES FOB LAGOONS 1-4. 6.7. AND 6 VOLATILE ORGA
Parameter
A/ockx-1260
Lagoon 1
Concentration
R»«.'
<0.037-<1.5
Average
Concentration*
<0.17
Lagoon 2
Concentration
Range'
<0.035-<1.4
Average
Concentration*
<0.20
Lagoon 3
OoncentiaSon
Range1
<0.035-<0.045
Avoago
ConcentraBon1
<002
Lagoon 4
Ooncenliallon
Rang.'
<0 038-0 055
Average
Concentration*
0.030
TAGMOoanup
Objective*
10.0
1.
2.
3.
4.
5.
6.
7.
a.
9.
The taw«i rang* value I* Ito lower ol either the lowed delected concentration or the toweM detection llmll observed. The upper range It limited to the highest detected concentration observed.
Sample recutl* reported at non-deled were Included In the determination ol average concentration! by using one-hall the detection Rrnlt lor each spedlic constituent.
TAGM cleanup objective - NYSOEC Technical and Administrative Guklence Memorandum fTAGM) No. 4046, November 16,10B2; recommended con cleanup objective to protect ground-water quality.
TAGM cleanup objective lor total PCBe In cubturlace tot. The TAGM cleanup objective lor PCBt In surface soil It 1.0 ppm.
The upper range value Is the highest delected concentration.
concentration but not In the determination ol the concentiaUon range.
The only delected concentration lor this data eel la the towed value ol the data eet. Non-dated values greater than this delected concentration exist end have been Included In the determlnaUon ol the concentration average and range.
Thlt table Includes dale coDeded lor only those samples located within the Imlla ol the source are* materials above cleanup levels lor each lagoon.
AD concentrationt ate reported In mgftg (ppm).
NA not vaBable.
ISST*
-------
TABLE 2
(Cootinueo)
CARROLL &DUBIES SITE
PORT JEIMS. NEW YORK
CONCENTRATION AVERAGES AND RANGES FOB LAGOONS M. 8. 7. AND 8 - VOLATILE ORGANICS. SUM-VOLATILE ORGANICS. PC83. AND PESTICIDES
Parameter
VolaBe Ctganlc*
Vinyl CHwIda
Melhytone Chloride
'Acetone
Cubon DisUBde
1.1-DicHoioethana
1,1-tXchkHwelham
1,2-Dichloio«thene (lolal)
Chtaolocm
2-Butanone
1,1.1-Titehloioethan*
TricHoroelhene
1.1,2-Tfichtofoelhane
Beniene
4-Melhyl-2-Penlinone
2-Hexanone
leUscHoioelhene
Tduen*
CWoioberuena
lagoon 6
ConoerbaHan
Range'
Avetaga
CofioeiitiabQn
.OIS*
<0.010-1.l*
<0.010-<120
<0.010-0.03B*
<0 010-0.54*
0.001-1.900
-------
TABLE 2
(Con&wad)
CMVKX1& DUDES StTE
PORT JEfMS. NEW YORK
CONCENTRATION AVERAGES AND RANGES FOH LAGOONS M. 6.7. AND 8 - VOLATILE OnSANICS. SEMI VOIAT1LE ORGANICS. PC83. AND PESTICIDES
Panvmlaf
Elhyftxniana
Total Xytonei
lagoon 6
OonocntaQoofi
Ranga1
0.008- <0.0 15*
<0 01 1-0.02
Avetaga
ConcenUatiorf
0.0064
0.0081
Lagoon 7
Conoanbalion
nanga'
<0 01 1-68'
0.002-310*
Aveiage
Coiccntialiorf
30.50
49.54
lagoon 8
Conoonbaton
Banfl.'
eni«na
Naphlhalerw
4-OHoiosniUne
2-Malhyfnaphttwtena
2-Chlmonaphlhaltna
Ac«naphthyien»
Acenaphlhene
<0.37-<3.1
0.034-0.1'
0.02-0.15'
0.29-0.1'
<0.37-<3.1
<0.37-<3.1
0.093-0.42*
0.14-O.1'
<0.37-<3.1
0.043-O.1*
0.055-0.16'
0.013-0.36'
0.038-0.110*
0.032-O.1*
0.12-0.67*
0.027-0.14*
<064
0.58
0.48
0.62
<0.64
<0.64
0.37
0.59
<0.64
0.58
0.31
0.39
0.30
0.58
0.27
0.36
<0.35-24.00
<0.35-<17.0
0.055-3.3*
0.35-9.1*
0.1-0.33'
<0.35-<17.0
0.073-0.33*
<0.35-.<17.0
0.033-4.7*
<0.35-<17.0
0.043-B10
<0.35-<17.0
0.033-610
0.059-270
0.041-0.054*
0.10-<17.0'
4.12
<2.2I
1.84
2.21
1.67
<2.2I
38.23
<2.21
1.93
<2.21
63.90
<2.21
61.98
20.49
1.50
M2
<0.34-<8.6
0.008-0.72
0.031-7.4
0.14-3.1
<0.34-<6.5
<0.34-<6.5
0.035^)051*
<0.34-<6.5
<0.34-<6.S
0.026-1.1*
0.014-3.0*
0.22-6.5
0.039-9.50
<0.34-<4.2
0.055-<4.Z*
0.071-1.8*
<0.75
0.21
0.93
0.62
<0.7S
<0.75
0.58
<0.75
<0.75
'0.55
0.83
0.99
1.71
<0.39
0.52
0.48
0.03
NA
NA
NA
0.1
NA
0.9
0.2
NA
NA
13.0
0.22
36.4
NA
41.0
90.0
-------
TABLE 2
(Continued)
CARROLL & CUBES are
PORT JEIMS. NEW YORK
CONCENTRATION AVERAGES AND RANGES FOR LAGOONS 1-4.6.7. AND 8 - VOLATILE ORGANICS. SEMI-VOLATILE ORGANICS. PC8S. AND PESTtdDeS
Paratnelet
Dbanzohjran
2.4-Oinlliololuent
Delhytphfhalala
4-CNofophenyl-phanyMhef
Flmxena
N.Nitiotodiphenytamlna (1)
Phananthreno
Anttvacena
Caibazole
D-n-butylphlhalale
Ruoranlhena
Pyiene
Butybenzytphlhalale
Benzo(a)anlhfacena
Chrysam
bls(2-Elhythexyt)phlhalal«
Di-ivoctylpnlhalala
Benzo(bjlhio)anthana.
lagoon 8
CancentraHon
Bangs'
0.062-O.461
<0.37-<3.1
0.011-0.38*
<0.37-<3.1
0.042-0.37*
<0.37-O.t
0.1 1-1 1.0
0.008-0.89*
0.008-0.88
0018-0.10*
0.088-12.0
0.11-8.9
0.014-0.10*
<0.37-<3.1
0.061-3.8
0.0854.5
<0.37-2.0*
0.024-0.083*
<0.37-4.4
Aveiaga
ConDenliation*
0.22
-------
TABLE 2
(Continued)
CARROLL &DUOES SHE
PORT JERVIS. NEW YORK
CONCENTRATION AVERAGES AND RANGES FOR 1AGOONS M. 6. 7. AND B VOLATILE ORGANICS. SEMI-VOLATILE OHGAN1CS. PCBS. AND PECTC1DE8
Parameter
Benzo(k)Ruotanlhane
6anzo(a)pytene
lndeno(l ,2,3-cd)pyi«ne
Benzo(B,h,l)peryten»
Lagoon 6
ConoenbaUon
Range1
<0.37-4.4
<0.37-3.9
<0.37-2.3
<0.37-3.1
Avetage
Coiicentmtion1
1.28
1.20
0.87
0.69
lagoon J
Concent aUoo
Bango"
<0.35-<17.0
<0.3S-<17.0
<0.35-<17.0
<0.35-<17.0
Avnage
CDnoenbalion*
<2.21
<22\
<^2I
<2.2I
Lagoon 8
Cbnoenbatton
nanga'
0.057-0.44'
0.14-0.35*
<0.34-<6.5
0.18-<4.2*
Aveiags
Conoanbafion*
0.53
0.54
<0.75
0.53
TAGMdcunup
Obfedh*'
1.1
11.0
3.2
800
^tesocicte^PCOB . *
alpha BHC
tala-BHC
gamma- BHC
Heplachlw
Endoeullan 1
Dieklrln
4.4'-DDE
4.4'-DDD
Endonjllan SUIalo
4,4'-OOT
EndrlnAktehyd*
Alpna-CHoidana
Gamma-CNotdane
Atoclw-1248
-------
TABLE 2
(Continued)
CARROU. & DUBES STE
PORT JBWIS. NEW YORK
CONCENTRATION AVERAGES AND RANGES FOR LAGOONS M. 6. 7. AND B-VOLATILE ORGANICS. SEM-VOIAT11E OOGANKS. PC8S. AND P6STK3DES
Ptvameler
Atodot-1254
AfOctOf-1260
Lagoon 6
GonoBntrafion
Range'
O.OI4-<0.74'
0.02S.<0.7«'
Average
Concentration
0.12
0.12
Lagoon/
Concentration
Range'
0.025- < 1.8*
<0036-0.65*
Avecaga
Oonoei iliaBon*
0.016
0.19
Lagoon 8
Concentration
Ranga1
<0.034-1.6
<0.034-0.13*
Aveiaga
Cunumtiatton
0.18
0.094
TAGM Cleanup
Objective*
10.0'
10.3*
teds*
1.
2.
3.
4.
S.
6.
7.
a.
9.
10.
II.
Thf lower range value It lha tower ol either lha lovnsl detected concentration or the (owed detection Until observed The upper range It limited to lha highest detected concentration obcerved.
Sample results reported at norvdetect wwt Included In lha determination ol average concentrations fay using one-hall the detection limit lor each cpedlic constituent.
TAGM cleanup objective - NYSOEC Technical and Administrative Guidance Memorandum (TAGM) No. 4046. November 16.1992; recommended soft cleanup objective to protect ground-water quality.
TAGM cleanup objective lot total PCBt In cubturiace col. The TAGM cleanup objective lor PCS* In curface coll Is t .0 ppm.
The upper range value li the highest detected concentration. Repotted laboratory detection Omit values gtealet lhan this highest delected concentration exists due to matrix Interferences or olhet teasons. and have been Included In the calculation ol lha averse
concentration but nol In the daletmlnallon ol-lhe concentration range.
The only delected conoenbalion tor this data set Is the lowest value ol (he data set. Notvdelecl values greater than this detected concentration exlel and have been Included In the determination ol the concentration average and tangs.
The detection DmU ol 900 ppm reported tot this constituent, which was not delected In the analysis ol sample T7-7 (2-4) was nol Inducted In the determination ol the concentration average and large.
TNs table Indudas data collected tot only (hose samples located within lha limits ol lha source area materials above cleanup levels lor each lagoon.
AD concentialions ate tepotted In rnoAg (ppm).
NA - nol avatlaH*.
-------
TABLE 3
CARROLL & DUBIES SUPERFUND SITE -
TOWN OF DEERPARK, NEW YORK
SUMMARY OF CHEMICALS OF CONCERN IN SOIL/SLUDGE
Volatiles
1,2-dichoroethene (total)
2-butanone
2-hexanone
4-methyl-2-pentanone
acetone
benzene
carbon disulfide.
chlorobenzene
ethylbenzene
methylene chloride
tetrachloroethene
toluene
trichloroethene
xylenes (total)
Semivolatiles :
1,2-dichlorobenzene
1,2,4 -trichlorobenzene
1,3-dichlorobenzene
1,4-dichlorobenzene
2-chloronaphthalene
2-methylnaphthalene
4-chloroaniline
4-methylphenol
acenaphthene.
anthracene
benz(a)anthracene
benzo(a)pyrene
benzo(b)fluoranthene
benzo(k)fluoranthene
bis(2-ethylhexyl)phthalate
butylbenzylphthalate
carbazole
chrysene
di-h-butylphthalate
di-n-octylphthalate
fluoranthene
fluorene
naphthalene
phenanthrene
phenol
pyrene
Inorganics
aluminum
antimony
arsenic
barium
beryllium
cadmium
chromium
cobalt
copper
cyanide
iron
lead
magnesium
manganese
mercury
nickel
selenium
silver
vanadium
zinc
Pesticides/PCBs
Aroclor 1254
-------
TABLE 4
CARROLL a DUBIES STE
POHTJERVIS. NEW YORK
SUMMARY OF EXPOSURE PATHWAYS
Pathway
ng cation
1
)ermal contact during
bathlrg.
Inhalation of uround water
contomlnanta during
showering. .,
t
SflUa
IncUentallngestlon
)ermal contact
Surface Sludaa
Ire (dental Ing esllon
Dermal contact
lima -Frame Evaluated :::;:r::-: ' 'Degree of A$scjssme
Receotor Present ;i"-% Futira ': ;.''":?: puant:V:'i"eJu^s'?:':
Resbent No Yes X
(Adult art) Child)
ResUent No Yes X
(Adult only)
Resbent No Yes X
(Adult only)
Trespasser Yes . Yes X
(Adult and Youth)
EwavaUon No Yes X
Worker
Trespasser Yes Yes X
(Adult and Youth)
Ewavatloh No Yes X
worker
Trespasser Yes Yes X
(Adult an) Youth)
Trespasser Yes Yes X
(Adult and Youth)
RatioMiotor SolscionorEmlustan :- :
Private wells exist In adjacent areas,
and although contamination las not
currently reached tiese wells, It may
In the future.
See Ingestlonpathway lor tils
medium.
Presence ol VCCs In
ground water.
Acces tt the die Is not eliminated,
and the) unk cars and open land
around the die may be an attraction
to adolescents
Construction arid eicavatlon activities
may occur In the luture
See Ingesllonpathway lor tils
medium and receptor.
See Ingostlonpathway lor Ills
medium and receptor.
Acces to the site Is not eliminated,
and the | unk cars and op en land
around the site may be an attraction
to adolescents.
See Ingesllonpathway
<:: ;-':'DatB"Evaiuaied .-.:''"' : ' "' .
Pending
Pending
Pending
Atton-sltesdl samples.
All on-slto sdl samples
All on-slte sdl samples.
All on - site sdl samples.
Surflclal slidge samples.
Surtfclal sludge samples.
-------
TA8l£ 4 (Contt)
P|}thwaY
Sibsuiface and surface
Sludafi..(£fi!(iiliifldL_
Incidental Ingestlon
Dermal ton lac 1
Laaaon 1 ehuidlm water
Dermal contact
All «.
nhalatlon ot Emlsskxawb
Partbulates (rom Soda
nhelatlon of emissions and
Partbulates horn Sludges '
RecfiBtQl
Excavation
woiker .
Excavation
woiker
Trespasser
(Adult and Youth)
Trespasser
(Jutland Youtr^
Excavation
woiker
Trespasser
(Adult and Youtf<
Excavation
woiker
PreseM FiAjta^.'' :::V:;::f::;:x:Quan»'H::;::-:'Dual':W Halkmala (or Seles ton or Exclusion . . Data Evaluated
No Yea X Construction and excavation activities All sludge samples.
may occur In the Mure.
No Yes X . See Ingestlonpathway for tils All sludge samples.
medium.
Yea Yes X Access to Ugoon 1 1s not eliminated and Lagoon 1 standing water sample and Hsdiplbate.
may be an attraction to adolescents especially.
Yes Yes X Dry soUcondllons end winds couW All son samples.
generate dusto.
No Yea X Dry soil conditions, winds, aid used . All soil tamples.
' heavy machinery and vehicles couU
generatedusb.
Yes Yes X Dry dudge conditions and wlrds could SullclalBluige samples.
generate dusts.
No ' Yes X Dry sludge conditions, winds, find use ol All sludge samples.
heavy machinery aid vohfckis couW
genucitedustt.
-------
TABLE 5
CARROLL & OUBIES
PORT JERVIS. NEW YORK
AVAILABLE TOXICITY CRITERIA FOR THE CARCINOGENIC CHEMICALS OF INTEREST
Chemical
VOLATILES
riethylene chloride
ienzene
'etrachloroethene
Trichloroathene
SEMIVOLATILES
1 ,4-OtohlorobenzBne
Bis(2-etnylnexyf)phtnalata
Carbazole
n Nctrosodiphenytamine
3enzo(a)pyrene
JenzD (a) anthracene
Benzo(b)rluoranthene
Benzo(k)fluoranthene
Chrysena
PCS*
ArodoM2S4
INORGANICS
Arsenic
Beryllium
Cadmium
Chromium (VI)
Nickel
subsutfide
refinery dust
Slope
Factor
1 /(mo/ko/davt
0.0075
0.029
0.051
0.011
0.024
0.0t4
0.02
0.0049
11.5
1.15
1.15 .
1.15
1.15
7.7
ND
4.3
ND
ND
ND
ND
Oral Route-: I! :
HHEG
Reference Class Reference
B2
A
B2 "
82
c
82
-82 . ..
"82 "
"* B2 *
B2 *
82
82
82
82
A
82
82
ND . "
82
ND *
Unit Risk
Factor
l/(mo/m(3H
0.00047
0.0083
0.000*2
0.0017
ND
NO
ND
ND
1.7
0.17
0.17
0.17
0.17
ND
4.3
2.4
1.8
12
0.48
0.24
Inhalation Route ,
Calculated (a)
Slope Factor 'i
1/(ma/ko/dav) Reference «
i
(b) * ij
0.029 .{
0.00182 " j
0.017 (C) " I
i
i
::
i
' 'I
i
6.1 . " \
0.61 "* |
0.61
o.6i :,
o.ei ;
!|
\
\
i
1
15 i
8.4 * .j
6.3 j
42
1.7
0.84 " !
Notes:
(a) Calculated using the following equation:
SF 1/(mg/kg/day) » UHF (m(3)/mg) x 70 kg + 20 m(3)/day
(b) As per US EPA (IRIS. 1992) guidance, it is not appropriate to calculate a slope factor..
(c) URF is based on a metabolized dose, thwetore the slope factor has not been catoutted using the unit risk factor.
References: .
IRIS, 1992
USEPA. 1991d
* Criteria based on toxic equivalency to benzo(a)pyrene (USEPA. 1991b).
-------
TABLE 6
CARROLL & DUBIES SITE -*
PORT JBWIS. NEW YORK '
SUMMARY OF CANCER RISKS
EXPOSURE
PATHWAY
3oi
ncidental Ingestion
Dermal contact
Oust Inhalation
Surficial Sludoe
Incidental Ingestion
De.iiial Contact
Dust Inhalation
Combined Surface/
Subsurface Stud oe
Incidental digestion
Dermal contact
Dust Inhalation
Laaoon 1 Standina Water
Dermal Contact
Ground Water
Ingaition
Dermal Contact
Vapor Inhalation
ijpaSaSiifBjgiihiir^^S^S:^^8
CU RRENT RECEPTOR
Tres
Adult
3E-08
NA
66-09
2E-08
4E-07
6E-09
NE
NE
NE
7E-08
NE
NE
NE
:*; 5E-07
assars
Youth
5E-07
NA
3E-08
3E-07
2E-06
3E-08
NE
NE
NE
4E-07
NE
NE
NE
::::;:S.. .:.::> .- ;.:-:,- .- - 3^iQgfA:;:-::.---:y
FUTURE RECEPTORS
Vorkerp la)
9E-08
NA
3E-06
NE
NE
NE
7E-07
3E-07
8E-08
NE
NE
NE
NE
^as*4E=Q!
Residents ft>
Adult !
NE(c)
NE
NE
NE
NE
NE
NE
NE
NE
NE
TBC(d)
TBC
TBC
:;:;:-::"-:?- -TBC^^
Youtti
NE
NE
NE
NE
NE
NE
NE
NE
NE
NE
TBC
NE
NE
= """" -TBC
Notes:
(a) Hypothetical excavation worker.
(b) Hypothetical use of on-site ground water.
(c) NE » Exposure pathway is not evaluated for this receptor.
(d) TBC a To be completed following additional ground-water investigation.
(e) NA » Not applicable. Dermal exposure to soil and sludges only evaluated for cadmium and. PCBs.
-------
TABLE 7
CARROLL & CUBES
PORT JSTVIS, NEW YORK
ChamicsJ
VOLATIIES
1 .2 Dlchtonoatnana
cis-
trana-
1 ,1 Oichloroathana
2-Butanona
4-Malhyl-2-pamBnona
Acatona
Caitoon dbulflda
Shtorabanzana
Etnybanzena
Matnylana cnlonda
Tatnchtcroathana
Tduene
Xylanea (total)
SEM1VOLATILES
1,2-OlcMarobanzana
1 ,2.4-Trichlcrabenzana
1 ,4 Olchtorcbanxflna
4C "WITH* Wi Ifl^l lu HlMII HJ
4-CWorotnmn«
4-M«mytpr»noi
Aconoptittwiai
VnttifBCBno
lte(2-atiylhaxyQphthalala
3utytb«xizylphfati8tB
^latttiytphthfttBtat
Dl-n-butytphthatata
3t-n-octylpmn..tatv
nuorwitttaMW
:hxxm
l^aphthaatao*
n^biltio8odtph8flyiatfnin>
Phand
Pyrana
INCRQMUCS
Antimony
Aiaanie
Barium
Sarylllum
Cadmium
food
v««ter
Chromium (111)
Chromium (VI
Ccppar
Cyanlda
Manganaaa
Marcuty
Ntakal
Satenium
SOvar
Thallium
\tanadlum
Zinc
RID
mo/ko/dav) Rafaranca
0.01 "
0.02
0.1 **
0.05
o.os
0.1
0.1
0.02
0.1
0.08
0.01 *
02
Z
0.09
0.00131
NO
Q on
u.uo
0.004 ***
0«J4
0.05 ~
0^8 *
OJ *
0.02
0.2
Q£
0.1
0.02
0.04
0.04
km *
NU
0.8
O03
OJO004 *
0.0003
0X35
0.005
0.001
0.0005
1
0.005
ND
ftn^
0.1
OAXQ **
0X32
0.005
OXX33 "
QX30Q07
0.007
0^ ~
RIC RID '|
(mo/mon (mo/ko/dav) Refaienca '
NO
NO
0.5
03
ojaa
NO
0X31
0.02
1
3
kin
NU
2
0.3
0.2
0.009
0.7
Kin
rau
wn
r»w
NO
hC
km
Nu
NO
NO
NO
ND
NO
ND
ND
NO
km
MJ
kafl
NU
NO
NO
ND
NO
0.0005
NO
NO
NO
ZOE-08
ZOE-06
NO
NO
0X3004
OXX303
NO
NO
NO
NO
NO
NO
!
1
1
i
O 1 ** i
U. 1 J
ox» * i
002 " )
1
OXX33 * 1
0.008 **
0.3 «
014 **
0.8 "
0.09 **
0.08 *
0.003 **
o o
Q^£
j
i
j
4
I
0.0001 ** 1
1
t
ee-07 *
86-07 **
OXXX31
8E-05 ~
(a) Catajl«^iBingtt» following aqua**:
RID (mg/kg/day) RIC (mo/m(5) x 2O m(3)/e*y * 70 kg
IRIS. 1002
* US6PA, 19910
2-MattiytaBpmTialana Is avaluatad using attarta lor riapMtialana.
** USS>AMa^umComaminanttjBvali3l.3mgfl_ TMsiabaaadonorgand«pticprepi
and manfora cannot Da ecnvanM to a haaim -oaaad todcrty
-------
TABLE 8
CARROLL & DUBIES SITE '
PORT JERVIS. NEW YORK
SUMMARY OF HAZARD INDICES
EXPOSURE
PATHWAY
§23.
Incidental Ingestion
Dermal Contact
Dust Inhalation
Surficial Sludpe
Incidental Ingestion
Dermal Contact
Oust Inhalation
Combined Surface/
Subsurface Sludoe
Incidental Ingestion
Dermal Contact '
Dust Inhalation
Laaoon 1 Standina Water
Dermal Contact
Ground Water
Ingestion
Dermal Contact
Vapor Inhalation
Totfll SflrT H=T»rrt tncficaa
CURRENT RECEPTORS
Trea
Adult
0.002
(d)NA
0.01
6E-05
0.02
NE
NE
NE
0.004
NE
NE
NE
O.D4
assets
Youth
0.02
NA
0.08
O.OS
0.0003
0.1
NE
NE
NE
0.02
NE
NE
NE
Workers (a)
0.05
NA
0.8
NE
NE
NE
0.2
0.0008
2
. NE
NE
NE
NE
FUTURE RECEPTORS
RasiderrS (B\
Adult 1 Youth *
NE
NE
NE
NE!
NEl
NEi
i
NE
NE
NE
NE
TBC (e)
TBC
TBC
TBC
NE
NE
NEi
NE!
NEli
i!
NE!
NE
NE
NE
TBC(e)
NE
NE
TBC
Notes:
(a) Hypothetical excavation worker.
(b) Hypothetical use of on-site ground water.
(c) NE - Exposure pathway is not evaluated for this receptor.
(d) NA »' Not applicable. Dermal absorption from soil and sludges is only evaluated for cadmium and PCBa.
(e) TBC = To be completed following supplemental ground- water investtgatoru
-------
TABLES
Detailed Cost Estimate for Selected Remedy, Alternative S,
Ex-Situ Vapor Extraction. BioSlurry Treatment, Stabilization, and Qn-Stte Containment-
Ham No
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
Description
EXCAVATION
Mobilization/Demobilization
Site Clearing
Erosion Control
Construct Equipment Decontamination Pad
Pre Treatment Verification Sampling
Excavation of Soil
Debris Management
CONTAINMENT (FOR TREATMENT AND CLOSURE)
Excavation for On-Site Containment Pad
Install 20 mil HOPE Geomembrane
Install 1'Sand Drainage Layer
Leachate Collection System Wet Well
VAPOR EXTRACTION
Pilot Study for Vapor Extraction
Install 6" PVC Perforated Pipes
Install 6" PVC Non Perforated Pipes
Install 8 Blowers
Air Water Separator, Heat Exchanger, Control Panels,
Wiring Etc.
Weatherproof Housing for Blowers
Electricity Charges tar 1 Year
Operator for 1 Year for Vapor Extraction System
Soil Amendments, Mixing Amendments, and Fertilizer
forl Year
Activated Carbon Units for Treatment of Vented Air
Install 20 mil HOPE Geomembrane
Post Treatment Verification Sampling
SLURRY TREATMENT
Pilot Study for Slurry Treatment
Construct Bioslurry Treatment Pad and Tanks
Install Pumps, Augers. Piping, Electrical Appurtenances,
etc.
Operating Costs for Bioslurry, Chemicals, Power, Labor,
etc.
Slurry Dewateringn/Vater Treatment
Est
Quantity -
1
66
20,300.
2.000
1,500
40,000
1,500
1,906
762
6
381,132
2,000
8
19,000
126
Unit
US
Acre
LS
LS
Samples
CY
CY
CY
SF
CY
LS
LS
LF
LF
Numbers
LS
LS
kWh
MH
LS
N urn DOTS
SF
Samples
LS
LS
LS
LS
LS
Unit Price Mat
&Lab<$)
4,000.00
2.500.00
15.00
50.00
15.00
0.30
15.00
11.00
13.00
7,500.00
0.10
30.00
6,000.00
0.30
1,400.00
Estimated Amount
($)
125,000
4.000
5,000
10.000
165,000
305,000
100,000
23,000
12.000
23.000
50,000
25,000
21,000
10,000
60,000
48,000
5.000
38.000
60,000
25.000
48,000
6,000
177.000
100,000
326,000
51,000
774,000
269,000
-------
29
30
31
32
33
34
35
36
37
38
39
40
41
Post Treatment Verification Sampling
STABILIZATION
Pilot Study for Stabilization
Stabilization of Excavated Soil
Stabilization of Soil Amendments
Post Stabilization Verification Sampling
CLOSURE
Install 2' Clay Layer
Install 20 mil HDPE Geomembrane
Install V Sand Layer
Install Geotextile
Install 24" Cover Layer
Install 6' Topsoil Layer
Backill and Compact Select Fill
Hydroseed Cap
43
17,600
800
18
3,000
46,000
1,800
46,000
3,600
900
20,300
1
Samples
LS
CY
CY
Samples
CY
SF
CY
SF
CY
CY
CY
Acre
1,400.00
-
100.00
100.00
1,400.00
25.00
0.30
15.00
2.00
15.00
20.00
15.00
2,500.00
Subtotal Capital Cost
Administration and Engineering 25%
Contingencies 25%
Total Capital Cost
60,000
25,000
1,760,000
80,000
25,000
75,000
14,000
27,000
92,000
54,000
18,000
305,000
3,000
5,403,000
1,351,000
1,351,000
$8,105,000 '
ANNUAL OPERATION AND MAINTENANCE COST
42
43
44
Annual Groundwater Monitoring
Cap Maintenance
Maintenance of Leachate Collection System
LS
LS
LS
Subtotal Operation «nd MaMenance Cost
. Conttioende. Zi%
Total Operation Mahtenance Co*
Present Worth Factor lot 30 Year. 65%- 1M7
15,000
5.000
2,000
22,000
6,000
28,000
430,000
TOTAL COST
$8,5335,000
Notes:
CF = cubic foot
CY = cubic yard
LF = linear foot
LS = lump sum
SF = square foot
SY = squart yard
-------
TABLE 10
Detailed Cost Esftnate for Contingency Remedy
Off-Site Inciiiefalien of Lagoon 7 Materials; Ex-Sftu Vapor Extraction, Stabilization, and On-Site Containment
Item No
1
2
3
4
S
6
7
B
9
10
11
12
13
.14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
Description
EXCAVATION
Mobilization/Demobilization
SHe Clearing
Erosion Control
'
Pre Treatment Verification Sampling
Excavation of Soil
Debris Management
CONTAINMENT (FOR TREATMENT AND CLOSURE)
Excavation for On-Site Containment Pod
Install 20 mil HOPE Geomembrane
Install 1'Sand Drainage Layer
Leachate Collection System Wet Well
VAPOR EXTRACTION
Pilot Study for Vapor Extraction
Install 6" PVC Perforated Pipes
Install 6" PVC Non Perforated Pipes
Install 8 Blowers
Air Water Separator, Heat Exchanger, Control Panels,
Wiring Etc.
Weatherproof Housing for Blowers
Electricity Charges for 1 Year
Operator for 1 Year for Vapor Extraction System
Soil Amendments, Mixing Amendments, and Fertilizer
for 1 Year
Activated Carbon Units for Treatment of Vented Air
Install 20 mil HOPE Geomembrane
Post Treatment Verification Sampling
OFF-SITE INCINERATION (LAGOON 7)
Transportation
Incineration
Soil Characterization and Verification at Incinerator
Facility
STABILIZATION
Pilot Study for Stabilization
Stabilization of Excavated Soil
Est
Quantity
1
66
20,300
2,000
1,500
40,000
1,500
1,906
762
8
381,132
2,000
8
19,000
126
5,100' .
5,100'
14,200
Unit
LS
Acre
LS
LS
Samples
CY
CY
CY
SF
CY '
LS
LS
LF
LF
Numbers
LS
LS
kWh
MH
LS
Numbers
SF
Samples
Ton
Ton
LS
LS
CY
Unit Price Mat
&Lab($)
4,000.00
2,500.00
15.00
50.00
15.00
0.30
15.00
11.00
13.00
7,500.00
0.10
30.00
6,000.00
0.30
1,400.00
14.00
1,100.00
100.00
||
Estimated Amount
(«
125,000
4,000
5,000
10,000
165,000
305,000
100,000
23,000
12,000
23,000
50,000
25.000
21,000
10,000
60,000
48,000
5,000
38,000
60,000
25,000
6,000
177,000
71,400
5.610,000
12,000
25,000 ||
1,420,000 ||
-------
29
30
31
32
33
34
35
36
37
38
Stabilization of Soil Amendments
Post Stabilization Verification Sampling
CLOSURE
Install 2' Clay Layer
Install 20 mil HOPE Geomembrane
Install 1' Sand Layer
Install Geotextile
Install 24" Cover Layer
Install 6" Topsoil Layer
Backill and Compact Select Rll
Hydroseed Cap
800
18
3,000
46,000
1,800
46,000
3,600
900
20,300
1
CY
Samples
CY
SF
CY
SF
CY
CY
CY
Acre
100.00
1,400.00
25.00
0.30
15.00
2.00
15.00
20.00
15.00
2,500.00
Subtotal Capital Cost
Administration and Engineering 25%
Contingencies 25%
Total Capital Cost
80,000
25,000
75,000
14,000
27,000
92,000
54,000
18,000
305,000
3,000
9,176,400
2,294,100
2,294,100
13,764,600
ANNUAL OPERATION AND MAINTENANCE COST
39
40
41
Annual Groundwater Monitoring
Cap Maintenance
Maintenance of Leachate Collection System
LS
LS
LS
Subtotal Operation and Maintenance Cost
Contingencies 25%
Total Operation Maintenance Cost
Present Worth Factor for 30 Years @ 5% = 15.37
Total Present Worth of Operation and Maintenance
TOTAL COST
15,000
5,000
2,000
22,000
6,000
28,000
430,000
14,194,600
Notes:
CF = cubic foot
CY = cubic yard
LF = linear foot
LS = tump sum
SF = square foot
SY = square yard
1 *
3,400 cu. yd soil (Lagoon 7) is assumed to weigh 5,100 tons.
-------
APPENDIX III
ADMINISTRATIVE RECORD INDEX
-------
CARROLL fi DUBIES SITE
OPERABLE UNIT ONE
ADMINISTRATIVE RECORD FILE
INDEX OF DOCUMENTS
1.0 SITE IDENTIFICATION
1.4 Site Investigation Reports
P. 100001 - Report: Engineering Investigations at ^Inactive
100322 Hazardous Waste Sites in the State of New York,
Phase II Investigations. Carroll and Dubies Sitef
Town of Deerpark. Orange County. New York.
prepared by Wehran Engineering, P.C., prepared for
Project Sponsors for Submission to Division of
Solid and Hazardous Waste, New York State
Department of Environmental Conservation, February
1987.
P. 100323 - Report: Preliminary Investigation of the Carroll
100429 and Dubies Site. City of Port Jervis. Oranae
County. New York. Phase I Summary Report, prepared
by Ecological Analysts, Inc., prepared for New
York State Department of Environmental
Conservation, November 1983.
3.0 REMEDIAL INVESTIGATION
3.3 Work Plans
P. 300001 - Report: Health & Safety Plan. Remedial
300053 Investigation/Feasibility Studyr Carroll & Dubies
Site. Port Jervis. New York, prepared by Blasland
& Bouck Engineers, P.C., January 1991 (Revised
June 1991)..
P. 300054 - Report: Quality Assurance Project Plan. Remedial
300250 Investigation/Feasibility Study. Carroll & Dubies
Site. Port Jervis. New York, prepared by Blasland
& Bouck Engineers, P.C., January 1991 (Revised
June 1991).
P. 300251 - Report: Work Plan. Remedial Investigations/
300325 Feasibility Study. Carroll & Dubies Site. Port
Jervis. New York, prepared by Blasland &
Engineers, P.C., November 1990.
Bouck
-------
3.4 Remedial Investigation Reports
P.
P.
300326
300762
300763
300948
300949
301359
Reportr Source Area Remedial Investigation.
Carroll and Dubies Superfund Site. Eort Jervis,
New Yorkf prepared by Blasland & Bouck Engineers,
P.C., December 1993.
Report: Preliminary Remedial Investigation
Results. Carroll & Dubies 'Superfund Site. Port
Jervis. New York. Volume 1 of 2. prepared by
Blasland.& Bouck Engineers, P.C., October 1992.
Report: Preliminary Remedial Investigation
Results. Carroll & Dubies Superfund Site. Port
Jervis. New York. Volume 2 of 2. prepared by
Blasland & Bouck Engineers, P.C., October 1992,
3.5 Correspondence
P.
P.
P.
301360 - Letter to Ms. Sharon L. Trocher, Remedial Project
301361 Manager, Eastern New York/Caribbean Section I,
Region II, U.S. EPA, from Mr. Frederick J.
Kirschenheiter, Senior Project Engineer II,
Blasland, Bouck & Lee, Inc. , re: validated soil
data tables from the Supplemental Hydrogeologic
Investigation for. the Carroll and Dubies Site,
January 17, 1994.
301362 - Letter to Mr. Tyler E. Gass, C.P.G., Vice
301362 President, Blasland & Bouck Engineers, P.O.,
from Ms. Sharon Trocher, Remedial Project Manager,
Eastern New York/ Caribbean Superfund Section I,
Region II, U.S. EPA, re: correction to item 3
of the January 8, 1993 letter from Mr. Gass,
January 12, 1993.
301363 - Letter to Mr. Tyler E. Gass, C.P.G., Vice
301365 President, Blasland & Bouck Engineers, P.C. , from
Mr. Doug Garbarini, Chief, Eastern New
York/Caribbean Superfund Section I, Region II,
U.S. EPA, re: the New York State Department of
Environmental Conservation's and the U.S.
Environmental Protection Agency's comments on the
December 29, 1992 letter: transmitting
modifications to the scope of work for
supplemental groundwater and on-site soil
sampling, January 11, 1993.
-------
P. 301366 - Letter to Ms. Sharon Trocher, Eastern New
301368 York/Caribbean Remedial Action Brandt, Region....II,.
U.S. EPA, from Mr. Tyler E. Gass, C.P.G.,
Executive Vice President, Blasland &-Bouck
Engineers, P.C., re: response to the January 5,
1993 letter from Doug Garbarini and subsequent
telephone conversations which have modified some
of the items addressed in'jbhat particular letter,
January 8, 1993.
P. 301369 - Letter to Mr. Tyler E. Gass, C.P.G., Vice
301372 President, Blasland & Bouck Engineers, P.O., from
Mr. Doug Garbarini, Chief, Eastern New
York/Caribbean Superfund Section I, Region II,
U.S. EPA, re: the New York State Department of
Environmental Conservation's and the U.S.
Environmental Protection Agency's comments on the
December 16, 1992 scope of work for the four
tentatively identified former lagoons (TIFLs)
located adjacent to the Carroll and Dubies
property, January 5, 1993. (Attached: Figure 1,
New Potential Source Area. Site Map and Proposed
Sampling Locations, prepared by Blaslanrl & Bouck
Engineers, P.C., October 19, 1992.)
P. 301373 . Letter to Mr. Doug Garbarini, Eastern New
301378 York/Caribbean Remedial Action Branch, Region II,
U.S. EPA, from Mr. Tyler E. Gass, C.P.G.,
Executive Vice President, Blasland & Bouck
Engineers, P.C., re: submission of various
documents to Ms. Sharon Trocher regarding the
tentatively identified former lagoons (TIFLs), and
a response to Attachment 1 of Mr. Garbarini's
November 20, 1992 letter entitled, "Additional
Issues to be Included in the Supplemental Work
Proposed on October 13, 1992", December 29, 1992.
(Attached: Figure 1, prepared by Blasland & Bouck
Engineers, P.C., (undated).)
P. 301379 - Letter to Ms. Sharon Trocher, Eastern New
301383 York/Caribbean Remedial Action Branch, Region II,
U.S. EPA, from Mr. Tyler E. Gass, C.P.G.,
Executive Vice President, Blasland & Bouck
Engineers, P.C., re: potential investigation of
possible adjacent lagoon area, Carroll and Dubies
Site, December 1£> 1992. (Attachedt Figure; 1,
New Potential Source Area. Site Map and Proposed
Sampling Locations, prepared by Blasland & Bouck
Engineers, P.C., October 19, 1992.)
-------
P. 301384 - Letter to Mr. Tyler. E. Gass, C.P.G., Vice
301392 President, Blasland & Bouck Engineers, P.C., from
Mr. Doug Garbarini, Chief, Eastern New
York/Caribbean Superfund Section I, Region II,
U.S. EPA, re: response to the October 13, 1992
letter which transmitted the proposed schedule for
completing the Remedial Investigation and
Feasibility Study (RI/FS)"and the proposed scope
of supplemental work for the Carroll and Dubies
Superfund Site, November 20, 1992. (Attached: l.
Enclosure 1, Report: Additional Issues to be
Included in the Supplemental Work Proposed on
October 13. 1992; 2. Figure 1, prepared by
Blasland & Bouck Engineers, P.C., (undated); 3.
Figure 2, Rock Aquifer Monitoring Well.
(undated).) .
P. 301393 - Letter to Ms. Sharon Trocher, Eastern New
301398 York/Caribbean Remedial Action Branch, Region II,
U.S. EPA, from Mr. Tyler E. Gass, C.P.G.,
Executive Vice President, Blasland & Bouck
Engineers, P.C., re: Carroll & Dubies Site, Port
Jervis, New York, Supplemental Investigation,
Scope of Work, October 13, 1992. (Attached: Site
Map and Proposed Supplemental Sampling Locations.
prepared by Blasland & Bouck, Engineers, P.C.,
October 6, 1992.)
P. 301399 - Letter to Ms. Vita DeMarchi, Senior Project
301400 Hydrogeologist, Blasland & Bouck Engineers, P.C.,
from Ms. Sharon Trocher, Remedial Project Manager*
Eastern New York & Caribbean Section I, Region II,
U.S. EPA, re: response to Ms. DeMarchi's December
6, 1991 letter proposing the analytical parameters
for the second round of groundwater samples to be
obtained from the Carroll and Dubies Site,
December 13, 1991.
P. 301401 - Letter to Mr. Tyler E. Gass, C.P.G., Project
301403 Director, Blasland & Bouck Engineers, P.C., from
Ms. Sharon L. Trocher, Remedial Project Manager,
Eastern New York and Caribbean Section I, Region
II, U.S. EPA, rer summary of the agreement
reached between Mr. William McCune and Ms. Sharon
L. Trocher during telephone conversations
occurring on September 17 and 18, 1991, September
18, 1991.
-------
P. 301404 - Letter to Ms. Sharon Trocher, Eastern New
301408 York/Caribbean Remedial Action Branch, Region IX,
U.S. EPA, from Mr. Tyler E. Gass, C.P.G., Vice
President, Blasland & Bouck Engineers, P.C., re:
proposed methods of resolving the outstanding
concerns raised in Ms. Trocher's letter dated
August 21, 1991 and the subsequent meeting of
September 5, 1991, September 16, 1991.
P. 301409 - Memorandum to Mr. Tyler E. Gass, C.P.G., Project
301410 Director, Blasland & Bouck Engineers, P.C., and
Ms. Debra L. Rothenberg, Esq., Winston & Stravn,
from Ms. Sharon Trocher, Remedial Project Manager,
Region II, U.S. EPA, re: Carroll and Dubies
Site - summary of 9/5/91 meeting, September 9,
1991.
P. 301411 - Letter to Mr. Tyler E. Gass, C.P.G., Project
301413 Director, Blasland & Bouck Engineers, P.C., from
Ms. Sharon L. Trocher, Remedial Project Manager,
Region II, U.S. EPA, re: concerns of the U.S. EPA
and the New York State Department of Environmental
Conservation regarding the sampling depth of the
sludge samples obtained from lagoons 1 and 2, and
the limited recharge rate of monitoring well OW-4,
August 21, 1991.
P. 301414 - Letter to Mr. Tyler E. Gass, C.P.G., Project
301415 Director, Blasland & Bouck Engineers, P.C., from
Ms. Sharon Trocher, Remedial Project Manager,
Eastern New York and Caribbean Section I, Region
II, U.S. EPA, re: summary of discussion between
Mr. Robert Patchett of Blasland & Bouck Engineers
and Mr. Robert Cunningham, an Environmental
Protection Agency representative, concerning the
development of monitoring wells for the Carroll
and Dubies Superfund Site, August 9, 1991.
(Attached: Transmission Confirmation Report,
August 12, 1991.)
P. 301416 - Letter to Ms. Sharon Trocher, Eastern New
301417 York/Caribbean Remedial Action Branch, Region II,
U.S. EPA, from Mr. Tyler E. Gass, C.P.G., Vice
President, Blasland & Bouck. Engineers, P.C., re:
an addendum to the Work Plan and Sampling and
Analysis Plan (SAP) for the Carroll and Dubies
Superfund Site in Port Jervis, New York, August 7,
1991.
-------
301418 - Letter to Ms. Sharon Trocher, Eastern New
301419 York/Caribbean Remedial Action Branch, Region II,
U.S. EPA, from Mr. Tyler E. Gass, C.P.G., Vice
President, Blasland & Bouck Engineers-, P.C., re:
acknowledgement of U.S. EPA's letter dated July
29, 1991 granting approval for use of mud rotary
drilling method during advancement of the
boreholes for the till monitoring wells, July 30,
1991.
301420 - Letter to Mr. Tyler E. Gass, C.P.G., Project
301421 Director, Blasland & Bouck Engineers, P.C., from
Ms. Sharon Trocher, Remedial Project Manager,
Eastern New York & Caribbean Section I, Region II,
U.S. EPA, re: approval of the use of mud rotary
drilling techniques for the construction of the
till monitoring wells, July 29, 1991.
301422 - Letter to Ms. Sharon Trocher, Eastern New
301425 York/Caribbean Remedial Action Branch, Region II,
U.S. EPA, from Mr. William T. McCune, Senior
Project Geologist II, Blasland & Bouck Engineers,
P.C., re: drilling methods considered for use
in drilling three glacial till boreholes at the
Carroll and Dubies Site in Port Jervis, New
York, July 26, 1991.
4.0 FEASIBILITY STUDY
4.3 Feasibility Study Reports
P. 400001 - Letter to Ms. Sharon Kivowitz, Office of Regional
400096 Counsel, U.S. EPA, from Ms. Debra L. Rothberg,
Attorney at Law, and Mr. Robert J. Glasser, Gould
& Wilkie, re: submission of the Technical
Memorandum on behalf of Respondents, Kolmar
Laboratories, Inc. and Wickhen Products, Inc.,
July 18, 1994. (Attached Report: Technical
Memorandum. Alternative Remedial Technology
Evaluation. Carroll and Dubies Site. Port Jervis,
New York, prepared by Remediation Technologies,
Inc., prepared for Mr. Robert J. Glasser, Gould
and Wilkie, and Ms. Debra L. Rothberg, July 15,
1994.)
P. 400097 - Report: Technical Memorandum. Carroll & Dubies
400113 Site. Port Jervis. New York, prepared by Blasland,
Bouck & Lee, Inc., February 1994 (Revised March
1994) .
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P. 400114 - Report: Source Area Feasibility Study. Carroll &
400438 Dubies Site. Port Jervis. New York, prepared by
Blasland, Bouck & Lee, Inc., January 1994 (Revised
May 1994; Revised July 1994).
4.6 correspondence
P. 400439 - Letter to Ms. Sharon L. Trocher, Remedial Project
400440 Manager, Eastern New York/Caribbean Section I,
Region II, U.S. EPA, from Mr. Tyler E. Gass,
C.P.G, Ph.G., Executive Vice President, Blasland,
Bouck & Lee, Inc., re: Carroll & Dubies Site,
Port Jervis, New York, Source Area Feasibility
Study, June 17, 1994.
P. 400441 - Letter to Ms. Sharon Trocher, Remedial Project
400446 Manager, Eastern New York/Caribbean Section I,
Region II, U.S. EPA, from Mr. Tyler E. Gass,
C.P.G.S., Executive Vice President, Blasland,
Bouck & Lee, Inc., re: Source area feasibility
study, Carroll & Dubies Site, Port Jervis, New
York, March 23, 1994. (The following are
attached: 1. Table 1, Carroll & Dubies Site, Port
Jervis, New York, Comparison of Volume of Source
Area Materials Above Cleanup Levels Proposed
in source Area Feasibility Study vs. U.S. EPA
Proposed Alternative Approaches, (undated); 2.
Table 2, Carroll & Dubies Site, Port Jervis, New
York, Soil Sample Data Above the Source Area
Feasibility Study Inorganic Cleanup Levels but not
Above U.S. EPA Alternative Inorganic Cleanup
Levels, (undated); 3. Figure 1, Carroll and Dubies
Site, Port Jervis, New York, Horizontal and
Vertical Extent of Source Area Materials Above
Cleanup Levels Using U.S. EPA Alternative 1.
prepared by Blasland, Bouck & Lee, Inc., March
1994; 4. Figure 2, Carroll & Dubies Site, Port
Jervis, New York, Horizontal and Vertical Extent
of Source Area Materials Above Cleanup Levels
Using U.S. EPA Alternative2. prepared by
Blasland, Bouck & Lee, Inc., March 1994.)
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400447 - Letter to Ms. Sharon Trocher, Eastern New
400450 York/Caribbean Remedial Action Branch, Region II,
U.S. EPA, from Mr. Tyler E. Gass, C.P.G.,
Executive Vice President, Blasland & "Bouck
Engineers, P.C., re: proposed soil cleanup values
for priority pollutant inorganics for the Carroll
& pubies Site, November 30, 1993. (Attached: 1.
Table 1, Carroll & Dubies Site, Port Jervis New
York, Proposed Priority Pollutant Inorganic
Cleanup Levels, (undated); 2. Table 2, Carroll &
Dubies Site, Port Jervis, New York, Risk-Based
Preliminary Remediation Goals (PRGs) for
Inorganics in Soils, (undated).)
400451 - Letter to Ms. Sharon L. Trocher, Remedial Project
400454 Manager, Eastern New York/Caribbean Section 1,
Region II, U.S. EPA, from Mr. Tyler E. Gass,
C.P.Gi, PHg, Executive Vice President, Blasland &
Bouck Engineers, P.C., re: addendum to
correspondence dated September 24, 1993 pertaining
to remedial action objectives, Carroll & Dubies
Site, October 1, 1993.
400455 - Letter to Ms. Sharon Trocher, Eastern New
400466 York/Caribbean Remedial Action Branch, Region II,
U.S. EPA, from Mr. Tyler E. Gass, C.P.G., PHg,
Executive Vice President, Blasland & Bouck
Engineers, P.C., re: proposed approach for
establishing cleanup criteria to determine the
extent of source area materials that need to be
addressed as part of the Carroll & Dubies Site
remedy, September 24, 1993. (Attached: 1.
Memorandum to Regional Hazardous Waste Remediation
Engineers, Bureau Directors, and Section Chiefs,
from Mr. Michael J. O'Toole, Jr., Director,
Division of Hazardous Waste Remediation, New York
State Department of Environmental Conservation,
re: division technical and administrative
guidance memorandum: determination of soil
cleanup objectives and cleanup levels, November
16, 1992; 2. Appendix A, Table 4, Recommended Soil
Cleanup Objectives fma/kg or ppm.} for Heavy
Metals, (undated); 3. Conventional Sediment
Variables. Total Organic Carbon (TOO. March
1986.)
8
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P. 400467 - Letter to Mr. Tyler E. Gass, C.P.G., Vice
400468 President, Blasland & Bouck Engineers, P.C., from
Ms. Sharon L. Trocher, Remedial Project Manager,
Eastern New York/Caribbean Section I,"Region II,
U.S. EPA, re: the development of soil cleanup
numbers for the Carroll & Duties Sewage Disposal
Site, May 21, 1993.
7.0 ENFORCEMENT
7.3 Administrative Orders
P. 700001 - Administrative Order on Consent, in the matter of
700030 Kolmar Laboratories, Inc., and wickhen Products,
Inc., Respondents, Index No. II CERCLA - 00202,
February 8, 1990. (Attached: i. Figure 1, Map:
Site Location Map. Carroll and Dubies Site,
(undated); 2. Appendix II, Outline of
Modifications to EPA RI/FS Work Plan. Carroll and
Dubies Site, (undated); 3. Map: Field
Investigation Location Map, prepared by Blasland &
Bouck Engineers, P.C., (undated).)
7.7 Notice Letters and Responses - 104e's
P. 700031 - Notice letter to Honorable R. Michael Worden,
700032 Mayor, City of Port Jervis, from Mr. William
McCabe, signing for Mr. George Pavlou, Acting
Director, Emergency and Remedial Response
Division, Region II, U.S. EPA, re: notification
that the City of Port Jervis may be a potentially
responsible party of the Carroll & Dubies
Superfund Site, April 22, 1993.
P. 700033 - Notice letter to Messrs Joseph Carroll and Gustave
700037 Dubies, Carroll and Dubies Sewage Disposal
Facility, Inc., Mr. Adolf A. Maruszewski,
President, Kolmar Laboratories, Inc., Mr. Richard
G. Holder, President, Reynolds Metal Company, Mr.
Jere D. Marciniak, President, Wickhen Products,
Inc., from Mr. Stephen D. Luftig, Director,
Emergency and Remedial Response Division, Region
II, U.S. EPA, re: offer to conduct a remedial
investigation and feasibility study at the Carroll
& Dubies Superfund Site, September 25, 1989.
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8.0 HEALTH ASSESSMENTS
8.1 ATSDR Health Assessments
P. 800001 - Report: Preliminary Health Assessment for Carroll
800025 & Dubies. Port Jervis. Orange County. New York,
prepared by New. York State Department of Health
Under Cooperative Agreement with the Agency for
Toxic Substances and Disease Registry, July 31,
1991.
10.0 PUBLIC PARTICIPATION
10.2 Community Relations Plans
P. 10.00001- Report: Community Relations Plan. Carroll and
10.00027 Dubies Sewage Disposal Site, Deerpark. Orange
County. New York, prepared by Alliance
Technologies Corporation, prepared for U.S. EPA,
June 14, 1991.
10.6 Fact Sheets and Press Releases
P. 10.00028- Fact Sheet: Superfund Update. Carroll and Dubies
10.00033 Site. Town of Deerpark. Orange County. New York.
Fact Sheet #2, Status of Current EPA Remedial
Activities, at the Carroll and Dubies Site.
January 1993.
P. 10.00034- Fact Sheet: Superfund Update, Carroll and Dubies
10.00039 Site. Town of Deerpark. Orange County. New York.
Fact Sheet II, EPA to Conduct Investigation of
Carroll and Dubies Site. May 1991.
10.10 correspondence (FOIA)
P. 10.00040- Letter to Ms. Frances Hodson, from Ms. Sharon
10.00042 Trocher, Remedial Project Manager, Eastern New
York/Caribbean Section, Region II, U.S. EPA, re:
response to Ms. Hodson's March 28, 1994 letter
requesting information on the status of the
Carroll and Dubies Site, April 22, 1994.
(Attached: Letter to Ms. Sharon Trocher, Remedial
Project Manager, U.S. EPA, from Ms. Frances
Hodson, re: request for information regarding the
Carroll and Dubies Superfund Site, March 28,
1994.)
10
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P. 10.00043- Letter to Ms. Frances Hodson, from Mr. Doug
10.00045 Garbarini, Chief, Eastern New York/Caribbean
Section I, Region II, U.S. EPA, re: response to
Ms. Hodson's September 23, 1992 letter requesting
an update on the Carroll and Dubies Superfund
Site, November 16, 1992. (Attached: 1. Update
for the Carroll and Dubies Superfund Site.
November 1992; 2. Letter to Mr. William McCabe,
Chief, New York/Caribbean Remedial Action Branch,
Region II, U.S. EPA, from Ms. Frances Hodson, re:
request for information regarding the Carroll and
Dubies Superfund Site, September 23, 1992.)
P. 10.00046- Letter to Ms. Frances J. Hodson, from Ms. Sharon
10.00047 Trocher, Eastern New York/Caribbean Section I,
Region II, U.S. EPA, re: response to Ms. Hodson's
November 12, 1991 letter concerning the status of
the Carroll and Dubies Superfund Site, November
17, 1991. (Attached: Letter to Ms. Sharon
Trocher, Remedial Project Manager, Eastern New
York/Caribbean Section I, Region II, U.S. EPA, re:
request for information regarding the Carroll and
Dubies Superfund Site, November 12, 1991.)
11
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CARROLL & DUBIES SITE
OPERABLE UNIT ONE UPDATE
ADMINISTRATIVE RECORD PILE
INDEX OF DOCUMENTS
4.0 FEASIBILITY STUDY
4.6 Feasibility correspondence
P. 400469 - Fax transmittal to Ms. Sharon Trocher, Remedial
400474 Project Manager, U.S. EPA, Region II, from K.
Jones, Remediation Technologies Incorporated, re:
Cost Estimates for Modified Remedial Alternatives,
plus LTTD, August 3, 1994. (Attached: Cost
Estimates for Modified Remedial Alternatives,
(undated).
10.0 PUBLIC PARTICIPATION
10.9 Proposed Plan
P. 10.00048- Plan: Superfund Proposed Plan, Carroll and Dubies
10.00059 Sewage Disposal Inc., Town of Deerpark, Orange
County, New York, prepared by U.S. EPA, Region II,
August 4, 1994.
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CARROLL AND DUBIES SITE
OPERABLE UNIT ONE UPDATE
ADMINISTRATIVE RECORD PILE
INDEX OF DOCUMENTS
4.0 FEASIBILITY STUDY
4.2 Feasibility Study Work Plans
P. 400475 - Plan: Vapor Extraction and Bioslurry Treatability
400495 Investigation Workplan. Carroll and Dubies Site.
Port Jervis, New York, prepared for Mr. Robert J.
Glasser, Gould and Wilkie, and Ms. Debra L.
Rothberg, Periconi & Rothberg, P.C., prepared by
Remediation Technologies, Inc., July 25, 1994.
(
4.3 Feasibility Study Reports
P. 400496
400513
P.
400514
400539
P.
400540
400675
Letter to Ms. Sharon Trocher, Carroll and Dubies
Site Project Manager, U.S. EPA, from Ms. Brenda B.
McDevitt, Environmental Scientist, Remediation
Technologies, Inc., and Ms. Barbara H. Jones,
Project Engineer, Remediation Technologies, Inc.,
re: Addendum to Treatability Study Report,
November 8, 1994. . (Attached report: Addendum to:
Technology Evaluation Laboratory Treatability
Study. Carroll and Dubies Superfund Site. Final
Report (October 10. 1994.). November 8, 1994.
Report: Cost Estimates for Modified Remedial
Alternatives. prepared for Mr. Robert J. Glasser,
Gould and Wilkie, and Ms. Debra L. Rothberg,
Periconi & Rothberg, P.C., prepared by Remediation
Technologies, Inc., October 13, 1994.
Report: Technology Evaluation Laboratory
Treatability Study. Carroll and Dubies Superfund
Site. Final Report, prepared for Mr. Robert J.
Glasser, Gould and Wilkie, and Ms. Debra L.
Rothberg, Periconi & Rothberg, P.C., prepared by
Remediation Technologies, Inc., October 10, 1994.
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4.6 Correspondence
P. 400676 - Letter to Mr. Doug Garbarini, Carroll- and Dubies
400681 Site Contact, U.S. EPA, from Ms. Brenda B.
McDevitt, Environmental Scientist, Remediation
Technologies, Inc., and Mr. Kevin R. Jones,
Associate, Remediation. Technologies, Inc., re:
ARARs Summary, December 21, 1994. (Attached:
Table 2-1. Carroll and Dubies Site. Port Jervis,
New York. Action~Specific ARARs, undated.)
P. 400682 - Letter to Ms. Sharon Trocher, Carroll and Dubies
400684 Site Project Manager, U.S. EPA, from Ms. Brenda B.
McDevitt, Environmental Scientist, Remediation
Technologies, Inc., re: Cost Estimate for Off-
Site Incineration of Lagoon 7 Material, December
9, 1994. (Attached: 1. Table 2-1A. Carroll &
Dubies Site. Port Jervis. New York. Detailed Cost
Estimate. Slurry Treatment for Lagoon 7 Soil.
undated; 2. Table 2-*lB. Carroll & Dubies Site,
Port Jervis. New York. Detailed Cost Estimate.
Incineration for Lagoon 7 Soil, undated.).
10.0 PUBLIC PARTICIPATION
10.4 Public Meeting Transcripts
P. 1000060 - Transcript: "Public Meeting for the Carroll and
1000157 Dubies Superfund Site, Port Jervis, New York,"
transcribed by Rockland and Orange Reporting,
transcribed on August 23, 1994.
10.9 Proposed Plan
P. 1000158 - Report: Superfund Proposed Plan. Carroll and
1000169 Dubies Sewage Disposal Inc.. Town of Deerpark.
Orange County. New York, prepared by U.S. EPA -
Region II, August 1994.
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APPENDIX IV
STATE LETTER OF CONCURRENCE
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NEW YORK STATE DEPARTMENT OF ENVIRONMENTAL CONSERVATION
50 Wolf Road. Albany. New York 12233
Langdon Marsh
Commissioner
JAN 30 1995
Ms. Kathleen Callahan
Director
Emergency & Remedial Response Division
U.S. Environmental Protection Agency
Region II
26 Federal Plaza
New York, NY 10278
Re: Carroll & Dubies Site ID No. 336015
Record of Decision
Dear Ms. Callahan:
The New York State Department of Environmental Conservation (NYSDEC) has
reviewed the Record of Decision (ROD) for Operable Unit 1 of the Carroll & Dubies site,
which addresses the source areas (lagoons and surrounding impacted soil). Alternative
number 5 as described in the ROD is NYSDEC's preferred alternative, which is also the
USEPA's preferred option, NYSDEC concurs with the ROD as written.
Please call Victor Cardona at (518) 457-3976 with any questions you may have.
Sincerely,
Ann Hill DeBarbieri
Deputy Commissioner
Office of Environmental Remediation
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APPENDIX V
RESPONSIVENESS SUMMARY
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RESPONSIVENESS SUMMARY
CARROLL AND BUSIES SUPERFUND SITE -
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RESPONSIVENESS SUMMARY
CARROLL AND DUBIES SEWAGE DISPOSAL INC. .SITE
INTRODUCTION
A responsiveness summary, required by the National Contingency
Plan (NCP) at 40 CFR §300.430 (f) (3) (F) , provides a summary of
public comments and concerns received during the public comment
period, and the United States Environmental Protection Agency's
(EPA's) and the New York State Department of Environmental
Conservation's (NYSDEC's) responses to those comments and
concerns. All comments summarized in this document have been
considered in EPA's and NYSDEC's final decision for selection of
a remedial alternative for the Carroll and Dubies Sewage Disposal
Inc. site (the site).
SUMMARY OF COMMUNITY RELATIONS ACTIVITIES
The Remedial Investigation and Feasibility Study (RI/FS) reports
and the Proposed Plan for the site were made available for public
review on August 4, 1994. The documents were placed in
information repositories located at the Deerpark Town Hall,
Drawer A, Huguenot, New York and the EPA Document Control Center,
26 Federal Plaza, Room 2900, New York, New York, and the Proposed
Plan was mailed to all names on EPA's community relations mailing
list. A public meeting was held at the Port Jervis High School
on August 23, 1994,. to discuss the results of the RI/FS, to
present EPA's preferred remedial alternative and to provide an
opportunity for the interested'parties to present oral comments
and questions to EPA on the Proposed Plan for remediation of the
site. A period for public review and comment on these documents
was held from August 4, 1994 to September 2, 1994.
The notice of the public meeting and the availability of the
above-referenced documents appeared in The Times Herald Record on
August 15, 1994.
Attached to the Responsiveness Summary are the following
Appendices:
o Appendix A - Proposed Plan,
Carroll and Dubies Sewage Disposal Inc.
Town of Deerpark,
Orange County, New York
o Appendix B - Public Notice
o Appendix C - August 23, 1994 Public Meeting
Attendance Sheet
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SUMMARY OF COMMENTS AND RESPONSES
The following section is a summary of comments and .xjuestions
received from the public, with EPA's responses. The comments
provided below are a summary of statements made at the public
meeting and written comments received during the public comment
period. In several cases, the responses provided at the meeting
have been supplemented with additional information.
Comments Regarding the Nature and Extent of Contamination
1. COMMENT: A resident requested that the existing results of
the groundwater sampling conducted at the site be
summarized. The resident was also interested in the
location and depth of the monitoring wells, as well as any
plans to install monitoring wells further downgradient of
the existing monitoring wells.
EPA RESPONSE: It should be noted that the groundwater
contamination will be addressed in operable unit II, as such
the groundwater investigation is not yet complete. A
significant amount of data have already been generated from
the on-going investigation. During 1991 and 1993,
groundwater samples were collected from monitoring wells
located within approximately 150 feet of the lagoons at the
site and were analyzed for organic and inorganic compounds.
(Refer to Figure 3 contained in the Record of Decision (ROD)
for the location of the monitoring wells.) Results can best
be described relative to lagoons 1 through 4 and 6 through
8. (Lagoon 5 is not considered here since it contained
tires and not industrial wastes.) Results indicated that
organic compounds (benzene, 1,2-dichloroethene,
tetrachloroethene and trichloroethene) were detected above
drinking water standards in the groundwater samples
collected from the monitoring wells located nearest to
lagoons 1 through 4 (e.g., MW-4, QW-2, OW-3), but were
detected at or near the State, or. Federal drinking water
standards in the groundwater samples collected from the
wells located furthest from lagoons 1 through 4 (e.g., OW-5,
OW-6, OW-7 and OW-8). During the 1993 sampling event,
inorganic compounds were detected at or near the drinking
water standards. Based on the results of this sampling, the
horizontal extent of the groundwater contamination plume was
determined to extend no farther than approximately 150 feet
downgradient of lagoons 1 through 4.
Benzene, chromium, lead and nickel were the primary
contaminants detected in the groundwater samples collected
from monitoring wells located downgradient of lagoons 6, 7
and 8 (e.g., OW-9 through OW-13). These contaminants were
detected above drinking water standards. Since contaminants
were detected above the drinking water standards in the
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furthest downgradient monitoring wells, it is evident that a
plume extends beyond the existing monitoring wells. In
August and September of 1994, additional monitoring wells
were installed (not shown in Figure 3) and groundwater
samples were collected to determine the extent of the
groundwater contamination plume. These monitoring wells
extended as far as the downgradient edge of the City of Port
Jervis landfill (approximately 1,000 feet from the site).
Additional monitoring wells will be installed if the results
of the recent sampling indicate that the site groundwater
contamination plume extends beyond the downgradient edge of
the landfill. A RI report which summaries the groundwater
sampling data from the site is expected to be completed in
mid 1995, while a Proposed Plan which addresses the
groundwater at the site is expected to be completed shortly
thereafter.
The materials encountered underlying the site consist of
glacially derived unconsolidated materials (e.g., sand,
gravel and clay) underlain by consolidated bedrock. The
glacially derived materials consist of two distinct units, a
glacial till unit overlain by glacial outwash deposits. The
monitoring wells installed during 1991 and 1993 monitor the
bedrock, the glacial till, the glacial outwash or both the
glacial till and outwash units. The monitoring wells
installed in 1994 primarily monitor the water table. The
deepest monitoring well at the site is located in the
bedrock and is approximately 87 feet below ground surface.
2. COMMENT: One commenter questioned whether EPA had
overestimated the depth to groundwater at the site (30 to 40
feet). The commenter has installed shallow wells at less
than 25 feet on Route 209 in Hugenot.
EPA RESPONSE: The depth to groundwater varies significantly
in the vicinity of the site. Along the southeastern
boundary of the site, the depth to groundwater from ground
surface ranged from approximately 30 to 40 feet. Whereas,
approximately 1000 feet from the site (towards Gold Creek)
the depth to groundwater from ground surface ranged from 10
to 20 feet. The reduction in depth to groundwater is due to
the proximity to the Creek. The water table is located at a
shallower depth near the Creek since groundwater is
discharging into it.
3. COMMENT: A resident asked whether residential wells in the
area would be tested.
EPA RESPONSE: The New York State Department of Health
(NYSDOH) has sampled a few private wells near the site along
Route 209. NYSDOH did not detect contaminants above
drinking water standards in any of the wells tested. During
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the August 23, 1994 public meeting, NYSDOH indicated that
they would sample residential wells located a reasonable
distance from the site if so requested by the.property
owners.
Comments Regarding the Evaluation of Remedial Alternatives and
the Preferred Alternative
4. "COMMENT: Commenter objected to burning contaminated soil at
the site and "to any process that would release contaminants
into the ambient air. (One commenter agreed that, all
things considered, Alternative 5 is the best alternative.)
Commenters wanted to know where the contaminants that were
"removed from the soil during the low-temperature thermal
desorption (LTTD) process ended up. These commenters were
concerned that the thermal inversions which frequently occur
in the Neversink Valley would inhibit dispersion of the air
emissions released during the remediation process, affecting'
the nearby residents and school children.
EPA RESPONSE: In addition to the factors set forth in the
Summary of Comparitive Analysis of Alternatives Section of
the ROD, the significant public opposition to the use of any
type of on-site thermal treatment unit has been taken into
consideration in selecting the remedy. As noted in the ROD,
the remedy has been modified from that proposed in the
Proposed Plan (see Public Acceptance and Documentation of
Significant Changes sections of the Decision Summary.)
Nonetheless, in response to the question, it should be noted
that the thermal desorption process described in Alternative
5 is not incineration, since the destruction of organic
contaminants is not the desired result. Thermal desorption
is a process that uses either an indirect or direct heat
exchange to heat organic contaminants to a temperature high
enough to volatilize and separate them from the contaminated
soil. Air or an inert gas is used as the transfer medium
for the vaporized components. Thermal desorption systems
are physical separation processes, that transfer
contaminants from one phase to another, and are not designed
to provide high levels of organic destruction. As the soil
is heated, the contaminants reach their respective boiling
points, vaporize, and then become part of the gas stream
which flows through the air pollution control equipment.
In evaluating the alternatives, it was anticipated that any
LTTD unit utilized at the site would be capable of treating
all the soil and sludge contaminated with organic compounds
in less than one year. Thermal desorption units have
extensive air pollution control systems which would comply
-with all State and Federal air pollution control
regulations. Two diff-erent types of LTTD units, an
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anaerobic thermal processor (ATP) and a typical screw LTTD
were considered. Flue gases from the ATP are extensively
treated prior to discharge. Treatment is by ll) cyclone and
baghouse for particle removal, (2) wet scrubber for removal
of acid gases, and (3) carbon adsorption bed for removal of
trace organic compounds. The screw-type LTTD unit uses
condensation and carbon adsorption to treat flue gases. The
air pollution control equipment associated with the LTTD can
achieve greater than 99 percent removal efficiencies. The
purpose of the separation process is to obtain a
significantly reduced volume of waste that can be treated
on-site or sent off-site for treatment and/or disposal. The
spent carbon would be regenerated off-site. Particulates
that are collected in the baghouse and cyclone are recycled
back to the LTTD unit or blended with the treated soil.
5. COMMENT: One commenter asked whether LTTD was the same
process included in a 1991 proposal to burn contaminated
soil in an area near the site. The proposal was withdrawn
since the residents were opposed to burning contaminated
soil.
EPA RESPONSE: It is EPA's understanding from the discussion
at the meeting, that the 1991 proposal included high
temperature combustion i.e, incineration. As noted above,
the LTTD process is not an incineration process.
6. COMMENT: A resident asked whether the LTTD process would
comply with provisions contained in the Town of Deerpark
Zoning law which prohibit the use of any equipment which
involves the burning or incineration of garbage or solid
waste.
EPA RESPONSE: EPA and NYSDEC believe that the LTTD units
would comply with the Town of Deerpark Zoning law since they
are physical separation systems and are not designed to
incinerate or decompose the organic contaminants. Refer to
response #4 for a further discussion on the LTTD unit.
7. COMMENT: A representative of Clean Earth of New York, Inc.
(CENY) stated that it currently operates a mobile thermal
treatment unit and expects a permit to operate a stationary
thermal-treatment unit by October 1994. CENY presented the
option of treating the contaminated materials off-site at
its stationary soil remediation facility instead of on-site
as proposed by EPA.
EPA RESPONSE: The off-site treatment and disposal of the
contaminated soil was evaluated. It was determined that the
on-site treatment of the contaminated soils was protective
of human health and the environment, will comply with
applicable or relevant and appropriate requirements (ARARs) ,
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will utilize permanent solutions and alternative treatment
technologies or resource recovery technologies to the
maximum extent practicable, meets the statutory preference
for treatment, and was much less expensive than treating and
disposing of the materials off-site. The selected remedy
calls for on-site treatment of the source area materials
utilizing ex-situ vapor extraction, bioslurry, and
solidification/ stabilization; on-site LTTD was removed from
consideration as an option for treatment of the source area
materials in the selected remedy. However, as noted in the
contingency remedy, if it is determined that the combination
of ex-situ vapor extraction and bioslurry will not
effectively treat the lagoon 7 materials, 'then the
contingency remedy will need to be implemented. The
contingency remedy would require that the lagoon 7 materials
be sent off-site for treatment (as necessary) prior to
disposal in accordance with Land Disposal Requirements
(LDRs) . The contingency remedy does not specify the type of
treatment to be used in treating the lagoon 7 materials
(although incineration was utilized for developing a
conservative cost estimate), so long as LDRs are achieved.
Therefore, if the contingency remedy is implemented, it is
possible that some or all of the lagoon 7 materials could be
treated off-site via LTTD.
8. COMMENT: A commenter asked why Alternative 6 wasn't the
preferred remedial alternative since it is permanent,
provides the greatest protection, transports the
contaminated soil to a facility which specializes in
handling this kind of waste, and avoids on-site containment
of lagoon material at a site where the water table is
located not far- from the ground surface. The commenter also
asked whether .cost is the deciding factor in selecting
Alternative 5 as the preferred remedy over Alternative 6.
EPA RESPONSE: Each of the proposed remedial alternatives
was assessed utilizing the nine evaluation criteria set
forth in the NCP. The primary criteria that must be
satisfied by any alternative are: 1) overall protection of
human health and the environment and 2) compliance with
ARARs. The remaining seven criteria: 1) long-term
effectiveness and permanence, 2) reduction of toxicity,
mobility or volume, 3) short-term effectiveness, 4)
implementability, 5) cost, 6) State acceptance, and 7)
community acceptance are used to make comparisons and to
identify the major trade-offs between alternatives. The
cost of the alternative is. considered only after it has been
determined that the remedy would be protective of human
health and the environment and meet ARARs.
6
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Although Alternative 6 would provide the greatest protection
to human health and the environment in the vicinity of the
site, Alternative 5 is considered to be fully-protective of
human health and the environment. The selected remedy
(Alternative 5) protects human health and the environment
through the permanent removal of organic contaminants from
soils containing levels of organic contaminants in excess of
! the treatment standards set forth in the Decision Summary;
the immobilization of the concentrated inorganic
contaminants that fail the RCRA TCLP for inorganic
constituents, and the placement of the source area materials
into a lined and capped containment cell with a leachate
collection system. Both of these alternatives satisfy the
primary criteria and are similar in their abilities to
satisfy the other criteria with the exception of cost.
Therefore, cost was the deciding factor in selecting
Alternative 5 as the preferred alternative over Alternative
6.
The depth to groundwater at the site is deep enough to allow
the installation of a lined containment cell above the water
table while maintaining a sufficient protection zone. The
depth to groundwater from ground surface ranged from
approximately 30 to 40 feet along the southeastern boundary
of the site. Along the northwestern boundary of the site,
the water table was not encountered before bedrock was
reached.
9. COMMENT: A resident questioned whether the long-term
effectiveness of stabilization/solidification had been
demonstrated for immobilizing organic and inorganic
contaminants.
EPA RESPONSE: The long-term effectiveness of immobilizing
'organic contaminants through stabilization/solidification
has not been demonstrated. However, stabilization/
solidification is not being used to immobilize the organic
contaminants. The organic contaminants will be removed from
the source area materials via ex-situ vapor extraction or in
the case of lagoon 7 materials via a combination of ex-situ
vapor extraction and bioslurry. Stabilization/
solidification will only be utilized to immobilize the
inorganics. The long-term effectiveness of stabilization/
solidification has been demonstrated for immobilizing
inorganic contaminants.
It should be noted that the selected remedy contains
redundancy in the treatment system to protect human health
and the environment. The mobility of organic contaminants
from the more highly contaminated source areas will be
reduced through treatment via ex-situ vapor extraction and
bioslurry, and placement into a lined and capped containment
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cell. The mobility of inorganic contaminants will be
reduced through stabilization/solidification and/or
placement into a lined and capped containment-cell.
Additionally, the containment cell will be sloped to a well
where any leachate (if generated) from the source area
materials will be collected. A groundwater monitoring
program will also be implemented to monitor the groundwater
(although it is unlikely that any appreciable amount of
contamination could migrate to the groundwater from these
materials).
10. COMMENT: A resident asked if it wouldn't be cheaper in the
long run to treat and dispose of the waste off-site, since
we may learn later that what appears to be a permanent
solution for addressing the waste is not. The resident
indicated that the deposition of the industrial waste in the
ground at the site was deemed acceptable at the time of
deposition; however, we are currently examining alternatives
to remediate this same waste.
EPA RESPONSE: At the time of the original disposal of this
material, there were no safeguards in place to ensure that
the materials did not leach. Alternative 5 permanently
removes organic contaminants from source area materials
through ex-situ vapor extraction and bioslurry, reduces the
mobility of inorganic contaminants through
stabilization/solidification and further reduces the
mobility of the organic and inorganic contaminants through
placement of source area materials in an on-site lined .
containment cell with a cap and a leachate collection
system. Both ex-situ vapor extraction and bioslurry, and
stabilization/solidification are proven technologies for
removing organic contaminants and immobilizing inorganic
contaminants, respectively. A proven technology is a
technology for .which there is extensive experience available
demonstrating its effectiveness. Additionally, further
treatability studies will be conducted to ensure that these
technologies will effectively treat the on-site
contaminants. The on-site containment cell is also a proven
technology for reducing the migration of contaminants, and
it provides redundancy in the treatment system for the
protection of the groundwater. After thoroughly evaluating
the various alternatives for addressing the contamination at
the site, EPA believes that Alternative 5 provides a
technically sound solution for treating the waste.
EPA and DEC do have particular concerns regarding the
ability to effectively treat the lagoon 7 materials. As
such, a contingency remedy has been selected in the event
ex-situ vapor extraction and bioslurry cannot effectively
treat the complex mixture of contaminants in lagoon 7; the
contingency remedy requires that the materials be sent off-
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site for treatment (as necessary) to comply with LDRs prior
to off-site disposal.
11. COMMENT: A resident asked why the slurry cut-off wall
proposed in Alternative 3 was not included in Alternatives
4 or 5.
i
EPA RESPONSE: Under Alternative 3, a cap and slurry cut-off
wall would be utilized to minimize the migration of leachate
from the untreated contaminated source area materials into
the surrounding soils and groundwater. The cap restricts
the infiltration of rainwater through the impacted soils and
sludges. The slurry cut-off wall is a vertical wall
constructed by filling excavated vertical trenches with low
permeable material which minimizes the migration of leachate
from the impacted soils and sludges into the surrounding
soils and groundwater. Alternatives 4 and 5 would curtail
the migration of contaminants through treatment of the
source area materials (stabilization/solidification under
Alternative 4 and ex-situ vapor extraction and bioslurry,
and stabilization/solidification under Alternative 5) and
through placement of the materials in an on-site lined
containment cell with a cap and leachate collection system.
Therefore, a slurry wall would not be heeded under
Alternatives 4 or 5.
12. COMMENT: In reference to the preferred alternative, a
resident requested information regarding the location of the
containment cell, whether the cap would be extended over all
the lagoons, and whether the containment cell would leak.
EPA RESPONSE: It is anticipated that the source area
materials will be consolidated to reduce the size of the cap
and that the cap will be installed in the area of lagoons 1
and 2. The actual location and size of the containment cell
will be. determined during the design phase.
If leaks develop in the liner, it is unlikely that this
would result in significant degradation of the groundwater.
This is because prior to the source area materials being
placed into the lined cell, the more contaminated source
area materials will be treated via one or more of the
following treatment processes: ex-situ vapor extraction,
bioslurry and solidification/stabilization. In addition, a
cap will be installed over the lined cell. The cap will
reduce the migration of untreated contaminants in, the cell
to the groundwater by restricting the percolation of
rainwater through the source area materials. The
containment cell will also be sloped to a well where any
leachate, if generated, will be collected. Finally, a
groundwater monitoring program will be implemented under the
groundwater operable unit.
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13. COMMENT: One commenter felt that the most economical
approach for implementing the preferred alternative would be
to locate a single centrally located cell large enough to
hold the 20,300 cubic yards of contaminated material. The
commenter believed that the cap should extend well past the
containment cell and over all the lagoons as well. The
commenter would like the cap to be keyed into the bottom
cliff bedrock to the northwest, so that no runoff penetrates
underneath the lagoons or the containment cell. The
commenter believed this would minimize the future leaching
of pollutants into the groundwater and could possibly reduce
the amount of soil that would be subjected to the thermal
desorption. The commenter also believed that the minimum
temperature used in the thermal desorption should be
increased considerably; suggesting that the minimum of 200°F
given in the proposed plan would be too low to boil off.all
the water, and would not vaporize many oily organics.
EPA RESPONSE: EPA also believes that the best approach
would be to consolidate the source area materials into a
single containment cell and is pursuing this approach. It
is difficult to determine whether keying the cap into the
bedrock would provide any additional benefits beyond those
afforded from a typical cap design; this approach could
present problems which would not be encountered with a
standard design. For instance, the presence of fractured
bedrock would prevent a good seal and could create movement
along the interface of the liner and the cap, resulting in
runoff entering the containment cell. Typical ways to
prevent runoff from entering the containment cell is through
joining the liner and the cap (e.g., heat bonding) or by
overlapping the cap over the liner. Additionally, the
drainage layer which is one of the layers of the cap and the
drainage system (e.g., trench around the perimeter of the
cap) diverts runoff away from the containment cell. The
location, size and other design details of the containment
cell will be determined during the remedial design of the
remedy.
As noted above, the selected remedy does not incorporate
LTTD. In any case, EPA agrees that if LTTD had been
selected as the treatment process, the temperature of the
soils would have to be heated above 200°F to remove organic
contaminants to attain the cleanup standards established for
the site. The 200°F was given as the bottom end of the
range to which.soils are heated in LTTD units. The upper
end of the range provided in the Proposed Plan was 1200°F.
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14. COMMENT: A resident questioned how bioslurry treatment
would work and whether it is a proven technology.
EPA RESPONSE: In bioslurry .treatment, the contaminated soil
is" mixed with water to form a slurry which is fed to a
bioreactor. Air and nutrients are added to the bioreactor
to promote aerobic microbial activity. Certain
microorganisms can digest organic substances that are
hazardous to humans. Microorganisms digest organic
substances for nutrients and energy thereby breaking down
hazardous substances into less toxic or nontoxic substances.
Bioslurry treatment has been used successfully at other
sites for the treatment of contaminated soil. The success
of bioremediation depends on the types and mixture of
contaminants present, the type of soil and other soil
conditions at the site.
15. COMMENT: One commenter questioned whether bioremediation is
applicable to a 20 year old toxic site that contained
everything from batteries to cosmetic dyes and anti-
perspirant chemicals. The commenter pointed out that
microbes are selective about what chemicals they degrade and
bioremediation would be more appropriate for a site that has
a single contaminant. The commenter also raised the concern
that the contaminants at the site may be too toxic for the
microorganisms.
EPA RESPONSE: Although a single contaminant that readily
biodegrades would be preferable for bioremediation,
bioremediation can occur under conditions where there are
multiple contaminants. Microorganisms are selective about
what chemicals they degrade. However, there is usually more
than one type of microorganism found in a given soil. The
growth of microorganisms can be stimulated to accelerate
bioremediation by adjusting soil conditions such as
temperature, pH, and oxygen and nutrient content.
Therefore, bioremediation can work at an old hazardous waste
site that contains everything from batteries (batteries were
not detected in the lagoons at the site) to cosmetic dyes
and anti-perspirant chemicals. However, the soil would
require pretreatment. Pretreatment would include removing
large objects, such as batteries, if they were present.
Additionally, if the contamination level is too toxic for
the microorganisms, pretreatment would also be necessary -to
reduce the toxicity of the soil. For instance, if the
levels of volatile organic contaminants were unfavorable for
sustaining microorganisms, air could be drawn through the
soil to vaporize and remove volatile organic contaminants
present in the soil to nontoxic levels prior to implementing
bioremediation. It is for this reason that ex-situ vapor
extraction will be utilized to treat the lagoon 7 materials
prior to their treatment via bioslurry.
11
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16. COMMENT: Two of the potentially responsible parties (PRPs)
believe that vapor extraction and bioslurry treatment are
alternatives to LTTD that will achieve the same remedial
objectives as LTTD and will satisfy the nine Comprehensive
Environmental Response, Compensation and Liability Act
(CERCLA) evaluation criteria as well as, or better than,
LTTD. The'two PRPs submitted preliminary test results to
demonstrate the capability of vapor extraction and bioslurry
in reducing the concentration of organic contaminants in the
soil.
The two PRPs believe that vapor extraction and bioslurry
technologies have been successfully demonstrated for actual
site source area materials; whereas, the treatability study
for LTTD encountered both treatment and implementation
problems. The problems encountered included: 1) the sludge
matrix did not reach the target treatment temperature due to
the high moisture content in the sludge and 2) the thermally
treated sludge could not be solidified due to the
characteristics of the material. The two PRPs believe that
selection of LTTD is not supportable given the existing
treatability information on the site source area materials.
The two PRPs also indicated that additional support for the
selection of soil vaporization and bioslurry technologies in
lieu of LTTD is provided by .USEPA guidance. Vapor
.extraction is one of the presumptive remedies for the .
treatment of organics in soils (USEPA, 1993; OSWER Directive
9355.048FS). In addition, bioslurry represents one of the
proven treatment technologies for organic impacted soils
that are subject to land disposal restrictions (Federal
Register. Vol. 58, No. 176).
EPA RESPONSE: Although additional treatability studies are
warranted to demonstrate the effectiveness of each of the
Alternative 5 treatment options, EPA believes that each of
the options could effectively treat all but the lagoon 7
materials.
A combination of physical and chemical factors make the
lagoon 7 materials highly problematic to treat: the
materials have a high clay and moisture content, and
significant concentrations of both volatile and semivolatile
organic compounds. As a result, none of the Alternative 5
processes, in and of themselves, appear to be particularly
well suited for implementation at the site. While it is
believed that lagoon 7 materials that are processed through
the LTTD could be treated to remedial action objectives, EPA
agrees that treatability studies have indicated that
commonly used LTTD units could experience significant
materials handling problems while processing the lagoon 7
materials; prior to implementing LTTD, additional
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treatability studies would be required to assure that such
material handling problems could be addressed/minimized
e.g., via blending the material with additives, or
utilization of an LTTD unit better designed to handle such
problems. Ex-situ vapor extraction is likely to be
effective in handling the volatile fraction of contaminants
in the lagoon 7 materials, however, it would not likely be
effective at treating the semi-volatile fraction.
Bioslurry, on the other hand, would be expected to be
effective in handling the semivolatile fraction of the
lagoon 7 materials. Therefore, it appears as though use of
ex-situ vapor extraction for treatment of volatiles, and
subsequent treatment of semivolatiles with bioslurry, would
be the most implementable combination of treatment options
under Alternative 5; this combination would avoid the
material handling problems which would be expected to be
encountered with LTTD. Based upon this assessment, and the
significant public comment opposed to the use of any type of
on-site thermal treatment unit, the bioslurry and ex-situ
vapor extraction options of Alternative 5 were specified as
the treatment options to be implemented iri the selected
remedy; the LTTD option was specifically excluded from the
selected remedy.
Comments Regarding Site Risks
17. COMMENT: A resident asked for a summary of the results of
the risk assessment conducted at the site.
EPA RESPONSE: A baseline risk assessment was conducted
using the soil data associated with lagoons 1 through 4.
Baseline risk assessments estimate the human health risk
which could result from the contamination at the site, if no
remedial action were taken. The baseline risk assessment
addressed the potential risk to human health by identifying
potential exposure pathways by which the public might be
exposed to contaminant releases at the site under current
and future land-use conditions. The exposure pathways
evaluated under the current land-use conditions included
exposure to trespassers through ingestion, inhalation and
dermal contact of soils and sludges. When considering
future land use, the exposure pathways included the
ingestion, inhalation and dermal contact of soils and
sludges by hypothetical construction workers. Because the
site is surrounded by a cliff, 'a landfill and a quarry,
future residential use of the property was not considered as
a reasonable scenario.
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The results of the baseline risk assessment indicated that
the soils and sludges associated with lagoons 1 through 4
pose an unacceptable noncarcinogenic risk for .hypothetical
construction workers at the site. The primary contributor
to the unacceptable noncarcinogenic risk is chromium-
containing dust which could be inhaled during excavation
activities. The risk assessment indicated that there are no
unacceptable noncarcinogenic risk to trespassers; nor were
there any unacceptable carcinogenic risks under .any of the
scenarios evaluated.
The risk assessment was prepared before the analytical data
associated with lagoons 6 through 8 were available.
Therefore, only the data collected from lagoons 1 through 4
during July and September 1991 were used in the risk
assessment. A separate risk assessment was not prepared for
lagoons 6 through 8 since it was anticipated that remedial
action would be taken at these lagoons due to the levels of
contaminants found, the presence of hazardous waste and
cross media impacts to groundwater. Higher baseline risk
levels would be expected if the analytical soil data from
lagoons 6, 7 and 8 were included in the risk assessment. A
risk assessment to identify the potential risk to human
health through groundwater pathways will be prepared as part
of the RI for the groundwater; it is anticipated that the RI
will be released to the public, in the summer of 1995.
18. COMMENT: A Town official asked whether the recreational use
of the towpath which forms the southeast border of the site
would result in exposure to site contaminants. He indicated
that the towpath has been designated to become a multiple
use pathway across the County.
EPA RESPONSE: The results of the baseline risk assessment
indicated that there are no unacceptable carcinogenic or
noncarcinogenic risk to trespassers. The remedial
alternative that was selected for the site eliminates the
pathway for exposure to site contaminants by trespassers
through the treatment of the contaminated source area
materials and the placement of the source area materials
into an on-site lined containment cell with a cap.
19. COMMENT: A resident asked whether it is better to leave the
contaminants in the soil to migrate to the groundwater or to
release the contaminants into the ambient air. The resident
indicated that he drinks six glasses of water a day while he
breathes twenty or thirty times a minute.
EPA RESPONSE: Neither is preferable. The selected
alternative will reduce the toxicity, mobility and volume of
contaminants in the soil via treatment. As an added measure
of-1 safety, the source -area materials will be placed in a
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lined cell to minimize the potential for the remaining low
level contamination to migrate into the groundwater.
.Measures will be taken during the implementation of the
remedy, to ensure that releases of contaminants into the air
are insignificant. EPA believes that implementation of the
selected remedy will be fully protective of human health and
the environment over the short and long-term.
20. COMMENT: A resident asked if excavation of the soil under
the preferred alternative would continue down to the bedrock
and if not, whether contaminated soil would be left at the
site.
EPA RESPONSE: All lagoon materials are to be excavated for
treatment and/or placement into an on-site containment cell.
The NYSDEC TAGM soil cleanup levels for organic compounds
were utilized to derive excavation levels which will be used
to determine the volume of soils impacted by the lagoon
materials, that also require excavation for treatment and/or
containment. The TAGM soil cleanup levels are objectives
which were established by NYSDEC and are conservatively set
at concentrations that are protective of human health and
groundwater quality. Therefore, contaminants of concern
(COCs) were selected for comparison to the NYSDEC TAGM
levels based on: their mobility (propensity to migrate from
the soil to the groundwater); their frequency of detection
in the soil and in the groundwater, and their concentration
level. The organic indicator COCs and their excavation
levels are as follows:
Table 1
Excavation Criteria for Organic Compounds
Indicator COCs Excavation. Level (ppm)
Benzene 0.06
1,2-Dichlorobenzene 7.9
1,4-Dichlorobenzene 6.0
Di-n-butylphthalate 8.1
Naphthalene 13.0
Tetrachloroethene 1.4
Toluene 1.5
Trichloroethene 1.0
The excavation criteria for the inorganic contaminants was
determined utilizing the highest levels of indicator
contaminants (chromium and nickel) detected in the
background soil samples collected from the site. The
highest levels of chromium and nickel detected in background
samples were 61.9 parts per million (ppm) and 36.7 ppm,
respectively. -Soil that has contaminants above the levels
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listed in Table 1 or levels above the highest background
level for chromium and nickel will require excavation.
Therefore, only soils below the excavation criteria will
remain on-site without being treated or placed into an on-
site containment cell. EPA and NYSDEC believe that these
excavation criteria will be fully protective of human health
and the environment.
Comments Regarding Funding of Remedial Alternatives.
Timeframes for Implementing the Site Cleanup and Enforcement
21. COMMENT: A resident wanted to know the potentially
responsible parties (PRPs) for the site and which of the
PRPs had funded the remedial investigation to date. (Note:
PRPs are companies or individuals who are potentially liable
under CERCLA for the costs of responding to the release and
threat of release of hazardous substances at and from a
site)The resident also wanted to know the extent of
participation by the City of Port Jervis in the
investigation of the site.
EPA RESPONSE: The five PRPs for the site are: 1) Carroll
and Dubies Sewage Disposal, Inc., 2) Kolmar Laboratories,
Inc., 3) Wickhen Products, Inc., 4) Reynolds Metals Company,
and 5) the City of Port Jervis. In September 1989, all the
PRPs, with the exception of the City of Port Jervis were
provided an opportunity to.fund and/or perform the RI/PS for
the site. The City of Port Jervis was not offered an
opportunity to participate in the RI/FS since it was not
determined that it was one of the owners of the site
property until February 1993, well after the RI/FS was
underway. To date, the extent.of participation in the RI/FS
by the City of Port Jervis has been limited to its granting
, access and use of its property to install monitoring wells
for groundwater sampling.
Of the four remaining PRPs, only Kolmar Laboratories, Inc.
and Wickhen Products, Inc. have funded and performed the
RI/FS for the site pursuant to Administrative Order on
Consent, Index #11 CERCLA 00202. All the PRPs will be .
offered the opportunity to fund and/or perform the cleanup
of the contaminated soils at the site.
22. COMMENT: A resident questioned who would pay for the
remedial investigation and the remediation of the site and
whether taxes would go up in the area to pay for the cleanup
of the site.
EPA RESPONSE: First, EPA looks for PRPs to fund the RI/FS
and the remediation of the site. If the PRPs are not
willing to pay for the RI/FS or the cleanup of the site,
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then EPA can order them to perform the response action, or
EPA can use Superfund monies to perform the work. When the
Agency uses its money for a response action at a site where
there are financially viable PRPs, it is authorized to take
an enforcement action against those PRPs to recover its
costs. EPA can ultimately recover these costs through
administrative settlements, judicial settlements or
litigation. The Superfund monies are primarily generated
from taxes on petroleum and chemical industries; a small
portion of the monies are contributed from general tax
revenues. Therefore, local taxes would not increase to fund
this remediation.
During the RI, EPA learned from the City of Port Jervis that
it owns a major portion of the site property where the
lagoons are located. As owner.of the majority of the site
property, the City of Port Jervis is one of. the five PRPs
that is responsible for the cost of the cleanup of .the site.
The City of Port Jervis was not offered an opportunity to
fund or to conduct the RI/FS at the site since, it was not
determined that it was a PRP until after the RI/FS was
underway. The City of Port Jervis will be offered an
opportunity, along with the other four PRPs, to participate
in the clean up of the site. This participation can include
funding and/or providing services to assist in the cleanup
of the site. For qualifying municipalities, the State has a
program to cover 75 percent of the municipality's share of
the cost to cleanup a site. Since the City's participation
in the cleanup, and subsequent sources of revenues for
participation are unclear, it is impossible for EPA to know
if taxes in the area would be increased to pay for the
cleanup of the site.
23. COMMENT: Two PRPs jointly provided the following, comment:
to date, only two (Kolmar Laboratories, Inc. and Wickhen
Products, Inc.) of the five PRPs for the site have
cooperated with the EPA and have expended substantial sums
in the investigation of the site. The EPA has the authority
under CERCLA to compel PRPs to participate in remediation of
hazardous substance disposal sites. Although the Agency has
long represented to the cooperating PRPs that it intends to
exercise its CERCLA authority against non-participating PRPs"
and affirmed its intentions again at the August 23, 1994
Public Meeting, no action to involve these additional
parties, other than notice letters, has been taken by EPA.
Both fairness and economic reality mandate that the EPA
exercise its CERCLA authority and compel other PRPs to
contribute to the costs of addressing the site. Following
issuance of the ROD, the EPA has indicated that it will
afford the PRPs the "opportunity" to conduct the remedial
design and remedial action. In the event that other PRPs
again fail to avail themselves of the-opportunity, the EPA
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should exercise its CERCLA authority and compel
participation of all PRPs.
EPA RESPONSE: EPA's policy is to seek the participation of
all PRPs in addressing sites. CERCLA authorizes EPA to
negotiate with and enter into settlements with PRPs to
perform and/or fund the work to be performed at a site, as
well as order PRPs to perform the work if negotiations fail
and a settlement cannot be reached. EPA will also, when
circumstances warrant, issue Administrative Orders requiring
those PRPs that have failed to reach a settlement, to
coQperate and coordinate with the PRPs that have settled
with EPA. EPA cannot, at this time, state definitively
whether such orders will be necessary in this matter.
However, it is EPA's intent to involve all PRPs in a
settlement for the implementation of the remedial design and
remedial action for the site.
24. COMMENT: A commenter expressed that until more definitive
property lines are established, it is uncertain as to who is
responsible for what and a decision of .any sort would be
inappropriate.
EPA RESPONSE: The owners of the property on which.the
lagoons are located have been determined. In February, 1993
the City of Port Jervis provided EPA with a survey map that
shows property boundary lines in the area of the site. The-
City of Port Jervis owns the property encompassing lagoons
1, 3, 4, 5, 6, 7 and 8 and part of lagoon 2. The Carroll
and Dubies Sewage Disposal, Inc. owns the remaining portion
of the site property (i.e., that property on which the
remaining portion of lagoon 2 is located).
25. COMMENT: A commenter questioned how long it would take to
begin remediating the soils at the site and to complete the
remediation. The commenter also questioned whether
attempting to have the PRPs clean up the site would hold up
the remediation of the site.
EPA RESPONSE: After the ROD is signed, EPA will send out
notice letters to the PRPs providing them with an
opportunity to implement the selected remedy under EPA
supervision or to fund the remediation. From the time
notice letters are delivered to the PRPs it usually takes
approximately four to six months to initiate and complete
negotiations with PRPs. If the PRPs decide not to fund the
cleanup of the site, EPA can either order them to do it or
pay for the cleanup itself and later seek to recover the
cost from the PRPs. In either case, the design of the
fcemedy would be initiated shortly after the conclusion of
negotiations. The period from signing the ROD to completing
the remedial design is about 2 years (or longer if
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treatability studies are required) regardless of who
performs the cleanup of the site. It is anticipated that it
would take another year to complete the cleanup of.the site
utilizing ex-situ vapor extraction, bioslurry, and
solidification/stabilization.
26. COMMENT: One commenter stated that the portion of the City
of Port Jervis property which, in essence, constitutes the
Carroll and Dubies site, is just a small contributor to the
overall contamination in the area caused by the City of Port
Jervis Landfill. The commenter believed that everyone who
disposed of waste in the landfill is responsible for
contamination in the area of the site and not just Joe
Carroll and Gustave Dubies. The commenter indicated that
the cost to clean up the landfill will be much greater than
the cost to clean up the Carroll -and Dubies site.
EPA RESPONSE: This ROD addresses only the Carroll and
Dubies site. The landfill is not being considered as part
of the site, and therefore, is not being investigated at
this time. However, given the close proximity of the site
to the landfill, monitoring wells which were installed to
delineate the groundwater plume migrating from the site are
located downgradient of both the site and the landfill. The
groundwater sampling results from these wells will provide
information on the levels and types of contaminants detected
in the groundwater .downgradient of the site and at the
landfill. These monitoring wells were recently installed
and were sampled in September 1994. The groundwater
sampling results and alternatives proposed to address the
groundwater at the site will be presented in a Proposed Plan
which is expected to be completed by the fall of 1995.
It should be .noted that landfills are subject to New York
State regulations for the management of solid waste
facilities (Part 360 of the New York. Code of Rules and
Regulations). These regulations include landfill closure
requirements which include installing a landfill cap. To
date, the City of Port Jervis has not installed a landfill
cap. Since the landfill is not part of the investigation
conducted to date, there are no costs available for
remediating the landfill. Typically, landfills are
addressed by installing a multi-layered cap over the
landfill to prevent the percolation of rainwater through the
landfill waste, thereby reducing the migration of
contaminants from the landfill to the groundwater. Given
the size of landfills, it is not practical to excavate and
treat the landfill waste. It is probable that the proper
closure of the landfill would be a multi-million dollar
effort. See response to comment 31 for further discussion
regarding closure of the landfill.
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EPA does not generally consider private parties who deposit
municipal solid waste (MSW) in landfills to be PRPs if they
only deposited household hazardous substances- However,
such parties may be considered PRPs if the MSW contains
hazardous substances from non-household sources. These
sources include, but are not limited to, wastes from
commercial or industrial processes or activities, or used
oil or spent solvents from private or municipally-owned
maintenance shops.
27. COMMENT: A commenter expressed concern that it had been
twelve years since the first sampling was conducted at the
site, and wanted to know how long it would be before the
groundwater was addressed and why the groundwater wasn't
being addressed along with the contaminated soil.
EPA RESPONSE: NYSDEC first conducted sampling at the site
in 1982 to assess the site for inclusion on the National
Priorties List (NPL) . This sampling was very limited and
consisted of the collection of only one sludge sample and
one-groundwater sample. The resulting sampling data was not
considered adequate to evaluate the site. More in-depth
sampling was conducted by NYSDEC in 1986. Based on the 1986
sampling results, the site was proposed for inclusion on the
NPL in June 1988 and placed on the NPL in February 1990.
After the site was listed on the NPL,. the RI/FS for the site
was conducted by the PRPs under EPA's supervision. The.
RI/FS was completed in 1994 with the issuance of this ROD
which presents the selected remedy for addressing the
contaminated soils at the site. Although it has been 12
years since the first sample was collected from the site, it
has taken EPA four years from the time the site was listed
on the NPL to investigate and select a remedy for the site.
EPA, however, acknowledges that the remediation at Super fund
sites is a lengthy program and is taking measures to
streamline the process.
In July 1992, it was determined that it would take longer to
collect additional data to complete the delineation of the
groundwater contamination plume than to finish delineating
the contaminated source areas. Therefore, instead of
delaying the selection of a remedy for the remediation of
the soils and sludges, EPA divided the site into two
distinctive components or operable units (i.e.,
soils/sludges and groundwater) . Following completion of the
additional groundwater investigation, a ROD formalizing the
selection of a remedy to address the groundwater will be
completed (late 1995) . The period from signing the ROD to
completing the design for the groundwater remedy would be
about 2-3 years . (refer to response #25) . How long it takes
to clean up the groundwater is extremely variable and
depends on a number of factors such as the extent of
20.
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contamination, type of contaminants, and the geology of the
site. At sites where dense non-aqueous phase liquids
(DNAPL) are present, it may not be practicable to clean the
groundwater to drinking water standards, as timeframes to
achieve such levels can be on the order of centuries. Other
sites are much better suited for treatment, and may require
a much shorter cleanup timeframes (on the order of years) .
The estimated timeframe for remediating the Carroll & Dubies
site groundwater (if necessary) will be estimated in the FS
and Proposed Plan for the groundwater operable unit II.
Miscellaneous Comments
28. COMMENT: Joe Carroll, one of the owners of Carroll & Dubies
Sewage Disposal Facility Inc., requested that the site name
be changed to one that does not refer to Carroll and Dubies,
since the City of Port Jervis owns the property where the
Carroll and Dubies facility is located. In addition, he
claimed that the City of Port Jervis created the first
lagoon (lagoon 8) at the Carroll and Dubies site to use to
deposit sewage sludge. Mr. Carroll and Gustave Dubies used
this lagoon to deposit waste along with other companies.
Thereafter, Mr. Carroll and Mr. Dubies started depositing
waste on adjoining City of Port Jervis land, which at the
time they believed they owned.
EPA RESPONSE: When the site was initially listed on the
NPL, it was only believed to. consist of lagoons 1 through 4;
it was also believed that the site was owned and operated by
Carroll and Dubies Sewage Disposal Facility Inc. The site
was listed on the NPL as the Carroll and Dubies Superfund
site in February 1990. In 1992, the site was expanded to
include three additional lagoons .(lagoon 6 through 8) which
were identified in historical aerial photographs. Shortly
thereafter (February 1993), it was.determined that the City
of Port Jervis owned a major portion of the property, where
all the lagoons are located. Carroll and Dubies Sewage
Disposal Facility Inc. owned only a small portion of the
site property. Although the property owners are different
than originally believed, Carroll and'Dubies Sewage Disposal
Facility Inc. was the operator of, and transporter of all
the waste in lagoons 1 through 4 and to EPA's knowledge, the
operation and the transporter of all the waste present in
lagoons 6 through 8. As such, EPA believes that the name of
the site is appropriate and has no reason to change that
designation.
21
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29. COMMENT: Joe Carroll suggested that his remaining property,
approximately thirty-two acres, should not be eliminated
from any further use such as building a small.summer home,
as this property was not used for disposal. The commenter
believed that<"No Action" should be selected for the thirty-
two acres of land owned by Joseph Carroll and Gustave
Dubies.
EPA RESPONSE: EPA is considering remedial alternatives to
address only the seven lagoons at the site. EPA is not
restricting,any use of property owned by Joseph Carroll and
Gustave Dubies, so long as the use of this property does not
interfere with any remedial action that may be taken to
remediate the groundwater, lagoons or impacted soils at the
site.
30. COMMENT: A resident wanted to know what was being done to
prevent future Superfund sites.
EPA RESPONSE: CERCLA was enacted in December 1980 to
provide EPA with a powerful means of responding to cases.of
environmental contamination. The CERCLA remedial program is
generally retroactive in nature, addressing previously-
contaminated sites. On the other hand, the Resource
Conservation and Recovery Act ("RCRA"), enacted in 1976,
(implementing regulations effective November 1980) regulates
hazardous waste from.cradle (generation) to grave
(disposal/treatment) thereby minimizing the potential for
Superfund sites in the future. RCRA regulations also
require owners and operators of RCRA regulated facilities to
maintain financial assurance in amounts sufficient to cover
the cost of "closing" the facility and-thus avoiding the
need.for a CERCLA clean up.
31. COMMENT: A resident indicated that we have studied only a
small area of Deerpark and that there exist a number of
other areas that should not be ignored. The resident
identified a number of areas along Route 209 that are
potentially adversely impacting human health and the
environment.
Another commenter was concerned about the hundreds of pounds
of lead shot and bullets on the site associated with the
shooting ranges as well as the informal ones at the site.
The commenter also identified the continuing Carroll and
Dubies operation, lagoons located to the North of the site a
few hundred feet, dozens of freon leaking refrigerators
located to the south of the site, and the landfill which has
never been capped as other pollution problems in and around
the site.
22
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EPA RESPONSE: CERCLA authorized EPA to identify hazardous
waste sites that threaten public health and the environment,
and to locate and properly dispose of the wastes found
therein. The first step of that identification process is
called the Preliminary Assessment (PA). In a PA, EPA
attempts to verify the existence of released hazardous waste
at a site that may fall under Superfund. Any person or
organization can petition EPA to conduct a PA at a site;
this is called a PA petition. After receiving a PA
petition, EPA will decide if there is reason to believe that
an actual/potential site exists, and whether EPA has the
legal authority under Superfund to respond to the site. If
the petition is approved, EPA will conduct a PA and provide
a copy of the PA to the petitioner. Based upon the results
of the PA, EPA will determine if the next step, a site
investigation (SI), needs to be conducted. Following the
SI, EPA would prepare a hazard ranking system score for the
site to determine its eligibility for inclusion on the NPL.
The site has not been used for the disposal of septic and
municipal sewage wastes since 1989. The referenced lagoons
are actually lagoons 1 and 2. They are the only lagoons at
the site which were not covered with soil. These lagoons
are no longer actively used and will be addressed as part of
the remedy being selected for this site.
It is true that the Port Jervis Landfill has not yet been
properly capped. The landfill will be closed (including
capping) as required by the New York Code of Rules and
Regulations (6 NYCRR Part 360) requirements for Solid Waste
Management Facilities. The NYSDEC has not yet developed a
schedule for the closure of the landfill. However, NYSDEC
has requested that any questions regarding the closure of
the landfill be directed to:
Mr. Victor Cardona
Federal Projects Section
Bureau of Eastern Remedial Action
Division of Hazardous Waste Remediation
New York State Department of
Environmental Conservation
50 Wolf Road
Albany, New York, 12233-7010
Telephone # (518) 457-3976
Problems related to discarded refrigerators, and other
pollution problems encountered around the site are best
referred to local authorities such as the City of Port
Jervis, or Orange County. If necessary, the City or County
would elevate these issues to NYSDEC. If NYSDEC determined
that the problem is best addressed by EPA, NYSDEC could then
refer the problem to EPA.
23
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APPENDIX A
.Proposed Plan
Carroll and Dubies Superfund Site
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Superfund Proposed Plan
Carroll and Dubies Sewage Disposal Inc.
Town of Deerpark
Orange County, New York
EPA Region 2
"August 1994
NYSDEC
PURPOSE OF PROPOSED PLAN
This Proposed Plan describes the remedial
alternatives considered for the Carroll and Dubies
Sewage Disposal (C&D> Superfund site (the site)
and identifies the preferred remedial alternative for
the soils with the rationale for this preference. The
Proposed Plan was developed by the U.S.
Environmental Protection Agency (EPA), as lead
agency, with support from the New York State
Department of Environmental Conservation
(NYSDEC). EPA is issuing the Proposed Plan as
part of its public participation responsibilities under
Section 117(a) of the Comprehensive
Environmental Response, Compensation, and
Liability Act (CERCLA) of 1980, 42 U.S.C. §§ 9601-
9675, and the National Contingency Plan (NCP), 40
C.F.R. § 300.430(f). The alternatives summarized
here are described in the Remedial Investigation
and Feasibility Study (RI/FS) reports which should.
be consulted for a more detailed description of all
the alternatives. As part of the Administrative
Record for the site, the RI/FS can be found'in the*
public repositories listed on page 2. '
s
This Proposed Plan is being provided as a
supplement to the RI/FS reports to inform the
public of EPA's and NYSDEC's preferred remedy
and to solicit public comments pertaining to all the
remedial alternatives evaluated, as well as the
preferred alternative.
The remedy described in this Proposed Plan is the
preferred remedy for the site. Changes to the
' preferred remedy or a change from the preferred
remedy to another remedy may be made, if public
comments or additional data indicate that such a
change will result in a more appropriate remediaT
action. The final decision regarding the selected
.remedy will be made after EPA has taken into
consideration all public comments. We are
soliciting public comment on all of the ai'ematives
considered in the detailed analysis of the RI/FS
because EPA and NYSDEC may select a remedy
other than the preferred remedy.
COMMUNITY ROLE IN SELECTION PROCESS
EPA and NYSDEC rely on public input to ensure
that the concerns of the community are considered
in selecting an effective remedy for each Superfund
site. To this end, the RI/FS reports. Proposed
Plan, and supporting documentation have been
made available to the public for a public comment
period which begins on August 4, 1994 and
concludes on September 2,1994.
A public meeting will be held during the public
comment period at the auditorium of the Port
Jervis High School, Route 209, Port Jervis, New
York on Tuesday, August 23,1994 at 7:00 p.m. to
present the conclusions of the RI/FS, to elaborate
further, on the reasons for recommending the
preferred remedial alternative, and to receive public
comments.
Comments received at the public meeting, as well
as written comments, will be documented jn the
Responsiveness Summary Section of the Record of
Decision (ROD), the document which formalizes
the selection of the remedy.
MARK YOUR CALENDAR
August 4,1994 to September 2.1994
Public comment period on Rl report.
Proposed Plan, and remedy considered.
Tuesday, August 23, "1994
Public meeting to be held at 7:00 p.m. in
the auditorium of the Port Jervis High
School, Route 209, Port Jervis. New York.
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^Vt^;
Landfill
mi M HDMOOC
Figure 1 - C&D She Map
Copies of the RI/FS reports, Proposed Plan
and supporting documentation are available
at the following locations: ; ; ;' w
Town Hall ; :;
Drawer A
Huguenot, New York 12746
Tel. (914) 856-2210
Hours: 8:00 a.m. - 4:00 p.m. (Mon. - Fri.)
EPA Document Control Center
26 Federal Plaza, Room 2900 / .
New York, New York 10278 "
Tel. (212)264-8770
Hours: 9:00 a.m. - 5:00 p.m. (Mon. - Fri.)
All written comments should be addressed to:
Sharon L Trocher
Project Manager
U.S. Environmental'Protection Agency
26 Federal Plaza, Room 29-100
New York, New York 10278
(212)264-8476
SITE BACKGROUND
The site is located just northeast of the City of Port
Jervis on Canal Street In the Town of Deerpark,
Orange County, New York, and is approximately
3.0 acres in size. The northwest boundary of the
site is formed by the valley wall, which consists of
exposed bedrock with talus comprising the base.
The southeast boundary and a portion of the
northeast boundary of the site is formed by
remnants of the former Delaware and Hudson
(D&H) Canal and towpath. The remainder of the
northeast property boundary is formed by the
valley wall and a sand and gravel quarry. Adjacent
to the southern boundary of the site is the City of
Port Jervis Landfill. The landfill is no longer active;
however, Orange County currently operates a solid
waste transfer station on a portion of the landfill
property. Approximately 1,500-feet to the east of
the site is Gold Creek. The nearest resident
located downgradient of the site is approximately a
quarter of a mile from the site.
From approximately 1970 to 1979. the site was
used for the disposal of septic and municipal
sewage sludge and industrial wastes, primarily from
the cosmetic industry. The industrial waste was
deposited in one or more of the seven lagoons
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located at the site (lagoons 1 through 4 and 6
through 8 depicted in Figure 1). Initially. EPA
believed that the industrial wastes were deposited
only in lagoons 1 through 4. In July 1992 however,
the site was expanded to include the investigation
of areas believed to contain four additional filled-in
lagoons (lagoons 5. 6, 7 and 8). These lagoons
were tentatively identified in historical aerial
photographs. Trenching in the area of lagoons 6. 7
and 8 confirmed the presence of sewage sludge
and industrial waste; trenching in the area of
lagoon 5 revealed the presence of tires Instead of
industrial waste. The dimensions of lagoons 1, 2,
3, 4, 6. 7 and 8 are approximately 100 feet by 60
feet, 200 feet by 60 feet, 100 feet by 35 feet, 100
feet by 40 feet, 60 feet by 20 feet, 100 feet by 45
feet, and 150 feet by 40 feet, respectively.
In 1978, lagoon 3 was ignited by the Port Jervis
Fire Department in order to practice suppression of
chemical fires. After this incident, lagoons 3 and 4
were filled in with soil and the area was
revegetated. With the exception of lagoons 1 and
2, all of the lagoons have been covered with soil.
Lagoons 1 and 2 were left uncovered and are
surrounded by a wooden fence. In June 1979,
NYSDEC prohibited the disposal of industrial
wastes at the site. The site continued to be used
for the disposal of septic and municipal sewage
wastes until 1989.
In February 1987, NYSDEC issued a Phase II .
Investigation Report which summarized past
investigations and included a Hazard Ranking
System (HRS) score for the site. Based on the
MRS score, the site was proposed for inclusion on
the National Priorities List (NPL) in June 1988 and
was placed on the NPL in February 1990.
On September 25, 1989, EPA sent "special notice"*
letters to four potentially responsible parties
(PRPs), affording them the opportunity to conduct
the RI/FS for the site. (PRPs are companies or
individuals who are potentially responsible for
contributing to the contamination at the site and/or
are past or present owners of the property.) The
PRPs were given 60 days in which to submit a
good faith offer to undertake or finance the RI/FS
for the site.
On November 30, 1989. two of the four PRPs
submitted to EPA a good faith offer to perform the
RI/FS. An Administrative Consent Order was ._-
signed by the two PRPs and by EPA in February
1990. The PRPs conducted the RI/FS under EPA's
"supervision.
During the Rl, EPA learned from the City of Port
Jervis that it owned a major portion of the site
property where the lagoons are located. In an April
22,1993 letter, EPA notified the City that It was
also a PRP for the site. After issuance of the ROD.
all the PRPs will be offefed the opportunity to
design and implement the selected remedial
alternative for the site.
SCOPE*AND ROLE OF ACTION
This is the first of two planned operable units for
the site. This operable unit addresses the source
areas (lagoons and surrounding impacted soils) at
the site and actions needed to ensure that the
source areas do not pose a threat to human health
or the environment, including any potential cross
media impacts to groundwater. The second
operable unit investigation which is currently
underway, will address the need for remediating
contaminated groundwater underlying the site. The
two PRPs which performed the RI/FS for the first
operable unit are currently performing the RI/FS for
the second operable unit with supervision by EPA.
REMEDIAL INVESTIGATION SUMMARY
The intent of the investigation was to characterize
the soil quality of the seven lagoons at the site and
any potential cross media impacts to the
groundwater quality in the vicinity of these lagoons.
The remedial investigation consisted of drilling
borings and constructing monitoring wells,
collecting soil and groundwater samples, and
conducting a geophysical survey. The PRPs hired
Elaslarid & Bouck Engineers (B&B) to implement
the RI/FS.
The geophysical survey determined that the
elevation of the site ranges from approximately 440
to 520 feet above mean sea level. The materials
encountered underlying the site consist of glacially
derived unconsplidated materials underlain by
consolidated bedrock. The thickness of the
unconsolidated overburden materials ranges from
zero feet at the exposed bedrock slope forming the
northwestern site boundary, to over 60 feet along
the towpath. The glacially derived materials consist
of two distinct units, including a glacial till unit
overlain by glacial outwash deposits. The outwash
deposit was observed to vary in thickness from 31
feet to 52 feet along the downgradient edge of the
site. The outwash deposits typically consist of
medium dense to very dense brown sand with
some clayey silt and gravel. The glacial till
deposits are characterized as dense to very dense
dark grey silt with sand and gravel. The glacial till
is not continuous beneath the site, and appears to
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pinch out toward the northwestern edge of the site.
The depth to groundwater from ground surface
ranged from approximately 30 to 40 feet along the
southeastern boundary of the site. Groundwater
movement is generally towards the southeast.
Between July and September 1991. approximately
20 soil/sludge samples were collected from
lagoons 1 through 4 and the surrounding soils;
these samples were analyzed for organic and
inorganic constituents. During January and
February 1993, 54 additional soil samples were .
collected to further delineate the horizontal extent
of lagoons 1 through 4 and to characterize the
berm soil around lagoons 1 and 2. Various organic
constituents were detected in these lagoons and
the surrounding soils. Some of the highest
concentrations of organic contaminants included
benzene (650 parts per million (ppm)). 1.2-
dichlorobenzene (430 ppm), 1,4-dichlorobenzene
(250 ppm), tetrachloroethene (290 ppm). and
toluene (370 ppm). Inorganic constituents
detected in lagoons 1 through 4 and surrounding
soils included arsenic (10.7 ppm), barium (1290
ppm), chromium (137 ppm), cyanide (320 ppm),
lead (1,400 ppm), and nickel (368 ppm).
Higher levels of organic and inorganic constituents
were detected in lagoons 6. 7 and 8. Approxi-
mately" 45 soil and sludge samples were collected
from within and around the perimeter of lagoons 6,
7 and 8 during January and February 1993. Some
of the highest concentrations of organic
contaminants detected included benzene (2.800
ppm), tetrachioroethene (12,000 ppm), and toluene
(13,000 ppm). Inorganic constituents detected in
lagoons 6, 7 and 8 included arsenic (9.7 ppm),
barium (933 ppm), chromium (16,000 ppm), and
lead (609 ppm). In general, organic compounds
were detected at higher concentrations in lagoon 7,
and inorganic compounds were detected at higher
concentrations in lagoon 8.
Five background soil samples were collected from
areas not affected by site contamination to use as
a point of reference. One of the five soil samples
was analyzed for organic constituents. All five
background soil samples were analyzed for
inorganic constituents. Other than 0.01 ppm of
methylene chloride, organic compounds were not
detected in the background soil sample. The
highest concentrations of various inorganic
constituents detected in the background soil
samples included 7:0 ppm of arsenic. 43.1 ppm of
barium. 61.9 ppm of chromium. 45.6 ppm of lead.
and 36.7 ppm of nickel. Cyanide was not detected
in any of the background soil samples.
The source materials from lagoons 1. 2, 7 and 8
were tested using the toxic characteristics leaching
procedure (TCLP) to determined if these materials
would be considered Resource Conservation and
Recovery Act (RCRA) hazardous waste based on
the characteristic of toxicity. The source materials
from lagoons 1 and 2 did not leach organic or
inorganic constituents at concentrations above the
regulatory criteria for determining a RCRA
hazardous waste. The source materials from
lagoon 7 failed the TCLP for benzene,
tetrachloroethene, trichloroethene and vinyl
chloride and are therefore considered RCRA
hazardous waste based on the characteristic of
toxicity. Lagoon 8 failed the TCLP for benzene and
chromium; therefore, these materials would be
considered RCRA hazardous waste based on the
characteristic of toxicity.
During August 1991, December 1991, March 1993
and October 1993. groundwater samples were
collected from the vicinity of the lagoons and
analyzed for organic and inorganic compounds.
Monitoring wells located downgradient of lagoons 1
through 4 were sampled during August 1991.
December 1991 and March 1993, and monitoring
wells located downgradient of lagoons 6, 7 and 8
were sampled in October 1993. These monitoring
wells monitor either the bedrock, the glacial till, the
glacial outwash or both the glacial till and outwash
units.
Four organic compounds, benzene, 1,2-dichloro-
ethene (total), tetrachloroethene and
trichloroethene were detected above the Federal
and/or State drinking water standards In the
monitoring wells located downgradient of lagoons 1
through 4 during August and December 1991 and
March 1993. These four organic compounds were
detected in the monitoring wells that monitor either
the glacial outwash or both the glacial till and
outwash. Organic contaminants were not detected
above Federal or State drinking water standards in
any of the bedrock or glacial till monitoring wells.
Aside from tetrachloroethene detected in
monitoring well OW-6. organic compounds only
were detected above the Federal and/or State
drinking water standards at monitoring wells
located along the D&H towpath (e.g.. OW-2. OW-3
and MW-4). The monitoring wells located
downgradient of the D&H towpath (e.g.. OW-5,
OW-6. OW-7 and OW-8). however, were installed in
1993 and were only sampled in the October 1993
sampling event. Higher concentrations of the four
organic contaminants were detected in 1991 than
in 1993. The highest concentrations of organic
compounds detected above drinking water
standards were benzene at 52 parts per billion
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(ppb) in monitoring well OW-3, 1,2-dichloroethene
(total) at 230 ppb in monitoring well OW-2,
tetrachloroethene at 130 ppb in monitoring wells
OW-2, and trichloroethene at 41 ppb in monitoring
well MW-2. The Federal and State drinking water
standards for benzene, tetrachloroethene and
trichloroethene are all 5 ppb. The State drinking
water standard for 1,2-dichloroethene isomers Is 5
ppb, which is more stringent than the Federal
standard.
Inorganic compounds (arsenic, beryllium,
chromium, lead and nickel) were detected above
the Federal and/or State drinking water standard in
monitoring wells downgradient of lagoons 1
through 4 only during the 1991 sampling events.
During the March 1993 sampling, only cadmium
was detected above drinking water standards.
Cadmium was detected in monitoring well OW-3 at
6 ppb, which is slightly higher than the Federal and
State drinking water standard of 5 ppb.
During the October 1993 sampling of monitoring
wells located downgradient of lagoons 6, 7 and 8
(OW-9, OW-10, OW-11, OW-12, OW-13. OW-14 and
BW-5), benzene was detected above both the
Federal and State drinking water standards; seven
other organic compounds were detected above the
State drinking water standards but below the
Federal drinking water standards. The highest
concentrations of organic compounds detected
were benzene at 1,300 ppb in monitoring well OW-
12; 1,3,5-trimethylbenzene at 12 ppb in monitoring
well OW-11; 1,2,4-trimethylbenzene at 44 ppb in
monitoring well OW-12; 1,2-dichlorpethene (total) at
12 ppb in monitoring well OW-13; ethylbenzene at
9.8 ppb in monitoring well OW-12; toluene at 9.6
ppb in monitoring well OW-12; and xylene at 40
ppb in monitoring well OW-12. The State drinking
water standard for 1,3,5-trimethylbenzene, 1.2,4-
trimethylbenzene, ethylbenzene. toluene, and
xylene is 5 ppb. The Federal drinking water
standard is 700 ppb for ethylbenzene, 1,000 ppb
for toluene and 10,000 ppb for xylene. A Federal
drinking water standard does not exist for 1,3,5-
trimethylbenzene or 1,2,4-trimethylbenzene.
Nine inorganic compounds were detected above
Federal and/or State drinking water standards in
the seven monitoring wells located downgradient of
lagoons 6. 7 and 8. Nine inorganic compounds
were detected above drinking water standards.
However, six of these inorganic compounds were
detected above standards only in monitoring welf
OW-10. Chromium, lead and nickel were detected
above drinking water standards in more than one
monitoring well and were detected at levels that
ranged from 106 to 2.930 ppb. 19.1 to 924 ppb and
100 to 1,560 ppb, respectively. The inorganic
compounds detected above drinking water
standards in monitoring well OW-10 were about an
order of magnitude higher than the levels detected
in the other monitoring wells. The Federal drinking
water standards for chromium and nickel are set at
100 ppb; the Federal action level for lead Is 15 ppb.
The State drinking water standards for chromium
and lead are 100 and 50 ppb, respectively. A State
drinking-water standard does not exist for nickel.
As previously mentioned, an Investigation to
determine the lateral and downgradient extent of
the groundwater plume is currently underway and
will be reported in the Rl for the second operable
unit.
The New York State Department of Health sampled
several off-site private wells in 1991 and again in
1993 for organic and inorganic constituents.
Organic constituents were not detected In the
groundwater from these wells, and inorganic
constituents were detected below drinking water
standards.
SUMMARY OF SITE RISKS
Based upon the results of the Rl. a baseline risk
assessment was conducted to estimate the risks
associated with current and future site conditions.
The baseline risk assessment estimates the human
health and ecological risk which could result from
the contamination at the site, if no remedial action
were taken.
As part of the baseline risk assessment, the
following four-step process is utilized for assessing
site-related human health risks for a reasonable
maximum exposure scenario: Hazard
/ctenf/fi'car/on-identifies the contaminants of
concern at the site based on several factors such
as toxicity, frequency of occurrence, and
concentration. Exposure Assessment-estimates
the magnitude of actual and/or potential human
exposures, the frequency and duration of these
exposures, and the pathway (e.g. ingesting
contaminated well-water) by which humans are
potentially exposed. Toxicity Assessment-
determines the types of adverse health effects
associated with chemical exposures, and the
relationship between magnitude of exposure (dose)
and severity of adverse effects (response). Risk
Characterization-summarizes and combines
outputs of the exposure and toxicity assessments
to provide a quantitative (e.g., one-in-a-million
excess cancer risk) assessment of site-related
risks.
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The risk assessment was prepared before the
analytical soil data associated with lagoons 6. 7
and 8 were available. Therefore, only the data
collected from lagoons 1 through 4 during July and
September 1991 were used in the risk assessment.
A separate risk assessment was not prepared for
lagoons 6, 7 and 8 since it was anticipated that
remedial action would be taken at these lagoons
due to the levels of contaminants found, the
presence of hazardous waste and cross media
impacts to groundwater. Higher baseline risk levels
would be expected if the analytical soil data from
lagoons 6, 7 and 8 were included in the risk
assessment.
The baseline risk assessment began with selecting
contaminants of concern which would be
representative of site risks. These contaminants
included benzene, 1.2-dichlorobehzene,
tetrachloroethene, toluene, arsenic, barium,
chromium, cyanide, lead, and nickel.
The baseline risk assessment addressed the
potential risk to human health by identifying
potential exposure pathways by which the public
might be exposed to contaminant releases at the
site under current and future land-use conditions.
The exposure pathways under the current land-use
condition included the exposure to adult and child
.trespassers through the dermal -contact with
standing water contained in lagoon 1, and through
the ingestion, inhalation'and dermal contact of soils
and sludges. When considering future land use,
the exposure pathways included the ingestion,
inhalation and dermal contact of soils and sludges
by construction workers. Because the site is
surrounded by a cliff, a landfill and a quarry, future
residential use of the property was not considered
as a reasonable scenario.
*
EPA's acceptable cancer risk range is 10"4 to 10"8
which can be interpreted to mean that an individual
may have a one in ten thousand to a one in a
million increased chance of developing cancer as a
result of a site-related exposure to a carcinogen
over a 70-year lifetime under the specific exposure
conditions at a site. The results of the baseline risk
assessment indicated that the soils and sludges
associated with lagoons 1 through 4 pose no
unacceptable carcinogenic risk to human health.
The sum of the current cancer risks for the
exposure pathways for adult and child trespassers
was 5 x 10"7 (fh/e in ten million) and 3 x 10"6 (three
in a million), respectively. The overall future
carcinogenic risk for construction workers, .through
ingestion, inhalation and dermal contact of
contaminated soils and sludges, was estimated to
be 4 x 10"" (four In a m'lIHpn). These carcinogenic
risks are within EPA's acceptable risk range.
To assess the overall potential for noncarcinogenic
effects posed by the contaminants at the site, EPA
has developed the hazard index (HI). An HI value
of greater than 1 is considered to pose a potential
noncarcinogenic risk. The calculated HI values for
trespassers are less than 1, which EPA has
determined to be acceptable. The total exposure
HI for construction workers assumed to be
participating in excavation and grading activities
was estimated to be 3.0. Therefore, there are
unacceptable noncarcinogenic risks associated
with the construction worker scenario. The primary
contributor to this risk is chromium-containing dust
which could be inhaled during excavation activities.
As previously noted, higher risk levels from
exposure to contaminated soil would have resulted
if the analytical soil data from lagoons 6, 7 and 8
were included in the risk assessment. A risk
assessment to identify the potential risk to human
health through groundwater pathways would be
prepared during the second operable unit. As
indicated by the groundwater sampling data,
contaminants from the soil are migrating into the
groundwater at concentrations above Federal and
State health-based drinking water standards.
*
The qualitative ecological assessment concluded
that the site provides low to moderate habitat value
to wildlife. The degree of physical disturbance on-
site and lack of continuous quality habitat in
adjacent areas restrict the diversity and extent of
wildlife'use at the site. Therefore, only minor
impacts on wildlife are expected to occur.
REMEDIAL ACTION OBJECTIVES
Remedial action objectives are specific goals to
protect human health and the environment. These
objectives are based on available information and
standards such as applicable or relevant and
appropriate requirements (ARARs) and risk-based
levels established in the risk assessment. The
remedial action objective for the source areas at
the site is to prevent leaching of contaminants in
the soils/sludges at levels which will contribute to
the contravention of groundwater quality and
drinking water standards in the groundwater in the
vicinity of the site and to minimize potential risks to
hypothetical excavation workers.
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SUMMARY OF REMEDIAL ALTERNATIVES
CERCLA requires that each selected site remedy
be protective of human health and the
environment, be cost effective, comply with other
statutory laws, and utilize permanent solutions and
alternative technologies and resource recovery
alternatives to the maximum extent practicable. In .
addition, the statute includes a preference for the
use of treatment as a principal element for the
reduction of toxicity, mobility, or volume of the
hazardous substances.
This Proposed Plan evaluates in detail six remedial
alternatives for addressing the soil/sludge
contamination at the Carroll and Dubies Sewage
Disposal Inc. site. As used in the following text, the
time to implement reflects only the time required to
implement the remedy, and does not include the
time required to procure contracts for design and
construction or to negotiate with responsible
parties for implementation of the remedy.
Alternative 1: No Action
Alternative 3: Low-Permeability Cap with Slurry
Cut-Off Walls
Capital Cost:
O & M/yr Cost:
Present Worth:
Time to Implement:
SO
$0
$0
0 months
The Superfund program requires that the "no- .
action" alternative be considered as a baseline for
comparison with other alternatives. Under this
alternative, the contaminated soil would be left in
place without treatment. The site would remain in
its current condition and no effort would be made
to change the current site conditions.
Alternative 2: Limited Action
Capital cost:
O & M/yr Cost:
Present Worth:
Time to Implement;
$ 52,000
$ 18,000
$ 328.660
6 months
This alternative consists of institutional controls
such as deed restrictions to limit future use of the
site and complete fencing of the site to minimize
potential human exposure to the source area
materials. The limited action alternative would not
utilize any remedial technologies for the treatment
of the source areas. A long-term groundwater
monitoring program would be implemented to track
the migration of contaminants from the source -"
areas into the groundwater utilizing existing
.monitoring wells at the site.
Capital Cost:
0 & M/yr Cost:
Present Worth:
Time to Implement:
$ 3.299,816
$ 147.060
" $5.560,128
12 months
This alternative includes the construction of a low-
permeabfflity cap over the source materials to
minimize the infiltration of precipitation. Limiting
the amount of water which percolates through the
source materials may reduce the leaching of the
chemical constituents into the groundwater
underlying the site. In addition to the cap. slurry
cut-off walls would be installed around the source
area to minimize the migration of son gas and
leachate from the impacted source areas into the
surrounding soils and to minimize the movement of
precipitation from outside the cap through the
source area materials. The cap would be
constructed of a low-permeability material such as
natural clay, geosynthetics, asphalt or
combinations of these materials. Additional
drainage and top soil layers would be included tc
achieve a well drained, vegetated surface upon
completion. Deed restrictions would be
recommended to limit future use of the site in order
to protect the integrity of the cap.
The cut-off walls would be constructed by
excavating vertical trenches while filling the
excavation with a soil-bentonite slurry. The slurry
walls would be keyed into the bedrock unit which
underlies the site. This bedrock unit consists of
shale and silt stone and ranges from ground
surface to 60 feet below grade. Groundwater at
the site is present within the overburden soil
materials. Therefore, hydrodynamic controls would
be required to maintain the effectiveness of the cap
and slurry wall. Hydrodynamic controls would
include pumping groundwater from within the
capped area to maintain a static water level within
the capped area. The collected water would be
treated on-site in a granular activated carbon
(GAC) adsorption treatment system prior to
discharge. The spent carbon would be
regenerated or shipped off-site to an appropriate
disposal facility. Groundwater monitoring would be
performed annually utilizing existing monitoring
wells at the site.
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Alternative 4: Stabilization/Solidification and
Placement into an On-Site Containment Cell
Capital Cost: $ 5,389.215
O & M/yr Cost: $ 26.400
Present Worth: S 5,794.983
Time to Implement: 12 months
This alternative involves the physical removal of
approximately 20,300 cubic yards (cy) of source
area materials and treatment of these materials
through stabilization/solidification. The volume of
source area materials requiring treatment consists
of materials that contained organic constituents at
levels above the NYSDEC soil cleanup levels
(Technical and Administrative Guidance
Memorandum No. 4046) and inorganic constituents
above the highest background level detected,
utilizing chromium and nickel as indicator
constituents. The approximate volume of source
area materials to be removed from each lagoon is
2,600 cy from lagoon 1. 3,950 cy from lagoon 2,
2.300 cy from lagoon 3, 2.320 cy from lagoon 4,
520 cy from lagoon 6, 3,420 cy from lagoon 7. and
5,200 cy from lagoon 8.
Stabilization/solidification is a process by which
. stabilization agents such as cement-based,
pozzolanic-based, asphalt-based, and organic-
polymer-based agents are mixed with the source
area materials to convert the waste to a more
stable form. Capture and control mechanisms
would be installed, as necessary to control air
emissions containing organic constituents emitted
during the stabilization/ solidification process to
ensure compliance with Clean Air Act standards.
Air monitoring would also be conducted during
implementation of this alternative to determine the
need for additional engineering controls.
*
The stabilized mass would then be placed into a
lined cell which would consist of a high density
polyethylene (HOPE) liner and a sand drainage
layer. The cell would be sloped to a wet well
located adjacent to the cell to collect any leachate
that is generated by the solidified materials. Once
the treated source area materials are placed into
the cell, a cap (modified New York Code of Rules
and Regulation, Part 360) would be constructed
over the cell to minimize the infiltration of rainwater.
The cap would consist of a low-permeability clay
layer, an HOPE membrane, a sand drainage layer,
and a topsoil cover layer. Deed restrictions would
be recommended to limit future use of the site iff
order to protect the integrity of the cap. Leachate
-would be removed periodically from the wet well
and sent off-site for treatment and disposal in
compliance with applicable regulations.
Groundwater monitoring would be performed
annually utilizing existing monitoring wells at the
site.
Alternative 5: Low-Temperature Thermal
Desorption, Stabilization/Solidification, and
Placement into art On-Site Containment Cell
Capital Cost:
0 & M/yr Cost:
Present Worth:
Time to Implement:
$ 11.351.132
$ 26.400
$ 11,756.900
12 months
This alternative consists of excavating
approximately 20,300 cy of source area materials
and treating some of these materials on-site using
a mobile Low-Temperature Thermal Desorption
(LTTD) unit LTTD is a process by which
soils/sludges are heated and the organic
constituents are desorbed from the soils/sludges
and volatilized into an induced air flow. The
soils/sludges are heated to temperatures ranging
from 200°F to 1.200°F. Air or nitrogen carrier gas
is passed over the soils/sludges to collet the
volatilized organic constituents. The carrier gas is
then treated by either condensation and carbon
adsorption or by thermal destruction in a
combustion afterburner to limit emissions to within
the regulatory requirements. Materials from
lagoons 1, 3, 7 and 8 (approximately 13,500 cubic
yards) which contain high concentrations of
organic contaminants would be treated with the
LTTD unit. Other means of treating the lagoons
containing high concentrations of organic
contaminants, such as vapor extraction or bidslurry
treatment could conceivably achieve appropriate
treatment levels for organics and could be
considered as a substitute for the LTTD portion of
this alternative if sufficient information is generated
during the public comment process which
convinces EPA that one of these alternatives would
be appropriate. Air monitoring would be
conducted during implementation of this alternative
to ensure air emissions are within regulatory limits.
Upon completion of the thermal treatment of the
source materials for their organic constituents,
lagoons 6 and 8 (approximately 5,700 cy) would be
treated through stabilization/solidification to reduce
the mobility of the inorganic constituents. Source
area materials from lagoons 1. 2. 3, 4 and 7 that do
not meet the RCRA-Regufated Levels for TCLP or
that are needed to achieve adequate load bearing
capacity would also be stabilized/solidified. All
excavated source area materials (approximately
20,300 cubic yards) would then be placed in a
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ined cell with a wet well for leachate collection,
and then capped. The lined cell and cap are the
same as that described in Alternative 4. Deed
restrictions would be recommended to limit future
use of the site in order to protect the integrity of
the cap. Groundwater monitoring would be
performed annually utilizing existing monitoring
wells at the site.
Alternative 6: Off-Site Disposal at a Permitted
Landfill
Capital Cost:
O & M/yr Cost:
Present Worth:
Time to Implement:
$ 32.679,764
$0
$32,679,764
12 months
This alternative consists of excavating 20,300 cy of
source area materials and transporting these
materials off-site to a RCRA-permitted treatment,
storage and disposal facility for treatment and
disposal, as appropriate. Excavated materials
would be placed directly into lined 20 cy roll-offs.
Some of the source area materials might need to
be dewatered prior to off-site transportation. Each
.roll-off would be sampled to characterize the
source area materials prior to transportation off-
"site. Based on-the analytical data available for the
source area materials, the materials from Lagoons
6, 7 and 8 would require pre-treatment to meet the
land disposal restrictions (LDRs) prior to disposal
at a RCRA-permitted landfill. Air monitoring would
also be conducted during implementation of this
alternative to determine the need for engineering
controls.
For purposes of evaluating this alternative,
incineration and solidification were considered to
be the appropriate pre-treatment methods to
address the source area materials which do not ,
meet LDR requirements. It is estimated that the
volume of source area materials that would require
pretreatment prior to land disposal is approximately
9.130 cy.
EVALUATION OF ALTERNATIVES
During the detailed evaluation of remedial
alternatives, each alternative is assessed against
nine evaluation criteria, namely, overall protection
of human health and the environment; compliance
with ARARs; long-term effectiveness and
permanence; reduction of toxicity, mobility, or
volume; short-term effectiveness; implementabilify;
cost; and community and state acceptance. For a
more detailed explanation, see the comparative
analysis contained in the FS.
Glossary of Evaluation Criteria
Overall protection of human health and the
environment addresses whether or not a remedy
provides adequate protection and describes
how risks are eliminated, reduced, or controlled
through treatment, engineering controls, or
Institutional controls. -
Compliance with ARARs addresses whether or
not a remedy will meet all of the applicable or
relevant and appropriate requirements and/or
provide grounds for invoking a waiver.
* Long-term effectiveness and permanence refers
to the ability of a remedy to maintain reliable
protection of human health and the environment
over time, once cleanup goals have been met.
It also addresses the magnitude and
effectiveness of the measures that may be
required to manage the. risk posed by treatment
residuals and/or untreated wastes.
» Reduction of toxicitv. mobility, or volume
through treatment is the anticipated performance
of the treatment technologies a remedy may
employ.
» Short-term effectiveness addresses the period of
time needed to achieve protection from any
adverse impacts on human health and the
environment that may be posed during the
construction and implementation period until
cleanup goals are achieved.
* Imptementabilitv is the technical and
administrative feasibility of a remedy, including
the availability of materials and services needed
to implement a particular option.
* Cost includes both estimated capital and
operation and maintenance costs, and net
present worth costs.
» State acceptance indicates whether, based on
its review of the RI/FS report and Proposed
Plan, the State concurs with, opposes, or has no
comment on the preferred alternative.
* Community acceptance will be assessed in the
ROD and refers to the public's general response
to the alternatives described in the RI/FS report
and" the Proposed Plan.
A comparative analysis of the remedial alternatives
based upon the evaluation criteria noted above
follows.
-------
Overall Protection of Human Health and the
Environment
Alternative 6 would be most protective of human
health and the environment since source area
materials would be removed from the site.
Alternatives 4 and 5 would mitigate cross-media
impacts to the groundwater from the source and
therefore would be protective of human health
and the environment. Alternative 5 would,
however, provide a higher degree of overall
protection of human health and the environment
than Alternative 4 since organic contaminants
would be permanently removed from source
area materials having high levels of organic
contamination. Alternative 3 may result in the
continued leaching of constituents to the
groundwater and therefore would not be as
protective to human health and the environment
as Alternatives 4, 5 and 6. Alternatives 1 and 2
would not reduce the leaching of the chemical
contaminants to the site groundwater and
therefore would not be protective of human
health and the environment.
Compliance with ARARs
All remedial technologies proposed for use in
Alternatives 3, 4, 5 and 6 would be designed and
implemented to meet ARARs. Wastes would be
treated using specific technologies or treated to
specific treatment levels, as appropriate, to
comply with air pollution control and RCRA
hazardous waste regulations. Federal and State
regulations dealing with the handling and
transportation of hazardous wastes to an off-site
treatment facility would be followed with regard
to Alternative 6. Alternative 2, 3, 4 and 5 would
require compliance with various local
requirements for implementing deed restrictions.
Alternative 1 would not be subject to any
ARARs. In addition, for reasons discussed
below under Long-Term Effectiveness and
'Permanence, Alternative 6 followed by
Alternatives 5, 4, and 3 would minimize-cross-
media impacts of contaminants migrating from
soil to groundwater thereby enabling
groundwater standards to be achieved in a
shorter time frame. Alternatives 1 and 2 would
not provide this benefit.
Long-Term Effectiveness and Permanence
Alternative 6 would provide the highest degree*
of long-term effectiveness and permanence
since the contaminated soils would be
permanently removed from the site. Alternatives
4 and 5 would mitigate the leaching of
contaminants to the underlying groundwater.
Alternative 5 would, however, provide the higher
degree of long-term effectiveness and
permanence than the remaining alternatives
since organic contaminants would be
permanently removed from the source area
materials having high levels of organic
contamination; it would also effectively address
Inorganic contaminants. Unlike Alternative 5,
Alternative 4 depends on the long term
effectiveness of the stabilization/solidification,
containment cell and leachate collection system
to prevent the leaching of organic contaminants
into the groundwater; it does effectively address
inorganic contaminants over the long-term.
Alternative 3 may continue to leach
contaminants from the source area materials
. into the groundwater; the permanence of
Alternative 3 would rely on the continued
maintenance of the cap and slurry cutoff wall.
and the operation and maintenance of the
hydraulic control system. Alternatives 1 and 2
would not provide any active treatment or
containment and therefore would not be
effective over the long-term or provide
permanent protection of the groundwater
underlying the site.
* Reduction in Tbxicity. Mobility, or Volume
Through Treatment
Alternative 6 would provide a reduction in
contaminant mobility, toxicity, and volume of
the organic and inorganic chemical
contaminants present at the site by permanently
removing the source area materials from the
site and treating the materials, as necessary,
prior to their disposal at a RCRA-permitted,
landfill. Alternative 5 would provide a reduction
in the mobility, toxicity, and volume of organic
contaminants in the source areas having high
levels of organic contaminants by permanently
removing the organics from the source areas.
Alternative 5 would provide a reduction in the
mobility of the inorganic contaminants through
stabilization/solidification of the source area
materials failing TCLP and placement of all
source area materials in a lined containment
cell with a leachate collection system.
Alternative 4 would provide a reduction in the
mobility of the organic and inorganic
contaminants present in the source area
materials through stabilization/solidification of
the materials and placement of the solidified
materials in a lined containment cell with a
leachate collection system. However, as noted
above the long-term effectiveness of
stabilization/solidification for immobilizing
10
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organic contaminants has not been
demonstrated. Alternative 3 would not provide a
reduction in the toxicity or volume of the organic
and inorganic contaminants in the source area
materials; however, this alternative would reduce
the mobility of the chemical constituents through
capping, installing slurry cut-off walls and
pumping groundwater from within the capped
area. Alternatives 1 and 2 would provide no
reduction in contaminant mobility, toxicity, or
volume.
* Short-term Effectiveness
Alternatives 1 and 2 would result In no additional
risk to the community or workers during
implementation, since source area materials
would not be disturbed. Alternatives 3, 4, 5 and
6 would include activities such as excavation
and handling of contaminated soils/sludges that
could result in short-term exposures to on-site
workers and the community during
implementation due to the generation of fugitive
dust. Mitigation measures such as water sprays
to suppress dust would be implemented to
control short-term environmental impacts
associated with off-site dust migration.
Alternative 5 would also result in the potential
exposure to on-site workers and the community
.to air emissions associated with the LTTD
treatment system. The air emissions from the
LTTD unit would be controlled by implementing
air emission treatment systems and air emission
monitoring programs. Alternative 6 would also
include activities such as off-site transport of
contaminated soils/sludges that could result in
potential exposure to the community. To reduce
the potential risks to the community and the
environment resulting from an accident during
transportation, a traffic control plan would be *
developed.
» Implementabilitv
All alternatives are technically feasible and could
be implemented .at the site. Alternatives 1 and 2
are the easiest to implement. A treatability study
would be necessary to demonstrate that
Alternative 4 (stabilization/solidification) is able
to render the lagoon 7 material nonhazardous
based on the characteristic of toxicity. The high
moisture content and clay-like material
properties of some of the source area materials
may make Alternative 5 (LTTD process) difficult
to implement. The implementability of LTTD
would need to be confirmed by treatability study
testing.
» Cost
According to the present worth cost estimates
for all alternatives evaluated, Alternative 6
($32,679,764) would b.e the most costly
alternative to implement, followed by Alternative
5 ($11.756,900). The present worth cost for
Alternatives 4 and 3 would be about the same
($5,794.983 and $5.560,128. respectively).
Alternatives 2 and 1 would be the least costly to
implement ($328,660 and $0, respectively).
Present worth considers a 5% discount rate,
and a 30-year operational period for Alternatives
2, 3. 4 and 5. Since Alternatives 6 and 1 do not
require any O & M costs, their present worth
costs are equivalent to their capital cost.
* Community Acceptance
Community acceptance of the preferred soil
alternative will be assessed in the ROD
following a review of the public comments
received on the RI/FS report and the Proposed
Plan.
* State Acceptance
NYSDEC concurs with the preferred alternative
for remediating the soils and sludges at the site.
PREFERRED ALTERNATIVE
Based upon an evaluation of the various
alternatives, EPA and NYSDEC recommend
Alternative 5 (Low-Temperature Thermal
Desorption, Stabilization/Solidification, and
Placement into an On-site Containment Cell).
Alternative 5 permanently removes organic
contaminants from source area materials and
reduces the mobility of inorganic contaminants
through stabilization/solidification and placement of
source area materials in a lined containment cell
constructed on-site. Alternative 5 ensures that no
leaching of contaminants to the underlying aquifer
will occur. The elimination of cross-media impacts
will have a positive impact on the effectiveness of
any future groundwater restoration program that
could be implemented at the site.
Alternative 5 is the only alternative that permanently
removes the organic contaminants from source
area materials except for Alternative 6 which is over
twice the cost of the preferred alternative and may
not comply with the statutory preference for
treatment as a principal element. The other
proposed alternatives which cost much less than
the preferred alternative do not permanently
remove contaminants from the source area
11
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materials. The preferred alternative will provide the
best balance of trade-offs among alternatives with
respect to the evaluating criteria. EPA and
NYSDEC believe that the preferred alternative will
be protective of human health and the
environment, will comply with ARARs, will be cost
effective, and will utilize permanent solutions and
alternative treatment technologies or resource
recovery technologies to the maximum extent
practicable. The remedy also will meet the
statutory preference for the use of treatment as a
principal element.
12
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Appendix B
Public Notice
-------
A he U.S. Environmental Protection Agency (EPA) will hold a
public meeting to discuss the Proposed Plan for the Carroll and
Dubies Sewage Disposal Inc. Superfund site, located in Port Jervis,
New York.
EPA has scheduled a public meeting to discuss the findings of the
Remedial Investigation/Feasiblity Study at 7 p.m., on Tuesday,
August 23, 1994, at the Port Jervis High School in Port Jervis,
New York. The release of the Proposed Plan and the scheduled
public meeting are in accordance with EPA's public participation
responsibilities under Section- 117(a) of the Comprehensive
Environmental Response, Compensation and Liability Act
(CERCLA) of 1980.
EPA reviewed several alternatives to address the contaminated soil
at the site. Alternatives included: 1) No Action; 2) Limited Action;
3) Low-Permeability Cap with Slurry Cut-Off Walls; 4)
Stabilization/Solidification and Placement into an On-Site
Containment Cell; 5)" Low-Temperature Thermal Desportion
(LTTD), Stabilization/Solidification, and Placement into an On-Site
Containment Cell; and 6) Off-Site Disposal at a Permitted Landfill.
Based upon an evaluation of these alternatives, EPA is
recommending: Low-Temperature Thermal Desorption,
Stabilization/Solidification and Placement into an On-Site
Containment Cell.
EPA, in consultation with NYSDEC, may modify the preferred
alternative or select another response action based on new
information or public comments. Therefore, the public is
encouraged to review and comment on all of the alternatives
identified herein. Documentation of the project findings is
presented in the Administrative Record File. These documents are
available at the:
Town Hall
Drawer A
Huguenot, New York 12746
(914) 856-2210
Comments on the Proposed Plan will be summarized and re-
sponses provided in the Responsiveness Summary section of the
Record of Decision. The Record of Decision is the document that
presents EPA's final selection for response actions. Written com-
ments on this Proposed Plan should be sent by close of business,
September 2, 1994 to: ,
Sharon Trocher, Project Manager
U.S. Environmental Protection Agency
26 Federal Plaza, Room 29-100
New York, New York 10278
-------
Appendix C .
August 23, 1994
Public Meeting Attendance Sheet
-------
United States Environmental Protection Agency
Region II
Meeting
For
Public Meeting for Carroll & Dubies Superfund Site
August 11, 1994
7pm
Please Print Clearly
NAME
STREET
CITY
Sign In Sheet
ZIP
PHONE
X7t"
n «* VT- ,
-------
United States Environmental Protection Agency
Region II
Meeting
For
Public Meeting for Carroll t Duties Superfund Bite
August 11, 1994
7pm
Please Print Clearly
LwbmifaAt
Sign In Sheet
ZIP
PHONE
-------
ROD FACT SHEET
SITE
Site name:
Site location:
HRS score:
EPA ID #
ROD
Date signed:
Selected remedy:
Capital cost:
O & M cost:
Present worth cost:
LEAD
USEPA
EPA Primary Contact:
Carroll and Dubies Sewage Disposal Inc.
Town of Deerpark, Orange County, New York
33 .74
NYD010968014
March 31, 1995
ex-situ vapor extraction, bioslurry,
stabilization/solidification and
placement into an on-site containment
cell
$ 8,105,000
$ 430,000
$ 8,535,000
Sharon Trocher (212) 264-8476
EPA Secondary Contact: Doug Garbarini (212) 264-0109
Main PRPs:
WASTE
Waste type:
Carroll and Dubies Sewage Inc., Kolmar
Laboratories, Wickhen Products,
Reynold Metals and City of Port Jervis
Volatile Organic Compounds
Inorganic Compounds
Waste origin: Septic and Industrial Wastes
Estimated waste quantity: 20,300 cubic yards
Contaminated medium: Soil (OU-1)
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